Chapter 1 - Introduction

1.1 Preamble (Mandatory)

The FRMS manual should include clearly defined policies, procedures, and practices to ensure that the risk of fatigue-related error is reduced as much as possible. The FRMS should be tailored to your operation. To ensure maximum effectiveness of your FRMS, the manual must reflect what you actually do.

The aim of implementing an FRMS is to institute a change in organizational culture that results in enhanced flight safety and a safer working environment. It is essential that organizations do not simply paraphrase generic FRMS policy statements but take the time to write their own. The FRMS manual should be used as the primary means of communicating to employees the FRMS policies and procedures to be followed as part of regular operations.

You should review and update the FRMS manual one year after implementation, and on a set schedule thereafter (e.g., every two years). You will need to include a control process for amending documentation as per CAR documentation requirements.

Points to Consider

  • Why is the organization implementing an FRMS?
  • Who will be affected by implementation of the FRMS?
  • What are the basic responsibilities of employees within the FRMS?
  • How often will the FRMS policy be reviewed and updated?

Sample Text

Section 1.1    Preamble (Mandatory)

  • This FRMS manual is required by Part V of the Canadian Aviation Regulations (CARs) for [insert company name] trading as [insert trading name if applicable]. This manual applies to all personnel employed by the company in any capacity (full time, part time, casual, or contract). All personnel shall abide by the procedures contained in this manual.

    The CARs must be observed at all times whether or not they are specifically referred to herein. Should conflict occur between this document and the CARs, this manual will be regarded as secondary.

    The FRMS manual will be made available to and read by all personnel employed by [insert company name]. Each employee is required to sign the Amendment Awareness Record in the master copy held by the person responsible for the FRMS. This signature shall be regarded as proof that the employee has read and understood the FRMS policy, and will act in accordance with procedures outlined in the manual. The FRMS policy will be reviewed one year after implementation or at an interval acceptable to Transport Canada, and at least every two years thereafter to ensure the relevance and currency of all procedures. Accordingly, the person responsible for the FRMS shall sign and date the review record in the master copy showing that the review was completed and indicating whether amendments were made.
  • The Fatigue Risk Management System (FRMS) policies and procedures manual provides [insert company name] employees with comprehensive directions concerning the handling of fatigue-related risk within the operational environment.

    The FRMS policies and procedures manual will be provided to everyone within the organization upon request. A revised amendment sheet will be issued with each amendment.

    The person responsible for the FRMS shall review the FRMS policy one year after initial implementation, and at least every two years thereafter.

1.2 Document Control (Mandatory)

All Canadian civil aviation certificate holders are required by the CARs to amend the FRMS manual whenever it is necessary to do so. You should systematically create, circulate, and record any amendments to the FRMS policy. You may choose to use your current procedure for this or the one described in the sample text below. This text provides a basic amendment process for a simple FRMS manual. You may wish to add extra controls suitable for the size or complexity of your operation.

Points to Consider

  • How will amendments to the FRMS policy be recorded?
  • How will employees be informed about FRMS policy amendments?
  • How will employee understanding of FRMS policy amendments be recorded?

Sample Text

Section 1.2    Document Control (Mandatory)

The person responsible for the FRMS shall create and distribute amendments to the organization’s FRMS policy. Line managers will be responsible for discussing details of FRMS policy amendments with employees at team safety meetings.

Once issued, the amendment shall be distributed according to the manual distribution list. The amendment number, date, policy section amended, description of changes, signature, and entry date shall be recorded in the appropriate place.

To maintain the integrity of the manual and to monitor amendments, the manual shall include a list of effective pages — pages that have been or may be amended and the date that they were last modified:

  • List of effective pages
  • Signature sheet
  • List of parts
  • Tables of contents for each part and section

All employees associated with [insert company names]’s FRMS must sign the Amendment Awareness Record as evidence of having read, understood and agreed to apply the procedures contained in the FRMS policy. All personnel who are required to sign must do so on joining the organization, and whenever an amendment has been made. It is the responsibility of the person responsible for the FRMS to ensure that each amendment is brought to the attention of all relevant persons.

