Here Comes an FAA Maintenance Fatigue Advisory Circular
By press time of this article a new AC (Maintenance Fatigue Risk Management) may be published. Of course, that is an iffy prediction since dotting the last i and crossing the last t is always tedious/time-consuming. In any case, the document is three plus years in production and has completed all review processes. It's time to promote the document. It is not likely to change from the information described herein. This summary offers checklists (sparing readers the scientific references and details) that are derived from the AC.
Don’t Worry, Be Happy
Often an Advisory Circular (AC) is published in conjunction with a rule. That is not the case with this AC. There is no immediate plan for a new rule on maintenance fatigue.
All segments of the industry and the FAA know that worker fatigue is a potential hazard that can contribute to risk. That is true not only for aviation safety but also for every aspect of life. Fatigue can impact our thinking and our actions. This new AC, a one-stop collection of FAA maintenance fatigue information, is designed to provide education, advice, and access to other fatigue sources. Readers are likely to appreciate this information as a way to address issues that emerge from their safety management system (SMS). If you don’t yet have a formal SMS, you likely have a reasonable idea if fatigue is a hazard in your organization. The information in the AC can help you. With no rule you can “take it or leave it.”
What’s in the AC?
ACs all have a similar format with headings like Purpose, Related Documents, Background, Critical Issues, Definitions, and More. This AC also has sections titled “How to Reduce Fatigue-Related Error” and “How to Minimize the Impact of Fatigue Related Error.” The purposes stated at the start is to:
1. Describe basic concepts of fatigue and fatigue risk management (FRM)
2. Describe benefits and how to implement FRM
The AC is more like a fatigue information source than a specific step-by-step means to comply with a rule. The authors tried to keep it straightforward, although the scientific facts are sources in the document.
Specific Information
The definitions section of the AC has a lot of details including the signs of fatigue (see AC, page 8, Figure 1) which include physical, emotional, and mental signs.
A few operational results of fatigue include: impaired judgment and decision making, impaired communication skills, decreased attention span and memory, irritability, slower reaction times, and increased risk taking.
Chronic (i.e., long term) fatigue not only affects performance at work but also can impact personal health that includes: heart disease and high blood pressure; depression, anxiety, and stress; gastrointestinal disorders (peptic ulcers, indigestion, heartburn, upset stomach, etc.); overeating; risk for higher alcohol consumption and drug use, and a lower sense of well-being.
A Shared Responsibility
There is not a grave need for government regulations for you to acknowledge what you already know. Individuals and companies can cooperate to address fatigue hazards, at little or no cost. In many cases companies and individuals know when they are creating fatigue-related risk, but are very good at rationalizing the actions/inactions. This AC does not suggest radical changes. Small changes can add up to significant improvements. Here are individual and company actions that affect fatigue hazards.
Factors primarily under control of the individual include:
• Amount of sleep over the past three days (average of 8 hours/day?) or quality of sleep conditions (See FAA site at www.mxfatigue.com)
• Continuous hours awake (risk increases after 16 hours)
• Medical or personal issues that affect restorative sleep (make up time for extended hours awake)
• Not taking advantage of all opportunities to sleep (like 20-minute naps)
Factors primarily under control of the company include:
• Start time and shift duration
• Acknowledging work and life schedule changes (like newborn baby and family situations)
• Sub-optimal shift rotations (rotate in direction of clock)
• Routine schedules
• Adjusting for midnight shift work
• Adjusting for travel and radical time-zone change (aka, jet lag)
• Repetitive and routine tasks
• Continuous sub-optimal conditions like staffing levels; insufficient breaks (including proper nutritional options), lighting, sound levels, extreme temperatures, and more.
Benefits of Managing Fatigue
The author has reported, repeatedly, in FAA reports and AMT articles (See October 2012, July 2013, and September 2014), that worker fatigue is always identified in the top 3 maintenance human factors risks. When companies apply proper root cause analysis to negative events, fatigue is often a significant contributing factor. For example, the night shift taxied an aircraft off the runway into the mud. It was a poor decision, they were not adhering to the procedures, and they were complacent. Oh, by the way, they had been on duty for 13 hours and worked all night. That is fatigue! Such fatigue-related behavior and consequence can be managed. The benefits are high. Proven FRM benefits include:
• Reduced number and severity of worker injuries
• Reduce worker illness
• Improved morale
• Reduced ground damage and rework
• Increased sleep quantity and quality
• Improved quality of life (As reported by flight crews after Part 117 Crew Fatigue rule enactment)
The Bottom Line – How to Manage Fatigue Risk
While the AC is full of facts and figures the document begs the question, What can we do about it? The personal and corporate lists mentioned provide guidance but here is more.
