This paper provides an analysis of (recent) scientific findings on fatigue (without taking individual situations in consideration) and the risks resulting from fatigue. The paper comments on the ways of mitigating the risks by introduction of risk management systems designed to address and mitigate fatigue risks in general. The aim is to find recommendations and guidance on the adoption of Fatigue Risk Management Systems (FRMS) additions in accordance.

In this paper the completeness of the policies of ICAO and IFATCA concerning fatigue related management systems have been evaluated. The evaluation is done by comparison to a theoretical FRMS elements model as drafted in this paper. In order to establish the theoretical FRMS elements model, a study has been performed based on technical and scientific literature. The FRMS elements model is based on the conclusions in the reviewed literature.

The evaluation of the policies of ICAO and IFATCA show that these are not complete in terms of the advised elements of a FRMS. Whereas ICAO policy focusses solely on the flight crew and the issues that are faced in that part of the operations, IFATCA’s policies do not specifically detail a FRMS, although some elements of the advised FRMS are mentioned.

It is the conclusion of this paper that current policies do not provide an applicable, complete overview of a FRMS. The inclusion of the FRMS elements Model as established in this paper in the IFATCA Professional and Technical Handbook is therefore advised.

The FRMS elements model can be summarized as follows:

The prerequisites in the FRMS elements model should be embedded in the organization, whereas the tools are active management tools to influence the fatigue build-up and with that the fatigue related risk development.

1.1 Task and relevance of this paper

During the IFATCA conference in April 2011 PLC was tasked to write a paper on Fatigue and on Fatigue Risk Management Systems (FRMS). This paper elaborates on recent research on fatigue and on how this could be interpreted in a model. This paper also provides guidance on the best practice of a FRMS and explains what it is, what it consists of and how it is set up.

At the moment fatigue issues are a subject of attention in aviation. In the US multiple incidents happened in 2011 when at different airports, air traffic controllers fell asleep on duty. These incidents received a lot of attention in the international press and became a highly scrutinized public concern.

Currently conclusions from numerous studies in the field of fatigue, fatigue risks and fatigue management are already available as well as the associated literature. These studies are performed on fatigue issues in general, in other sectors and in the transport sector; all the studies relate to the assessment of the issue and the determination of the actions to be taken.

ICAO has stressed the importance of a FRMS by publishing the Fatigue Risk Management Systems Manual for Regulators (Doc 9966) in 2011. This manual provides guidance on the development, implementation, approval and monitoring of a FRMS.

ICAO Annex 6, Part I added Appendix 8 in December 2011. This Appendix describes the Fatigue Risk Management System Requirements. Although this manual is for flight and cabin crew members, a lot of the information could well be applicable for personnel providing ATC services.

1.2. Objective

The following sub questions were taken into account resulting in a conclusion on how FRMS can be addressed:

• ‘What can we learn when we compare (current) scientific knowledge on fatigue?’
• ‘What can we learn from (current) scientific findings to mitigate the effects of fatigue on safety critical staff?’
• ‘What can we learn when we compare science to current regulation regarding fatigue?’
• ‘How is a FRMS built up, what are its main elements based on scientific knowledge and applied FRMS in other fields of operation (air crew, road, water, railway)?‘
• ‘Can we use ICAO / IFATCA policies on FRMS as guidelines?’

2.1 Introduction

Many argue that fatigue is an increasing health and safety problem in our daily lives due to the so-called 24-h society with round-the clock operations. Life expectancy, global communication result in decreasing emphasis on the need for sleep, and the nature of work has changed to comprise more sustained attention and monitoring tasks.

There is compelling evidence that fatigue compromises safety, and that fatigue and its causes need to be managed carefully (Williamson et al, 2009).The basic goal for managing fatigue is safety, as fatigue is a hazard that must be managed comprehensively. Safety management is about safety of the individual and safety of the overall system operation. Fatigue management in ATC, for all the complexities, can be seen as simply as respect for the known basic human performance limitations. (Shallies, 2011)) Without a holistic approach, fatigue will degrade individual performance and pose a threat to safety (Shallies, 2011 and Brathwaite, 2012).

2.2 Fatigue related incidents and their causes

In 2011 at least seven incidents happened in the US where an air traffic controller fell asleep during a midnight shift. These incidents prompted negotiations between the government and the controllers’ union to change the way controllers are scheduled to work. The Federal Aviation Administration (FAA) acknowledged that there was a widespread problem with fatigue among controllers and that the organization instituted changes in work schedules. Two of the new rules established in the agreement are more time off between shifts (minimal 9 hours) to allow for appropriate rest and longer mandatory rest periods. Two other rules are allowing controllers to listen to the radio and read appropriate printed material while on duty during the hours of 10 p.m. and 6 a.m., as traffic permits. It also allows controllers to request a leave of absence if they are too fatigued to work.

