Staff Instruction

Staff Instruction
Subject: Fatigue Risk Management System Assessment Guide

Issuing Office: Standards
Activity Area: Oversight SI No.: SUR-007
File No.: Z 5015-11-2 Issue No.: 01
RDIMS No.: 2441010 v4 Effective Date: 2008-10-15
TABLE OF CONTENTS
1.0 INTRODUCTION.............................................................................................................................. 3
1.1 Purpose............................................................................................................................................ 3
1.2 Applicability ...................................................................................................................................... 3
1.3 Description of Changes.................................................................................................................... 3
2.0 REFERENCES AND REQUIREMENTS ......................................................................................... 3
2.1 Reference Documents ..................................................................................................................... 3
2.2 Cancelled Documents ...................................................................................................................... 3
2.3 Definitions and Abbreviations .......................................................................................................... 3
3.0 BACKGROUND............................................................................................................................... 5
3.1 Introduction ...................................................................................................................................... 5
4.0 FRMS ASSESSMENT PROCESS .................................................................................................. 6
4.1 Determine Assessment Scope......................................................................................................... 8
4.2 Certificate Holder under Review ...................................................................................................... 8
4.3 Pre-Site Visit Documentation ........................................................................................................... 8
4.4 Site(s) Visit ....................................................................................................................................... 8
4.5 Observations .................................................................................................................................... 9
4.6 Apply Measures ............................................................................................................................... 9
4.7 Rollup ............................................................................................................................................... 9
4.8 Assessment Report.......................................................................................................................... 9
5.0 MASTER PROTOCOL .................................................................................................................... 9
5.1 FRMS Framework ............................................................................................................................ 9
5.2 FRMS Expectations ....................................................................................................................... 10
5.3 FRMS Questions............................................................................................................................ 20
6.0 EVALUATION................................................................................................................................ 31
6.1 Measurement Criteria..................................................................................................................... 31
7.0 FATIGUE RISK MANAGEMENT SYSTEM ASSESSMENT SCORING RULES ......................... 41
7.1 Scoring Award Level ...................................................................................................................... 41
7.2 Optional Components .................................................................................................................... 42
7.3 Failure to Meet Minimum Requirements ........................................................................................ 42
7.4 Scoring Using the Criteria .............................................................................................................. 42
7.5 Suspension of the Operating Certificate ........................................................................................ 43
8.0 COMPLIANCE WITH THE CARS REQUIREMENTS ................................................................... 43
9.0 CONTACT OFFICE ....................................................................................................................... 45
Fatigue Risk Management System Assessment Guide
1.0 INTRODUCTION
1.1 Purpose
(1) This assessment guide contains all the information needed to set up a FRMS assessment
protocol for a certificate holder. It includes the process outline to conduct an assessment. Each
step is summarized and the relevant charts and tables are included.
(2) This guide should be used to set up the assessment—it has the master protocol, which is
modified according to TC intelligence and past assessment history. The expectations with their
associated questions are included along with the methods to develop observations and apply the
measurement criteria. The guide concludes with the evaluation methodology and the TC scoring
system.
1.2 Applicability
This document is applicable to Transport Canada Civil Aviation (TCCA) Headquarters and
Regional personnel.
1.3 Description of Changes
Not Applicable.
2.0 REFERENCES AND REQUIREMENTS
2.1 Reference Documents

It is intended that the following reference materials be used in conjunction with this document:
(a) TP 14572E: FRMS for the Canadian Aviation Industry;
(b) TP 14573E: FRMS for the Canadian Aviation Industry: Fatigue Management Strategies
for Employees;
(c) TP 14574E: FRMS for the Canadian Aviation Industry: Employee Training Assessment;
(d) TP 14575E: FRMS for the Canadian Aviation Industry;
(e) TP 14576E: FRMS for the Canadian Aviation Industry: Policies and Procedures
Development Guidelines;
(f) TP 14577E: FRMS for the Canadian Aviation Industry: Fatigue Audit Tools;
(g) TP 14578E: FRMS for the Canadian Aviation Industry: Trainer's Handbook;
2.2 Cancelled Documents
Not applicable.
2.3 Definitions and Abbreviations
The following definitions and abbreviations are used in this document:
(a) Accountable Executive means the individual responsible for operations or activities
authorized under the certificate and accountable on their behalf for meeting the
requirements of the Canadian Aviation Regulations (CARs). The Accountable Executive
must have [full] control of the financial and human resources that are necessary for the
activities and operations authorized under the certificate.
(b) CAD means Civil Aviation Directives.
(c) CARs means Canadian Aviation Regulations.
(d) Error means a safety-critical event that does not result in equipment damage, injury or
death, but could potentially do so in different circumstances.
(e) Fatigue means an increased level of sleepiness associated with impaired cognitive
and/or physical functioning and, as a consequence, an elevated risk of error or accident.
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For the purposes of this policy, fatigue is due primarily to increased duration of
wakefulness and/or reduced duration of sleep.
(f) Fatigue Audit means one in which an electronic or manual tool can be used to calculate
the relative sleep opportunity for an “average” individual using work schedules as the
primary data input for the audit activity.
(g) Fatigue Audit InterDyne (FAID) means a software package that calculates the relative
sleep opportunity for a hypothetical ‘average’ individual using scheduled attendance as
the primary data input. The sleep opportunity (or FAID) score at any particular time is a
weighted aggregate based on the timing and duration of work and non-work periods, the
time of day at which they occur and social and family factors influencing the propensity to
sleep. Typically the result is expressed as a score between 0—150. Scores below a
task specific threshold are generally considered to provide an adequate sleep
opportunity. Scores over the threshold are generally considered to provide a reduced
sleep opportunity and require significant additional levels of hazard control. In general
the level of control required is proportional to the degree to which the FAID score
exceeds the threshold.
(h) Fatigue Proofing Strategies means strategies to reduce the consequence of an incident
when individuals are required to work through periods of high fatigue.
(i) Fatigue Reduction Strategies means strategies to reduce the likelihood of individuals
being at risk of making a fatigue-related error while at work.
(j) FRMS means Fatigue Risk Management System.
(k) Person Responsible for the FRMS means the person(s), accountable to the Person
Responsible for Maintenance or Operations Manager, with specific responsibilities under
this document.
(l) Hazard means a source of potential error or incident that or a situation with a potential
cause to damage equipment, result in injury or death.
(m) Incident means a safety critical event that does result in equipment damage, injury or
death.
(n) Legal Entity means a person having legal personality (capable of enjoying and being
subject to legal rights and duties). A legal entity may be:
(i) a natural person, or a group of natural persons
(ii) an incorporated organization or association, or a group of such companies or
associations
(iii) a body corporate or politic created by statute
(o) Non-work related causes of fatigue means factors contributing to a state of fatigue for
which an individual employee is primarily responsible.
(p) Organization means a council, an individual, a company or an organization, and is used
generically.
(q) Operator means the same as “organization” .
(r) Owner means the legal entity holding the Civil Aviation Document (CAD).
(s) Policy means the operator’s FRMS policy and procedures document.
(t) Recovery sleep means the sleep achieved away from the workplace enables the
individual to recuperate from the work period and begin to pay back any sleep debt
accumulated while on shift.
(u) Regulator means Transport Canada.
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(v) Risk means a calculation of consequence (potential loss) and likelihood