Fatigue Alertness Training – This solution is listed first because it has been repeatedly proven to be of high value. There are a lot of fatigue awareness training products on the market. FAA’s web-based fatigue awareness training is the best and most widely used. An estimated 100,000 aviators have taken the two–hour course and passed the end-of-course test, since 2011. It is available at www.faasafety.gov. It is complemented by FAA’s 20-minute video on maintenance fatigue.
When workers and managers have knowledge about fatigue it can foster communication and peer cooperation to identify and mitigate fatigue-related challenges.
Hours of Service (HOS) Limits – FAA has an HOS regulation in CFR 14, 121.377. For all practical purposes it is without practical value for safety. The AC does not specify maximum daily hours or continuous days. It does suggest “progress restrictions" (page 17). For example, after a worker has been on duty for 12 hours (day shift), or eight hours (night shift), or has already more than 60 hours in a seven-day period, then they should be considered at fatigue risk. That could limit the kind of tasks they perform without double inspection. They should not be allowed to conduct critical tasks, like rigging of flight controls, etc. There are many variables in conditions and tasks; organizations must decide what works best for them. Organizations and individuals should establish and follow their own rules. That is fatigue risk management!
Scientific Scheduling – There are plenty of scheduling software packages available. There is a considerable learning curve to master the scheduling software. It is usually well worth the investment to assign an internal individual or small group to this task. Get them properly trained in order to maximize the effectiveness of the product. If you make the decision to hire a scheduling consultant be aware that such commitments are often longer and more expensive than originally expected. Besides, your own internal experts know the subtitles of the organization, thus increasing the fit between the solution and the company.
Napping Strategies – Naps have been proven helpful for pilots, air traffic controllers, truck drivers, and many other occupations. This author is unaware of formal scientific napping studies in the aviation maintenance environment. However, it is certainly reasonable to generalize among humans. At a minimum, consider creating an environment that is conducive to a nap. That might be a quiet room with low light and comfortable chairs. Workers could take 20- to 30-minute naps, during breaks or lunch. Start small and see if there is an impact on workers. Again, that is another step in managing fatigue.
Excused Absences – Working fatigued is like working sick. Calling in sick should be considered like any other sick leave. Extensive sick leave should trigger a required visit to a sleep specialist. Sleep apnea is one example of a common medical condition that can be corrected.
Event Investigations – When something goes wrong be sure to conduct sufficient root cause analysis to see if fatigue was a contributing factor. For starters, look at previous sleep duration/quality, time awake, and time of day.
Modifying Job Demands – Aircraft fly during the day and are commonly maintained at night. The midnight shift is a reality of a 7x24 industry. Fatigue is one of the hazards of night work. Task scheduling, workplace design, supervision, and inspection practices are all partial remedies to address the risk of fatigue. That is fatigue management.
Read the AC – This short article merely summarized the 25-page document. The author suggests that all companies make the AC required reading for managers. Talk about the recommendations. Celebrate that this is merely advisory material and not a rule. Set up reasonable policies that start your fatigue risk management system. For further information go to www.humanfactorsinfo.com. Sleep well.
About the Author
Dr. Bill Johnson
Chief Scientific and Technical Advisor Human Factors in Aviation Maintenance, FAA
““Dr. Bill” Johnson is a familiar name and face to many industry and government aviation audiences. Johnson has been an aviator for over 50 years. He is a pilot, mechanic, scientist/engineer, college professor, and senior executive during his career. That includes 16+ years as the FAA Chief Scientific and Technical Advisor for Human Factors.
Dr. Bill has delivered more than 400 Human Factors speeches and classes in over 50 countries. He has 500 + publications, videos, and other media that serve as the basis for human factors training throughout the world.
Recent significant awards include: The FAA “Charles E. Taylor Master Mechanic” (2020); The Flight Safety Foundation - Airbus “Human Factors in Aviation Safety Award” (2018), and the International Federation of Airworthiness “Sir Francis Whittle Award” (2017).
Starting in 2021 Johnson formed Drbillj.com LLC. In this new venture he continues to bring decades of human factors experience to aviators, worldwide.