Fatigue Risk Management System - IATA Perspective


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Fatigue Risk Management System - IATA Perspective

  1. 1. Fatigue Risk Management System (FRMS) IATA’s Perspective CNPAA Meeting 25/APR/2014 Safety and Flight Operations IATA Brazil
  2. 2. A IATA (International Air Transport Association) is an international organization that supports the global commerce related to the aviation industry. Founded in 1945, has 240 member airlines representing 84% of the world air traffic. Our mission is to represent, lead and serve the industry. Our Vision is to deliver standards and solutions in order to ensure a successful and safe air transport worldwide. About IATA
  3. 3. Fatigue Management Approaches Prescriptive; • Flight and duty time limitations. • Identified by regulator. • One-size fits all. • Arbitrary “safety” line. Fatigue Risk Management System (FRMS); • FTLs identified through operator’s processes. • Specific to operational context. • Continually evaluated and updated.
  4. 4. Fatigue Management Provisions ICAO Annex 6 Part 1 (Flight and Cabin Crew): • FRMS Standards and Recommended Practices (SARPs). • Appendix 8. • Attachment A (guidance for FTL regulations). ICAO Doc 9966 - FRMS Manual for Regulators FRMS Guides (IATA& ICAO) developed for: • Operators. • Regulators.
  5. 5. Annex 6 - FM SARP: 4.10.2 The Operator: Where FRMS regulations are offered, can choose how to manage their fatigue risks: • Comply with prescriptive regulations or; • An FRMS for all operations. or; • An FRMS for some operations and prescriptive regulations for the remainder of operations.
  6. 6. Safety policy & objectives Safety risk management Safety assurance Safety promotion SMS Components FRMS Components FRMS policy & documentation Fatigue risk management processes – Identification of hazards – Risk assessment – Risk mitigation – Implementation Fatigue safety assurance processes – Monitor effectiveness of FRMS – Processes for managing change – Continuous improvementofthe FRMS FRMS promotion processes – Training programmes – FRMS communication plan Annex 6 - Appendix 8
  7. 7. IATA’s FRMS Guide Collaboratively developed. Aligned with ICAO’s FRMS Manual for Regulators. Provides comprehensive implementation guidance including scientific principles. Freely available on the web • www.gsic.iata.org • www.icao.int • www.ifalpa.org
  8. 8. Regulatory Decisions, Activities and Tools Chapter 1.Chapter 1. FRMS defined. FRMS SARPs and their intent. Chapter 7. Considerations when deciding to offer FRMS regulations. Chapter 8. Process Chapter 8. The FRMS Approval Process Chapter 9. Oversight Chapter 9. Providing FRMS Oversight Appendix D. FRMS (Example) Appendix D. FRMS Evaluation Form (Example) The Scientific Background Chapter 2. The scientific principles on which an FRMS approach is based. Components of an FRMS Chapter 3. Policy and Documentation Chapter 4. Fatigue Risk Management Processes Chapter 5. Fatigue Safety Assurance Processes Chapter 6. FRMS Promotion Processes Supporting Information Appendix A. Glossary Appendix B. Tools for measuring fatigue Appendix C. Procedures for Controlled Rest on the Flight Deck IATA’s FRMS Guide
  9. 9. FRMS Definition (IATA/ICAO) “ A data-driven means of continuously monitoring and managing fatigue-related safety risks, based upon scientific principles and knowledge as well as operational experience, that aims to ensure relevant personnel are performing at adequate levels of alertness.”
  10. 10. What are the scientific principles? The physiological need for sleep: • Quantity. • Quality. Recovery from sleep loss: • Transient; • Cumulative; Circadian biological clock;
  11. 11. Doctor? Scientist? Safety Expert? Labour? Who is the expert? Pilot Fatigue Subject Matter Expert (SME) Flight Operations Management
  12. 12. Fatigue (ICAO Definition) “…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” vs. “Tired” There is a difference!!
  13. 13. Why is Fatigue Getting so Much Attention? All aspects of a carrier’s operation are affected • Headcount • Crew Utilization • Equipment Utilization • Network Planning • Scheduling Fatigue Management = Additional Constraints Increasing operating costs with sick crews.
  14. 14. Ops Conference 14 16-18 April 2012, Rio de Janeiro Sitting at the Fatigue Management Table
  15. 15. The Regulator Role • Provide a regulatory framework for the adequate management of fatigue related risks. • Ensure that the operator is managing their fatigue related risks to an acceptable level of safety. • Recognizes that FRMS needs to be unique to each operator.