(probability/frequency) of a potential incident.
(w) Shift work means any work schedule that requires the individual to work at night
(between 2100hrs and 0700hrs), in the afternoon/evening (after 1700hrs), weekend work
(Saturdays/Sundays), very early hours (pre 0600hrs starts), or working shifts longer than
8 hours (including managers on open contracts with unspecified hours if they take work
home, come in early and go home late, are on call and carry a pager they never turn off).
(x) Sleep means a reversible behavioural state of perceptual disengagement from, and
unresponsiveness to the environment.
(y) Sleep Apnea means a respiratory sleep disorder that causes multiple awakenings during
sleep and, as a consequence, reduced recuperative value for sleep and increased levels
of fatigue. In severe cases it has also been associated with significant cardiovascular
disease and long-term health problems.
(z) Sleep debt means when an individual does not achieve adequate restorative sleep. A
sleep debt can accumulate over a period of days of inadequate sleep. This debt may
result in impaired performance, reduced alertness and higher levels of sleepiness and
fatigue. A sleep debt can only be repaid with recovery sleep.
(aa) Sleep deprivation means loss of sleep that can occur either acutely (total night’s sleep
loss) or partially (some sleep lost each night over a period of nights). Both result in
reduced levels of alertness and performance.
(bb) Sleep duration means the period between sleep onset time and wake up time, less
awakenings.
(cc) Sleep inertia means the delayed impairment effects of sleep on cognitive performance
immediately following waking. The main effects of sleep inertial normally dissipate after
approximately 20 minutes.
(dd) Sleep opportunity means the time within a 24-hour period that a person has available
for sleep. Hours of work, together with commute times, primarily dictate the duration of
sleep opportunity, and the timing and type of work will dictate whether the sleep
opportunity is regular, irregular, predictable or unpredictable.
(ee) Sleep length means the total amount of sleep obtained during each sleep period.
(ff) SMS means Safety Management System.
(gg) Sufficient sleep means that the average person requires 5 hours sleep on a once-off
basis, and 6 hours sleep on a recurring basis per 24-hour period before experiencing
fatigue-related performance decrements.
(hh) TC means Transport Canada.
(ii) Work-related causes of fatigue means factors contributing to a state of fatigue for
which the organization is primarily responsible.
3.0 BACKGROUND
3.1 Introduction
(1) The Fatigue Risk Management System (FRMS) Assessment Protocol is the primary assessment
reference for delegated officers. The protocol covers the components and elements of the Civil
Aviation FRMS model. Expectations have been developed for each element with associated
questions and evaluation criteria based on the Civil Aviation Regulations (CARs).
(2) This Assessment Guide contains the master protocol. It is to be used in support of assessment
activity by adding past assessment data, and current Transport Canada (TC) intelligence for any
certificate holder to generate a case-specific protocol.
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(3) A case-specific protocol is unique to the organization being assessed and will vary depending on
the current FRMS regulatory framework.
4.0 FRMS ASSESSMENT PROCESS
(1) The FRMS Assessment Protocol has been developed to give TC a tool for systematically
evaluating the effectiveness of FRMS in civil aviation approved organizations. It is not meant to
be an inspection or compliance audit, but rather, the assessment focuses on the effectiveness
and efficiency of a management system and makes judgments on its performance.
(2) The FRMS assessment is supported by the relevant CARs. A five component FRMS model with
associated elements forms the basis of the Protocol. TC has developed the protocol which
comprises a set of defined expectations for each component and element. The expectations,
along with a set of accompanying questions for each expectation, form the master protocol for the
FRMS assessments.
(3) It is anticipated that the master protocol will change as the CARs evolve and experience in using
the protocol is gathered. The primary steps in the assessment process are detailed in the
following sections of the FRMS Assessment Process, as shown in figure 1.
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Figure 1
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4.1 Determine Assessment Scope

