I just left a big meeting at the International Civil Aviation Organization (ICAO) about the realities of implementing fatigue risk management systems (FRMS). First, I have to say that I continue to be amazed at ICAO’s new sense of openness. I found myself surrounded by a mixture of industry leaders, regulators and scientists that never would have been allowed through those hallowed doors a few years ago. In addition, we had in our hands excellent guidance material that walked both the operator and the regulator through the process of FRMS implementation. It was especially exciting to see that the material carried the logos of ICAO, the International Air Transport Association and the International Federation of Air Line Pilots’ Associations.
But this was not a party to celebrate a roll-out; this meeting addressed real implementation issues. It included a frank discussion about what could go wrong and where FRMS should not even be attempted. It is important to remember that FRMS is optional. It can be used as an airline’s primary scheduling tool or as a tool to tweak existing flight-time and duty-time rules, or it can be left on the shelf. FRMS rests on a foundation of flight time and duty time rules. It does not replace them.
There are plenty of good reasons to implement an FRMS. It is a once-in-a-generation gift from science. When done right, FRMS relieves the company from arbitrary restrictions and gives crews the right rest at the right time. Pilots who have flown for companies that have adopted this approach say they wake up every day feeling better than they did when they were working for other airlines. FRMS can be one of those rare “win-win” programs.
What can go wrong? Unfortunately, quite a bit. A short-sighted labor leader could use it to justify unreasonable bargaining positions. A misguided operator, with a weak regulator, could use it to generate a data smoke screen to justify Draconian work rules. Or, a poorly protected system could allow a lot of very personal information to be disclosed in court in a way that could damage both the airline and its employees. So here are some not-so-simple pre-conditions for a successful FRMS: First, there must be a real commitment to the program on the part of the company and the employees.
They have to agree that they are going to do this thing in a way that makes life better, the company more efficient and operations safer; second, there has to be a regulator involved that is smart enough to know the difference between an FRMS and a fancy PowerPointtm presentation and confident enough to act on that knowledge; third, the effort must involve all the parties — if a union doesn’t exist, there still must be a way to fully involve the crews, and every layer of management has to understand the program, including scheduling, human resources and any other concerned department; finally, there must be a plan to protect all this amazing data so it doesn’t end up in the newspaper after the first operational incident or worker’s disability claim.
Missing a few of those conditions? That isn’t a shock. Conduct a frank and honest assessment and see what can be salvaged. Keep in mind this is not an “all or nothing” exercise. And remember to read the directions first.
Here’s a link to the program description: www.icao.int/safety/fatiguemanagement/FRMS2011/Pages/default.aspx.