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Position Paper on Fatigue Risk Management within the Aviation Maintenance Industry

Prepared for: The Part V CARAC Technical Committee

Date: March 18th, 2003

Background

In 1996 the Safety of Air Taxi Operations (SATOPS) Task force recommended that Transport Canada "...initiate a Canadian Aviation Regulation Advisory Council (CARAC) review to determine if AME duty times should be regulated, and if so, determine appropriate limitations." As a result of this recommendation, Transport Canada commissioned a study to assess the impact of fatigue in the civil aviation maintenance environment.

The study, conducted independently for Transport Canada by Dr. Wayne Rhodes, looked at the impact of fatigue on human performance through an analysis of numerous variables, including: shift duration, shift times, number of consecutive days worked, geographic location and type of work arrangement. The study also considered personal variables such as family status, number of jobs held and age and sex of the participants.

There has been much debate in Canada regarding levels of fatigue in the aircraft maintenance industry. Furthermore, prior to the AME duty time survey, much of the evidence suggesting that maintenance personnel may be working long hours and as a consequence may be fatigued, was largely anecdotal. The AME duty time survey provided evidence to suggest that fatigue and excessive periods of work may be present in the workforce.

In September 2002, Transport Canada (TC) convened a special purpose CARAC Part V Technical Committee meeting to discuss methods of dealing with the issues raised in the study. As a result of these discussions, two clear positions emerged. The first was a clear consensus that traditional approaches to fatigue based on prescriptive limits to duty times were unlikely to be an effective solution. There was also a reasonable level of doubt expressed about whether such an approach would actually achieve the stated goal of improving safety. In addition, there was considerable discussion over how a prescriptive rule-set would be formulated and by whom.

Given the range of operational settings found within the Canadian aviation industry, there was a genuine skepticism that any set of prescriptive rules could be sufficiently flexible to embrace all of the industry operating environments. There was also concern that such an approach would be unwieldy and bureaucratic and unnecessarily expensive with respect to compliance and enforcement.

A second view, expressed by the regulator, was that TC could take a non-prescriptive approach to fatigue management and require each approved maintenance and aircraft operator to present a 'safety case' to the regulator. In other words a documented argument as to how the organization is managing fatigue issues within the work environment. From this perspective, the regulator would mandate the requirement for an approved maintenance organization to implement a fatigue management system within the organization. Such an approach would then require and enable individual organizations to develop a locally tailored fatigue management system as part of their broader safety management system.

Many of the participants in the discussions were attracted by and could appreciate the benefits of the non-prescriptive approach. However, there were concerns expressed about how such an approach could be operationally defined and how individuals or organizations might possibly subvert it. Several participants expressed concern that a non-prescriptive approach would not provide clear guidelines, thereby making it difficult to enforce in a coherent or consistent manner. There was also concern that the development of such an approach might be unnecessarily expensive for small operators.

As a result of these discussions, the industry group decided that a non-prescriptive approach had considerable merit but it was important that they could see what this would mean in practice. By looking at some practical examples of what a Fatigue Risk Management System (FRMS) would look like in practice they may be in a better position to make an informed decision. The group then suggested that TC should put together a prototype FRMS and present this approach to the industry at a future meeting in 2003.

This paper highlights the basic requirements of a fatigue risk management program, recognizing of course that any fatigue risk management program must be individually tailored to meet the requirements of each individual company. This paper recognizes the diversity of the industry and the fact that the system must be responsive to the needs of each organization. A prescriptive approach, therefore, is not the appropriate methodology to be used in this case; any specific example might reasonably be resisted by the many operators for whom it would be inappropriate.

Fatigue Risk Management: Basic Elements

This paper describes a set of criteria that constitute an adequate safety case for an approved maintenance organization to justify to Transport Canada that it is applying risk management techniques and is doing as much as is reasonably practicable to manage fatigue related issues in the workplace.

In essence, this paper presents a 'check-list' of the issues that must be addressed by an approved maintenance organization when developing a Fatigue Risk Management Plan to present to Transport Canada. Fatigue risk management systems are viewed from the "toolbox" perspective. In essence, the FRMS "toolbox" comprises a set of pre-approved methodologies, policy templates, training materials and other tools that approved maintenance organizations could use to develop a fatigue management system. This approach ensures that the FRMS meets the organizations own needs; whilst also ensuring Transport Canada that the approved maintenance organization is managing fatigue-related risks appropriately.

The 'toolbox' consists of three main components:

  • Policy templates for approved maintenance organizations that should address corporate responsibilities, employee responsibilities, accountability and reporting mechanisms;
  • Competency-based training and education materials; and
  • Audit methodologies that enable organizations to determine the level of organizational risk associated with fatigue. This should include considerations of the location of the risk in time and location and the capacity to assess whether interventions have reduced the risk. These methodologies should be tailored approaches for small, medium and large approved maintenance organizations.

Detailed description of a Fatigue Risk Management Toolbox

Before attempting to construct a toolbox, it is important that the organization clearly assess the nature of their operating environment including the organizational culture, the existing regulatory requirements and existing policies that relate to and may interact with a fatigue risk management program such as a safety management system. This will allow for a clear understanding of the operational environment and the specific audit tool requirements.