  16. 16. Regulator Needs A platform of robust prescriptive flight and duty limitation regulations; Time and resources to develop sufficient knowledge related to fatigue management processes; Access to scientists; Experience in oversight of performance-based regulations; Clear approval and oversight processes; Basis : ICAO Doc 9966 (FRMS Manual for Regulators, 2011) Outputs: • FAR117 (2013) “Flightcrew Member Duty and Rest Requirements”. • AC 117-3 “Crew Fitness”. • EASACAP371.
  17. 17. Challenges for the Regulator Providing a regulatory environment that supports effective safety reporting. Performance-based regulations require different regulatory skill sets Assessing the balance - flexibility with tolerable risk. Provision of consistent and comprehensive guidance to operators. Consistency in regulatory decisions.
  18. 18. The Operator Role • Own and manage their fatigue related risk to an acceptable level of safety; • Within the regulatory framework provided, identify the most appropriate means of managing their fatigue-related risk; • Provide the operational environment to allow a pilot to manage their fatigue-related risk on any given day or time.
  19. 19. Operator Needs Operate competitively within the global aviation environment. A level playing field amongst global carriers. Operational flexibility to react quickly to unforeseen circumstances. Data-driven and/or results-oriented resource allocation. Free-flow of information from pilots.
  20. 20. Challenges for the Operator Limited Resources: • Data collection. • Undertaking scientific research. • Effective application of available information. • In-house expertise. Regulatory demands…
  21. 21. The Pilot Role • Use the resources provided to assure he/she is adequately rested to perform his/her duties safely. • Recognize when they are unable to perform their duties safely and if so remove themselves from the operation.
  22. 22. Pilots Needs Information, schedules and resources for allowance to responsibly prepare for, and execute duties. Effective safety reporting culture. High standards of professional behaviour.
  23. 23. Challenges for Pilots Focusing on safety needs vs. industrial desires. Focusing on safety needs vs. personal preference. Group acceptance of scientific principles and their application. Confidence in the operator’s reporting system.
  24. 24. Pilots - Fitness For Duty Essential Elements • Opportunity for rest • Use of rest opportunity • What do we do when it doesn’t work as planned. Responsibilities • Pilot’s role • Operator’s role
  25. 25. Safety x Labor Relations Deal breakers: • Pilots - Interrupt data collection and/or halt participation for industrial reasons. • Operators - Use voluntary information for punitive reasons or other than intended purposes. • Regulators - Fail to set rules to protect data.
  26. 26. How to Avoid the Deal Breakers Collaborative Relationship (CDM) • Pilots; • Operators; • Regulators; Mutual Respect. Commitment to meet respective responsibilities.
  27. 27. FRMS Basics Data-driven and scientifically based process; Allows for continuous monitoring and management of safety risks associated with fatigue-related error; Part of a repetitive performance improvement process; Leads to continuous safety enhancements; • Identification and management of fatigue factors across time • Changes physiological and operational circumstances associated with a specific operation May be integrated into an operator’s overall SMS.
  28. 28. Elements of an FRMS Current flight time and duty period limitations. Rest scheme consistent with limitations. A fatigue management policy. Education and awareness training program. Fatigue reporting process. System for monitoring and analyzing flight crew fatigue. Evaluation program.
  29. 29. FRMS Process Identify / Assess Current Risk Assessment of Fatigue Risk Manage and Mitigate Fatigue Risk Monitor for Effectiveness
  30. 30. Effective Safety Reporting System Permits crewmembers and other employees to report fatigue. Contains valuable data. An effective safety reporting system. • Does not provide full immunity from acts resulting from willful and/or gross negligence and illegal acts; • Does provide clear descriptions of acceptable and non- acceptable behavior and their consequences; • Does provide the environment that encourages free reporting.
  31. 31. Types of Data Reactive - wait for incidents to happen and try to understand why; Proactive - analyze near misses, identified risks to mitigate before they turn into an accident / incident; Predictive - mature system which conducts predictive analytics (statistical modeling) to identify and mitigate risks;
  32. 32. Fatigue Reports A system for monitoring flight crew member fatigue in day-to-day operations • Not-fit for duty; • Hazard report ; Should contain operational procedures to follow when one identifies or suspects fatigue risk in oneself or others.
