Fatigue Risk Management

20 February 2017

ASMS has provided a submission in response to CAA's discussion paper on fatigue risk management.

CAA proposes to update the prescriptive fatigue management requirements currently provided in Advisory Circulars, and to also provide the option for an operator to implement an Fatigue Risk Management System (FRMS) as an alternative. In theory this would improve the management of fatigue as the prescriptive requirements provide a "backstop" while the optional FRMS enables the operator to adopt a different system if it will better suit its requirements.

Key points in our submission are:
  • Get a review of the scientific literature done by a suitably qualified expert, and base the regulated scheme(s) and the principles for FRMS on that review;
  • Fatigue is a safety risk, ergo no matter how it is managed it is part of the broader safety management system;
  • Don’t make assumptions about what might or might not be reasonably practicable, but instead apply analysis based on the legislative definition of reasonably practicable; and
  • Support all safety management initiatives, including fatigue risk management, with a genuine commitment to just culture.
We also noted that any effort to increase reporting will continued to be hampered by enforcement activities, and made reference to the proposal in our Review of Joining Procedures at Unmanned Aerodromes that safety reports should be collected by an organisation independent of the enforcement authority.

A full copy of our submission can be accessed here.

Image courtesy of Ktoine. Used under Creative Commons Licence CC BY-SA 2.0.