Part II: Fatigue Management Programs vs. Fatigue Risk Management Systems

Last month we outlined the concept of a fatigue management program. One of the hallmarks of fatigue management programs is that they vary from organization to organization and from industry to industry because regulators have not yet applied regulations to the requirements of Fatigue Management Programs.

In contrast to fatigue management programs, the requirements of Fatigue Risk Management Systems (FRMS) are usually under regulatory control and this results in FRMS documents that are similar across organizations within the same industry. These documents are comprehensive and process and procedure oriented. They normally describe processes to identify, measure and monitor fatigue and its associated risks along with procedures to prevent future fatigue, reduce the effects of current (extant) fatigue and reduce the risks of negative outcomes associated with fatigue.

FRMS documents may include scheduling practices that apply limits to daily and weekly work hours and night shifts, and impose requirements for off-duty and recovery periods or they may refer to scheduling practices detailed in other documentation. Likewise, FRMS documents may refer to other practices, processes, procedures and programs that support fatigue management. For example, an FRMS document may detail how an organization ensures that their workforce obtains training on sleep health through a company training program. In this case, the company training program would be detailed in a separate document and would include information on training in sleep health.

There are two key elements that distinguish FRMS’s from all other fatigue management approaches. The first element is that the identification, measuring and monitoring of fatigue and its associated risks allows for a flexible and tailored use of strategies to manage fatigue according to the situation rather than applying the same strategy to all situations. This can mean that limits and requirements dictated by scheduling practices may be surpassed if data from the identification, measuring and monitoring processes indicates that fatigue is being managed according to preset criteria.

The second element acknowledges the idea that complacency can lead to a regression in safety when key performance indicators are static. In essence, the idea is that when organizations continuously meet a set of static fatigue management goals with seemingly little effort, the workforce may expend even less effort in ensuring fatigue management practices are followed. This can allow previously mitigated hazards to be present without mitigations and subsequently result in accidents and incidents.

To counteract potential safety regressions, FRMS’s will often include continuous improvement processes that set increasingly challenging key performance goals. For example, an organization may begin with a goal to ensure that all operators endorse the sleepiness level of 7 or lower on the Karolinska Sleepiness Scale (KSS is a validated assessment of subjective fatigue) at the start of all duties. After continuously meeting this goal for a predetermined period of time, the goal could be changed to ensuring a sleepiness level of 6 or lower at the start of all duties. To meet this new goal, the workforce would have to make certain they were expending enough effort to meet the goal rather than allowing their efforts to lessen.

Although continuous improvement is a key element for FRMS, regulators have not universally included it in their requirements. As indicated last month[link to last month’s article], the area of fatigue management is a novel one and the idea of mitigating safety regressions with a continuous improvement process is not yet accepted by all regulators. At the present time, this element is only included in the FRMS requirements of progressive and trend setting safety conscious regulators.

For an example of regulations governing FRMS, have a look at the Canadian Aviation Regulations (CARs); specifically, beginning with the regulations under Division V - Exemption - Fatigue Risk Management System (CAR 700.200): https://laws-lois.justice.gc.ca/eng/regulations/SOR-96-433/page-85.html#docCont. When you look at the CARs for FRMS in Canadian civil aviation, note how detailed, and confusing, they are…this is quite typical of regulations governing FRMS. In fact, their complexity usually necessitates additional guidance documents to help fatigue managers understand what they need to do to comply with the regulations. Transport Canada published such a guidance document. It is Advisory Circular (AC) No. 700-046: Fatigue Risk Management System Requirements, see https://tc.canada.ca/en/aviation/reference-centre/advisory-circulars/advisory-circular-ac-no-700-046.

Stay tuned for Part III in which we will position fatigue management plans somewhere in between fatigue management programs and management systems.