Written by Managing Principal Consultant Sarah Booth
Following on from my recent Reflections on Fatigue Risk Management (FRM) in European Flight Operations blog inspired by the EASA /AESA FRM meeting in Madrid this February, we move onto the topic of competency to manage the risk associated with fatigue.
Competency
There are always new people being welcomed into the wonderful world of fatigue risk management. This means it’s essential to ensure that everyone is competent and understands what fatigue is, and how it is managed – otherwise, the system will not be effective, and we can be unwittingly exposed to elevated risk levels.
Fatigue training is competency-based training and must be delivered across the organisation – not just to the crew. As the regulation states:
ORO.FTL.250 (a) The operator shall provide initial and recurrent fatigue management training to crew members, personnel responsible for the preparation and maintenance of crew rosters and management personnel concerned.
Who are management personnel concerned?
Is it just the Head of Safety and Head of Flight Operations, or do we train a broader group than that? Which personnel in Management can impact the fatigue of crew members, or may be involved in processes related to crew fatigue? Suddenly, our training pool potentially widens:
- The Accountable Manager – accountable for all risks within the organisation, so an understanding of fatigue will support them in their role.
- The Head of Finance – is fatigue considered in decisions within the financial setting, for example when it comes to headcount?
- The Head of HR – HR may get involved in discussions around fitness for duty and may help in supporting crew who are having difficulties that are identified through the fatigue reporting process.
- Network Planning – opening new routes or airport slot times offer exciting business opportunities, but may cause elevated fatigue if not carefully managed. Equally, in an organisation with an ‘approved FRMS’ (or FRM in EASA language), there are business opportunities available when fatigue is well managed – like Ultra Long Range (ULR) routes or reduced rest in specific stations.
Of course, these individuals need a different training focus from crew. This is another essential element of competency-based training – the training content needs to be appropriate tailored to the needs of each group.
Tools to support competency
Competency isn’t just about training. Training is generally infrequent, but this isn’t our only opportunity to increase competency. Giving people tools that either enhance what they know, or bridge gaps supporting competency. One such tool is freely available and useful for those developing approaches to manage fatigue within an operation.
In February 2024, EASA published the 3rd edition of its FTL/FRM Inspector’s Checklist. This document is designed for Inspectors (as the name suggests), but it simply lists examples of what good looks like. Not all the examples given will be appropriate for all operators – those who are small, those who have limited resources, and those with limited fatigue risk levels may only need a very simple approach to control fatigue. If so, the checklist provides a framework against which to identify what you will do as an operator to control the risk, and how you will justify not doing other examples. This supports you building the overall argument that fatigue levels are controlled to As Low As Reasonably Practicable (ALARP).
Summary
As a last word on competency: I have been attending these events for 12 years. The EASA regulations have been published for 11 years and have been a requirement for 9 years. As one delegate at the conference said – how long can we keep saying that ORO.FTL is a challenge because it is new?
Have you identified areas where support is needed to help increase FRM competency in your organisation? Our training and consultancy services can support you, find out more by contacting our FRM experts at +44 (0)1276 535 725 and hello@bainessimmons.com
We offer a range of FRM and safety training courses, including:
Both of these courses can be delivered virtually or in-company, to find out more speak to the team at hello@bainessimmons.com.