The FAA in March, 2016 issued AC-120-MRFM, Maintainer Fatigue Risk Management. As ¶ 1.2 states:
This AC is informational and is not mandatory. It does not constitute a regulation.
To translate that verbiage to plainer English, it means that
- the FAA did not want to undergo the controversy which such rules attract,
- but felt compelled to issue this advisory language (not subject to an NPRM),
- really wants the airlines to adhere to the “recommendations” made in the AC
- all carriers can expect that their PMI will use those terms as a test in the next review.
Why did the Flight Standards organization use this policy promulgation process?
It is important to note that the application of fatigue management to aviation maintenance technicians has been staunchly supported by the leading expert of maintenance workers and aviation safety, John Goglia.
Flight and Duty Time, now called Part 117 FLIGHT AND DUTY LIMITATIONS AND REST REQUIREMENTS: FLIGHTCREW MEMBERS, ranks among the FAA’s most contentious and long festering safety/policy debates. About a year ago, that battle was resolved with a set of rules, and more importantly the establishment of a fatigue management regime for the cockpit and management. That final rule incorporated the most advanced scientific approach to deal with the issues of a flight crewmember’s fitness to report for duty and of the demands imposed on the pilots by their schedules.
There is a large coterie of FAA staff—Flight Safety, Legal, Policy, Congressional and Senior Executives—who can point to grayer hair, perhaps added pounds, certainly lost sleep and other forms of stress indicia during their careers working the Flight & Duty Time process. In addition to the difficult work of trying to balance the strong views of management and unions, enduring with the reviews of experts at the Office of Secretary and OMB, being witnesses at heated Hill hearings and participating in multiple Court of Appeals reviews. Thus, they have an aversion to facing another battle on fatigue.
The AC describes the basic concepts of human fatigue and how it relates to safety for aviation maintenance organizations and individual maintainers; provides information on Fatigue Risk Management in terms of fatigue hazards and mitigation strategies specific to aviation maintainers; describes the benefits of implementing FRM methods within aviation maintenance organizations; and identifies methods for integrating FRM within a Safety Management System.
It is a 23 page document heavy on science, includes popular suggestions like naps and excused absences, the use of caffeine, assigning tasks based on the worker’s level of fatigue and an extensive explanation of the how and why of integrating SMS.
The AC is a draft and all may comment on it. It will, however, be interesting to see how advisory it really is.
Oh, by the way, there is a bill pending which would regulate the time between scheduled work for Flight Attendants.