(1) The scope of an assessment is determined by:
(a) The scope of operations of the certificate holder, i.e. maintenance or operations. that
determines which parts of the CARs are applicable.
(b) Full-scale assessment or follow-up from a full-scale assessment.
(c) Intelligence on the certificate holder—changes in the type of flying they do, complaints
from employees or other operators, evidence of fatigue-related errors, incidents or
accidents, etc.
(2) This information will set the extent of the assessment (see note) and from this, the time needed
and the team size. The modified master protocol is called a case-specific protocol. It should be
noted that there is no expectation that an organization’s FRMS mirrors that of TC. However, it
must contain all of the elements required to achieve the minimum level of regulatory compliance.
Note:
As the assessor becomes confident that the organization’s FRMS is operating
effectively, the assessor may choose to audit only parts of the organization’s
FRMS, rather than looking over evidence of all components in detail. For example,
rather than looking at a whole year of rostering data, they may choose to only look
at one month, or reports of roster analyses where inadequate sleep opportunity has
been allocated, and the actions taken as a consequence.
4.2 Certificate Holder under Review
The Certificate Holder under review is determined in accordance with the Frequency of Inspection
Policy Document, in line with the broader SMS (as specified within the SMS Implementation
Guide [TP 14343]), or as a result of cause.
4.3 Pre-Site Visit Documentation
(1) Once the need for an assessment has been determined by the Convening Authority, the scope is
set, the team is collected and the certificate holder is notified so that the actual assessment can
commence.
(2) The documentation review will take place two months in advance of the physical assessment. All
policies, procedures and supporting documentation will be requested from the assessee.
(3) The Assessment Manager will determine the required documents that must be present and the
certificate holder will send these documents to TC for review. FRMS assessments will not
proceed beyond this point until all required documentation is in place. The Assessment Manager
will make no more than three requests for missing documentation before the organization is
deemed non-compliant with the FRMS requirements.
4.4 Site(s) Visit
(1) Once the document review is complete, the Assessment Manager will set up the site visit(s) at
which the following three reviews will be conducted for the purpose of gathering evidence:
(a) Site walk through
(b) Interviews with personnel
(c) Document review (this review assures that not only is it in place but that it reflects what
actually takes place). It will also include a sampling of documentation such as fatigue-
related reports to ensure that the internal processes are effective.
(2) This is an iterative process and reviews a) to c) can be revisited as more information comes to
light.
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4.5 Observations
During the site visit, each assessment team member should take notes throughout the review
process. The assessment team members will then compare their notes for each expectation and
make observations about the FRMS element measurement table. The elements are grouped
according to FRMS component.
4.6 Apply Measures
The observations for each of the elements in the organization’s FRMS are then compared to the
measurement criteria. These can be found in the evaluation section (section 6) of this guide.
The resulting measure is then placed in the FRMS element measurement table. The elements
are grouped according to FRMS component.
4.7 Rollup
The results of the FRMS element measurement table are used to develop a measurement for
each component. This in turn is placed in the FRMS component measurement table, which acts
as a rollup for the entire assessment. The measures are then compared against the TC
assessment guidelines. This will determine if the certificate holder is meeting the FRMS CARs,
and is demonstrating an effective FRMS. Certificate removal or re-visit schedules are also
determined from these guidelines.
4.8 Assessment Report
The assessment report will be written, reviewed, approved by the convening authority and
delivered within 30 days. The results must be acted upon within the time constraints given in the
assessment guidelines. These can be found in Section 5
5.0 MASTER PROTOCOL
This protocol has been organized in four parts: A—framework, B—expectations, C—questions,
and D—criteria.
5.1 FRMS Framework
(1) The master protocol framework is outlined in Table A. This follows the same structure as the TC
FRMS model, which is outlined in guidance document TP 14575E. It has five components and
corresponding elements, with component ‘0’ representing the overall FRMS.
(2) Expectations for the protocol elements are used in the preparation of assessment observations,
firstly by focusing information gathering efforts (be it through review of documentation or through
interviews) and secondly by guiding the analysis of collected information.
Table A—FRMS Assessment Protocol Framework
Component Element
0. Fatigue Risk Management System
1. Fatigue Risk Management Plan 1.1 Fatigue Risk Management Policy
1.2 Roles, Responsibilities & Employee Involvement
1.3 Communication & Consultation
2. Fatigue Risk Management Controls 2.1 Work Hours & Sleep Opportunity
2.2 Personal Fitness for Duty—Prior Sleep and Wake
Personal Fitness for Duty—Symptoms and Behaviours
2.4 Fatigue Proofing Strategies
3. Fatigue Risk Management Oversight 3.1 Hazard Identification & Reporting Processes
3.2 Investigation and Analysis
3.3 Risk Management
4. Training 4.1 Training, Awareness and Competence
5. Documentation 5.1 Identification and Maintenance of Applicable Regulations
5.2 FRMS Documentation
5.3 Records Management
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5.2 FRMS Expectations

The FRMS Master Protocol includes all of the expectations for the FRMS components and
elements. The expectations are detailed in Tables B0 to B5. The expectations are gathered from
the CARs, guidance documents and industry best practices. Where the guidance material and
industry best practices exceed the CARs requirement, then bonus points are awarded to the
organization being assessed. This is clarified in the TC scoring detail found in Table E.
Table B0—Fatigue Risk Management System

Component 0. Fatigue Risk Management System
Element
Expectations
• A Fatigue Risk Management System with defined components is established, maintained and
adhered to.
• A single FRMS is established for holders of multiple operator’s certificates with integrated operations.
• The FRMS is coordinated with the FRMS of organizations providing services.
• The FRMS is appropriate to the size and complexity of the organization.
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Table B1—Fatigue Risk Management Plan

Component 1. Fatigue Risk Management Plan
Element 1.1 Fatigue Risk Management Policy
Expectations
• A fatigue risk management policy is in existence.
• The organization has based its FRMS on the fatigue risk management policy.
• The fatigue risk management policy is appropriate to the size and complexity of the organization.
• The fatigue risk management policy states the organization’s intentions, management principles and
commitment to continuous improvement in the safety level.
• The fatigue risk management policy is approved by the accountable executive.
• The fatigue risk management policy is promoted by the accountable executive.
• The fatigue risk management policy is reviewed periodically.
• The fatigue risk management policy includes a commitment to involve personnel at all levels in the
establishment of the FRMS.
• The fatigue risk management policy is communicated to all employees with the intent that they are
made aware of their individual fatigue risk management obligations.
• There is a clear declaration of commitment to managing fatigue related risk.
• Senior Management has a clear commitment to managing fatigue related risk.
• Senior Management demonstrates their commitment to managing fatigue related risk through active
and visible participation in the FRMS.
• The policy is included in key documentation and communication media.
• Senior managers clearly articulate the importance of safety when addressing organizational
personnel.
• Verification that personnel have understood the message.
• Senior executives have made a commitment to the development and ongoing improvement of the
FRMS.
Element 1.2 Roles, Responsibilities and Employee Involvement
Expectations
• A person has been appointed to manage the operation of the FRMS.
• The person managing the operation of FRMS fulfils the required job functions and responsibilities.
• Safety authorities, responsibilities and accountabilities are promulgated to all personnel in key
documentation and communication media.
• All personnel understand their authorities, responsibilities and accountabilities in regards to all fatigue
risk management processes, decisions and actions.
• Safety authorities, responsibilities and accountabilities of personnel and partners at all levels of the
organization are defined and documented.
• The role of Certificate Holders, Applicant and Delegate is defined where applicable.
• There is clear evidence that the accountable executive understands that he or she has ultimate
responsibility for safety within the organization.
• The accountable executive demonstrates their commitment to safety within the organization on a
daily basis.
• There are documented organizational diagrams, where applicable, and job descriptions.
• There is a logical flow within organizational authorities, responsibilities and accountabilities for
managing fatigue related risk.
• Fatigue risk management imperatives are clearly described in senior management duties and
responsibilities.
• Senior management recognizes the significance of contributions from all levels of the organization for
the establishment and maintenance of the system.
• Employee involvement and consultation arrangements are documented.
• There is evidence that FRMS procedures have penetrated all levels of the organization
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Element 1.3 Communication and Consultation

