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Recap from the EASA Fatigue Risk Management (FRM) Conference

The European Union Aviation Safety Agency (EASA) and Austro Control recently cohosted a conference dedicated to Fatigue Risk Management in Vienna, Austria, on January 30 and 31, 2024. The conference aimed to draw attention to issues involving aircrew fatigue and the resulting safety risks that may affect EASA Member States. SAFTE-FAST Product Director Robert Mora and IBR Director of Sleep Science Jaime Devine had the privilege of attending the two-day event that was designed to be an active exchange of ideas and discussion of best practices for superior fatigue risk management.

Right from the beginning, the conference was designed to take logistics into account. Opening remarks began shortly after noon on January 30th, and the conference wrapped up by mid-afternoon on the 31st. Rather than designing a one-day event that started early and ended late, which usually means that attendees have to fly in a day early and fly out the next day, the organizers set up the EASA FRM conference so that European attendees could easily arrive in Vienna the morning of the first day and depart in the early evening after the event’s conclusions. Those of us commuting from North America did not benefit from the split afternoon-to-morning schedule since crossing the Atlantic Ocean is never convenient, but I appreciate the forethought on the parts of EASA and Austro Control.

The conference was attended by representatives from across Europe, with speakers representing EASA, regulators from Norway and Luxembourg, and operators from across Europe. With several SAFTE-FAST users in attendance as well. EASA and Austro Control pulled out all the stops to encourage discussion in a relaxed atmosphere, plying attendees with free beer, glasses of wine, and massive Bavarian pretzels after the end of the first day’s events. Honest thoughts tend to rise to the surface after a drink. The organizers also made copious use of Slido to poll the audience and allow attendees to ask questions without disrupting the flow of the presentations.

An early Slido poll revealed that 50% of the attendees believe that a “lack of knowledge” is the largest barrier to effective FRMS. Ninety-four percent (94%) also believe that the responsibility of managing fatigue requires cooperation between the operator and the crew. Recurring themes throughout the talks boiled down to the need to educate crew, to trust that they will not abuse fatigue reporting, and not to over-rely on biomathematical modeling.

New EASA regulations recommend that operators use, at a minimum, the Prior Sleep Wake Model (PSWM), a questionnaire that asks crew to report how long it has been since their last long sleep—naps do not count. Operators are free to use other models provided that they measure sleep events similarly to the PSWM. Operators had a number of questions about how to fit this basic equation, which Aurora Consulting’s Dr. Alex Holmes politely pointed out was not designed for use in night duties, to their overnight schedules or in cases of split sleep. EASA’s Irina Petrova pointed out that some of the more advanced biomathematical models do not account for naps either and that split sleep opportunities do not generally satisfy the legal requirement for a full rest period. Petrova had a firm but fair answer to why EASA recommends the PSWM rather than a more complex system—EASA needs to ensure that operators can comply with basic fatigue risk management but appreciates that not every operator can afford a commercialized FRMS software product. The PSWM may be no better than using a Karolinska Sleepiness Scale or Samn-Perelli to assess subjective fatigue, but it requires the operators and the crew to be aware of their rest opportunities in a way that is fair to small airlines.

It was particularly interesting to me as a sleep neuroscientist to learn more about how biomathematical modeling integrates into rule-making. When I think about biomathematical modeling, I am thinking about how mathematical equations are used to represent our understanding of rhythmic biological functions like the sleep-wake cycle. One airline mentioned their use of AI to support their in-house model, a point which was praised but underappreciated as a standard enhancement. I didn’t use ChatGPT to write this blog, but I could have. Artificial intelligence tools are no longer the stuff of science fiction and can be used to write algorithms that describe the cyclical nature of biological functions. The question was asked at one point, “Can you imagine an individual crew member using a biomathematical model to assess their risk?!” The answer was supposed to be a resounding “no”, but here I am sitting in the audience with my SleepTank app—a tool IBR has already designed specifically to help individuals manage their own fatigue in the context of operational readiness. Yes! I imagine crew members using a model just as much as they use any of the features on their watches. If a Garmin wearer can use Body Battery, they can use a model. However, what I am imagining is the ability to import sleep data and schedule data into an application that is based on a one-step, three-process model and can provide continuous updates about alertness using a cloud-based platform to provide feedback to the individual user. I am not imagining that a novel individualized application of biomathematical modeling would ever replace the need for operators to monitor fatigue risk at the operational level.

During a panel on shared responsibility and fatigue reporting, a panelist mentioned that it would be “20 years” until we had individualized biomathematical modeling. However, mobile apps like CrewAlert, SleepTank, and 2bAlert already exist. Pilots and crew members are already wearing smart watches that track their sleep (some with better accuracy than others), and their organizations are already tracking their rosters. The barriers to individualized applications of biomathematical modeling in aviation at this point are regulatory, logistical, and ethical, not technological. My estimate is 5 years until individualized biomathematical modeling tools are available as individual sleep hygiene tools. It may be several years beyond that until they are good, but so was the case with sleep tracking and heart rate detection in smart watches. That is also not to say that individualized applications of biomathematical modeling would ever supersede a holistic FRMS in the same way that generalized BMM applications do not comprise the totality of an operator’s fatigue risk strategies today.

Beyond cooperation between crew and management, EASA’s Alberto Ottomaniello advised operators to cooperate with their commercial departments as well. If lack of knowledge is the major barrier to successful FRMS, then it might be time to change the ad campaign. Proper safety guidance needs to be advertised, and the safety officers should appreciate that money drives everything. “Profit-driven ignorance” was a term dropped into the Slido word cloud that stood out to me. Another point made was that operators are constantly fearing that someone else will be able to provide their services for a cheaper price. Aviation is a competitive market. Anyone who has compared flights on Google, Expedia, Priceline, Trivago, Booking, etc. knows the importance of the ticket cost—but there is no filter option for safety. I am reminded of the scene from the 1988 movie “Rainman”, in which Dustin Hoffman’s autistic character refuses to fly on any airline except for Qantas because of their superior safety record. Neurotypical Tom Cruise is flabbergasted by Hoffman’s logic but it was an excellent advertisement for the airline and for safety in general.

Safety always seems to have to fit itself into the context of affordability. That same panelist made the comparisons between a pilot reporting fatigue and a pilot reporting a strange smell or noise that may be related to an aircraft issue. The flight is grounded without delay for a strange smell even though it is a subjective complaint, but fatigue is second-guessed. The fear of losing money or credibility due to an aircraft malfunction is greater than the fear of human error occurring because of fatigue. Perhaps it is because the first aviators were adventurers or military—the importance of the mission outweighed the risk. This culture has trickled down through the ages, even though today’s pilots risk more than their own lives when they fly tired. This got a nod of agreement from an airline representative from northern Europe who noted that working at one of the world’s oldest commercial airlines, she could see the cultural remnants of the explorer’s attitude towards fatigue.

Europe is used to cultural change as much as it is used to cultural exchange. I am old enough to remember the days before the European Union or the Euro. From my experience conducting research in North and South America, across Europe, and in Australia, I can say that European privacy protections (GDPR) are easily the most stringent. GDPR was just born in 2018, though! EASA ‘s regulatory updates were met with arguments, but they will be met with compliance. My point is that Europe changes quickly, so perhaps they can change the stigma around fatigue as well. EASA is planning to host another forum later this year in Madrid.


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