Features Procedures Safety & Training
The Art of Fatigue Management

Is the English language disintegrating or am I just getting old? We
live in an age which has a seemingly endless supply of buzzwords and
catchphrases. Words such as ‘network’ and ‘dialogue’ have gone from
being nouns to verbs, and words normally associated with inanimate
machines, such as ‘units’ and ‘interface’, are now regularly used to
describe family structures and personal conversations. The next thing
you know, dogs will be living with cats.

As
much as I long for the days of plain old English, some of these new
phrases can catch your attention. The latest one to come drifting by is
‘Fatigue Risk Management System’ and it refers to a proposal to ensure
that AMEs on the job are properly rested. (when I was growing up it was
called ‘being properly rested’!) This is an important issue for anyone
who takes aviation safety seriously and, my jibe about the state of our
language notwithstanding, the process begs our involvement.

My
first brush with fatigue came early in my career when I was a pilot
without portfolio, one of those 100-hour wonders who was fortunate
enough to get a position as a dispatcher with the offshore crews in St.
John’s. The lads got called out to take some urgently needed equipment
to the rig early one morning and I had to come in and man the radios.
Being a young enthusiastic type and hyper-eager to make a good
impression, I bolted through the door of the office at three in the
morning and helped the lads prepare for their flight. They departed for
the rig in due course and I dutifully passed on clearances and position
reports during the outbound trip. Save for the occasional yawn, I was
holding up pretty well. Upon landing on the rig, our crew called to say
they would be three hours or so onboard before coming home. Having
missed a night’s sleep and with no witnesses in sight, I hove to at the
desk for a quick nap. The next thing I know it’s 8 a.m. and my boss
walks through the door to find his junior dispatcher at a 45- degree
angle in the chair, head tilted back, feet on the desk, arms by his
side and snoring quite loudly. I can only guess at what went through
his mind as he burst out laughing and brought me right to my taps!

With
the implementation of CARs came the CARAC process which allows all
stakeholders (another buzzword) to weigh in on any given issue and
supposedly affect the outcome of the rule-making process. Notice of
Proposed Amendment #2004-010 is an excellent reason why we should take
advantage of this opportunity

The proposal suggests a course of
action to ensure that AMEs are not fatigued on the job, which I think
is an absolutely wonderful idea. The course suggested, however,
requires the interpretive skills of a Philadelphia lawyer and the
subjective academic discipline of Freud to understand and implement.
Why do they always try to make it so complicated?

We have been
managing fatigue for years among pilots with flight and duty time
regulations, and despite a few hiccups at the starting gate, I think it
has worked out pretty well. These pilot regulations are deemed
‘prescriptive’ (another buzzword), a definition which our current rule
proposers seem most anxious to avoid. But please consider that unless
you have the previously mentioned lawyer and a good doctor in your back
pocket, prescriptive rules are all we can accurately rely on to get us
through.

It is not fair or particularly bright to expect
individuals and managers to be consistently proficient at recognizing
and mitigating something as nebulous as fatigue. What training do I
have as a manager or a pilot, to recognize who is most fatigued among a
group?

Providing a little direction, with structure and an
occasional rule thrown in, is not a bad thing and has served the pilot
community well for years. In managing flight and duty times
subjectivity is kept to a minimum and, for a non-health care
professional, that suits me fine. All the companies and managers are
used to it, all the pilots are used to it. It is not a big stretch to
imagine that implementing a similar system for AMEs would be relatively
simple.

If the proposal as written ever hits the CARs I would
respectfully suggest that it will have a dramatic and opposite effect
from Fatigue Management as we all lose sleep over how to implement and
manage the beast.

Review the NPA:2004-010 and see what you think.