Expectations
• There are communication processes in place within the organization that permit the FRMS to function
effectively.
• Communication processes are commensurate with the size and scope of the organization (written,
meetings, electronic, etc.).
• FRMS information is established and maintained in a suitable medium that provides direction in
related documents.
• There is a process for the dissemination of fatigue risk management information throughout the
organization.
• There is a means of monitoring the effectiveness of the process for disseminating fatigue risk
management information within the organization.
• Organization wide, uncomplicated, reciprocal communications related to fatigue issues are plainly
evident.
• All areas, including out-stations and outsource functions, are included in the communication network
of the organization.
• There is an established means of inter-departmental communication to spread information on FRMS
related matters.
• There exists a formal means of communicating with experts in FRMS so that advice can easily and
quickly be obtained by personnel. The documentation should indicate where these experts could be
located.
• All personnel are informed as to who is their primary contact for aviation fatigue related matters.
• There is a process for communication strategy that includes electronic communication, frequent
meetings, FRMS award systems, employee recognition system, FRMS bulletins, etc.
• There is a process for sharing fatigue related information with outside sources that might be impacted
by this information.
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Table B2—Fatigue Risk Management Controls

Component 2. Fatigue Risk Management Controls
Element 2.1 Work Hours & Sleep Opportunity
Expectations
• Work schedules and rosters are planned and recorded for easy access by the organization,
employees and TC. Controlled copies are kept on file in chronological date order by a responsible
manager.
• Work schedules and rosters are recorded in a manner that is easy to understand by the organization,
employees and TC.
• Actual work hours are recorded and are easily accessible by the organization, employees and TC.
They are simply coded for ease of understanding. Records should include the employee name, type
of work being performed (e.g. trip log, type of maintenance duties, etc.), start and finish time of shift,
and the date. Controlled copies of actual work hours are kept on file in chronological order by a
responsible manager.
• The organization has a validated process or system for ensuring that both planned and actual work
hours provide sufficient sleep opportunity for employees.
• All planned work schedules and rosters are analyzed for sleep opportunity prior to releasing them to
employees.
• A sample of worst-case actual work hours are analyzed for sleep opportunity at minimum on a
monthly basis (see note).
• Reporting systems and required actions upon discovering insufficient sleep opportunity within a given
roster are clearly defined.
• Employees are provided with guidelines of what they are expected to do if their shift runs over their
rostered period to ensure they still obtain sufficient sleep opportunity.
• The process or system for assessing sleep opportunity is reviewed on a regular basis to ensure it is
operating effectively.
• Employees are consulted about work schedules and rosters. Names and dates of those present
during the consultation are recorded and kept on file.
• The organization risk manages maximum amounts of work performed by any employee.
• The organization has a program that ‘flags’ rosters, schedules and actual work hours that have
provided employees with insufficient sleep opportunity.
• There is evidence of reports that have been generated and circulated to relevant managers and
employees when actual work hours were shown to have provided insufficient sleep opportunity.
• There is a management process in place to ensure that all casual employees and contractors are
obtaining sufficient sleep opportunity.
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Element 2.2 Personal Fitness for Duty—Prior Sleep and Wake

Expectations
• The organization has a set of validated parameters defining minimum sleep and maximum wake
thresholds required for the average employee to be considered fit for work.
• There is evidence of employee consultation during the development and review of these parameters.
• The prior sleep and wake thresholds are reviewed periodically to determine whether they are
effective.
• Reporting systems and required actions are clearly defined for occasions when employees obtain
insufficient sleep or experience extended wakefulness. Employees are provided with guidelines of
what they are expected to do in these circumstances.
• Prior sleep and wake data is taken into account during the FRMS review and audit process.
• Reports of insufficient sleep are dealt with in a just manner.
• The organization has an employee assistance program in place to refer employees who consistently
have trouble obtaining sufficient sleep.
• Employees actively discuss action plans with a supervisor prior to commencing any work after
obtaining insufficient sleep.
• The organization documents actual sleep records for all employees on a regular basis for review and
audit purposes.
• The organization has provided easy reference tools for employees to determine whether they have
obtained sufficient sleep.
Element 2.3 Personal Fitness for Duty—Symptoms and Behaviours
Expectations
• The organization has provided easy reference tools for employees to assess fatigue-related
symptoms and behaviours.
• Reporting systems and required actions are clearly defined for occasions when employees exhibit
fatigue-related symptoms, or observe fatigue-related symptoms in a colleague.
• Reports of fatigue-related symptoms and behaviours are dealt with in a just manner.
• Fatigue-related symptom and behaviour data is collected from employees on a periodic basis for
review and audit purposes.
• Employees actively discuss action plans with a supervisor prior to commencing any work when
experiencing significant fatigue-related symptoms and behaviours.
• Peer- and supervisor-monitoring for fatigue-related symptoms that may indicate performance
impairment is actively promoted within the organization.
• The organization has a sleep-disorder screening program in place for employees who exhibit fatigue-
related symptoms and behaviours on a regular basis.
Element 2.4 Fatigue Proofing Strategies
Expectations
• The organization has a set of clearly defined fatigue proofing strategies for use by employees when
experiencing mild or moderate levels of fatigue.
• There is evidence of employee consultation in defining the use of fatigue proofing strategies.
• The availability of fatigue proofing strategies is decided using a risk-based process.
• Employees receive competency-based training about the use and application of fatigue proofing
strategies.
• Fatigue proofing strategies are periodically reviewed to determine their effectiveness.
• The organization has quiet, temperature controlled napping facilities available for employees.
• The organization has a napping policy, describing where and when to nap, as well as the caution
required when suffering from sleep inertia.
• The organization provides individual assistance to employees who regularly suffer from fatigue and
require regular use of fatigue-proofing strategies.
• The organization consults fatigue risk management experts to discuss the effectiveness of fatigue-
proofing strategies in different circumstances.
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Note:
The most extreme work hours should be selected and analyzed using fatigue
modeling software. Examples of extreme work hours would include long work
shifts, more than 2 night shifts worked in a row, more than 2 early morning starts in
a row, breaks of 12 hours or less between shifts, long blocks of shifts and few days
off. If these analyses indicate that sufficient sleep opportunity was provided, with a
fatigue score within an appropriate pre-defined range, it can be assumed that the
remainder of work shifts will also be compliant. If any of the analyses indicate
insufficient sleep opportunity was provided, the organization should have
documented actions to prevent reoccurrence, and further analyses of other
recorded work hours should be undertaken to determine the extent of the problem.
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Table B3—Safety Oversight

