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Integrating an FRMS into an existing safety management system
We are now starting to implement our response to the independent review of the fatigue rules. Content on this page will be updated soon. Read more about these changes.
Operators intending on operating to Appendix 7 have to develop and implement a fatigue risk management system (FRMS).
If the operator already has a CASA-approved safety management system (SMS) in place, their FRMS needs to be integrated into their SMS before CASA can issue a trial or full FRMS-implementation approval.
How do I integrate my FRMS into my Safety Management System?
For effective integration, the components of the FRMS need to be extended throughout the safety management system.
The table below outlines CASA’s suggested steps towards integration of your FRMS into your SMS.
Form a fatigue safety action group (FSAG) or equivalent
The FSAG may be separate to, or a subcommittee of, the safety committee or safety action group. It is responsible for coordinating and overseeing all FRMS activities. This includes providing advice to operational management staff, managing project resources, supporting operations staff, ensuring employee representation, providing subject-matter expertise for investigations, ensuring the FRMS is appropriate for the organisation and is being continually improved and managing fatigue risk throughout any changes to the organisation.
Draft FSAG terms of reference, FRMS accountabilities, responsibilities and authorities
The FSAG considers which SMS accountabilities, responsibilities and authorities can be incorporated into the FRMS.
Do a gap analysis of existing SMS documentation, procedures and processes and FRMS requirements
The gap analysis must include:
Develop the FRMS policy and objectives
FRMS policy should state the purpose and objectives of the FRMS, including the responsibility of both management and employees for managing fatigue-related risk.
Use the results of the gap analysis to develop FRMS-related documentation, procedures and processes
You must decide how you will incorporate FRMS-related documentation into the SMS documentation. FRMS procedures and processes should determine your approach to identifying fatigue-related risks (i.e. reactively, through reporting mechanisms; and proactively, by fatigue surveys/questionnaires/performance data).
Develop a plan for SMS/FRMS integration
The implementation plan should cover the process of integrating the FRMS with the SMS; provide a timeline showing:
You also need to contact CASA regarding approval of the FRMS (see below).
Develop a comprehensive FRMS communication plan
The communication plan outlines what needs to be communicated to relevant stakeholders, how and when.
Review current operations to assess where/when fatigued-related risks may exist and use the risk management process to determine the best way to control them. These results should be reflected in FRMS documentation.
This stage of the process should include a review of rostering arrangements and possible rostering improvements aimed at better managing fatigue-related risk better.
Develop fatigue- and FRMS-related training material
Initial fatigue-related training should establish a common level of understanding among employees about fatigue and the impairment it causes. As the FRMS develops, training content should then expand to cover the FRMS itself.
Determine whether to use bio-mathematical models to assist identify potential increases in fatigue-related risk.
If you decide to use a bio-mathematical model, you must integrate its application into the FRMS documentation and processes. This material should reflect when and how the model is used (e.g. when developing rosters, fatigue studies, incident investigation etc.). It is strongly recommended that you do not use biomathematical models to determine the level of fatigue of a particular individual. These models are based on broad population averages not the characteristics and circumstances of any one individual.
Develop periodic review processes for FRMS to ensure continuous improvement.
The review must look into the FRMS’s capability, operational integrity and fitness for purpose, and how FRMS performance will continue to be measured to ensure ongoing improvement.
- Develop a fatigue risk management system (FRMS) (Appendix 7)
- Safety management systems
- Fatigue management resources (includes resources for implementing an FRMS)