Federal Aviation Session 4: Country Perspective on FRMS ...clacsec.lima.icao.int/.../dia27/sesion4.pdf · Federal Aviation Administration FRMS Authority 14 CFR Part 117, Section 117.7

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

Federal AviationAdministration 2

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


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


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


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


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


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


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


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


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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