Component 3. Safety Oversight
Element 3.1 Hazard Identification & Reporting Processes
Expectations
• The organization has a non-punitive FRMS reporting system. Employees are encouraged to report
any fatigue-related hazard or event without fear of unfair retribution.
• The organization has a process or system that provides for the capture of internal information
including fatigue-related hazard identification, fatigue occurrences, incidents, accidents or other data
relevant to the FRMS.
• The reporting system is simple, accessible and commensurate with the size of the organization.
• Reports are reviewed at the appropriate level of management.
• There is a feedback process to notify contributors that their reports have been received and to share
the results of the analysis.
• There is a process in place to monitor and analyze trends documented.
• Corrective and preventative actions to respond to event analysis.
• The organization has a process in place to ensure confidentiality as requested.
• The organization has planned self-evaluation processes, such as regularly scheduled reviews,
evaluations, surveys, operational audits and assessments.
• The organization has identified primary sources of internal information for fatigue risk assessment,
including reports from employees, accident and incident data, performance on flight data monitoring
programs (FDM) or Line Operations Safety Audits (LOSA), reports of fatigue-related symptoms and
behaviours, individual sleep and wake data from employees, and analysis of rosters and actual work
hours.
• The range and scope of fatigue related hazards, occurrences or deficiencies that must be reported
are explained and defined.
• There is a process to ensure that information contained in reports and evaluations is validated for
accuracy prior to analysis.
• All reports are subjected to a risk analysis process to determine the extent and priority of further
action.
• Personnel invited in its reporting process are empowered to suggest corrective actions.
• The reactive report form(s) is (are) simple, standardized and accessible across the organization.
• There is a process to ensure that information is received from all areas of the organization within the
scope of the FRMS.
• There are data collection processes throughout the safety critical areas of the organization to permit
organization wide analysis of fatigue risk management issues.
• There is a process in place to investigate and analyze reported events.
• Corrective and preventative actions are generated in response to hazard and event analysis.
• Participation in industry operational and fatigue risk management activities such as conferences,
symposia and other fatigue-related meetings is a priority.
• The organization conducts formal hazard analyses for:
- Introduction of new shift/roster systems
- Introduction of new long range or ultra long range operations
- Long duty hours for maintenance personnel
- Changes in manning for high-risk tasks
- Any work being performed between 2100hrs and 0600hrs
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Element 3.2 Investigation and Analysis

Expectations
• There are procedures in place for the conduct of investigations.
• Measures exist that ensure all reported occurrences and deficiencies are investigated.
• There is a process to ensure that occurrences and deficiencies reported are analyzed to identify
contributing and root causes.
• Corrective and preventative actions are generated in response to event investigation and analysis.
• The organization has a staff of technically competent investigators commensurate with the size and
complexity of its operation.
• When identifying contributing and root causes, the organization considers multiple aspects of how
fatigue may have been related.
• Results of the analysis are communicated to the responsible manager for corrective/preventative
action and to other relevant managers for their information.
• All reactive reports are subjected to a risk analysis process to determine the extent and priority of
further action.
• Responsibility and timelines are established for each corrective action.
• There is a process in place to monitor and analyze trends.
• Where fatigue is found as a contributing factor or root cause of an error, incident, or accident,
Investigation results are collated and shared with the wider aviation community.
Element 3.3 Risk Management
Expectations
• There is a structured process for the assessment of fatigue-related risk associated with identified
hazards, expressed in terms of severity, level of exposure and probability of occurrence.
• There are criteria for evaluating risk and the tolerable level of risk the organization is willing to accept.
• The organization has risk control strategies that include corrective/preventative action plans to
prevent recurrence of reported occurrences and deficiencies.
• The organization has a process for evaluating the effectiveness of the corrective/preventive measures
that have been developed.
• Corrective/preventive actions, including timelines, are documented.
• There is a risk classification system that guides the organization in developing fatigue related risk
control strategies.
• The organization uses its risk assessment results to develop best practice guidelines that it shares
with the industry.
• The results of the risk management program are built into the organization’s methods and
procedures.
• The organization is able to demonstrate the risk management process through records and is able to
show periodic review documentation.
• The organization runs formal fatigue risk management workshops with all personnel performing
safety-critical tasks.
• The organization has developed key performance indictors to evaluate their FRMS and determine
whether fatigue-related risk has increased or decreased over periodic risk assessments.
2008-10-15 17 of 45 SI SUR-007 Issue 01

