It is time to get educated!

On 5 May, a delegation of 11 BeCA members attended an FRMS Basics (Fatigue Risk Management Systems) conference organised by ALPL (Luxembourg’s Airline Pilot Association) and ECA (our European structure). Considering that SMS is a requirement since the end of last year and that FRMS will become compulsory in all airlines as of 2016, this gathering was very important to educate pilots and other interested parties on this essential concept. In most Belgian companies, these topics are new and a lot needs to be learned. Amongst the speakers were scientists, regulator representatives and pilot experts, including Didier Moraine, BeCA’s ECA Director and chair of the ECA Flight Time Limitations Working Group.

What is fatigue?

ICAO defines fatigue as follows: “A physiological state of reduced mental or physical performance capability resulting from sleep loss or extended wakefulness, circadian phase, or workload (mental and/or physical activity) that can impair a crew member’s alertness and ability to safely operate an aircraft or perform safety related duties.”

Fatigue can be measured either subjectively by having the crew members rate how they feel or objectively by measuring their performance. Sleep quality and sleep restriction are factors that can cause fatigue. Given the specific nature of flight operations, pilots often face these problems and fatigue can become a safety hazard. This is why scheduling must be thought carefully to ensure appropriate rest.

Discoveries in sleep science and circadian rhythms provide a scientific basis for FRMS. But science does not address every detailed operational question. Therefore, there will always be a need to combine operational experience and scientific knowledge to manage fatigue risks.

Safety Culture: a prerequisite to any SMS or FRMS

According to Dr Flaherty, an effective SMS is based on Safety Culture. But this concept is still perceived in different ways. “Everybody wants to have one, but doesn’t know what it is, how to get it and if it works.”

She feels Just Culture is an atmosphere of trust that has to work on a daily basis. When a mistake has been made, a balanced follow-up is needed with constructive actions behind to avoid future mistakes. An informed organisation is one with a just culture and a reporting culture.

SMS and FRMS: a new paradigm

Mr Daniel Coutelier (EASA) argued that FRMS allows an operator to improve safety and increase operational flexibility. However, this concept brings a totally new paradigm (see previous CF article). Whilst in the past regulators performed their oversight duties following a “tick-in-the-box” system allowing to measure legal compliance, they will now move towards a “performance-based system”, where it is the operators’ responsibility to demonstrate their performance. As a result, operators have to identify their own hazards, analyse the risks and implement appropriate mitigation measures, through their FRMS. If we want this task to be performed properly, it is of paramount importance that all stakeholders be trained and actively involved in the process, including us, pilots. And it is our airlines’ responsibility to provide all its crew members the appropriate training.

For such data-driven systems to be effective, data collection is essential (surveys, roster metrics, fatigue reports, self reporting, scientific studies, audits, etc), as well as mutual trust. Crews should be encouraged and trained to report using correct wording.
Mr Delbeke, representing DAC-L (CAA Luxembourg), explained that fatigue is a shared responsibility involving operators and crew members. As fatigue is complex, it is important to understand how the operator is measuring it. A management system helps deal with this complexity.

The implementation process

SMS and FRMS are linked, but FRMS goes beyond SMS in managing fatigue risks. No FRMS can be implemented without a functioning SMS. A project leader (the dedicated person in charge) is necessary for the start-up and stakeholders should be consulted from the early stages of the implementation process. The graph hereunder sums up the SMS/FRMS process.

Like SMS, FRMS relies on effective communication throughout the operator’s organisation:

• regular communication to all stakeholders about the activities and safety performance of the FRMS is needed
• crews and other stakeholders need to report promptly and clearly     

Inhibitors of an effective FRMS are:

• lack of data
• lack of just culture
• lack of trust in the management
• FRMS not customised
• use of FRMS only to justify operations

A success story: Cargolux

Dr Robert Klein from Cargolux explained the FRMS work within their FSAG, Fatigue Safety Action Group. In this airline, FRM started years ago and a continuously evolving system is in place. Data collection on targeted routes and rotations started from a sleep diary to an advanced tablet application that provides valuable information. Acti-watches are used to measure fatigue. He stressed that fatigue reporting should be made as easy and as accessible as possible to be effective.

As a conclusion, Just culture within an FRMS is vital. It is difficult to build up, but easy to ruin. Fatigue is more than a physiological problem: it is an ethical problem. One of the most frequent reasons for not reporting fatigue is fear of punitive actions from the employers. If implemented properly, “FRMS can be one of those rare win-win programs” for both the crews and the operators. As pilots, it is therefore also our responsibility to be informed about it, to report appropriately and to actively participate in these processes. BeCA’s Air Safety Committee has developed some material (a video and a presentation) to help our members understand the subtleties of SMS and FRMS. We invite you to have a look at them and to send us any doubt, question or comment you would have. If you want to go deeper into the subject of FTL legislation, you can have a look at EASA’s regulation CS-FTL1 here.