The agreement reinforces existing FAA policy that prohibits air traffic controllers from sleeping while performing assigned duties. The FAA will continue to provide controllers breaks on midnight shift based on staffing and workload. Controllers on break will still be expected to “conduct themselves professionally and be available for recall at all times,” the FAA said in written statement.

In contrary to FAA policy, a fatigue study by FAA and the National Air Traffic Controllers Association resulted in understanding the following; scheduling of air traffic controllers often does not give them time to adjust to any one set of waking and sleeping hours. Often they will work a week of midnight shifts, then a week of morning shifts, then a week of swing shifts beginning in the afternoon — such changes can take an exhausting toll on the body and mind. The chief in charge of the study recommends that controllers be allowed sleeping breaks of as long as 2.5 hours during mid-night shifts.

Other fatigue experts concur that Air Traffic Controllers often bounce from morning shifts, to afternoon, to night shifts, leaving little time for the body to adjust. Fatigue experts like Philip Gehrman, director of the Behaviour Sleep Program at the University of Pennsylvania, said it is crucial that their shifts remain more constant. “It would be nice if there were a greater appreciation that our bodies have a limit – we’re not equally able to function at all hours of a 24-hour day,” Gehrman said.

2.3 Definition of fatigue

There are many definitions of fatigue to be found, for this paper we thought to find a definition that is most tangible, to the point and specific for the aviation industry. For this reason, to keep the discussion clear, in this document we base ourselves on the same definition as ICAO for fatigue:

‘A physiological state of reduced mental or physical performance capability resulting from sleep loss or extended wakefulness, circadian phase, or workload (mental and/or physical activity) that can impair a crew member’s alertness and ability to safely operate an aircraft or perform safety related duties.’ (ICAO FRMS Manual for Regulators, Doc 9966, 2011)

When we look at this definition we see that the state of fatigue is determined by physiology, has effects on both mental as physical performance. The state is determined by sleep loss, extended wakefulness, the circadian phase (explained below under causes of fatigue) and workload. It mentions that the ability to perform safety related duties is impaired.

The definition does not relate to the personal (subjective) effects of these variables and the definition relates to aircraft crew. For this reason the definition used in this document will be defined as follows:

Fatigue: A physiological state of reduced mental or physical performance capability resulting from sleep loss or extended wakefulness, circadian phase, or workload (mental and/or physical activity), affecting the subjective state, that can impair an air traffic controller’s alertness and ability to perform safety related duties.’

The level of fatigue of a person can be measured in various ways by measuring physical effect. For this paper however the methods of establishing the level of fatigue is not under review as it will have no effect on the FRMS elements (rather on the determination of fatigue than on the management thereof).

2.4 Causes of fatigue

Fatigue is a normal physiological effect related to your everyday routine. There is a physiological system defined that influences the level of fatigue (physiological state) that a person experiences. This system is called the circadian rhythm (Halberg et al, 2003, Akerstedt, Folkard and Portin, 2004, see also the framework below).

Fatigue is largely determined by the combined influence of the duration of sleep/wakefulness and the circadian rhythm (Williamson et al, 2009, London Department for Transport, 2010). The circadian rhythm in sleep is the result of a pattern of increasing and decreasing sleepiness across a roughly 24-hour period, with the highest level of sleepiness occurring in the early morning between around 02:00 and 06:00 when the urge to sleep is the strongest. The lowest levels of sleepiness occur around mid-morning and in the evening between around 20:00 and 22:00.

The more activities planned out of phase with your circadian rhythm, the more effect the work will have on your physiological state; fatigue will arise earlier when performing duties outside of your personal circadian rhythm (e.g. sleeping during the day and awake during the night) (Di Milia et al, 2009).

Process W (waking) reflects sleep inertia, i.e. “a transitional state of lowered arousal occurring immediately after awakening from sleep and producing a temporary decrement in subsequent performance”. Process W is also an important factor to be considered as it might have a safety impact when considering napping during duties. (Van Dongen, 2004)

These models predict that two conditions impact the alertness level, the circadian factor and the homeostatic factor. Under some circumstances, only one condition is met, e.g. during daytime sleep after a night duty, the sleep pressure is maximum but the timing is not appropriate, leading to a disturbed and shortened sleep and thus a disturbed recovery. The effects combined lead to the presented graph S+C in the graphs above in the condition that the subject awakes at 6 AM.