Table B4—Training
Component 4. Training
Element 4.1 Training, Awareness and Competence
Expectations
• The organization has a Fatigue Risk Awareness training program in place that covers
- A basic overview of sleep, why we need it, and what happens if we don’t get it;
- Definition of fatigue and fatigue-related risk;
- Examples of the consequences of fatigue, including performance, health and lifestyle
factors;
- An overview of the reasons why fatigue-related risk needs to be managed—including
legal liabilities;
- Personal fatigue risk management strategies—such as sleep hygiene, lifestyle, diet,
stimulants, exercise and relaxation.
• The organization has a competency-based Fatigue Risk Management training program in place that
covers
- A synopsis of the information covered in fatigue risk awareness training;
- An overview of the organization’s FRMS;
- Organizational and individual responsibilities in managing fatigue-related risk;
- A detailed explanation of each of the FRMS controls and management strategies;
- Fatigue-Reporting systems and expectations;
- Fatigue-risk management problem shooting (see note).
• There is a documented process to identify training requirements so that personnel are competent to
manage fatigue related risk.
• There is a validation process that measures the effectiveness of training.
• The training includes initial, recurrent and update training as applicable.
• The organization’s fatigue risk management training is incorporated into indoctrination training upon
employment.
• Training includes human and organizational factors.
• There is a formal and objective training needs analysis.
• Training requirements are documented for each area of activity within the organization, including
areas where training requirements are not defined by regulations. The attendance of symposiums
outside of FRMS should also be considered.
• A training file is developed for each employee, including management, to assist in identifying and
tracking employee training requirements and verifying that the personnel have received the planned
training. This file should be completed in accordance with the training guidelines that are developed.
• Training needs are included as part of the performance appraisal process.
• Management recognizes and uses informal opportunities to instruct employees on fatigue risk
management.
• Continued occupational competency is maintained.
• Evidence exists that management supports fatigue risk management training initiatives.
• The training exercises and methods are kept current to reflect new techniques, technologies, results
of investigations and corrective actions and regulatory changes.
• The organization keeps an up-to-date fatigue risk management library for employee access.
Note:
For example, introduction of sleep disorder screening, or referral to doctor upon
experience of symptoms; what will happen if multiple-fatigue-occurrence reports
are received from one person, or one work group in a short period of time.
2008-10-15 18 of 45 SI SUR-007 Issue 01

Table B5—Documentation
Component 5 Documentation
Element 5.1 Identification and Maintenance of Applicable Regulations
Expectations
• A documented procedure has been established and maintained for identifying applicable regulatory
requirements relating to the FRMS.
• Regulations, standards and exemptions are periodically reviewed to ensure that the most current
information is available.
• All pertinent technical and regulatory information is readily accessible by personnel.
• The organization has defined specific triggers that would lead to a review of the operational
documentation.
Element 5.2 FRMS Documentation
Expectations
• There is consolidated documentation that describes the FRMS and the interrelationship between all
of its elements.
• This information resides or is incorporated by reference into approved documentation, such as
DAPM/EPM, Organizational Operations Manual, Maintenance Control Manual, as applicable, and
where these approved documents are not required by regulation, the organization includes the
information in a separate, controlled document.
• Manuals or controlled electronic media are used to document the system.
• The consolidated documentation is readily accessible by personnel.
• There is a process to periodically review FRMS documentation to ensure its continuing suitability,
adequacy and effectiveness, and that changes to the organization’s documentation have been
implemented.
• The system is documented in suitable organizational media at both corporate and operational levels.
• Documentation reflects functional coordination within the management system that ensures the
organization works as a system and not as a group of separate or fragmented units.
• Documents show lines of authority, accountability and responsibility at the corporate level of
management. This documentation also indicates the authority within the Organization and the
authority granted by the regulator.
• Acceptable means of documentation include, but are not limited to, organizational charts, job
descriptions and other descriptive written material that define and clearly delineate the system of
authority and responsibility within the organization for ensuring safe operation.
• The organization has a process to identify changes within the organization that could affect
organizational documentation.
Element 5.3 Records Management
Expectations
• The organization has a records system that ensures the generation and retention of all records
necessary to document and support FRMS requirements, and is in accordance with applicable
regulatory requirements.
• The system shall provide the control processes necessary to ensure appropriate identification,
legibility, storage, protection, archiving, retrieval, retention time, and disposition of records.
• The organization has a policy that defines how long records that are not specifically required by
regulations are kept.
For each expectation, associated question(s) can be posed to gather evidence needed to assess. These
questions are shown in tables C0-C5.3 in Section 5.3.
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5.3 FRMS Questions

(1) The questions shown in relation to each expectation are meant to assist in the assessment. They
are intended for guidance only. It is not mandatory to ask all the questions. If the assessor feels
that enough information has been gathered to effectively assess the element or if a different
“open-ended” question will elicit a better response, it can be used. The assessor may also
rephrase the question if it is more comfortable to do so. It is expected that answers to any
question would lead to others not shown on this list. It is also expected that questions aimed at
determining performance with respect to one criterion may lead to information relevant to the
assessment of other criteria for either the intended component or others. Assessors will use their
experience to follow-up on information that is uncovered and apply revelations to the assessment
of FRMS components and elements as appropriate.
(2) In the Questions column of Tables C0-C5 below, the letter coding in brackets to the left of each
question indicates the level 3 expectation (from the Measurement Criteria tables following) that
the question relates to. Questions labelled BP (best practice) are aimed at level 5 criteria.
Certain questions are suggested for direction to the accountable executive, department heads
and management, and employees in general. The phrasing of these questions and their
categorization is not intended to be prescriptive. Interviewers are invited to rephrase and pose
questions as appropriate to the audience they are addressing during the site visit(s).
(3) To obtain valuable information related to the performance of the FRMS, it is recommended that,
as much as possible, questions are open ended. Where a question would lead to a yes/no
answer, the assessor may prompt the assessee by asking why/why not? Or ask for an
explanation or proof (documentation). Depending on the maturity of the FRMS, management and
employees may be able to provide case examples to support their statements.
Table C0—Questions : Fatigue Risk Management System

Element
Questions
To the accountable executive:
(A) Has a FRMS been established for your organization?
(A) How do you maintain it?
(A) How do you ensure that it is adhered to?
(BP) Are you a multiple certificate holder? If so, explain how you have established a single FRMS with
integrated operations
(B) How do you ensure that your FRMS procedures are appropriate to the size and complexity of your
organization?
To the functional department heads:

(BP) Is your organization a multiple certificate holder? If so, explain how you have integrated FRMS
activities with departments under other certificates.
(BP) How are your FRMS activities coordinated with the FRMSs of organizations providing services?
To employees:
(A) What is your understanding of your organization’s FRMS?
2008-10-15 20 of 45 SI SUR-007 Issue 01

