Aviation Fatigue Risk Management Systems in an EASA Part 145 Maintenance Environment

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The purpose of the Fatigue Risk Management System (FRMS) is to serve to reduce, as far as practicably reasonable, workplace fatigue and its associated risks, to ensure a safe and error-free work environment for employees, contractors, and clients.

Driven by ICAO EASA, FAA & Transport Canada are promoting effective FRMS within the maintenance environment.

It is widely understood throughout the aviation industry that fatigue increases an individual’s risk of human factors error. Human error may serve as a precursor to an incident or accident. We also understand that such incidents and accidents can be managed and thus effectively prevented.

An effective Safety Management System should also encompass the management of any risk which may be associated with fatigue. This is typically achieved through the implementation of a Fatigue Risk Management System (FRMS).

FRMS is applicable and relevant for Maintenance Staff and all active members of a Maintenance Repair Organisations (MRO).

As with any Safety Management System, commitment from senior and line management together with effective engagement including active communication with all employees should be ensured to provide a positive safety culture.

An FRMS should be part of your wider SMS as an integrated set of work practices and procedures for monitoring and improving the safety of all aspects of your organization. It recognizes the potential for fatigue-related errors and establishes robust defenses to minimize the likelihood of incidents or accidents.

As with all safety management systems, fatigue risk management involves goal setting, planning, documentation, and measuring performance against goals. An FRMS should be a comprehensive, integrated tool for managing fatigue in operational settings.

FRMS is a shared responsibility!

» An essential obligation affecting all parties is the recognition of the shared responsibility between the Service Provider (The MRO) and the individual employee, together with the need for effective oversight by the Regulatory Authority(Competent Authority CA)
» The Maintenance Organisation Should be able to demonstrate to the State (typically through the medium of audit) how the program operates and how effective is the actual delivery of what is essentially a shared responsibility undertaking.

EU Working Time Directive

The EU’s Working Time Directive (2003/88/EC) requires EU countries to guarantee the following rights for all workers:

» A limit to weekly working hours, which must not exceed 48 hours on average, including any overtime;
» A minimum daily rest period of 11 consecutive hours in every 24;
» A rest break during working hours if the worker is on duty for longer than 6 hours;
» A minimum weekly rest period of 24 uninterrupted hours for each 7-day period, in addition to the 11 hours’ daily rest;
» Paid annual leave of at least 4 weeks per year;
» Extra protection for night work, e.g.
» Average working hours must not exceed 8 hours per 24-hour period.

Night Shift Working

Night workers must not perform heavy or dangerous work for longer than 8 hours in any 24-hour period, in addition, night workers also have the right to free health assessments and, under certain circumstances, to transfer to day work.

Sofema Aviation Services (www.sassofia.com) and Sofema Online (www.sofemaonline.com) offer Classroom, Webinar and online training covering all elements of EASA Part 145 Approval including Quality, Safety & Production Planning including the Development & Management of Fatigue Compliant Organisational Systems. For additional questions or comments please contact team@sassofia.com

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