These important factors have to be kept in mind when considering the effects of rostering of ATCOs.

2.4.3 Individual/personal factors

Apart from work related factors, factors from the life outside work play a role in the fatigue level of a person; (Canada tripartite steering committee on ATC fatigue, 2001, Halberg et al, 2003, Parkes, 2004, Di Milia et al, 2009, London Department for Transport, 2010)

1. Personal circadian rhythm; this is affected by the ATCO’s age, sex, race (sleep duration varies by race), societal, family, and various environmental (e.g. light exposure) influences. This is also called the circadian chronotype. Individuals differ in terms of the time of day of their peak alertness and sleepiness (morning or evening types).
2. Duration of wakefulness and time awake (time in hours since last sleep).
3. Quantity and quality of (prior) sleep, sleep requirement (versus sleep obtained) and sleep debt. Sleep loss is cumulative; repeated day-to-day sleep loss results in the accumulation of sleep dept. The greater the sleep debt, the greater the level of fatigue. Employees working and sleeping out of phase with their circadian rhythms gradually accumulate sleep debt which will lead to fatigue.
4. Mental exertion in proportion to the relative fitness (both physical and mental) at commencement of the work shift. Each consecutive year working in irregular shifts (regardless age) reduces the mental ability of a person.
5. Personal demographics (e.g. age, commuting times and gender), psychosocial milieu.Age; Aging seems to result in a gradual deterioration and more difficult adjustment of the mechanisms that support the physiological, circadian, and sleep systems. Due to the aging process various factors affect the recovery from fatigue and the flexibility in the ability to cope with disturbances of the circadian system. Furthermore Aging increases the tendency to morningness, advancing the circadian phase position up to 2 hours.Deterioration of the biological systems begins from about the age of 45-50 years. E.g. altering eyesight (diminished visual acuity, narrowed peripheral vision, and cataracts), slower speed of perception and response to stimuli, and reduced muscle strength. Commuting time and type (transport); commuting time can be an important determinant of sleep duration (short(er) recuperative sleep and excessive daytime sleepiness). Also the length of the commute to and from work can appreciably add to the demands of the work day.
6. Lifestyle issues, partner/marital status, off-duty activities, household/social issues (e.g. dependency care (childcare responsibilities, family members)) disturbed socio- temporal patterns (resulting from atypical work hours leading to family problems, reduced social support, and stress).

2.4.4 Health factors

All these causes interact in a complex manner on the physiological state and have their effect on the level of fatigue. Apart from these three main factors, health factors also play a role in the physiological state of a person, such as (Parkes, 2004, Sirois, 2009, Di Milia et al, 2009, London Department for Transport, 2010):

a. Medical sleep disorder problems, medication use.

b. Physical and mental health status, underlying health issues (e.g. hypertension, diabetes, epilepsy, gastrointestinal complaints, cardiovascular disease, cancer, pregnancy and reproductive disorder, etc.) disturbed metabolic and other pathophysiological systems.

c. Improper timing and content of food (i.e. building cardiac risk factors, digestive disorders), diet, nutritional status.

d. Use/abuse of coping substances (e.g. cigarettes, caffeine, sleeping pills, alcohol, drugs, etc.).

Related to circadian rhythm is a sleep disorder known as the shift work sleep disorder (SWSD). The exact prevalence is unknown, but the disorder is probably uncommon, representing a small proportion (5% to 10%) of patients presenting to sleep disorders centres with the complaint of insomnia. For this reason this disorder related to shift work for the purpose of this paper is regarded as an illness (American Academy of Sleep Medicine in association with the European Sleep Research Society, Japanese Society of Sleep Research, Latin American Sleep Society, 2001, FNV bondgenoten, 2012). Sleep disorders can disrupt both the quantity and quality of sleep, leading to both chronic and acute sleep loss (Williamson et al, 2009).

Error rates increase exponentially with an increase of fatigue; Errors are broadly comparable in nature and frequency with other forms of impairment (e.g. alcohol intoxication) (Dawson and McCullough, 2004, UK CAA, 2007, London Department for Transport, 2010).

Chronic sleep loss can be a risk factor in a range of serious illnesses. Sleep loss has been shown to be a risk factor for obesity and diabetes, while shiftwork has been shown to increase the risk of gastrointestinal problems. Research has also suggested a possible link between the circadian disruption associated with night shiftwork and an increased risk of cancer (London Department for Transport, 2010).