Table C1—Fatigue Risk Management Plan

Component 1. Fatigue Risk Management Plan
Element 1.1 Fatigue Risk Management Policy
Questions
(A,C) How would you summarize your fatigue risk management philosophy and expectations from your
organization’s FRMS? Are there any particular FRMS policy initiatives with which you or your senior
management are personally identified? (show me)
(D,F) How do you communicate your FRMS performance expectations to the organization? Are there
any FRMS issues that you expect to have a significant impact on your organization’s performance?
(E) How often do you critically review the standing FRMS policy? Who is involved in this review?
(BP) How do you assess the extent to which the FRMS policy and FRMS processes are understood
within your organization? How do you measure your organization’s FRMS performance? How is the
information from these performance appraisals used?
(B) How has your FRMS policy influenced the development of your FRMS? Show me an example.
(G) Outline the organization’s commitment in managing fatigue-related risk.
(H,I) What is the organization’s policy for fatigue risk management?
(F) What expectations does your employer have with respect to you and your department’s FRMS
performance? How are these expectations communicated to you? Can you explain your role in the
development of your safety obligations and your department’s FRMS performance criteria?
(D) How do you communicate FRMS processes/obligations to personnel within your department?
How do you assess the extent to which FRMS policy and FRMS processes/obligations are understood
within your department?
(J) How are employees involved in the maintenance of the FRMS?
(G) How committed is the organization to managing fatigue-related risk? Explain.
To employees:
(F) What is your understanding of management’s expectations of you with respect to organizational
FRMS performance?
(D) How would you characterize management’s commitment to strong FRMS performance?
(BP) How does management make you aware of the relationship between the FRMS policy and
different fatigue risk management initiatives?
(J) To what extent (how) have you been involved in the establishment and review of the FRMS?
2008-10-15 21 of 45 SI SUR-007 Issue 01

Element 1.2 Roles, Responsibilities and Employee Involvement

Questions
(C,H) What do you understand your FRMS-related responsibilities to be? Are these documented
anywhere? (show me)
(B,C) Who is the person appointed to manage the operation of the FRMS within your organization?
How were they selected for this position? What do you understand their FRMS-related responsibilities to
be? Are these documented anywhere? (show me)
(F) How are personnel informed about their responsibilities under FRMS?
To the person appointed to manage the operation of FRMS:
(E,F) What do you understand your FRMS-related responsibilities to be? Are these documented
anywhere? (show me)
(C,F) What authorities, resources and support have been given to you in order to allow you to fulfill your
role as person appointed to manage the operation of FRMS for the organization? Are these supported by
documentation and actions from management? (show me)
(C) What qualification and experience do you have that justify your appointment to this position?
How confident are you in this role?
(H) What do you understand to be your FRMS-related responsibilities to be? Are they documented
anywhere?
(D) Do you feel that roles and responsibilities for FRMS management within the organization are
clearly and appropriately defined? If not, why not and where could they be sharpened?
(E) When are fatigue risk management authorities, responsibilities and accountabilities reviewed?
(BP) Can you show me a sample of job descriptions and/or an organizational diagram illustrating
FRMS responsibilities within the organization?
To employees:
(H) What do you understand your own FRMS roles and responsibilities to be?
2008-10-15 22 of 45 SI SUR-007 Issue 01

Element 1.3 Communication and Consultation

Questions
To the accountable executive and functional department heads:
(A) What communication and consultation processes or methods are in place within your
organization? Explain how these processes help your FRMS to function effectively.
(B) How often are FRMS meetings held? Who attends these meetings? Do you attend any FRMS
meetings? How often?
(C) How is FRMS related information distributed to personnel? Where and how is this recorded?
(show me)
(D) How is fatigue risk management information shared within the organization? (horizontally and
vertically throughout the organization). How do you know these methods/processes are working?
(D) How is information on the FRMS related matters shared between departments? How do you
ensure there is organizational wide, uncomplicated communications?
(BP) What mechanisms are in place that allow consultation with personnel about fatigue-related
issues? (Horizontally and vertically throughout the organization)
(BP) How do you know what the results of the consultation meetings are? How are minutes or decision
records kept? How are the results of these consultation meetings communicated to the wider employee
body?
(BP) How are all ideas, including out-stations and outsource functions included in the communications
and consultation network?
(BP) How are personnel informed as to who their primary contact for FRMS related matters is?
(BP) How are best practices identified and shared across the organization?
To employees:
(A) How do you know FRMS activities are going on within your organization? What evidence do you
see that shows FRMS is or is not working?
(B) How often are meetings held? Who attends these meetings? Do you attend any FRMS
meetings? How often?
(C) If you needed information related to fatigue risk management issues, procedures or processes,
how would you get it?
(C) How is fatigue risk management information communicated to you?
(D) How do you communicate fatigue-related information? Do you believe your opinions are heard
and acted upon?
(BP) Has there ever been a fatigue related or quality matter that you felt should be brought to the
attention of management? How did you deal with this? What response did you receive from
management?
(BP) Who is your primary contact for aviation fatigue risk management related matters? Do you feel
comfortable bringing issues to this person? (explain why/why not)
2008-10-15 23 of 45 SI SUR-007 Issue 01

