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POI Workshop Federal AviationAdministration 11
Session 4: Country Perspective on FRMS; Implementation and Case Study
Dale E. Roberts, Aviation Safety Inspector Air Transportation Division (AFS-200)Federal Aviation Administration
Federal AviationAdministration
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Fatigue Management Rules
Prescriptive rules (Part 117, Part 121 Subparts Q, R or S)
Fatigue Risk Management Programs (FRMP) describes how the air carrier will manage and mitigation fatigue risks associated with their type and kind of operation from within the regulatory structure. The FRMP must be designed to improve flightcrew member alertness and reduce performance errors
Fatigue Risk Management Systems (FRMS) is an alternative method of compliance (AMOC) targeted to the specific limitation(s). Must demonstrate an equivalent level of safety to the targeted limitation(s), requires data collection, and must be FAA-approved
Federal AviationAdministration
FRMS Authority 14 CFR Part 117, Section 117.7
14 CFR Part 121, Subparts Q, R and S
• Q = Domestic operational rules• R = Flag operational rules• S = Supplemental operational rules
FRMS approval process guidance may be found in Advisory Circular (AC) 120-103A
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FRMS Overview No carrier may exceed any provision of part 117 (or part 121,
Subparts Q, R or S) unless approved by the FAA under a FRMS
The FRMS must provide at least an equivalent level of safety against fatigue-related accidents or incidents as the other provisions of part 117 or part 121, Subparts Q, R or S, as applicable
The FRMS will be applied either as an alternative to the limitation or beyond the constraints of the limitation
In either event, the FRMS must demonstrate an equivalent level of safety to the targeted limitation(s)
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FRMS Objectives An optional approach to fatigue mitigation
FRMS is a data-driven system based upon scientific principles
An alternative method of compliance (AMOC)
Targeted to specific limitation(s)
FRMS must demonstrate at least an equivalent level of safety against fatigue-related accidents or incidents
Requires data collection and monitoring for continuous improvement
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FRMS Functional Objectives Gap analysis identifying the needs and requirements for the FRMS
Safety case for the FRMS
FRMS procedures used to mitigate fatigue risk as an AMOC to the targeted limitations in 14 CFR § 117.7 or part 121, Subparts Q, R or S, as applicable
The foundation of the FRMS needs to be data-driven and scientifically-based (science-based)
Needs to enable continuous monitoring and management of safety risks associated with fatigue-related error and hazards
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FRMS Functional Objectives Must provide a means for measuring, monitoring, managing,
mitigating, and reassessing fatigue-related risk
Includes schedule assessment, data collection, and systematic analysis
Fatigue risk management processes
Safety assurance processes
Should provide scientifically guided fatigue mitigations – both proactive and reactive
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Applying the FRMS Identify the limitation(s) the proposed FRMS will target
Develop a proposed AMOC and a safety case
Identify data collection requirements
Develop required FRMS documentation, define objectives, develop data collection plan and identify planned data output
AMOC will be a substitute for the targeted limitation(s)
The AMOC must support an equivalent level of safety for each of the targeted limitation(s) where the FRMS will be applied
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Basic FRMS Structure A completed gap analysis An accountable executive An FRMS Policy Statement signed by the accountable executive A safety case Allocation of financial and human resources An FRMS implementation plan An FRMS documentation plan. This can be expected to evolve as
the FRMS becomes operational An FRMS communication plan. This can be expected to evolve as
the FRMS becomes operational Training plan ready for all personnel who will be involved in the
FRMS An established Fatigue Safety Action Group (FSAG or equivalent)
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Safety CaseWhen applying for a FRMS, the operator has to provide a safety case that is appropriate to the expected level of risk associated with the variation. Some or all of the following areas may need to be addressed:
The nature and scope of the variation, including which of the prescriptive rules it affects, the operations to which it applies, and why it is needed
The operating environment in which the variation will apply (this may include people, procedures, equipment, stakeholders, the physical environment, the organizational culture, the legal and regulatory environment, natural hazards, and external threats)
Potential impact of the variation on other services, for example ATC or airport services
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Safety Case A well-substantiated estimate of the impact of the variation on crew
member fatigue, for example using published data from scientific studies or appropriate bio-mathematical models
Explanation of how the potential effects of the variation on fatigue will be monitored and documented
Description of the processes for risk assessment, if new fatigue hazards are identified as a result of the variation
Description of additional mitigations that can be put in place, if needed
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Study Design Define the goals or aims of the study
Describe the data collection methods, the groups or conditions that will be studied and compared and the measurements to be taken
Identify the frequency and timing of those measurements and the crewmembers to be studied
Describe the timeframe of the data collection, the methods of analysis, the criteria to be applied to evaluate the findings relative to the goals or aims of the study, and