2.6 Theoretical tools of fatigue mitigation

In the studied literature a number of practical to theoretical measures are referred to, aiming to mitigate the risks of fatigue. The most tangible measures are discussed below, followed by assessed pros and cons and the opinion on the measure in terms of sufficiency and practicality.

2.6.1 Tool 1: Breaks

The effect of breaks has been studied in various researches. Although breaks as shown in the literature do not provide a complete answer to the fatigue risk, it can be one of the tools used to mitigate fatigue in a FRMS. Strategic use of breaks has an impact on the level of alertness, as hours of consecutive work is one of the variables shown in the fatigue factors (see paragraph 2.4.1). The following can be derived from the literature:

Taking a break from activity is a short-term countermeasure against mental and physical fatigue (London Department for Transport, 2010, Transportation Safety Board of Canada, 2011). The established norm is two hours on position followed by a relief break. This applies when handling complex and busy air traffic (breaks need to be frequent as a higher workload is concerned). This period may be extended to four hours (but should not exceed) in the case of a low workload and subject to other employed mitigating measures. A meaningful break means that the individual is not responsible for an operating position. The minimum duration of a break should be 10 minutes plus 10 minutes per hour of work. Breaks should allow napping (typically 20 to 40 minutes) with ample time (20 minutes) to overcome subsequent sleep inertia (period of grogginess experienced upon waking). (Canada tripartite steering committee on ATC fatigue, 2001, Eurocontrol, Managing shiftwork in European ATM, 2006, Baumgartner (ATM/HLG5), 2012).

Studies show it is important to control the amount of sleep during controlled rest breaks. (Canada tripartite steering committee on ATC fatigue, 2001, Eurocontrol, Managing shiftwork in European ATM, 2006, UK CAA, 2007, Transportation Safety Board of Canada, 2011, Gimbrere, 2011, Anthony, 2011, Braithwaite, 2012) Napping is a countermeasure to fatigue, it can increase productivity, creativity and problem-solving skills. The ability to sleep/nap during midnight shifts has been found to reduce the level of performance degradation experienced by controllers working these shifts. When only limited time is available, study shows that the best reaction times were demonstrated after naps of 20 minutes maximum. This may be a direct result of awakening from slow–wave sleep in the longer nap condition (sleep inertia). When more time is available a recuperative break of up to 2.5 hours is advised during the midnight shift (Gimbrere, 2011). Napping is considered the only effective countermeasure for sleep deprivation (Eurocontrol, Managing shiftwork in European ATM, 2006,). Therefore, strategic and prophylactic naps are suggested as very effective at maintaining alertness during circadian rhythm troughs, as well as under conditions of sleep loss. Ten to twelve minute ‘power naps’ can refresh for a short period of time. Napping is considered part of a duty period and should not extend it.

• The model does not cover all of the factors that influence the fatigue level of a person. Personal factors are taken into account, though it fails to emphasise the personal responsibility.
• Implementation of PSWM could be difficult as it could result in a bureaucratic procedure, without any means of controlling the correctness of the data used.

2.6.5 Tool 5 Awareness of fatigue and Team Resource Management (TRM)

A major part of fatigue related factors concern factors that relate to personal lifestyle. Awareness of the risks of fatigue and how one can recognise and reduce these risks is imperative for a well working FRMS. To create this understanding training should be provided to ATCOs (Canada tripartite steering committee on ATC fatigue, 2001). Fatigue management is a shared responsibility between all parties involved (e.g. employer, individual employees). All parties have a vital role, which must be accepted by all ‘players’.

The ANSP should encourage personnel to take action when symptoms of fatigue are identified. As TRM has showed, the promotion of a culture of a jointly felt responsibility is essential, as is an open culture where employees feel safe to speak their minds freely. TRM could be a useful tool to recognize the onset of fatigue in yourself or in others and increase the willingness to take action.

The ANSP is responsible for providing optimal working conditions, information on fatigue and facilities to enable fatigue to be effectively managed; training on fatigue management and enable workplaces to adopt practices that minimise fatigue (Canada tripartite steering committee on ATC fatigue, 2001).

ATCOs are obligated to make appropriate use of rest time and report fit for duty. Employees must therefore take responsibility to make the appropriate lifestyle decisions consistent with the nature and demands of shift work (Transportation Safety Board of Canada, 2011).

