by Carsten Reuter, ECA FTL Working Group & Vereiningung Cockpit Chairman FDT Committee
One year ago – on 18 February 2016 – the new European rules on Flight Time Limitations (FTL) became applicable throughout Europe. With the overarching aim of preventing air crew fatigue from posing a threat to flight safety, two key objectives of these new rules were to achieve a harmonised regulation across Europe, and to improve flight safety standards through a better anticipation and management of fatigue risks at the level of individual airlines. Have these two objectives been achieved?
The new EASA FTL concept intends to combine two fundamentally different approaches to provide sufficient protection from fatigue: the traditional approach of a tightly regulated prescriptive rule set and a flexible customisable system under a Fatigue Risk Management (FRM or FRM(S)). The latter, once approved by the national aviation authority (NAA), validated by EASA, and fine-tuned at operator level, would allow to accommodate the operators’ individual operational needs, but still provide the same – or even a higher – level of safety. As such, FRM(S) would come on top of the prescriptive rules, providing an additional and proactive safety layer, and providing more operational flexibility.
The proper application of FRM – as the very back bone of EASA’s ‘deviation’ process and of any operator’s safety management – is quite often either not understood, poorly handled, inadequately overseen or simply misused to cover ongoing malpractice. An ECA internal benchmarking of almost 30 airlines’ FRM, in 2016, showed that most operators’ FRM is still immature and not fit for purpose. This is worrying.
Unfortunately, in times of budget cuts and staffing shortages at national level, only a small minority of national aviation authorities have a good understanding of the rules and can properly oversee operators. At the same time, ‘self-management’ of FRM by the companies themselves works only hand-in-hand with a strong oversight and controlling authority. For this, the authority needs to understand both the EASA FTL rules and the way FRM works, and to develop a clear concept on what to look for when overseeing an operator. Few have this ability today.