Recent International Civil Aviation Organisation’s Initiatives with Regard to Aircrew Fatigue – A Summary
The Task Set by the Air Navigation Commission
The Air Navigation Commission (ANC) has tasked the Operations Panel of experts (OPSP) ‘To review available information from States relating to objective fatigue indicies for flight crew, and to develop proposals for Annex 6 SARPs and guidance material concerning limits for flight time, flight duty periods and rest periods for flight crew members’. ICAO SARPs and guidance material do not at present contain any guidance on actual limitations.
Current SARPs and Guidance Material Published in Annex 6, Part I
Annex 6, Part I, Chapter 9 – Aeroplane Flight Crew, requires the State of the Operator to establish regulations specifying the limitations applicable to the flight time and flight duty periods for flight crew members. It addresses the need to make provision for adequate rest periods, and to ensure that fatigue occurring either in a flight or on successive flights or accumulated over a period of time due to these and other tasks does not endanger the safety of a flight. Chapter 12 – Cabin Crew, reflects this in a single sentence, ‘The State of the Operator shall establish regulations specifying the limits applicable to flight time, flight duty periods and rest periods for cabin crew’. Chapter 4 – Flight Operations, requires commercial air transport operators to specify rules in accordance with the regulations established by the State of the Operator or approved by that State, and to include these in its operations manual. Also, they are obliged to maintain current records of flight time, flight duty periods and rest periods of all their crew members. A Note appended beneath each of the references mentioned above instructs the reader that guidance on the establishment of limitations is given in Attachment A: some terms related to this subject are described in Chapter 1 – Definitions.
OPSP Working Group 1 – Initial Progress
Working Group 1 of the Panel decided to concentrate first upon all definitions that should apply to its discussions, for it quickly became apparent that unless all members kept an identical meaning or interpretation in mind, it would not be possible to move on to key issues identified by the ANC. Whilst a search has begun to identify where any objective fatigue indicies applied by States might be found, consideration is being given also to so-called ‘prescriptive’ (specimen State) regulations that, having evolved over time, are held by most States to serve effectively the fatigue management needs of those cultures within in which they are applied. However, the Working Group has expressed interest in an alternative method that has been suggested, whereby fatigue risk management (FRM) might be used for the regulation of flight and duty time limits. Consideration of the latter would not mean that SARPs would necessarily exclude either, a possibility being that – if proved suitable – States might elect through their regulations to prescribe either or indeed both. However, it is acknowledged that FRM must first be validated and that it should be shown to be capable of implementation, globally, in an even-handed and user-friendly manner.
Discussions have also addressed possible enhancements to Part I Attachment A, which is applicable to both flight and cabin crew, to reflect issues such as duty periods, augmented crews, and time-zone changes that do not appear in the current version. To date, the Working Group has not found time to address any proposed ‘hard numbers’, although some have been suggested, preferring to delay looking at these until the search phase has been completed. The Working Group has established a small subgroup that has been tasked with identifying all relevant factors associated with fatigue management systems (prescriptive systems, FRM, etc) and developing proposals for consideration by members of the Working Group.
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