When it comes to mitigating the risks of pilot fatigue, sticking to Europe’s Flight Time Limitations rules alone is not an option anymore. Instead, Fatigue Risk Management (FRM) is supposed to complement the prescriptive rules and to offer additional protection against fatigue, as explained in an ECA Position Paper.
Since October 2014, Safety Management System (SMS), including FRM are expected to be reality in every European airline. No doubt this will be a paradigm shift, not to mention a great challenge for all involved in the process of implementation. From the rostering and safety department’s point of view, it will not be sufficient anymore to schedule a flight duty by simply sticking to the prescriptive limits, set by EU legislation. In addition to that, a risk assessment on fatigue will have to be performed for the flight duties in accordance with the Safety Management System procedures.
However, observation of many ECA experts, who participated in the FRM Workshop held at EASA last month, is that FRM might remain an unachievable aspiration. The lack of detailed guidelines for the implementation of a mature SMS and FRM, lack of expertise in many National Aviation Authorities (NAAs) and the unwillingness of some airlines to apply FRM for genuine safety enhancement, threaten to undermine this tool. To add fuel to the fire, SMS and FRM have to be seen as the premises of a future EASA performance-based environment, which focuses on desired, measurable safety outcomes, rather than only a mechanic compliance with prescriptive limits or procedures. This makes it particularly difficult for operators and NAAs to oversee the implementation of FRM. With these challenges in mind, FRM is facing a tough time. Letting it fail, however, is not an option for pilots, who consider this an essential tool to manage fatigue risk.
What are the essential requirements that must be present in any Fatigue Risk Management? Read more in ECA’s position paper on Fatigue Risk management in Europe (Nov 2014).