New FAA draft guidance spotlights the threat fatigue poses in the maintenance environment and suggests methods operators and MRO providers can use to combat the risk of fatigue-induced errors.
Fatigue risk-management systems (FRMS) are not new to aviation, but their application in maintenance has lagged behind other areas, such as piloting aircraft. Traditional FRMS programs target “continuous control tasks,” where the primary threat is falling asleep, the FAA notes in draft advisory circular (AC) 120-MFRM.
But the MRO world presents different challenges.
“In maintenance, falling asleep at work is not the main hazard created by fatigue,” the FAA says. “Rather, a fatigued maintainer is at increased risk of maintenance errors due to impaired mental functioning.”
The AC aims to provide an FRMS framework tailored to maintenance. At the center are hours-of-service limitations, which are spelled out in the FAA’s regulations. Helpful tactics include fatigue-proofing tasks, training personnel to spot signs of fatigue, restricting responsibilities of fatigue-affected workers, science-based scheduling, naps and even “careful use of caffeine.” The tactics should be bonded together with a risk-assessment strategy, incident-reporting system, committed management, clear company policy, constant program evaluation and—when needed—improvements.
“An overall approach to FRM in maintenance can include interventions directed at three objectives: reducing fatigue, reducing or capturing fatigue-related errors and minimizing the harm caused by fatigue-related errors,” the FAA says. “Most fatigue countermeasures can actually address more than one of these objectives.”
The agency says that the push to keep aviation personnel from falling asleep on the job means most FRMSs focus on fatigue reduction. “However, maintenance organizations have greater opportunities to alter the scheduling and method of task performance in response to the threat of fatigue,” the FAA notes. “Therefore objectives two and three deserve special attention in maintenance operations.”
The draft AC was issued for public comment through late April. The FAA will review the public’s input and work toward a final version.