  33. 33. Confidential Reporting Confidential reporting can be used for the following safety concerns: • Unsafe behaviors; • Inadvertent errors and mistakes; • Near miss occurrences (incidents that did not occur but could have easily resulted in a serious event); • Inadvertent errors or violations of aircraft handling or servicing systems; • Procedures or processes that could be improved;
  34. 34. Other Data Sources Other data sources to consider when identifying and assessing fatigue occurrences: • Internal audit results; • Procedural errors • Schedule deviations ~ planned vs. actual • Accident Reports
  35. 35. Summarizes supporting science Explains the minimum requirements Describes how to implement an FRMS Provides operational examples of various means of compliance Stresses the need for joint responsibility amongst all stakeholders IATA’s FRMS Guide
  36. 36. SMS and FRMS SMS Framework FRMS Safety policy and objectives FRMS policy and documentation Safety risk management FRM processes • Identification of hazards • Risk assessment • Risk mitigation Safety assurance FRMS safety assurance processes • FRMS performance monitoring • Management of operational andorganizational change • ContinuousFRMS improvement Safety promotion FRMS promotion processes • Trainingprograms • FRMS communicationplan
  37. 37. FRMS Framework Fatigue Safety Action Group Co-ordinates fatigue risk management activities Risk Management Processes (Chapter Four)Policy (Chapter3) Safety Assurance Processes (Chapter Five) Promotion Processes (ChapterSix) Documentation (Chapter3)
  38. 38. Methods of Hazard Identification Reactive Methods • Assess the contribution of crewmember fatigue to safety reports and events. • At what time of day did the occurrence take place? • Was the crewmember’s normal circadian rhythm disrupted? • How many hours had the crewmember been awake at the time of the occurrence? • Does the 72-hour sleep history suggest a sleep debt? 38
  39. 39. Methods of Hazard Identification Predictive Methods • Identify areas of future fatigue related risks: o Previous experience; o Evidence-based scheduling practices; o Bio-mathematical models; 39
  40. 40. Methods of Hazard Identification Proactive Methods • Monitor fatigue levels in an operation; • Self-reporting of fatigue risks; • Crew fatigue survey; • Flight crew performance data; • Available safety databases and scientific studies; • Analysis of planned x actual time worked; • Sleep monitoring (sleep diary, actigraphy, polysomnography) I f conf ident ialit y r equir edt ick her e ● Fatigue Report Form Nam e Em ployee No. Pilot /CCM ( cir cle) WHEN DI D I THAPPEN? Local r epor t dat e Tim e of event ( local r epor t t im e) Dut ydescr ipt ion ( t r ippat t er n) Sect or onwhich f at igue occur r ed Fr om To Hour sf r om r epor t t im et owhen f at igueoccur r ed Disr upt ? Yes/ No Air cr af t t ype Num ber of cr ew WHAT HAPPENED? Descr ibe how youf elt ( or what youobser ved) Please cir cle how youf elt 1 Fully aler t , wide awake 5 Moder at elylet down, t ir ed 2 Ver ylively, som ewhat r esponsive, but not at peak 3 OK, som ewhat f r esh 6 Ext r em elyt ir ed, ver ydif f icult t o concent r at e 4 A lit t le t ir ed, lesst hanf r esh 7 Com plet ely exhaust ed Please m ar kt heline below wit h an‘ X’ at t hepoint t hat indicat es how youf elt aler t - - - - - - - - - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -dr owsy WHY DI DI THAPPEN? Fat igue pr ior t odut y? Yes /No How long had youbeen awakewhen t he Hot el Yes /No event happened? hr s m ins Hom e Yes /No How m uchsleep did youhave in t he24hr s Dut yit self Yes /No bef or et heevent ? hr s m ins I n- f light r est Yes /No How m uchsleep did youhave in t he72hr s Disr upt Yes /No bef or et heevent ? hr s m ins Per sonal Yes /No f light decknap? Yes/ No I f yes, when st ar t end Ot her com m ent s WHAT DI DYOU DO? Act ionst akent o m anageor r educef at igue( f or exam ple, f light decknap) WHAT COULD BE DONE? Suggest edcor r ect iveact ions 40 1 = extremely alert c2 3 = alert 4 5 = neither sleepy nor alert 6 7 = sleepy, but no difficulty remaining awake 8 9 = extremely sleepy, fighting sleep
  41. 41. Data Collection Devices
  42. 42. Data Analysis
  43. 43. Data Analysis Analysis and interpretation • Scientists • SME Application • Operator Note: Ask scientists about science, not operations
  44. 44. Applying the Findings Build into pairings. Build into rosters. Build into day-to-day crew scheduling. On-Board Sleep facilities. Training • Management. • Flight Crew. • Support Staff.
