Five years after the implementation of Safety Management Systems (SMS) and Fatigue Risk Management (FRM), and three years after the entry into force of EASA FTL, too many European airlines are still struggling to implement some of the basic principles of these regulations when it comes to managing the fatigue risk in their operations.

The complexity of these regulations does not explain alone this failure. The lack of expertise on FRM, even after 5 years, demonstrates an insufficient investment from the industry and from the regulators on this matter:

• Last year, EASA deplores up to 75% of Member States to have deficiencies when it comes to FTL related oversight, it’s up from 50% a year before.
• An internal survey performed by ECA among 14 pilot associations shows that only 15% of the operators are subject to regular oversight of their FRM by their national authorities.
• Only a third of these operators have involved a pilot representative in the setting up of the their FRM process.
• And 45% of them don’t even have a pilot representative in their Fatigue Safety Action Group (FSAG).
• At the end, only 25% have adapted at least one pairing or rotation based on the data gathered by their FRM.

A reason for this poor performance could be found in the lack of incentives granted to the good FRM performers. Implementing a functional FRM, and not only a paper-tiger version, is yet wrongly considered as a costly investment that won’t necessary improve the safety of operations, and may limit the flexibility compared to a basic compliant approach. It should be noted that, after 3 years, only a few operators chose to implement a full FRM under the EASA FTL regulations to derogate from the basic regulation.

Some operators that have implemented genuinely the FRM principles in their SMS now show  weaker investments in their efforts. An increase in the production or in the productivity, a temporary difficulty to hire experienced pilots or to train the new ones, a simple change in the management structure are some examples that may easily jeopardise the good resolutions taken some years ago. Their efforts don’t pay off. Their competitors are not investing more than the minimum in their FRM, and at the end the regulator continues to focus mainly on the compliant issues.

To revert the trend, EASA needs not only to increase its standardisation activities towards the Member States but needs also to review some of the key principles in the EASA FTL regulation. The publication in February 2019 of the scientific study (https://bit.ly/2uz2FGN) mandated by EASA on disruptive schedules and night flights is an opportunity not be missed to strengthen the basic FTL compliant regulation. A generic call from EASA for more education and training on FRM may not solve any fatigue safety concern that will be raised by this study. The regulation should be amended in its basis to reflect the most accurate scientific and medical knowledge. The good FRM players have to be encouraged to further invest in their FRM to gain flexibility compared to a basic compliant approach. The poor performers should be penalised and lose flexibility. That would be a radical change that will boost the whole industry to invest in their performance tools for the future.

By Didier Moraine, BeCA’s ECA Director