State the proposed approach to establish that an FRMS provides an effective AMOC
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Initial Meeting with the FAA Prior to development of the FRMS application package, the carrier
should schedule time to discuss their plans for going through the FRMS approval process
This meeting may be conducted as either an in-person meeting or a teleconference
During this meeting, the FAA will review the approval process with the carrier and outline all of the items required for the process
Opportunity to speak with the FAA scientists to manage the air carrier’s data collection and analysis expectations
Additionally, this meeting will serve as an opportunity for the carrier to ask the FAA any questions relative to any part of the approval process
The objective is to manage the carrier’s expectations of the FRMS approval process
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Communication Plan The AMOC must have a communication plan that:
Explains FRMS policies, procedures and responsibilities for all stakeholders; and
Describes communication channels used to gather and disseminate FRMS-related information
The communication plan needs to addresses the frequency and type of communications necessary for the AMOC to be effective
The information provided also needs to be tailored to the needs and roles of different stakeholder groups to ensure people are not swamped by large quantities of information that has little relevance to them
The communication plan must support two-way communications among all stakeholders
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Training Plan These must include:
Training plan to ensure that all involved personal are trained and competent to undertake their responsibilities in the FRMS; and
An effective FRMS communication plan that explains FRMS policies, procedures and responsibilities to all relevant stakeholders, and describes how information relating to the FRMS is gathered and disseminated
The content of training plan should be adapted to make sure that each group has the knowledge and skills they need for their role in fatigue management under FRMS. This will entail more in depth training than when using only a prescriptive approach
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Data Collection Methods Alertness and performance data PVT and actigraphy Crew logs and surveys Fatigue incident reports Aviation Safety Reporting Systems (ASRS) Aviation Safety Action Program (ASAP) reports Bio-mathematical computer modeling: fatigue modeling Modeling of pairings, assignments, and actual FDPs
and flight times Actual vs. Scheduled FDP and flight times (Realistic
Scheduling)
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Data Reporting Requirements During the validation period the air carrier must provide data
reporting at least once a month
Once the validation period has been successfully completed, the air carrier must report data on the following schedule:
First two years of FRMS operations: every quarter
Year three: semiannually
Year four and beyond: Once a year
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Fatigue Reporting Fatigue reporting process
Fatigue incident reporting process
How will the carrier handle the fatigue reporting data?
How can the fatigue data be used to improve the overall effectiveness of the FRMS?
Will the fatigue data be reported during the required reporting intervals?
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Monitoring Fatigue Describe the methods used to monitor the flightcrew member
fatigue
How will the air carrier use this data?
What is the importance of monitoring fatigue?
How will the monitoring of fatigue help with the overall effectiveness of the FRMS?
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Approval Process - Overview Formalized approach.
5-Phase process containing 9 gates
Each gate identifies specific tasks that must be completed
Each gate must be satisfactorily completed in sequence prior to moving to the next phase
Phases must be completed in succession
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FRMS Approval ProcessAssessment, Planning,and Preparation
2. Formal Application
1. Preapplication, Planning, & Assessment
3. Documentation & Data Collection Plan
4. Demonstration & Validation
5. Authorization, Implementation & Monitoring
Detailed FRM Process andProcedure Development
a. Data Collection Prepb. Petition for exemptionc. Data Collection
Data Analysis & Validation
OpSpec Authorization
Gates 1-4
Gates 5 & 6
Gate 7
Gate 8
Gate 9
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Protection of All Data and Documents
All documents, to include policies and procedures, associated with the FRMS applications and authorizations are protected due to the proprietary nature
All performance data collected and validated is protected from disclosure due to the proprietary nature
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Summary If a certificate holder determines that the rule constrains a certain
flight operation, an FRMS could be proposed to the FAA
The FAA FRMS authorization process requires a systematic & progressive approach including scientific review and evaluation
Carriers utilize Fatigue Risk Management & Safety Assurance processes to demonstrate that their proposed FRMS provides an alternative means of compliance for managing & mitigating fatigue, with continuous monitoring, and adjustment, if necessary
Following demonstration & validation, the issuance of OpSpec A318 authorizes the carrier with a specific FRMS authorization
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Additional Resources AC 120-100 Basics of Aviation Fatigue AC 120-103A Fatigue Risk Management Systems for Aviation
Safety AC 117-2 Fatigue Education and Awareness Training AC 117-3 Fitness for Duty InFO 10017 Fatigue Risk Management Programs InFO 10017 SUP Fatigue Risk Management Programs
Supplement ICAO DOC 9966 Manual for the Oversight of Fatigue Management
Approaches 2nd Edition ICAO Fatigue Management Guide for Airline Operators 2nd Edition
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Questions?
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