Who is responsible for FRM?

FRM is a joint responsibility between the individual and organisation. Sleep can

be affected by factors at work and outside of work (stress, commuting time,

illness, lifestyle). The organisation needs to ensure schedules and the

environment are optimal for sleep and individuals are responsible to use

recovery time (before a block of work and between shifts) to obtain sufficient

sleep and employ strategies to reduce fatigue risk. The following are some

examples of work-related and individual factors that affect fatigue. Work-related:

• Working pattern (start and end times, consecutive number of shifts, rotating vs

f ixed patterns) • Workload and nature of tasks • Rapid turnarounds (inadequate

recovery between shifts) • Overtime and on-call arrangements • Environmental

conditions • Access to food and water • Safety culture (just culture is a subset) •

Sleep environment Individual: • Sleep environment • Sleep/alertness strategies •

Commute • Health • Domestic and social commitments • Sleep disorders •

Illness

Which Regulations and Guidance materials are relevant to Part 145

organisations? In Europe, regulatory requirements for managing fatigue in

maintenance are outlined in Regulation (EU) No 2021/1963 amending the ‘EASA

Continuing Airworthiness Regulation (European Union [EU]) 1321/2014’1 in

points: • 145.A.47 Production planning; • AMC (Acceptable Means of Compliance)

Production planning. For full text of these points, please see the appendix of this

paper. Regulation (EU) 1321/2014 has been retained and amended in UK

domestic law.2 The applicable date for complying with the FRM regulation

depends on where organisations have their approval in the UK only or in both the

UK and the EU. These regulations require fatigue risk to be considered within

production planning, and managed as part of the management system (145.A.47

(b) and (d)). As shown in the appendix, AMC include: • Providing fatigue training

and education • Implementing fatigue reporting systems • Conducting regular

fatigue risk assessments • Considering fatigue in the planning of maintenance •

Ensuring schedules provide adequate sleep opportunities and do not cause

serious disruption to the sleep/wake cycle associated with alternating night/day

duties • Putting controls in place to reduce fatigue risk identified. As stated by

the regulation, fatigue should be managed within the SMS (Safety Management

System). As SMS is a new regulatory requirement for European and

UK-based Part 145 organisations, managing fatigue risk may be seen as an

additional challenge. However, managing fatigue should not be seen as a

separate set of systems and approaches. Fatigue is simply another hazard which

needs to be quantified, evaluated and managed using the same principles

(assessment, management and monitoring) as the rest of the SMS. How do I

know fatigue may be a problem in my operation? It is not reasonable to assume

that because you are compliant with the European Working Time Directive
(EUWTD)3, your operation is safe. One problem is that the EUWTD was originally

designed to improve worker welfare. It is too generic to control fatigue risk in

safety critical industries due to the type of work being carried out and the

different contexts in which organisations operate. This means that fatigue

contributors may also be different and cannot be effectively controlled by broad

prescriptive regulations. It cannot be assumed that a particular shift schedule is

safe because it is compliant and/ or it has been in place for a number of years or

because there are no or few reports of fatigue-related incidents or accidents. The

lack of fatigue-related incidents or accidents may be due to the lack of a

reporting system or workers avoiding reporting as fatigue may be seen as an

individual problem and the fear of being blamed (see later reference to Just

Culture) rather than a shared responsibility between the organisation and

employees. Prescriptive limits on hours of work cannot control for the impact of

fatigue that workers ‘bring’ to the workplace from home. The assumption that

having 12 hours off between shifts for example guarantees adequate sleep is

flawed. Next, the question is: what happens if workers report to work having only

obtained 5 hours of sleep? Using FRM allows us to understand how spread out

inadequate levels of sleep may be in the operation and how to mitigate its

impact on performance, paramount in safety critical settings. What does

understanding fatigue risk involve? Understanding fatigue risk involves collecting

data that indicate where the fatigue hotspots may be in the operation and where

they come from. There are two main approaches to data collection: 1) Identifying
safety risks from events that have occurred in the past (reactive) Safety

