For operators who would like to follow a flexible approach to fatigue management, a Fatigue Risk Management System (FRMS) may be appropriate.
To start adopting this approach, read about how to apply for an FRMS approval (Appendix 7).
FRMS rules and requirements
The standards we require for an FRMS are based on the standards and guidance published by the International Civil Aviation Organization (ICAO).
We outline our requirements in Appendix 7 of Civil Aviation Order 48.1 Instrument 2019 (CAO 48.1).
If you choose to operate to Appendix 7, you will need to obtain approval from us.
The FRMS approach is a scientifically based, data driven means of continuously monitoring and managing fatigue-related safety risks.
With an approved FRMS, operators may be able to assign resources more efficiently and increase operational flexibility, while maintaining or improving safety.
We must assess and approve your FRMS. During assessment, you must demonstrate to us that the proposed operation outside of the prescriptive limits is safe.
An FRMS imposes enhanced requirements on you beyond those inside the prescriptive limits (outlined in Appendices 1 to 6 of CAO 48.1).
We base an FRMS on a number of principles including:
- identification and assessment of potential fatigue hazards and risks
- comprehensive fatigue monitoring underpinned by ongoing data collection and analysis
- continuous assessment of the effectiveness of the fatigue mitigation strategies
- ongoing allocation of resources to address operational fatigue hazards and risks, including appropriate fatigue management training for all relevant staff.
Where an operator already has established Safety Management System (SMS) processes in place, implementation of an FRMS may be easier.
You may find you can build on the SMS processes to address the requirements of an FRMS.
The FRMS must include all relevant limits, with the limits you have established and that satisfy our rules.
We can not use an FRMS to create one broad set of limits that used across all aspects of a varied operation. You need to identify and manage fatigue hazards specific to your operations.
For example, an operator with a mixture of aerial work, unscheduled (charter) flights, EMS and training would not be able to establish one generic set of limits to cover all operations under an FRMS.
You will need to identify, risk assess and mitigate every fatigue hazard in each aspect of your operations. The FRMS processes would be likely to identify different sets of limits for the different types of operations.
Within a category of operation, the limits may vary.
For example, in aerial work the operator would have different fatigue hazards in aerial photography compared to power-line stringing.
You must create different limits to reflect the different fatigue risks of your unique activities.
FRMS resource requirements
As FRMS processes are ongoing, this approach imposes enduring obligations on an operator to allocate the required resources.
We must approve, in advance, all significant changes. This includes for example:
- increases to maximum flight duty period
- reduction in off-duty periods.
The FRMS will be subject to regular oversight and audit by us.
In allocating resources you may find an FRMS may not result in an appropriate return on investment. This includes operations conducted inside the prescriptive limits or where fatigue-related risks are low.