  45. 45. FRM Processes What they do: • Identify where fatigue is a hazard; • Assess the level of risk that given fatigue hazard represents; • If necessary, put in place controls and mitigation strategies, and monitor to make sure that they manage the risk at an acceptable level
  46. 46. DAY FLT DEPARTS ARRIVES BLK M/U TURN M 60 EQP ACT/MAX 10 D 920 ATL 1440 LGA.1705 2.25 932 2.25DHD JFK 0.00/Layover 0.00B 2.25TL 11 16 JFK 2050 BOM.2150 15.30 0.15 * 7102 BOM 48.26/Layover 15.30B 15.45TL 15 17 BOM 0020 JFK.0650 16.00 0.04 * EWR 22.13/Layover 16.00B 16.00TL 16 D1749 EWR 0552 ATL.0803 2.11 0.03 3735 2.11DHD 0.00B
  47. 47. Is there existing science / experience / literature? Does anyone already do something similar? Answer : Yes • Flight Safety Foundation ULR Working Group • NASA studies • Singapore Airlines • SIN-LAX o Safety Case o Validation What do we already know from our own experience?
  48. 48. JFK-BOM B777-200ER 16+ hours block time 10.5 hour time zone shift Evening departure Maximum capabilities of aircraft No crew base for aircraft
  49. 49. Sequence of Events Commercial • City Pair/Time/Aircraft Ops/Safety • Can we conduct this flight at an acceptable level of risk? Ops/Scientists/Commercial • What are the available mitigations? Ops • Formulate a plan using available resources to conduct the flight Ops/Safety/Scientists • Review the plan
  50. 50. FRMS Implementation (the real truth!) There is no ‘off-the-shelf’ version of an FRMS that will suit all operators; An FRMS needs to be developed, understood and managed by people who have comprehensive experience in the complex operational environment to which it will apply; A fully functioning FRMS doesn’t happen overnight; Implementation is necessarily accomplished in phases;
  51. 51. Ops Conference 55 16-18 April 2012, Rio de Janeiro Phased Implementation
  52. 52. Bio-mathematical Models Used for: • Pairing/Roster Comparisons • New Routes • Evaluation of Mitigations • Incident Investigation • Complaint Resolution • Evaluation of New Regulations Not Used for: • Firm Go/No Go Decisions
  53. 53. The Circadian Component The circadian component of alertness follows a sinusoidal trend The peak in the late afternoon (1700-1800) The trough is in the morning (0500-0600) copyright frms int ltd. 0 2 4 6 8 10 12 14 16 18 20 22 24 Time of day (h) Alertness
  54. 54. The Alertness Component Alertness is low immediately after waking • Effect of sleep inertia It increases to a peak 2-4 hours after waking Thereafter it decreases exponentially copyright frms int ltd. 0 6 12 18 24 30 36 42 48 54 60 0 2 4 6 8 10 12 14 16 18 Time since sleep (h) Alertness
  55. 55. Examples copyright frms int ltd.
  56. 56. Examples
  57. 57. Current State 5 models commercially available • BAM • CAS • FAID • SAFE • SAFTE/FAST 3 models public domain (maybe more) 1 model produced by an operator. More coming….
  58. 58. Current State No International Standards. No International Validation Process. Experience with Most has Been Outside of Aviation.
  59. 59. Model Challenges Straight Science vs. Reality Which Model is the Best? Over Reliance by Stakeholders User Education Accuracy of Predictions-Limited Data Validation Accounting for Crew Mitigations Additional Constraint During Optimization
  60. 60. IATA Activities IATA, ICAO, IFALPA FRMS Seminars: • All Stakeholders invited and encouraged to attend; - Regulators; - Airlines; - Pilot Associations; - Etc.. • Deliver a consistent message with a collective voice.
  61. 61. IATA FRMS TASK FORCE Provide assistance and guidance to Industry with FRMS implementation; Collaborate with Regulators;
  62. 62. Opportunities Standardization; Safety Performance Measures; Acceptance and use of credible Scientific Principles / Data; Identification of Models / “Experts”; Common Data Reporting; Training ~ including CBT training for front line employees (regulatory requirement); Inclusion of fatigue management provisions into IOSA;
  63. 63. Opportunities – CBT Training CBT Training under development • Flight Crew • Cabin Crew • Maintenance • Dispatch / Ops Control • Crew Scheduling / Crew Planning
  64. 64. Opportunities - IOSA FRMS concept introduced as Guidance Material in ISM Edition 6 effective by September 2012. • Applicable to Flight and Cabin Crew items: - FLT 3.4.3 - CAB 3.1.4
  65. 65. Summary Overall an FRMS may offer a way to more safely conduct flights by offering flexibility that may not be available within regulatory limits; An FRMS complements prescriptive flight time, duty, and rest requirements; Improves operational efficiency; Provides for a performance-based regulatory approach that is “tailored” to an operator’s specific operation;
  66. 66. José Alexandre.T.G. Fregnani AssistantDirector – Safety & Flight Operations IATA Brazil fregnanij@iata.org Tel: +55 11 2187 4236 “Represent, lead and serve the industry.”