Fatigue risk management training is a foundation for many of the defences against fatigue. It provides employees with knowledge on how to identify, avoid, mitigate and report fatigue issues. Education of employees on their responsibility in reducing fatigue (Canada tripartite steering committee on ATC fatigue, 2001, Mein, 2001, Transportation Safety Board of Canada, 2011, Gimbrere, 2011) is therefore imperative. Fatigue awareness training should reflect current scientific findings and fatigue mitigation strategies. Support should be personalised and include practical operational needs (Gimbrere, 2011). Supervisors should be trained to identify and consider the fatigue status of individuals prior to commencing shifts or extending shift lengths (Canada tripartite steering committee on ATC fatigue, 2001). To create awareness there are special programmes developed to measure fatigue (London Department for Transport, 2010). These Fatigue models use ‘science-based’ algorithms to predict the fatigue associated with work hours, based on variables such as the duration and timing of shifts and breaks (e.g. FAID (2003), the Health and Safety Executive (HSE) Fatigue/Risk Index (2006), SAFE (2007), FIYT (2009) and CAS-5 (2011).

The development of a monitoring system such as a symptom checklist for recognition of fatigue signs is recommended. The checklist can score behaviour and visible signs of fatigue, combined with supervisor knowledge of the individual ATCO.

Nowadays software has been developed that can administrate the activities of employees in order to determine a fatigue index score. The application of such software is not deemed practicably applicable at this time it forms a great intrusion of the employee’s personal private life. It is suggested that employee’s awareness is increased by training and emphasis on personal responsibilities (ICAO FRMS Manual for Regulators, Doc 9966, 2011).

2.8 Recommendation

Based on the outcome of the literature a FRMS elements model can be defined. In the model below we follow the fatigue risk trajectory of Dawson and McCullough, (2004), expanded with additional findings from the literature. In this FRMS elements model we have recognised so- called prerequisites and tools. Pre-requisites being elements of a FRMS that are non-active but detrimental to the effective management of fatigue. The tools provide insight in the active measures to be taken in day-to-day operations.

FRMS elements model:

The FRMS elements model above will be used to compare the FRMSs under review, in paragraph 3, to draw conclusions on the quality of the FRMS, based on most current knowledge of the management of fatigue.

The FRMS elements model can be adjusted when new scientific research indicates different approaches. The mentioned control mechanisms should be included in the more overall safety management system (SMS) alongside the other safety related issues and following the same principles (Dawson and McCullough, 2004).

3.1 introduction

The aim of an effective FRMS is to reduce the potential negative impact of fatigue on safety. In the past rest (sleep) was identified as the principle means to mitigate fatigue. However in 24/7 operations involving human operators and shift work, fatigue will always be a potential safety risk. Therefore, in addition to measures that aim to reduce fatigue related risks, specific fatigue mitigation strategy needs to be employed to minimise the extent and cause of degraded human performance during operational duties. Finally there must be mitigation strategies in place to form a final line of defence so that human errors posing a potential threat to safety result from fatigue-degraded human performance, the errors would be captured or otherwise diverted from resulting in an incident, accident or other occurrence (Canada tripartite steering committee on ATC fatigue, 2001).

Awareness of fatigue related risks resulting from fatigue is ever growing at this point in time; ANSPs and aviation organizations alike acknowledge the need to mitigate risk that threaten air traffic safety. In this chapter we will compare the fatigue risk mitigation guidelines of ICAO and IFATCA respectively, for applicability in the operations of ANSPs.

The ICAO Standards and Recommended Practices (SARPs) regarding FRMS Requirements (Annex 6, Part I, chapter 4, 4.10.6 and Appendix 8) are reviewed in 3.2, the IFATCA recommendations regarding FRMS and fatigue are reviewed in 3.3. In 3.4 the tools employed in the respective recommended fatigue risk manuals, are compared to the found preferred composition of a fatigue risk management system as shown in paragraph 2. In 3.5 a conclusion will be drawn upon the usefulness of the respective guidelines for ANSPs to aid them in their implementation of the recommended FRMS.

3.2 ICAO SARPS

ICAO has issued SARPs for flight and cabin crew on the issue of fatigue management in Annex 6, Part I, chapter 4, 4.10.6 (ICAO FRMS Manual for Regulators, Doc 9966, 2011, ICAO FRMS Implementation Guide for Operators, 2011), including particular standards that enable the effective regulation of FRMS. These are, in turn, supported by Annex 6 Appendix 8, which details the requirements for a FRMS. For the purpose of this paper the detailed requirements of an FRMS are evaluated for the appropriateness for ANSPs to apply these guidelines in their implementation of a FRMS in the ANSP’s safety management systems (SMS).

The SARPs as defined by ICAO include the risk assessment phase. Although in order to set up and implement a FRMS it is necessary to understand the risks, for this paper we did not include a risk assessment phase in the recommendations. As risks are mostly generic, in this paper we focus on the advised elements of a FRMS instead. When deemed necessary, the process of setting up individual risk assessment procedures can be included in another paper.

