Comair flight 5191 did much to elevate the issue of fatigue within
the air traffic control community. The 2006 tragedy was the result of
the Bombardier regional jet overrunning the end of the Lexington,
Kentucky, runway before it could become airborne, killing all 47
passengers and two of the three flight crew.
The next year the National Safety Transportation Board issued three
recommendations on measures to prevent fatigue affecting the performance
of controllers, one to prevent them from carrying out non-essential
administrative tasks while aircraft are taxiing under their control.
Six years on, there is a real prospect of potentially radical
mitigation measures being developed for air traffic control as US
aviation agency ICAO readies itself to develop a bespoke system to
mitigate the ever present risk of fatigue.
Lydia Hambour, director of fatigue risk management at American
Airlines, helped develop a Fatigue Risk Management System or FRMS for UK
low cost carrier EasyJet, integrating the system operationally and
assessing the impact of crew fatigue on performance.
“24-hour operations expose employees in the aviation industry to
varying and often lengthy periods of time on duty, disruption to
circadian patterns compounded by reduced and often interrupted rest
periods. On top of this are workload influences, including external and
internal factors that can vary from one duty or shift to the next,” she
explains. “These hazards can interact and result in a fatigued employee –
one whose ability to perform safety-related duties is impaired.”
Professor Philippe Cabon is a human factors professor at Paris
Descartes University and a member of the ICAO task force that developed
the standard recommended practices and guidelines for the airline FRMS
that were issued in 2011 as an alternative to prescriptive flight and
duty limitations to address crew fatigue.
He says progress by the industry to address this critical safety
issue – even since the NTSB declared fatigue as one of its ‘most wanted’
– has been slow despite the large amount of available scientific
knowledge. “The reason is probably because fatigue is a complex concept
raising issues beyond safety such as productivity and social aspects,”
he says.
IFATCA, the international organisation representing approximately
40,000 air traffic controllers in more than 100 countries, has lobbied
long and hard for a FRMS for the profession. It believes that the safety
prerogative has been railroaded.
In a working paper presented by IFATCA at the recent ICAO 12th
Air Navigation Conference it insisted that for too long, fatigue
management has been addressed as a labour relations rather than a safety
management issue.
IFATCA reckons that as the industry embraces a safety management
ethos, it is now time to treat fatigue management as a component of a
safety management system. After all, the same principles can be applied
as for the management of other safety hazards and FRMS fits well within
existing frameworks, based as it is on a pragmatic review of operational
practices augmented by scientific knowledge.
Scheduling has, it is true, become a frequent proxy in the labour
bargaining process, on all sides of the equation: by both employers and
employee organisations.
As Cabon points out, the organisation of duty cycles is devilishly
difficult simply because the ideal schedule does not exist. Scheduling
is always a compromise between safety, health requirements, productivity
and social acceptance.
Industrial negotiations may influence
remuneration and how many hours people work, but they do not necessarily
address safety. If improved safety outcomes are the goal, FRMS offers a
real step in the right direction:Millar
“One of the first aspects to consider is the direction of shift, i.e.
clockwise known as delayed rotation or counterclockwise known as
advanced rotation. From a physiological point of view, most shift work
experts argue that clockwise rotations are better than counterclockwise
rotations because of the dynamics of the circadian cycle, which has a
natural delaying trend,” he explains.
From the controller’s perspective, however, such delaying schedules
are often unpopular as they tend to compress the weekend and so, if a
clockwise schedule is adopted, it is necessary to find a way to keep
sufficient time off for the weekend period.
Here, Dr Michelle Millar, FRMS project co-ordinator at ICAO, notes
that to be successful, a workable system for the world’s controller
community requires the same level of tripartite collaboration as
occurred between ICAO, airline industry body IATA and pilot organisation
IFALPA that led to the successful development of the airline FRMS last
year.
“Industrial negotiations may influence remuneration and how many
hours people work, but they do not necessarily address safety. If
improved safety outcomes are the goal, FRMS offers a real step in the
right direction,” says Dr Millar. “Separating these considerations
requires a strong relationship between the union, the operator or
service provider and the regulator.”
For Lydia Hambour, an organisation intent on implementing a FRMS will
therefore require a programme of education and awareness training so
that all parties are clear about their respective obligations.
“If the understanding of FRMS is unclear it may be perceived solely
as a means of increasing employee productivity. Conversely, at the other
extreme, it may be seen as facilitating employee absence through
providing a readily accessible justification based on abuse of a safety
absolute.”
To prevent both scenarios, Hambour says it is vital that an FRMS is
based on scientific evidence, objectivity and transparency and is
underpinned by organisational commitment to a just culture and
non-jeopardy reporting.
The alternative, as Hambour sees it: simply relying on legal
limitations as a means of controlling the fatigue risk is fast becoming
acknowledged as incomplete and therefore unacceptable.
FRMS essentially provides a way of extracting data from the specific
operational environment and comparing it with scientific knowledge on
sleep and shift sequences. It therefore effectively manages the risks
posed by fatigue as a result of the operational circumstances that
actually exist. It is proactive and continuous so as to identify the
risks, implement mitigating strategies and review the outcome, ensuring
the risks are controlled effectively and continuously.
The essential challenge of FRMS therefore is to overcome the inertia
which is part and parcel of more static legacy solutions. Those who have
already embarked on FRMS within the airline industry would agree that
it is far from easy to implement and that it requires not only a
willingness to change but also a genuine shift in mindset to a position
where operational fatigue risk is actively managed.
Sadly, we have known examples where an
implemented FRMS is little more than a ‘box ticking exercise’ where base
rosters are usually at the maximum permitted fatigue level: Shallies
While FRMS does require education, increased expertise and
understanding, its champions are convinced that any investment made will
be recoverable through the accrued benefits it brings. The ultimate
upside for the controller community is a situation where there is a
demonstrable reduction in incidents, cognitive slips and lapses
accompanied by less instances of impaired decision-making, less
communication failures and less risk-taking behaviour.
David Hillis from scheduling software business Quintiq says the
potential increase in complexity involved in existing within a FRMS
environment would mean that more ANSPs would need specifically developed
systems. “What ANSPs are concerned about is that FRMS means more rules,
more restrictions in how they can plan – and that that will cost them
more. We would say that if you have a good system you can generate good
and efficient rosters and still meet FRMS requirements and you may not
be able to do that with a spreadsheet.”
With the prospect of a global FRMS for controllers by the end of
2015, Scott Shallies, executive vice president at IFATCA issues a
salutary warning. “Sadly, we have known examples where an implemented
FRMS is little more than a ‘box ticking exercise’, where base rosters
are usually at the maximum permitted fatigue level, and where any extra
hours inevitably push the individual above ‘acceptable’ limits, but are
nevertheless assessed as ‘safe’ by a rudimentary measure of prior sleep
and management ‘acceptance’ of ‘residual’ risk,” he says.
Like any tool, Shallies believes an FRMS only works properly if it
has been built and used properly. That is why IFATCA policy calls for a
future FRMS to be auditable, by the regulator, as part of a safety
management system.
Till then, see ya~
