(3) Ensure reporting systems to identify fatigue-related hazards.
(4) Assess, manage, and monitor effectiveness or fatigue risk management plan as with other SMS initiatives.
(5) Provide training on the management of fatigue.
The EASA proposed AMC 2 145.A.47(b) provides additional detail saying that the policy and other documentation should be included in the following paraphrased details:
(a) Duty time schedule should address:
(1) Maximum scheduled hours/day;
(2) Maximum allowed hours with overtime;
(3) Maximum hours/month;
(4) Minimum rests between shifts (based on shift length);
(5) Minimum rest hours per week.
All of the above must consider the time of shift:
(b) Hour limits should not be extended for management convenience even if worker agrees. If hours are exceeded then a written plan for fatigue risk management should include:
(1) Additional supervision and independent inspection;
(2) Limitation of task to nonsafety critical;
(3) Use of additional rest breaks; and
(4) Permission to nap in accordance with established guidelines.
The proposed EASA rule comment period is closed and EASA is preparing responses to comments, likely out late summer-early fall. One might expect some push back on the reference to the European Union Work Directive, especially from non-EU holders of the EASA Part 145 certificate. Whether that reference remains in the final rule is immaterial for at least two reasons. First, one of the clauses in the EU Directive is something like: “You don’t have to follow the rule if the worker and the company agrees, as long as you mitigate the risk.” Regardless of that language in the EU Directive, the language of the EASA rule makes a similar caveat on the Directive. If one does not want to create an elaborate plan for extended hours then they can merely follow the directive, included in the AMC.
The bottom line on the proposed EASA FRM regulations and the new FAA Part 117 is that the rules are reasonable. They make sense for safety and for efficient aviation business. They are likely representative of the kind of maintenance fatigue rules that could emerge from FAA sometime in the future. The regulations help ensure that workers are adequately rested and fit for duty. Again, that ensures worker safety, reduction in error when the aircraft is on the ground, and continuing flight safety.
Dr. William Johnson is the FAA Chief Scientific and Technical Advisor for Human Factors in Aircraft Maintenance Systems. Johnson is a member of the Human Factors Advisory Group to the European Aviation Safety Agency (EASA). The group worked with EASA to define human factors aspects of the proposed Safety Management System regulations.
The three-part document, which addresses all aspects of Maintenance SMS for operators and regulatory authorities, is nearly 500 pages. EASA considers not only safety but also costs.
The FAA proposes to set a nine-hour minimum opportunity for rest prior to the duty period, a one-hour increase over the current rules.