The SARPs emphasise that regulations should be established for the purpose of managing fatigue. These regulations shall be based upon scientific principles and knowledge, with the aim of ensuring that flight and cabin crew members are performing at an adequate level of alertness.

The SARPs however state that it is the responsibility of the state to establish fatigue managing regulations, rather than promoting the own responsibility of the organization to self-regulate the risks related to fatigue. This would imply that rather than the organisation (in the SARP the operator), the state is responsible for the safety of its operations. IFATCA does not oppose state involvement in the safety of air traffic by the issuance of a set of minimum requirements of a FRMS, however emphasise that internally developed systems can fit better in the organisation’s needs, will need less external supervision on the correct implementation thereof and is likely to be more effective than an external set of guidelines and rules. For the purpose of this paper we focus on the recommended combination of measures to be taken by the ANSP, rather than the recommended regulations to be set by governments.

The prerequisite staffing and overtime policy as defined in the FRMS elements model is not considered a factor in the SARPs, and therefore deviates from the advised FRMS elements model.

The SARPs take into account the necessary opportunity to sleep for flight and cabin crew members and to comment on the quality of sleep obtained (ICAO FRMS Manual for Regulators, Doc 9966, 2011, ICAO FRMS Implementation Guide for Operators, 2011). The recommendations made however focus on the issues as befall pilots and flight crew, and therefore do not address the issues ATCOs might have.

ICAO Document 9966 looks at the implementation of a FRMS for flight and cabin crew. Short breaks are not a typical instrument to be applied on flight and cabin crew, while they can be a viable method to reduce fatigue for ATCO’s.

The SARPs leave out the maximum shift length recommendation. As the SARPs are solely aimed at flight and cabin crew this is understandable, as a shift is dictated by the length of the flight. Instead recommendations are made on the regulation of flight time duty periods and rest period limitations. These recommendations aim at the same problem of maximum working time, and is thus far comparable to the in paragraph 2.6.2 (HOS model) recommended shift and over hours limitation. This automatically has repercussions on the recommended applied rostering / scheduling. This being said the SARPs are comprehensible, but they do not provide guidance to ANSP’s on how to implement a roster that reduces fatigue risks.

The SARPs introduce the joint responsibility of both operator and personnel, in the same manner as is advised upon in the previous paragraph. The SARPs refer to recommended training of personnel and the necessary commitment of all staff, from management to flight and cabin crew, to reduce fatigue related risks. The SARPs even suggest a required accountability of personnel when these rules are not followed. Although accountability can be a way of enforcing regulation to be followed, the enforcing thereof in this subject could be very difficult. For this reason the accountability was not incorporated in the FRMS elements model. The requirement to make attendance mandatory to fatigue related training programs however is a valuable one, which can be incorporated in the FRMS-model for ANSPs.

Finally, the outcome based FRM is incorporated in the SARPs, by ensuring that output, results and deviations from regulations are reported upon and used for further refinement of the regulations, by the operator.

3.3 IFATCA Technical & Professional Manual 2012

In the Technical and Professional Manual 2012, IFATCA has made recommendations regarding fatigue risks. IFATCA has narrowed down the hours for which the regulations should be applied as the hours of ‘operational duty’. This de facto means that in the IFATCA policy the management of the hours out of active duty are not governed by any rule or recommendation.

There is no direct reference to the personal responsibility of the ATCO with regard to fatigue in the IFATCA Manual. As is shown in this paper IFATCA considers that one of the vital pillars of the management of fatigue related risks is the joint responsibility of both ANSP – to manage work time within the latest established boundaries in terms of length of duty, time between shifts and so on – and the ATCO – to plan work and private time in such a manner that the work duties cannot be impaired by disregard of necessary personal rest periods (i.e. partying all night right before an early morning shift leads to an increased fatigue related risk).

Policy WC 1.3.2. stipulates specifically the maximum length of a shift, the maximum hours of active duty per week and the minimum rest hours. With a difference of 30 minutes the hours taken into account are defined a little more restrictively then the recommended hours as found in the research used in this paper. It can therefore be considered to be conservative, but also safe when they are implemented in an active duty roster.

Maximum operational time and minimum break time is specified in regard to the FMRS element of breaks. In Policy MED 2.2.5 the requirement of management to allow for strategic naps and to provide room for this purpose is included.

A mention in WC 1.3.2 is made with regards to the liability of the controller, which would be void, as per recommendation, when the controller has registered formal complaint towards the duty roster which is applied.

