On the fourth of February 2025, EASA and AESA (Agencia Estatal De Seguridad Aerea – the Spanish National Aviation Authority) hosted the 2nd EASA Fatigue Risk Management Conference in Madrid. These conferences, arising from workflows outlined in the European Plan for Aviation Safety (EPAS) to support operators with fatigue risk management, are an opportunity for the industry to discuss current challenges, reflect on the current state, and learn best practices from each other.
Now, this conference was a few weeks ago, and many people have already published conference summaries, not least EASA, so that is not my aim in this blog post. Instead, I want to take the opportunity to discuss in slightly more detail some of the challenges that appeared in discussions and hopefully give some helpful thoughts on how these may be addressed.
First, some background information and important terms:
- The conference focussed on Commercial Air Transport (CAT) operations with aeroplanes (i.e. primarily airlines), where flight time regulations are contained within ORO.FTL.
- ORO.FTL was first published by EASA in 2014 and became applicable in 2016.
- The Regulation requires all operators to manage fatigue as a hazard within their Safety Management System (SMS).
- Two similar terms with different meanings also appear in the text:
- Fatigue Risk Management (FRM) as outlined in ORO.FTL.120. Other parts of the world call this an ‘FRMS’ – i.e. a data-driven system that goes above and beyond managing fatigue through the SMS, with the intent to support operations outside of specific elements of the published flight time limitations.
- Appropriate FRM (CS FTL.1.205 (2) applies to all operators who operate night and late finish duties and requires the operator to actively manage the fatiguing effect of duties operated at this time.
- Unfit due to fatigue, is terminology used by some in the industry to specifically refer to crew who are too fatigued to fly due to non-roster related factors. I use it more holistically – any crew member who declares themselves too fatigued to fly is unfit. The reason why is then identified.
Appropriate FRM was introduced in EASA decision 2023/023/R as a result of the studies into the effectiveness of the flight time limitations, which found that fatigue in all night-time and late finishing duties was not effectively managed under the flight time limitations. However, as a term, it seems to be causing some confusion – what is appropriate? What are operators expected to actually do to show that they are managing fatigue sufficiently?
So, what is Appropriate FRM?
Put simply, Appropriate FRM requires the operator to collect data to demonstrate that the risk of elevated fatigue due to flying at night is managed.
EASA has published guidance material (GM1-GM5 CS FTL.1.205(a)(2) outlining the types of data that can be collected to inform the operator that fatigue should be appropriately controlled within these duties (including proactive data through fatigue surveys, and predictive data through the Prior Sleep Wake Model or bio-mathematical modelling), the use of fatigue reports, fatigue metrics and the safety assurance process.
But is this really new?
The Operator Responsibilities were published with the original regulation in 2014, and have been a requirement for 9 years now. Amongst them are the following:
(b) ensure that flight duty periods are planned in a way that enables crew members to remain sufficiently free from fatigue so that they can operate to a satisfactory level of safety under all circumstances
and
(g) provide rest periods of sufficient time to enable crew members to overcome the effects of the previous duties and to be rested by the start of the following flight duty period
In our environment of performance- and risk-based management of safety, these two elements of the regulation say, to me, that as an operator you need to satisfy yourself that no matter what the roster timing, fatigue is being appropriately managed. Just as through the SMS, all hazards must be appropriately managed.
And how do we do that?
Well, as in the guidance material related to night duties and appropriate FRM – we need data. All SMS risk assessment, risk management and assurance processes live and breathe through data. Fatigue reporting, either through a dedicated fatigue reporting system, or data collected through voluntary and mandatory safety reporting streams provides reactive data (if you have a strong safety culture). It may also provide proactive and predictive data – through crew submitting fatigue reports about general ‘concerns’ or future roster patterns that they consider to be fatiguing. Annual safety surveys are common across airline operators – questions related to fatigue (for example regarding the amount of sleep usually obtained between duties of different timings, asking crew to rate the most fatiguing elements of duties, etc.) can further support data regarding fatigue levels and contributors.
Again, we embrace our SMS principles – the level of data collection and risk control reflects the level of risk that your organisation is exposed to. A largely day-time, low frequency operation through simple airspace is going to have a very different level of fatigue exposure to a busy short-haul carrier with early starts, late finishes and tight turnaround times. A short-haul carrier are then also very different to the long -haul carrier with day and night duties between Europe and the US.
Many operators are embracing technology through bio-mathematical fatigue modelling of roster patterns to support their predictions of fatigue levels. Our scientific principles can support here too:
- Shifting our sleep/wake timing is hard. So, a roster with significant changes in start or end times of consecutive duties will likely cause more fatigue.
- For very early starts, every slight shift earlier in the start time is likely directly reflected in sleep loss.
- A 10 hour minimum rest period out of base that provides an 8 hour sleep opportunity is difficult – how long does it take crew to get to the hotel, eat food, wind down, and prepare for duty the next day before leaving for the next report time? Providing crew with slightly longer rest periods may increase the robustness of your rosters, through reducing delayed report times, and avoiding curtailed sleep periods that are more likely to result in the crew being unfit due to fatigue.
- And the list goes on
So, we ask the crew, we undertake surveys, we adjust rest periods to make sure that crew do have that 8-hour minimum sleep opportunity (but ideally more, as sleep need for adults is between 7-9 hours). The order that early starts fall within the roster can be adjusted to reduce fatigue at no cost to the airline and no increase in crew.
If you need support identifying if fatigue is being appropriately managed or want to confirm that you are meeting the operator responsibilities appropriately, contact us. Our FRM Diagnostic service is designed to identify the maturity of your fatigue management within the SMS, and how well you are meeting the operator responsibilities. To find out more, contact us at +44 (0)1276 535 725 or hello@bainessimmons.com.