1.3 Definitions and Abbreviations (Mandatory)

It is important to provide employees with clear definitions of key concepts in the FRMS policy. This helps the organization to avoid confusion and function with clear goals. If the content of this section is covered in your SMS manual, you may chose to simply cross-reference it here rather than repeating the information.

Define the meaning of words and phrases unique to the FRMS policy only. For example, you may want to define the terms “management,” “competent person,” and “responsible person.” Any terms or titles that you introduce in the manual should be defined here.

You must define “company” (operator/ organization) as the legal entity referred to throughout the manual.

You may wish to include references or other information sources in this section.

Points to Consider

  • What terms used in the FRMS policy could be ambiguous or unknown to the user?
  • What words are likely to recur throughout the document as acronyms?

Sample Text

Section 1.3   Definitions et Abbreviations (Mandatory)

All definitions contained in the CARs, the Aeronautical Information Publications, and the Transport Canada website apply wherever they appear in this document. The following definitions are provided for users’ convenience:

DEFINITIONS

Accountable Executive — The individual responsible for operations or activities authorized under the civil aviation certificate and accountable for meeting the requirements of the Canadian Aviation Regulations (CARs). The accountable executive must have full control of the financial and human resources necessary for the activities and operations authorized under the certificate.

Actigraph — A small watch-like device worn on the wrist to measure movement and infer sleep/wake activity

Aerodrome — A defined area of land or water including any buildings, installations and equipment intended to be used either wholly or in part for the arrival, departure and surface movement of aircraft

Body Mass Index (BMI) — Used to define nutritional status and is derived from the formula: weight (kg)/height (m)2 or weight in kilograms divided by the square of height in metres. The standards are the same for men and women. The normal healthy range is 20-25. Obesity is taken to start at a BMI of 30 and gross obesity at 40. A BMI of 18-20 is defined as mild starvation and severe starvation begins when BMI falls below 16.

Circadian rhythm — Human beings are programmed to sleep during the night and to be active during the day. The sleep/wake cycle is a circadian rhythm. The term circadian comes from two Latin words, circa (about) and diem (a day). Thus, circadian rhythms refer to physiological functions that cycle over a day. Examples are the sleep/wake cycle, alertness and performance, body temperature, production of hormones like melatonin and cortisol, and heart rate. These rhythms are regulated by a biological clock in our brains. Circadian rhythms do not generally adjust easily to shift work.

Commute time — The time it takes for employees to travel between their worksite and home

Company — The term “company” is used generically, and may include a council, an individual, or a company.

Error — A safety-critical event that does not result in equipment damage, injury or death, but could potentially do so in different circumstances.

Facility — Premises used for the operation of aircraft on an aerodrome. These premises may be fixed or portable, and may include communication facilities.

Fatigue — An increased level of sleepiness associated with impaired cognitive and/or physical functioning that may, as a consequence, result in an elevated risk of error or accident. For the purposes of this policy, fatigue is due primarily to increased duration of wakefulness and/or reduced duration of sleep.

Fatigue audit — Where an electronic or manual tool is used to calculate the relative sleep opportunity for an “average” individual using work schedules as the primary data source.

Fatigue Audit InterDyne (FAID) — A commercial software package that calculates the relative sleep opportunity for a hypothetical “average” individual using scheduled working hours as the primary data input. The sleep opportunity (or FAID) score at any particular time is a weighted aggregate based on the timing and duration of work and non-work periods, the time of day when these occur, and social and family factors that may influence the propensity to sleep. Typically the result is expressed as a score between 0-150. Scores below a task-specific threshold are generally considered to provide an adequate sleep opportunity. Scores over the threshold are generally considered to provide a reduced sleep opportunity and require significant additional levels of hazard control. In general the level of control required is proportional to the degree to which the FAID score exceeds the threshold.

