FATIGUE RISK MANAGEMENT SYSTEMS (FRMS) A PILOT’S PERSPECTIVE Captain Don Wykoff Chairman, Flight Time Duty Time Committee

Pilot Fatigue Top Flight Safety Issue Current flightcrew member duty and rest rules not based on modern sleep science Need new rules to comply with ICAO U.S. Part 117 science-based rule effective January 4, 2014

Pilot Fatigue Top Flight Safety Issue Cargo operations excluded ALPA seeking legislation to include cargo Part 117 – First time FRMS process is included in a regulation Part 117 sets standard for adoption by other countries

Pilot Fatigue Top Flight Safety Issue Pilots support FRMS concept FRMS not a replacement for prescriptive rules Allows limited flexibility from rules Viable FRMS must include pilots as partner

Fatigue Risk Management Plan (FRMP) FRMP is a building block to get to FRMS All U.S. operators, including cargo, must have a plan FRMP’s goal – reduce fatigue and improve alertness Tailored to operation Voluntary fatigue reporting

Fatigue Risk Management Plan (FRMP) Review schedules for fatigue Operator must investigate reports Need Fatigue Review Committee Pilots key to Committee and FRMP

FRMS ICAO Annex 6 has guidance for FRMS FRMS Implementation Guide for Operators – 1st Ed., July 2011 Establish Fatigue Safety Action Group (FSAG) FSAG is a safety oversight group Successful FSAG will have pilot representative

FRMS FRMS is a six step program Step 1 – Identify City Pair Step 2 – Determine fatigue hazards and gather data Must have cooperation of pilot group to gather good data Agreements for process to collect data Need to protect personal data

FRMS Step 3 – Analyze data to identify fatigue hazards Predictive process Proactive process Reactive process Step 4 – Assess safety risk Step 5 – Select and implement controls and mitigations Step 6 – Validation period

FRMS Effective FRMS is tri-partite approach: Operator Regulator Pilots Pilots are key member of any successful FRMS

FOULS (How we can mess up a perfectly good program) Pilots Interrupt data collection and/or halt participation for industrial reasons Operators Use voluntary information for punitive reasons or other than intended purposes Regulators Fail to set rules to protect data, not hold everyone accountable How to avoid the “Fouls” ? The Three “R’s” Relationship Respect Responsibility The fouls can be avoided by a responsible approach and a professional relationship and respect with other stakeholders

QUESTIONS