Policy WC 1.3.5 addresses the issue of staffing levels, and considers established documentation on the adverse effects of extended hours of work. In the FRMS elements model presented in this paper this is considered one of the prerequisites for an adequate FRMS. It is not specified whether overtime in this policy should be viewed ‘on top of’ the recommended shift duration, or as part thereof. For this purpose IFATCA suggests overtime to be voluntary, without any pressure from management or peers. In policy MED 2.2.5 the recommendation is made to avoid overtime at all cost shortly before or just after a night shift.

Policy MED 2.2.5 suggests member associations identify fatigue related risks. In the FRMS elements model, it states that management has the prime role in the avoidance of fatigue related risks. In this paper however it is concluded that even though management does have a major role, the personal role of the ATCO is integral to a FRMS model, as not all risks can be managed by rules and regulations of the ANSP.

In policy MED 2.2.5 the physical arrangements such as rest / break areas, but also the arrangements allowing the ATCOs to continue their daily eating habits and rooms for the strategic naps (20 – 50 minutes according to the policy), are expected to be provided for by management. How these arrangements should be set up is not specified in the policy. These breaks are considered to be included in the duty time.

In policy MED 2.2.5. extra emphasis is made on the staffing levels, especially at night time and / combined with workload.

Policy MED2.2.5 comments on the awareness for MAs and their management of fatigue risks and causes. MAs should inform members about the causes of fatigue in ATC so that they can identify those to which they are most exposed to. Members should be informed about the countermeasures available. Education in human factors is mentioned, including theory about the physiological principles related to sleep and circadian rhythms, both in controllers retraining and basic education. Such training should include knowledge of ways to take deliberate actions (countermeasures) to better meet controllers’ operational requirements.

Furthermore MAs should advise their members to seek professional psychological advice when they believe that they are subject to excessive stress-inducing agents, any indications or symptoms are not mentioned.

Policy MED 2.2.5 concludes with:

In the FRMS elements model the auditable FMS relates to the outcome based fatigue management system that should be part of the SMS.

3.4 overall comparison

In this paragraph we compare the recommended elements of a FRMS to the respective regulations of the reviewed organizations, in a table. When the control mechanism as mentioned in the respective regulation can be applied by ANSPs, the table shows ‘YES’ when it isn’t it shows ‘NO’. Other remarks are referred to by number.

1: The general recommendation can be used. It however needs to be recommendation aimed at operators and flight and cabin crew into a recommendation applicable for air traffic controllers.

2: The application of the forward rotating roster is neither included in the ICAO nor in the IFATCA recommendations. They should be included, in accordance with the findings in the literature.

4.1 Introduction

In this paper PLC has reviewed the available scientific findings relating fatigue and the management thereof in comparison with ICAO and IFATCA policy to find recommendations and guidance on the adoption of FRMS additions in accordance.

This paper provides insight into the wide range of factors that influence the state of fatigue of an ATCO, from work related, environmental to personal factors.

4.2 Recommended measures of mitigation of fatigue related risks

In the scientific literature a broad array of measures can be found, where each of these measures specifically target an element of fatigue inducing factors. In this paper PLC has reviewed these theoretical measures in order to establish the applicability and the viability.

The findings are that many of the newer measures provide an overlap with the older ones and that the previously accepted measure of mitigation of fatigue (p.a. working hours and rostering) have been found to be lacking.

Based on the relative state of the theoretical development, and to what degree it has proven itself in the field, the measures have been evaluated for usability in the day-to-day operations of ANSPs.

Following this comprehensive analysis PLC created a model of a theoretical ideal FRMS. The model has been set up to show the general direction of the FRMS elements. The specifics of the elements as established in the model in this paper are not in the scope of this paper, these should be further defined in future studies.

In this FRMS elements model we have recognized prerequisites and tools. Prerequisites being elements of a FRMS that are non-active, but detrimental to the effective management of fatigue. The tools provide inside in the active measures to be taken in the day-to-day operation.

5.1. To insert in the manual at MED 2.2.5 Fatigue in Air Traffic Control:

ATCO fatigue is defined as follows:

A physiological state of reduced mental or physical performance capability resulting from sleep loss or extended wakefulness, circadian phase, or workload (mental and/or physical activity), affecting the subjective state, that can impair an air traffic controller’s alertness and ability to perform safety related duties.