Fatigue or error proofing — Strategies to reduce the likelihood or consequence of an incident when employees are required to work through periods of high fatigue

Fatigue reduction — Strategies to reduce the likelihood of employees being at risk of making a fatigue-related error while at work

Person responsible for the FRMS — Person(s) with specific responsibilities under this document

Hazard — A source of potential error, incident, or situation with a potential to cause damage to equipment or result in injury or death

Incident — A safety-critical event that results in equipment damage, injury, or death

Legal entity — A person having legal personality (capable of enjoying and being subject to legal rights and duties). A legal entity may be:

  • a natural person, or a group of natural persons
  • an incorporated company or association, or a group of such companies or associations
  • a body, corporate or politic, created by statute

Non-work related causes of fatigue — Factors contributing to a state of fatigue for which an individual employee is primarily responsible

Organization — Has the same meaning as “company”

Operator — Has the same meaning as “company”

Owner — The legal entity holding the Civil Aviation Document (CAD)

Policy — Refers to the current FRMS policies and procedures document

Recovery sleep — The sleep obtained away from the workplace enables the employee to recuperate from the work period and begin to pay back any sleep debt accumulated while on shift.

Regulator — Transport Canada

Risk — A calculation of consequence (potential loss) and likelihood (probability/frequency) of a potential incident

Shift work — Any work schedule that requires the employee to work at night (between 9 p.m. and 7 a.m.), in the afternoon/evening (after 5 p.m.), weekends (Saturdays/Sundays), very early hours (pre 6 a.m. starts), or longer than eight hours (including managers with flexible schedules that may require them to take work home, come in early and go home late, be on call, and carry a pager they never turn off).

Sleep — A reversible state of perceptual disengagement from, and unresponsiveness to, the environment.

Sleep apnea — A respiratory sleep disorder that causes multiple awakenings during sleep and, as a consequence, reduces the recuperative value of sleep and increases levels of fatigue. In severe cases it has also been associated with significant cardiovascular disease and long-term health problems.

Sleep debt — Occurs when an employee does not obtain adequate restorative sleep. A sleep debt can accumulate over a period of days. This debt may result in impaired performance, reduced alertness, and higher levels of sleepiness and fatigue. A sleep debt can only be repaid with recovery sleep.

Sleep deprivation — Loss of sleep that can occur either acutely (loss of a complete night’s sleep) or partially (some sleep lost each night over a period of nights). Both result in reduced levels of alertness and performance.

Sleep duration — The period between the onset of sleep and waking, less awakenings.

Sleep inertia — The impairing effect of sleep on cognitive performance immediately after waking up.

Sleep opportunity — The time during a 24-hour period that a person has available for sleep. Hours of work together with commute times generally dictate the duration of sleep opportunity. Scheduling and type of work dictates whether the sleep opportunity is regular, irregular, predictable, or unpredictable.

Sleep length — The total amount of sleep obtained during each sleep period.

Sufficient sleep — The average person requires 6 hours sleep per night before experiencing fatigue-related performance decrements.

Work-related causes of fatigue — Factors contributing to a state of fatigue for which the organization is primarily responsible.

ABBREVIATIONS

CAD — Civil Aviation Document

CARs — Canadian Aviation Regulations

IFLS — Individual Fatigue Likelihood Score

FLS — Fatigue Likelihood Score

FAID — Fatigue Audit InterDyne

FRMS — Fatigue Risk Management System

SMS — Safety Management System

For operational abbreviations refer to the CARs.

1.4 Relevant Operational Publications (Mandatory)

This section is required when additional documents are relevant to your FRMS. You may wish to include references to regulatory material cited in this manual.

NOTE: If data such as accident statistics are included, they must be kept up to date.

Points to Consider

  • Does the FRMS manual refer to any existing regulatory material or company documents?

Sample Text

Section 1.4    Relevant Operational Publications (Mandatory)

This manual makes reference to the following Transport Canada publications:

  • The Canadian Aviation Regulations (CARs)
  • Safety Management Systems for Flight Operations And Aircraft Maintenance Organizations — A Guide to Implementation, Transport Canada, 2002. TP 13881
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