Airlines can strike a balance between safety and productivity on their flight decks by instituting fatigue risk management systems (FRMS) as an overlay to flight-time regulations and company policies. Such systems require a “just culture,” a working environment in which pilots can provide feedback without fear of punishment, says the president of the International Federation of Air Line Pilots’ Associations (IFALPA).
“We don’t punish for normal errors and omissions made by a reasonable person going about their daily business so long as they fess up and give us the opportunity to learn from that,” said Martin Chalk, IFALPA president. “We consider discipline only where you have deliberately or thoughtlessly created a challenge.”
An Airbus A380 captain with British Airways, Chalk was named to lead the Montreal-based umbrella organization of world pilots’ associations in April 2015. Speaking with AIN at the recent Farnborough Airshow outside of London, he summarized IFALPA’s current focus areas—implementing FMRS, the “unholy rush” toward airline industry liberalization and the influx of remotely piloted aircraft systems (RPAS).
IFALPA describes an FRMS system as a set of scientifically based and data-driven procedures that allow for a cooperative and flexible means of managing pilot fatigue as part of an operator’s safety management system. In Chalk’s words, it facilitates a “constant loop” of training, reporting and analysis into pilot scheduling. Layered over a company’s fatigue management policies and the “prescriptive” flight-time limitations of regulatory authorities, FRMS provides an extra level of safety. A prerequisite of successful implementation is a just culture atmosphere of trust and confidentiality that encourages pilots to report into the system.
“Operators are often from our perspective somewhat irrational in their resistance to an open conversation as to when fatigue becomes a challenge and what impact that has on the safety margins available,” Chalk said. “The most important thing to any professional pilot is to deliver their core professional promise of a safe operation. Fatigue, because it is so insidious, because it affects your ability to make informed, considered decisions, is incompatible with professional piloting.
“We are most concerned about ensuring that our [duty] rosters are produced in such a way that we can always deliver on that professional promise,” he added. “Equally, we want our companies to be profitable; we don’t want a nice three-hour day where nobody ever gets in any way tired. That’s great, but the companies are never going to make a profit on that. We are very aware that there has to be this balance between productivity and safety.”
The FRMS concept is not universally well understood, and it is important that regulators and operators be apprised of both the costs and the benefits of such a system in terms of improved safety margins, Chalk said. “One of the challenges is it has both a positive and a negative effect,” he explained. “When you institute a good FMRS, the first year pilots see fatigue days disappear and management sees more productivity, but you’ll come to a point where it plateaus. You still need to maintain your FMRS to maintain that benefit, but there is no longer year-over-year improvement.”
If an operator decides to eliminate the cost of the system, “you have to go back to a prescriptive, less nuanced system and so the cost of the fatigue risk management system is in retaining that percentage improvement whatever that happens to be, and it will differ from operator to operator,” Chalk said.
Airline industry liberalization presents another dichotomy of cost and benefit, pitting system safety against healthy competition. Chalk mentioned South America specifically as a region where a growing number of large carriers are creating pressure for lax regulation. “They’re playing regulators off against each other, they’re clearly saying to one country we can supply all of our service to your country without any airplanes licensed there, without any need for your government interference,” he said. “They’re practicing all sorts of weird systems. They have something called ‘interchange,’ where they will have a single airplane on more than one AOC [air operator’s certificate]—it’s on multiple national AOCs. One day it will be flown by one country’s nationals, the next day it will be flown by another country’s nationals. What happens then is there no clarity as to who is responsible for the oversight.”
The issue is not confined to one region; Chalk also mentioned Ireland as causing IFALPA concern. “The Irish are quite light-handed; they’ve made their regulatory authority semi-detached from the government,” he said. “Although it’s a nonprofit organization it has to fund itself and that is having a negative effect on the basics.”
IFALPA is calling for regulatory authorities to work together to produce similar regulations governing RPAS access to unrestricted airspace. “From our perspective the modularity of regulation is really important. To have different rules in different places just makes our lives more complicated and opens up the opportunity for error and omission,” Chalk said.
The federation supports the development of regulations that will frame the commercial use of remotely piloted aircraft. It is less accommodating of recreational drones. “We would prefer the toys to be kept away from civil aviation,” Chalk said. “We don’t want there to be a string of accidents produced by drone strikes in the way that we’ve had to deal with bird strikes in the past. Common sense says something that is made of plastic and batteries and metal is likely to do you more harm than something that is made of feathers and blood.”