reporting scheme Fatigue-related events are required to be reported through the

internal safety reporting scheme. Reports need to be supplemented with relevant

fatigue-related questions to help people complete a report successfully. Training

in how to complete a report needs to be provided. What kind of fatigue-related

events can be reported? A report can be completed by any employees to raise a

concern about: • the fatiguing feature of a working pattern, e.g., whether timings

allow for adequate sleep to be obtained • the fatiguing feature of a task, e.g.,

low or high workload, whether it occurred in the WOCL with no controls or

controls were not effective • a possible fatigue-related error that may have

happened to the person completing the report or to others. Trust in a Just

Culture4 is key for developing an open and honest reporting system. Effective

fatigue reporting processes allows the organisation to identify when and where in

the operation fatigue is elevated, and how spread out the occurrence of fatigue-

related errors/events may be so that fatigue risk can be managed in the

operation.

vestigations You may be already conducting safety investigations. Fatigue

investigations are similar in principle in that the aim is to understand the factors

that lead to an incident to minimise the likelihood of them recurring. In FRM, it

involves understanding whether fatigue played a role in an incident or accident

the sleep obtained was reduced or disrupted (sleep history) and the possible

contributors • performance at the time of the event was consistent with fatigue-

related performance • fatigue contributed to the event.5 2) Identifying safety

risks within the system before events occur If only reactive data were used, we

could only reduce fatigue risk after accidents and incidents occur and are

investigated. This approach is limited as it is reliant on past events and cannot

account for the impact of changing operations and context and variability in

performance in the present. Within FRM, we may ask the following questions: •

Do our current shift patterns support adequate sleep opportunities between

shifts? • What are the predicted fatigue levels when overtime is worked? • What

is the lowest level of fatigue predicted during a shift and when does it occur?

Fatigue modelling Bio-mathematical or fatigue models can be used to estimate

(predict) the fatigue level (low, moderate, high, severe) associated with different

types of schedules and at any given time during a shift. Fatigue models use

scientific principles of sleep and the circadian rhythm to estimate fatigue levels

based on working timings as input. The output of the model provides metrics

which can be used to quantify and evaluate shift-related fatigue and develop

schedules that promote alertness and mitigate fatigue risk. Although the GM in

Regulation (EU) 1321/2014 does not list the use of fatigue models to predict

fatigue, this methodology is being increasingly used (in flight operations) and is

recognised as a valuable tool to support FRM as a multi-layered approach.

to quantify fatigue by offering a snapshot of fatiguing aspects across the

operation. There are two basic types of surveys: 1. Retrospective surveys ask

people about sleep and fatigue in the past. They are usually completed once a

year and can capture the following: • workers’ approach to FRM, e.g., sleep and

alertness strategies used • fatigue contributors in the operation • commitment

and engagement with the organisation’s FRM strategies and procedures 2.

Prospective surveys assess real-time sleep and fatigue (e.g., how sleepy or

fatigued you feel right now). An example is measuring fatigue on night shift

(start, middle and end) across a week using a validated scale like the Karolinska

Sleepiness Scale or monitoring sleep patterns across a period of time using

research grade sleep monitors. Again, the use of such data and the scale of data

collection will be dependent on operational questions and needs.

Who is responsible for FRM? FRM is a joint responsibility between the individual

and organisation. Sleep can be affected by factors at work and outside of work

(stress, commuting time, illness, lifestyle). The organisation needs to ensure

schedules and the environment are optimal for sleep and individuals are

responsible to use recovery time (before a block of work and between shifts) to

obtain sufficient sleep and employ strategies to reduce fatigue risk. The following
are some examples of work-related and individual factors that affect fatigue.

Work-related: • Working pattern (start and end times, consecutive number of

shifts, rotating vs f ixed patterns) • Workload and nature of tasks • Rapid

turnarounds (inadequate recovery between shifts) • Overtime and on-call

arrangements • Environmental conditions • Access to food and water • Safety

culture (just culture is a subset) • Sleep environment Individual: • Sleep

environment • Sleep/alertness strategies • Commute • Health • Domestic and

social commitments • Sleep disorders • Illness

FRM EXAMPLES