5.2. It is recommended that the FRMS elements model be included in the IFATCA Technical and Professional manual as provisional policy at MED 2.2.5 Fatigue in Air Traffic Control:

The FRMS elements model

5.3. It is recommended that specifics of the FRMS elements model should be further studied by IFATCA and presented as a working paper at conference 2014. As part of this study, existing IFATCA policy on fatigue should be reviewed.

Moore-Ede, M. (2009) ‘Circadian, the definition of human fatigue’.

Sirois, William G. (2009) ‘Circadian, the myths & realities of fatigue’.

Prof. Dawson, D. & McCullough, K. (2004) ‘Managing Fatigue as an Integral Part of a FRMS’.

Akerstedt, T., Folkard, S. and Portin, C. (2004) ‘Predictions from the Three-Process model of alertness’.

FNV bondgenoten (2012) ‘Arbeidstijden’.

London Department for Transport (2010) Road safety research report no. 110, ‘FRMS; a Review of the literature’.

Eurocontrol (2012) ‘Some Perspectives on Fatigue Risk Management Systems’.

Report to the tripartite steering committee on ‘ATC fatigue’ (Canada) (2001).

Van Dongen, H.P.A. (2004) ‘Comparison of Mathematical Model Predictions to Experimental Data of Fatigue and Performance’.

Transportation Safety Board of Canada (2011) ‘Aviation reports A11F0012’.

Mein, D.T.E. (2001) ‘Fatigue management in Air Traffic Control’.

CAA PAPER 2005/04 (2007), ‘Aircrew Fatigue: A Review of Research Undertaken on Behalf of the UK Civil Aviation Authority’.

Baumgartner, M. (2012) ‘Fatigue in ATC, A discussion paper for the Air Traffic Management High Level Group (ATM/HLG 5)’.

ICAO DOC 9966, FRMS Manual for Regulators (2011) Unedited Version.

Grasso, F. (2012) ‘Powerpoint update on EASA ATM rulemaking activities’.

ICAO ‘FRMS Implementation Guide for Operators’ (2011).

Eurocontrol (2006) ‘Managing shiftwork in European ATM’.

Parkes, K.R. (2004) ‘Shiftwork and health’.

Di Milia, L. et al (2009) ‘Accident Analysis and Prevention, Demographic factors, fatigue, and driving accident; An examination of the published literature’.

Williamson, A. et al., (2009) ‘Accident Analysis and Prevention, The link between safety and fatigue’.

Dawson et al., (2010) ‘Modelling fatigue and the use of fatigue models in work settings’.

Air Force Research Laboratory: Science and Technology for Tomorrow’s Aerospace Force (2003) ‘Warfighter fatigue countermeasures, Sleep, Activity, Fatigue and Task Effectiveness (SAFTE) Model Fatigue Avoidance Scheduling Tool (FASTTM)’.

Hursh, S.R. (2004) ‘Fatigue Models for Applied Research in Warfighting’.

Halberg, F. et al., (2003) ‘Transdisciplinary unifying implications of circadian findings in the 1950s’.

Braithwaite, A. (2012) ‘Fatigue Risk Management System Webinar co-hosted by IFATCA en Quintiq’.

Kronauer, R.E. Forger, D.B. Jewett, M.E. (1999) ‘Quantifying human circadian pacemaker response to brief, extended, and repeated light stimuli over the phototopic range’.

Della Rocco, P.S. et al., (1999) ‘The role of shiftwork and fatigue in Air Traffic Control operational errors and incidents’.

The American Academy of Sleep Medicine in association with the European Sleep Research Society, Japanese Society of Sleep Research, Latin American Sleep Society (2001) ‘The International Classification of sleep disorders, revised, diagnostic and coding manual’.

Eurocontrol ‘When are you too tired to be safe? Exploring the construction of a fatigue index in ATM’.

Millar, M. (2011) ‘The Controller, ICAO Fatigue Management’.

Peters, P. (2011) ‘The Controller, Foreword’.

Marien, P. (2011) “The Controller, Editorial’.

Gimbrere, P.F. (2011) ‘The Controller, Science/based fatigue Mitigation’.

Shallies, S. (2011) ‘The Controller, IFATCA on Fatigue’.

Anthony, T. (2011) ‘The Controller, Wake me when my shift is over’.

Cabon, P. (2011) ‘Hindsight 13, Fatigue in Air Traffic Control‘.

EC 1108/2009 in Annex Vb.

ICAO Annex 6 Operation of Aircraft, Part I, Chapter 4, 4.10.6 and Appendix 8 Fatigue Risk Management System Requirements.

MITRE (2010) ‘Human Performance and Fatigue Research for Controllers’.

IFATCA Technical and Professional Manual 2012.