Tool 1: Policy Statements

Policy statements should be constructed at two levels:

  1. the corporate level- to underline the commitment from senior management; and
  2. the operational level - a working document, stating how the FRMS will work in practice.

The corporate level policy is one of the first development stages of an effective FRMS. The policy is a short document that acknowledges fatigue as a significant workplace hazard. Furthermore, it should highlight the commitment from senior management for effective fatigue management.

The operational level statements will:

  • obtain support from senior management;
  • provide practical guidance on how to eliminate or minimize fatigue-related risks;
  • review legal and operational responsibilities of fatigue management;
  • clarify employer and employee responsibilities;
  • provide guidelines to develop a draft policy;
  • provide guidelines to review and redraft the policy as required; and
  • provide guidelines for effective implementation strategies.

Tool 2: Competency Based Training and Education

Training and education has been noted as one of the key factors in effective change management. That is, when introducing new systems, it is important that employees have a clear understanding of the reasons behind the change, as well as an understanding of their responsibilities therein.

Therefore, shift work and fatigue training should be directed at:

  • new hires;
  • existing employees; and
  • management.

Newly hired employees should have a training and education package that discusses general issues relating to shift work and fatigue. As such, the training should be focused on the following topics:

  • explain how shift work and fatigue impact on individuals, families, social lives and health;
  • provide a summary of practical strategies they can be used to minimize the impact of shift work and fatigue; and
  • clearly outline the relevant personal responsibilities in managing fatigue.

Existing employees should receive training and education similar to that mentioned above. However, it should additionally include:

  • a formal competency-based course; and
  • access to additional resources for further reading if interested.

In regards to management, training and education should involve knowledge of the above processes, in addition to an understanding of specific legal and personal responsibilities associated with the FRMS.

Training Requirements

Training can be achieved through a number of media, including:

  • web-based training;
  • paper-based training; and
  • workshops.

Ideally training of this nature should encompass traditional learning environments and it is recommended that whichever delivery method is chosen that it encompass some level of face-to-face introductory workshops.

The training and education component should be focused on issues that highlight how fatigue can impact ones ability to optimize on-the-job performance. Training should be competency based i.e. examinable. The following list, whilst by no means inclusive, provides an example of the type of issues the training and education program should cover.

  1. Sleep (good sleep hygiene);
  2. Napping (the restorative power of short sleeps);
  3. Shift work and Digestion (how food can be used to promote sleep or alertness);
  4. Drinking Water (the benefits of adequate hydration);
  5. Caffeine, Alcohol and Sleeping Tablets (practical information about these commonly used substances);
  6. Family Issues (pressures on shift-working families);
  7. Social Life Issues (ways that shift workers can remain involved in social and community groups);
  8. Commuting (dangers of driving fatigued);
  9. The Shift System (rostering system);
  10. Shift Length (advantages and disadvantages of longer shifts);
  11. Fatigue and Performance (advice on how to deal with fatigue at work);
  12. Health Impacts of Shift work (how to avoid the potential health effects associated with shift work); and
  13. Physical Exercise (promotes the role of exercise in sleeping well).

Tool 3: Audit methodologies

The basis for determining acceptable fatigue limits and assessing current rostering practices should be partially achieved within the system wide evaluation of work-related fatigue. This can be done through the use of a computer-based audit system or can be done manually provided that the activity is appropriately recorded and documented. Automated computer software is available to carryout this function where appropriate. The value of this activity lies in the ability to highlight issues that impede safety within operations by creating fatigue issues. Furthermore, this will also allow for an accurate indication within the organization as to where staffing and/or workload may need to be addressed.

Specifically, the audit methodology will assist the organization in pinpointing specific issues at any level such as:

  • System, state, crew or individual concerns relating to work-related fatigue.
  • Rostering or other industrial rules that contribute to work-related fatigue problems.
  • Employee arrangements that cause issues attributable to under- or over-staffing.

Auditing within a fatigue risk management program requires accurate data collection, consultation with stakeholders, dissemination of results, assessment of local factors and development of on-going systems and the application of risk management techniques to the audit findings. In addition, auditing also involves the significant development of procedural guidelines so that the auditing systems developed can be used with minimal assistance by all involved with the system. The knowledge and upkeep of these processes are a valuable asset and can be used to demonstrate the system's effectiveness when building a safety case. This is particularly true considering that the system will be subject to a Transport Canada audit.

CONCLUSION

In summary, Transport Canada proposes that fatigue risk management systems comprising three levels of activity be adopted. The following activities constitute a fatigue risk management program:

  1. The development of policy statements for management and employees;
  2. Training and education programs for all employees; and
  3. Audit systems for determining fatigue levels within an organization.

This position paper represents Transport Canada's interpretation of the broad requirements of a fatigue risk management program and is offered as the basis for the development of notices of proposed amendment to the Canadian Aviation Regulations requiring organizations to implement these systems.

Transport Canada believes that the implementation of fatigue risk management programs in the aviation maintenance environment offers a flexible and company specific approach to managing workplace fatigue.

Date modified:
2010-03-31