Fatigue risk management seems to be a difficult concept to sell to much of the industry. That is a pity considering it is undoubtedly the way of the future, replacing - for those that embrace it - the inadequate, one-size-fits-all flight time limitation rules.
Now that airlines such as EasyJet have validated the fatigue risk management model and can demonstrate improvements in performance, it is surprising to find continued resistance in many parts of the industry. So, it is worth revisiting what a typical flight time limitation system is designed to do: ensure that crews do not work so long as to get dangerously tired.
That is a simple concept, and it only deals with duty hours. But that is just the core: other rules deal with multi-sector duties that start at times inimical to pilots' circadian rhythm, or cross several time zones.
The variations flight time limitations cannot begin to deal with are those particular to individuals: difference of temperament, lifestyle, or personal circumstances. As fatigue science has advanced, the limitations of such systems have become progressively more apparent, as has the fact that they are not the best, nor the only, way of setting benchmarks for a system to reduce fatigue risk.
Flight time limits can work for operators whose flights are short haul and repetitive in destination and departure time, and mostly completed in daytime.
Fatigue risk management, however, should help operators that carry out ad hoc work with little repetition, or work outside circadian rhythm times. For many business aircraft operators, or freight operators that do a great deal of work at night, the flight time limitation system is hopelessly unsuitable, because it is designed for airlines with repetitive, diurnal operating patterns.
The main psychological barrier to persuading business aircraft operators to embrace the fatigue risk management system, despite its suitability relative to flight time limitations, is that, even in Europe, until EU Ops Subpart Q came along, most were practically unregulated. So the objection is not really to a fatigue risk management system, but to being regulated.
But flight time limits to replace Sub-Part Q are coming whether the business aircraft community likes it or not, as is the requirement to embody fatigue risk management in its safety management system. The choice is to co-operate, as the European Business Aviation Association is asking, in designing a tailor-made business aviation fatigue risk management system, or adopt an ill-fitting solution that ticks the regulatory boxes.
Source: Flight International
