Fatigue Risk Management Systems
A fatigue risk management system (FRMS) is a science-based, data-driven process used to continuously monitor and manage fatigue risks. An FRMS is intended to be implemented within an airline’s safety management system (SMS) to allow operational efficiency for unique and specific operations when needed while also mitigating fatigue-inducing factors. An FRMS offers an effective, alternative means of evaluating and managing risk when compared to a purely prescriptive scheme but it is intended to be built upon – and create synergy with – defined, prescriptive flight and duty time regulations. I would invite the committee to review ALPA’s white paper on FRMS, published in June 2008, for additional information on this subject.
Revised regulations must provide guidance based on science that accounts for start and stop times related to crew circadian rhythms, the number of takeoffs and landings related to crew duty days, and any time zones that must be crossed. Science-based regulations, coupled with an FRMS, can allow some flexibility in unusual flight operational situations.
Since fatigue is such a critical factor in daily airline operations, ALPA published The Airline Pilots’ Guide to Fighting Fatigue in October 2008. This booklet may be carried by crews and provides guidance to understanding and dealing with fatigue. Understanding and mitigating fatigue is extremely important and assists crews in flying in as rested a state as possible, given the inadequate regulations governing the tempo of operations. We are presently updating this document to give pilots guidance on “responsible commuting.”
Airline Training Programs
Most airlines, which include many of the major or “legacy” carriers and the larger, “mature,” regional airlines, do an outstanding job of hiring and training pilots. They normally require significant flight experience including substantial amounts of multi-engine and turbojet time. However, some smaller regional airlines which may have very thin profit margins due to the economics of the contract between them and their major airline, have traditionally not offered compensation packages which enable them to hire experienced pilots. As a result, they must often employ pilots with little experience and bare minimum qualifications who are willing to take these low-paying positions in exchange for an opportunity to build experience so that they can move to a career airline. ALPA has prepared a white paper on improving future airline pilot performance which discusses training, hiring, and mentoring airline pilots which we would be pleased to make available to the committee.
Some airline training programs, including those at mature regional airlines, are extensive and exceed the regulatory minimums. When pilot experience at the new-hire level dropped severely below 1,000 hours, or less than a year’s worth of total flight experience, these airlines wisely extended their training process and doubled the initial operating experience (IOE) program requirement for these pilots. However, this cannot be said for all airlines.
Economic pressures push some airlines to train to the minimum requirements set by regulations. These minimums were established decades ago and were based on pilots coming into the airlines with much more experience than many pilots have today. Experience allows pilots to broaden their approach to problem solving and decision-making above the technical proficiency needed to fly the aircraft. It allows for the recognition of outside patterns and trends that develop during the course of routine flights and permits crewmembers to accomplish tasks specific to their cockpit position as well as be aware of the tasks being performed by other crewmembers. Experienced pilots tend to identify more pertinent clues and generate more alternatives in problem solving and decision making than inexperienced pilots
ALPA believes the licensing and training methodologies used successfully in the past may not work where airline pilots entering airline operations do not have the background or experience that previous generations of incoming airline pilots possessed. In meeting this challenge, the airlines and other training providers must develop methodologies to “train experience” that in the past was acquired in the traditional maturation and progression to becoming an airline pilot. This training should include extensive and detailed academic courses of learning taught in classrooms by well-qualified instructors.