Page 14 - 2018-Issue2

ALL IN: FRMS IS A THREE-WAY ENDEAVOUR 14
“All In” DECISION-MAKING & GOVERNANCE

In addition to the nuts and bolts of the FRMS operations, there should be pilot representation at the top level decision-making forums as well. This
FRMS is a Three-Way Endeavour ensures that concerns raised in subordinate forums (such as those reviewing the rosters or reports) are given the proper credence and attention, the
decisions made are transparent, and higher-level considerations (such as executive strategies) may be better understood.
REGULATOR RELATIONS
Much like contributions that can be made to the airline’s processes, the pilots’ association can provide the regulator with perspectives to which it may
not otherwise have access. Unique perspectives on engagement levels, perceived effectiveness, general hazard identification and validation may only
be available directly from the pilots. Regular contact with the regulator can assist them with their own audit focuses on FRMS strengths and weaknesses
and help the regulator guide other operators with the association’s FRMS experience. Furthermore, the pilot representation will play a pivotal part in
the proving and approval processes involved in moving operations outside existing rules. The introduction of ULR operations on Singapore to New
1
York provides an excellent early example of this .
INDUSTRIAL INTERACTION
Since work rules for the purposes of fatigue management often reside within -or parallel to- industrial agreements, pilot representatives involved in
FRMS must understand the difference between fatigue and other considerations when dealing with these rules. This is essential to maintain the integrity
of the FRMS processes (so as to not become a forum for non-fatigue related grievances), as well as maintain the credibility of the pilots’ association to
keep its safety objectives pure. Pilot representatives working in the FRMS should be internally advising other parts of the association where needed,
such as when monetary or lifestyle demands in contract negotiations are in conflict with fatigue management objectives.
SELECT REPRESENTATIVES
Like any pilot representative position, selection of the right people is important to maintain credibility and ensure effectiveness. Representatives should
be upstanding among the pilot community and disciplined in their positions wherever they may be. While some airlines have a tendency to unilaterally
select pilot representatives, the best method is either to entrust this to the association, or to at least allow the association approval of any nominees.
Training should be provided by the airline, but considering the vast amount of expertise and resources available to IFALPA MA’s, the pilot association
may be even better placed to provide initial or further training.
CONCLUSION
Different operations and different regions have their own challenges getting pilot representation at the various levels of FRMS operation. A full-func-
tioning FRMS is certainly not appropriate for a great many operators, at least not initially. In many parts of the world, airlines and regulators don’t even
consider it necessary to include pilot representatives in any FRMS functions. While it is only recommended in the ICAO documents, this seems a flawed
approach considering the benefits pilot representation can bring. Wherever you are in the world, it is important to ensure that the pilot perspective is
inserted in FRMS or fatigue management operations wherever it can be, for the benefit of all three parties.

1. Fourth Workshop Yields Insights into Early Ultra-long-range Flight Experience, in Flight Safety Digest. 2005, Flight Safety Foundation.

Figure 1: A Sample FRMS Representative Structure

InterPilot | The Safety and Technical Journal of IFALPA ISSUE 2 | 2018