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Thaden, too, found that night shifts and


shift rotations (alternating between day and night shifts) “apparently leads to bad sleep quality.” She also learned that “shops with two shifts report fewer fatigue concerns than those with three shifts.”


Family activities and the maintenance


professional’s social life often can impede adequate rest, especially for night- shift workers. Personal activities can be distractions and difficult to juggle with an unconventional work schedule. “Technicians may want to participate in family activities when they really should be resting,” Thaden explains.


In short, fatigue is caused by not getting the seven to eight hours of quality sleep a day that the body needs. Only four percent of the respondents to Thaden’s survey said they get “very good sleep.” Thirty-two percent said they get fairly good sleep; 48 percent, moderately good sleep; 11 percent, fairly bad sleep, and five percent get very bad sleep. In short, more than 60 percent of the respondents are not getting adequate rest.


Thaden’s research holds much more


data relative to fatigue among maintenance professionals. “But we’ve done just preliminary analysis,” she says, adding that further analysis “is on hold” and requires additional funding to complete. Thaden presented raw data from her survey at PAMA’s Great Lakes Aviation Maintenance Conference in January. “There were a lot of management people at the conference,” she says. “We asked if the survey’s preliminary results represented a correct assessment of working conditions [in aircraft maintenance]. They agreed that they do.”


Fatigue Regulation Despite the perceived problem of fatigue, there is limited regulation addressing maintenance crew duty time. FAA’s only related rule, FAR Part 121.377, states that maintenance personnel shall be relieved from duty “for a period of at least 24 consecutive hours during any seven consecutive days, or the equivalent thereof within any one calendar year.” It applies to maintenance of commercial aircraft only. But the regulation can be “liberally


interpreted,” and maintenance professionals could still work long, consecutive hours and still be in compliance, says Johnson. Therefore, FAA has made clearer Part 121.377’s intent. In late 2011, the Federal Register published a clarification, stating that maintenance personnel must be assured 24 hours off within a seven-day period. Some suggest that the rule dates back to the Book of Genesis, says Johnson.


Although FAA plans to issue HoS guidelines in its fatigue-management toolbox by this summer, the agency indicates it will not regulate further maintenance-crew duty time. “Realistically, it’s not in the cards that there will be a [new] regulation any time soon,” Johnson tells AM. “You don’t need a weatherman to know when the wind blows nor a regulation to know fatigue is a problem.”


“I think we should be establishing a fatigue risk management system and educational tools,” he contends. “That’s more important than requiring a specific number of [work and/or rest] hours.” Dr. Katrina Avers, an industrial


organizational psychologist with FAA’s Civil Aerospace Medical Institute (CAMI), agrees. “It’s not just an hours-of-work issue,” she states. Fatigue’s adverse effects “involve the tasks performed. For example, working on an ETOPS [extended-range, twin-engine operations] aircraft or on flight controls demands a greater standard of care than, say, simply cleaning parts.” A FRMS would take into account the tasks assigned, says Avers. In a process some call “fatigue proofing,” procedures also may be modified to reduce fatigue-induced errors. FAA negates the call for further


regulation, despite the fact that NTSB has long recommended a duty-time rule covering maintenance professionals, as have 21 of the 25 participants in the 2nd annual Maintenance Human Factors Leader Workshop held in March 2011. The Aviation Safety Chief Scientific and Technical Advisor (CSTA) program (within FAA’s Certification Directorate) funded this workshop, which included a cross section of the aviation maintenance industry. It was part of a series, succeeding the first workshop, held in 2010, which outlined the 10 highest, human-factor priorities in aircraft maintenance. Fatigue was deemed the second highest priority, behind documentation, which was covered in the third workshop, held this year. Johnson says future human-factors workshops are planned. NTSB and workshop participants are not


alone in recommending maximum crew duty times. In comments entered into Docket No. FAA-2001-0367, PAMA recommended that an aircraft technician’s maximum daily duty time not exceed 14 hours if work begins before 11 a.m. and 12 hours if it starts after 11 a.m. The association also suggests “no aircraft be released from maintenance between the hours of 2 a.m. and 4 a.m. if the MRO or operator does not have a normal, fully functional second shift. This will require that a fresh morning maintenance crew perform quality control checks of the previous night’s work.”


22 Aviation Maintenance | avm-mag.com | June / July 2012


But FAA is not alone in not choosing HoS mandates for maintenance personnel. “In the maintenance environment, fixed duty times may be difficult to implement, hence the reason why Transport Canada has proposed an alternate FRMS approach to the management of fatigue,” says an official with the Canadian agency. In fact, Transport Canada does plan “to


introduce FRMS requirements in the CARs [Canadian Aviation Regulations], which will also be applicable to aircraft maintenance organization,” says an official with the agency. “The amendments are not published yet.” Transport Canada provides its TP 14576 guidance document to help build an effective FRMS policy and procedure manual. And Canada’s agency and aviation industry, along with the University of South Australia, have developed an FRMS toolbox. In addition, Transport Canada, which has become a leader in tackling the fatigue issue, has human factors training requirements in the CARs that relate to maintenance personnel. FAA has, as yet, no maintenance-


training requirement pertaining to fatigue. Delegates at FAA’s Human Factor Workshop encouraged instituting “fatigue awareness education in the maintenance schools operating under Title 14 of the Code of Federal Regulations Part 147.” They assert that it “should sensitize aspiring mechanics to fatigue issues during their initial training.”


Emphasis on FRMS FRMS is regarded a prime weapon against fatigue by ICAO, the European Aviation Safety Agency (EASA) and the Civil Aviation Safety Authority of Australia, as well as by FAA and Transport Canada. Some delegates at the FAA Human Factors Workshop go a step further with the view that “an FRMS should be ‘called out’ as an explicit SMS [safety management system] requirement,” according to a post FAA workshop report. (Of note, the U.S. Congress mandated a fatigue risk management plan for airline pilots in 2010.)


The FRMS concept extends beyond crew scheduling and involves task assessment, accountability and responsibility, education, modeling tools and, importantly, an effective fatigue-related reporting system. Transport Canada defines FRMS as providing “a performance-based mechanism for managing fatigue.”


The FRMS is meant “to make predictive assessments, so tasks can be assigned more strategically,” says Bob Kelley, aviation systems standards quality control specialist with FAA. A system would require fatigue assessment tools, such as a sleep diary, symptom checklist and other data gathering.


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