Adapting commercial FRMS to business aircraft operations
On both sides of the Atlantic new requirements have been published for commercial air operators to implement Fatigue Risk Management Systems (FRMS) into their flight and duty times.
For now, only scheduled carriers are mandated to consider fatigue risks (no such requirements exist for non-scheduled on-demand commercial operations with a maximum seating configuration of 19 or less), emergency medical services, and single-pilot commercial airplane operations. In the US, FAR Part 117 that addresses pilot fatigue in the cockpit also excludes cargo airline operations from mandatory compliance.
Although these requirements are not mandatory for Business Aviation operators, fatigue remains a major issue. Business jet operators with an IS-BAO (International Standard for Business Aircraft Operations) registration in place are required to have a Safety Management System (SMS) - part of which requires identification of safety hazards and managed related risks.
Flight-crew fatigue may in fact be more of an issue in Business Aviation than in Commercial Aviation (where schedules tend to be planned well in advance). Business aircraft operations are characterised by an inherently unpredictable schedule, and thus the cumulative effects of fatigue are different to those of commercial airlines.
Periods of flying outside the standard limits and allowances that are imposed on commercial operators are not necessarily offset by the lower number of hours typically flown over the course of a year by business aircraft operators. Business Aviation operators undertake a far wider variety of missions than the pilot of a Scheduled Airline.
For example, pilots of a business aircraft are more likely to experience a wider variety of destinations and airports, each with differing challenges. Moreover, in a flight department operating multiple aircraft, they could alternate their flying duties between a variety of aircraft types – some being more labour intensive than others.
So on aggregate, while a corporate pilot may be less exposed to the risk of fatigue resulting from actual hours flown, they may well be more exposed per single unit of production (i.e. when a flight is undertaken a corporate pilot experiences more fatigue, stress and liability). Thus it is worth considering what these new fatigue risk management requirements actually imply, even though Business Aviation pilots are not currently governed by them.FRMS Outline
EASA AIR OPS at ORO.FTL.120 (the requirement is similar in scope to FAR Part 117.7 and 117.9) states that the FRMS established, implemented and maintained is to provide for continuous improvement to the overall performance of the FRMS. The system is to include:
- A description of the philosophy and principles of the operator with regard to Fatigue Risk Management (FRM), referred to as the FRM policy;
- Documentation of the FRM processes, including making personnel aware of their responsibilities and the procedure for amending this documentation;
Scientific principles and knowledge;
- A hazard identification and risk-assessment process that allows managing the operational risk(s) of the operator arising from crew member fatigue on a continuous basis;
- A risk mitigation process that provides for remedial actions to be implemented promptly, which are necessary to effectively mitigate the operator’s risk(s) arising from crew member fatigue and for continuous monitoring and regular assessment of the mitigation of fatigue risks achieved by such actions;
- FRM safety assurance processes; and
- FRM promotion processes.
The FRMS is to correspond to the flight-time specification scheme, the size of the operator and the nature and complexity of its activities, taking into account the hazards and associated risks inherent in those activities and the applicable flight-time specification scheme. The operator is to take mitigating actions when the FRM safety assurance process shows that the required safety performance is not maintained.FRM Guidance
FRM clearly embraces the SMS framework for safety management and how an FRMS is meant to be a specific function within an air operator’ SMS, with focus on the hazard of flight crew fatigue and its consequences. Corporate flight departments interested in managing the risk of fatigue more proactively may find useful guidance in the acceptable means of compliance and guidance materials within ORO.FTL.120 in EASA AIR OPS and/or FAA Advisory Circular (AC) 120-103A.
Guidance may also be found in the FRMS Implementation Guide jointly released by ICAO, IATA and IFALPA in 2011, although it should be remembered that these materials have been developed for use by the commercial airlines.
The core of the requirements and of the guidance materials is that scientific methods be used to monitor and manage crew fatigue levels. These methods include bio-mathematical fatigue models, and software models used as practical tools for estimating work-related fatigue associated with shift workers’ duty schedules.In tailoring models developed for commercial airlines for your own flight department, the cumulative effects specific to business aircraft operations needs to be taken account.
There will be a need to sample a number of days for performance monitoring. The long-term fatigue, based on the number of flight hours and the number of flying days in a month and annually needs to be factored when setting short-term limits for flight operations over a 24- or 48-hour period.
Waiting and standby times as well as the effect of time zone changes (to determine the reference for WOCL hours) must also be taken into consideration by the Business Aviation operator.
Help is always at hand if you are seeking to adapt FRMS to its own operations. The use of a good safety consultant could prove a worthwhile investment in the long-run as you seek to take preventative measures against the effects of fatigue within your flight department.