The European Union Aviation Safety Agency (EASA) recently hosted its second annual conference dedicated to Fatigue Risk Management (FRM) with the Spanish Authority-- the Agencia Estatal de Seguridad Aérea (AESA)-- in Madrid, Spain on February 4th and 5th, 2025. This year’s conference built upon the foundation started during the 2024 EASA Fatigue Risk Management Conference, hosted in Vienna, Austria in collaboration with AustroControl. The conference was attended by 140 representatives in person and over 600 additional attendees joining online. SAFTE-FAST Product Director Robert Mora and IBR Director of Sleep Science Jaime Devine had the privilege of attending the two-day event and giving a presentation during the panel on predictive tools in appropriate FRM and FRMS. The key takeaways from the conference, the full agenda, copy of PowerPoint presentations, and YouTube recordings of Days 1 and 2 can be found here.
The conference began with welcome notes from EASA and AESA, followed by a presentation of findings so far from the Effectiveness of Flight Time Limitations (FTL 2.0) study being conducted by the Netherlands Aerospace Centre (NLR) and German Aerospace Center (DLR). This extensive research study aims to review the effectiveness of current duty time limitations and rest requirements on aircrew alertness. The study focuses on duties longer than 13 hours during the day, duties longer than 11 hours in an unknown state of acclimatisation, high sector duties, the effects of standby or reverse periods, and the incidence and impact of controlled rest. Controlled rest refers to brief naps on the flight deck during periods of low workload. Controlled rest is practiced in a number of countries and regions but is not permitted in others. So far, the NLR and DLR researchers found that controlled rest was used by pilots mostly during eastward bound travel, night flying, flights that crossed time zones or when pilots were in an unknown state of acclimatization. Pilots reported using controlled rest to mitigate or prevent fatigue. Other preliminary findings from the study indicate that more work is related to greater feelings of fatigue, and that amount of prior sleep is a better predictor of fatigue than number of sectors, age, gender, or time of day effects.
Next was a panel on the implementation of disruptive schedules with panelists from EASA, the French regulator Ecole Nationale de l'Aviation Civile (ENAC) and carriers EasyJet and Transavia. Panelists discussed three kinds of night duties that encroach on the window of circadian low (WOCL), defined roughly as the hours between 0200 and 0600—1) duties that begin during the window of WOCL; 2) duties that end during the WOCL and; 3) duties that work through the WOCL. These duties are considered disruptive. The panelists discussed ways of mitigating fatigue risk during disruptive schedules, including the EASA regulation regarding night duties, biomathematical modeling tools, using Systematic Integrity Risk Analysis (SIRA) methodology, and appropriate FRM. Later in the day, Robert Mora demonstrated new settings within SAFTE-FAST that allow users to identify night duties within rosters for enhanced fatigue risk assessment.
The forum also focused on challenges implementing flight time limitations. As one panelist pointed out, there is a difference between rule and reality. The use of Commander's Discretion and Just Culture can be crucial to day-of decision making provided that organizations educate their crew members about how to use them effectively. Commander’s Discretion refers to a decision made solely by the pilot in charge of the operation based on their personal information about the crew’s ability to perform. Just Culture is a framework where employees are expected to report safety concerns to their organizations, and organizations are expected in turn to be responsible for employee behavior with an emphasis on cooperation rather than blame. Both these tools can be helpful if used properly but can create problems if they are used improperly.
Culture is another challenge to fatigue risk management. A company’s ‘chrono-culture’, or collective perception of what times of day are subjectively better than others, can affect crew members’ bidding practices, adherence to fatigue management best practices, and thoughts about fatigue reporting. Cultural change was frequently mentioned as a linchpin for improving fatigue risk management during the conference. A company culture that perceives fatigue as a moral failing or fatigue reporting as using a ‘get out of work free card’ undermines safety, for example. Fatigue reporting shouldn’t be used just in instances where the consequences are obvious but should be used to report instances of fatigue where nothing went wrong in order to create a robust dataset about risk. Many talks throughout the two-day conference touched upon the importance of data and highlighted the many barriers they face in collecting high quality data. Data is crucial for conducting a trend analysis of fatigue reports, developing new regulations and generally managing an organization’s safety culture.
Data is also important for biomathematical modeling. The forum featured a panel about predictive tools for use in FRMS and many presentations touched upon how biomathematical modeling can help support safety culture. Models can help to identify situations where crew members may be more fatigued. Models can be used proactively for schedule design, in real time during operations, and to support a retroactive analysis of fatigue. However, one biomathematical model is not a one-size-fits-all solution to fatigue risk management. Models should be adapted if they are going to be used for a new or different operation. The models that airlines use should be flexible enough to accommodate new use cases and dynamic enough to begin to account for individual differences.
Biomathematical models, including SAFTE, have historically been informed by population averages. For example, the average person needs eight hours of sleep per night. However, one individual may need 9 hours to perform safely while another person only needs six hours of sleep in order to perform safely. Today’s technology allows us to collect and mathematically incorporate a wider range of those individual differences. Logically, models should include information about individual crew members’ sleep needs, performance and demographics to create a more scientifically-accurate prediction of fatigue. However, the warning that I would like to give to this approach is that it would be easy to use this approach to either discriminate against someone based on a perception about their resilience (age discrimination is a good example), assign more work to resilient individuals in a punitive or unfair manner, or pressure employees into falsely portraying resilience.
Abuse of perception about individual differences in fatigue resilience reminds me of the point made by the aviation psychologist José Manuel Ponz during his flash talk on fitness for duty. His talk occurs at the 2:12 mark during the Day 2 video of the conference on YouTube here. Captain Ponz discussed our personal bias in believing that we are titanium, or indestructible. We may believe that our individual differences mean that we are more able to handle fatigue relative to our co-workers—a dangerous assumption. Equally dangerous is when there is external pressure to present a resilient persona. There is always the caveat that the individual should be trusted over the model when it comes to assessing their own fatigue. This is true of population-based models as well as individualized models.
I could dedicate several more pages of text to describing the content of the 2nd EASA Fatigue Risk Management Conference, but it all boils down to the first key takeaway bullet point on the online agenda. The first point says: “EASA Continues to Work on Fatigue”. There are many issues to discuss, changes to address, perspectives to consider, and tools to develop. Fatigue may seem relentless, but it’s reassuring that EASA and global regulators continue collaborating with airlines, scientists, unions, and stakeholders to foster a safety culture benefiting everyone.
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