Implementing a Fatigue Management Program: A Human Factors Dimension to Your SMS

Chapter 11 of ISBAO centers on a Fatigue Management program. Introduced as its own chapter in 2016, the section emphasizes the need to have a Fatigue Management Plan (FMP), which is often viewed as a daunting task for operators of all sizes and complexities. In reality though, if seen as an extension of your existing SMS, the challenge is not as big as you might think. And, an FMP delivers many benefits with minimal impact to your business workflows.

Consider the basic tenets of the FMP: Policies, Education and Training, Flight and Duty limits, Deviation and Risk Management processes, Reporting, and Tracking trends. These are very similar to your existing SMS framework. Fatigue is simply another form of risk, and an FMP provides a framework to manage it—just like you are already managing all the other forms of risk in your existing SMS.

Your company’s safety culture is supported in the safety policy of your SMS, and fatigue risk is a legitimate threat to safety. In fact, stating this seemingly obvious point is a key purpose of the fatigue policy in an FMP. The fatigue policy should also set forth the roles and responsibilities of relevant staff in managing fatigue risk, and affirm management support by being signed and dated by an accountable executive.

Just as an SMS relies on sound procedures, a fatigue risk management process is bookended by sound flight and duty limits. These limits are grounded in scientific principles and substantiated by industry bodies; in general aviation, they are typically defined in terms of the Flight Safety Foundation Duty Rest Guidelines of 2014. Depending on the nature of your operation, you may be continuously within those limits, or you may need a deviation from time to time. In any case, the fact remains that it is common to be operating within the guidelines and yet be experiencing high levels of fatigue risk. It is also possible to be operating under a deviation from the guidelines with a low level of fatigue risk. A central function of the risk management process of an FMP is to quickly identify to what degree fatigue risk is an issue for each flight in your operation. Knowing where the high risk zones are is an essential first step to planning appropriate countermeasures. Biomathematical tools provide the analytical engine for evaluating risk mitigation options on the fly. They also serve to objectively substantiate the prescriptive limits and/or mitigation options you’ve been using.

Your FMP should provide a means for everyone in your operation to report fatigue issues or fatigue statuses throughout their work shifts. A good reporting tool affords the safety personnel a view of the portions of their operation where fatigue issues appear to be the worst. Supplementing your existing Hazard Report forms with sections for fatigue considerations is an efficient approach that can also shed light on potential relationships between fatigue and specified hazards. By monitoring the feedback and data from these reports and performing root cause analyses, you can evaluate mitigation options for future consideration.

Fatigue risk is a “we” issue. Everyone works together to promote safety per your SMS, and the same holds true for managing fatigue risk. From the decisions made by the operational team scheduling duties and flights, to the personal responsibility of individuals to report to work fit for duty, everyone has a proactive role to play in keeping fatigue risks to a minimum.

Usually, fatigue countermeasures are negligible to the operation. Real-world examples include small shifts of flight departure time, power naps, extra breaks on shift, or a cup of coffee at just the right time. Simply making everyone aware that elevated fatigue levels may occur during an upcoming flight plan can galvanize the team: the sense of personal responsibility will motivate flight crew to plan ahead and get more sleep leading up to the shift/flight.

You will find that incorporating a Fatigue Management Plan in your existing SMS is not that daunting a task. And, you will quickly find it gives a significant boost to your efforts to promote a culture of safety in your air operation.