Table C2—Fatigue Risk Management Controls

Component 2. Fatigue Risk Management Controls
Element 2.1 Work Hours & Sleep Opportunity
Questions:
(A) What system does your organization have in place to record planned work schedules and rosters?
(show me)
(BP) How are your work schedules and rosters coded so that everyone can easily understand them?
(B) What system does your organization have in place to record actual hours of work? (show me)
(C) Describe the process for ensuring planned work schedules and rosters provide sufficient sleep
opportunity for employees (prospective analysis).
(C) Describe the process for ensuring actual hours of work have provided sufficient sleep opportunity
for employees (retrospective analysis).
(D,E) In what time frame are planned work schedules and rosters, as well as actual work hours analyzed
for providing sufficient sleep opportunity?
(F) What actions are taken if your analyses indicate that insufficient sleep opportunity has been
provided? (for both prospective and retrospective analyses)
(G) How are your analyses of sleep opportunity, and any actions taken as a consequence of analyses,
recorded and documented? (show me)
(H) Where actual hours of work vary significantly from planned hours of work, how do you ensure that
employees are provided with sufficient sleep opportunity?
(I) What checks and balances do you have in place to ensure the processes you have for ensuring
sufficient sleep opportunity are effective?
(BP) What role do employees have in developing and revising work schedules and rosters?
To employees:
(H) How often do your actual work hours vary from your planned work hours?
(B) How do you inform your supervisor/manager of your actual work hours (versus your planned work
hours)?
(C) Do your work hours generally provide you with sufficient sleep opportunity?
(F) Describe the effort taken by management to ensure you are provided with sufficient sleep
opportunity in between work shifts.
(F) What actions are taken by both yourself and management, if insufficient sleep opportunity has
been provided (i.e. too little time off in between shifts)?
(BP) To what extent are you involved in work schedule and roster development and review?
Element 2.2 Personal Fitness for Duty—Prior Sleep and Wake
Questions:
(A,B) What parameters are in place to determine whether individual employees have obtained sufficient
sleep to be fit for work (Set thresholds for prior sleep and wake rules)? How did you set these
parameters?
(C) How are the prior sleep and wake rules reviewed to determine whether they are effective?
(D) What is expected of employees when they have not obtained sufficient sleep according to the prior
sleep and wake rules?
(B) What reference tools are provided to inform employees whether they have obtained sufficient
sleep?
(E) How is prior sleep and wake data collected for review and audit purposes within the organization?
To employees:
(D) How much sleep does the organization require you to obtain prior to commencing work? (prior 24
& 48 hours)
(D) What actions are you expected to take if you have not obtained sufficient sleep prior to
commencing work?
(D) Do you feel comfortable discussing your sleep with management and/or your supervisor? Why/why
not?
(F) If you are regularly having problems obtaining sufficient sleep, what actions are taken by you and
your organization?
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Element 2.3 Personal Fitness for Duty—Symptoms and Behaviours

Questions:
(A) What tools and/or processes are in place to monitor employees for fatigue-related symptoms and
behaviours?
(B) What actions are taken if an employee is observed to be exhibiting fatigue-related symptoms and
behaviours?
(C) What action is taken if an employee exhibits fatigue-related symptoms and behaviour on a regular
basis?
(D) How is fatigue-related symptom and behaviour data collected for review and audit purposes within
the organization?
(D) What checks and balances do you have in place to ensure the processes you have for ensuring
your process for observation of fatigue-related symptoms and behaviours is effective?
To employees:
(A) What are some of the major symptoms and behaviours that indicate fatigue-related impairment?
(B) What action would you take if you observed significant fatigue-related symptoms and behaviours
in yourself?
(BP) What action would you take if you observed significant fatigue-related symptoms and behaviours
in a colleague?
(C) Do you feel comfortable reporting fatigue-related symptoms and behaviours to your supervisor
and/or manager as a reason for unfitness for duty? Why/why not?
(C) If you were regularly experiencing fatigue-related symptoms and behaviours, what actions would
be taken by your organization?
Element 2.4 Fatigue Proofing Strategies
Questions:
(A) What fatigue proofing strategies are currently employed by your organization to minimize the
consequence of fatigue-related risk?
(B,C) How did you decide on these as appropriate proofing strategies for your organization?
(D) How are these strategies promoted for use amongst the employee body?
(BP) What napping facilities and policies are in place within your organization?
(C) Under what circumstances are employees permitted to use each of the fatigue-proofing strategies?
(B,E) How do you determine the effectiveness of each fatigue-proofing strategy?
To employees:
(A) What fatigue proofing strategies are promoted for you to use for reducing the consequence of
fatigue-related risk?
(BP) Are you ever allowed to nap at work? If so, at what times and where? How long should you take
to wake up from a nap before performing safety-critical work?
(A) Are there any fatigue proofing strategies you use on a regular basis? Which ones? Describe how
they assist in reducing the effects of fatigue.
(E) Are there any fatigue proofing strategies that are ineffective? Which ones? Explain why you
believe this.
(C) Under what circumstances are you permitted by management to use each of the fatigue proofing
strategies?
Table C3—Fatigue Risk Management Oversight

Component 3. Fatigue Risk Management Oversight
Element 3.1 Hazard Identification and Reporting Processes
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Questions:
To the accountable executive and upper management:
(A) What consequences are there for employees who report fatigue-related hazards or events? How
is this determined?
(B,D) How does the organization ensure that fatigue-related hazards, occurrences, incidents, accidents
and other data relevant to FRMS are captured? What is done with this data after it has been collected?
(C,D) Is there a reporting process that captures fatigue-related information such as hazards,
occurrences, incidents and accidents? Please explain how this process works and why it is appropriate
for your organization.
(BP) Show me the report form(s). Who has access to these forms? What do employees have to do to
get (and then submit) these forms?
(D) Do you review reports? How do you determine which reports to review? On what basis do you
pass on the reports to other levels of management?
(D) How do employees know if their reports have been read or heeded?
(BP) Is there a process in place to investigate and analyze reported events? Explain.
(H) Explain how FRMS data is analyzed, trends identified and monitored.
(J) Explain the data collection processes throughout the safety critical areas of the organization. How
do these processes permit organization wide analysis of fatigue-related issues?
(K) Explain the standard procedure for response to fatigue-related event analysis What is the
timeline for these actions? How does this impact the future operations of the organization?
(H) Explain how the organization evaluates its own FRMS. Can you identify planned self-evaluation
processes? How often are these processes conducted?
(BP) What are your criteria for evaluating risk? What is considered a tolerable level of risk and how is
this level determined?
(B) How are hazards, incidents, accidents and other data relevant to FRMS captured within your
department? What type of information, reports or data are collected to proactively identify safety
concerns, or to investigate whether fatigue was a contributing factor to incidents or accidents? What is
done with this data once collected?
(D) How are reports reviewed? On what basis do you pass on reports to other levels of
management?
(E) How do employees know if their reports have been read or heeded?
(F) Is there a process in place to investigate and analyze fatigue occurrences? (see note) Explain.
(F) Is there a process in place to monitor and analyze documented fatigue occurrences? Explain.
(K) Is there a process in place to investigate and analyze reported events? Explain.
(F) Is there a process in place to monitor and analyze trends documented? Explain.
(L) What actions are taken in response to event analysis? If a trend is revealed, what type of
mitigation actions are taken? How does this affect future operations within your department?
(H) Explain how the effectiveness of FRMS is evaluated within your department. Can you identify
planned self-evaluation processes? How often are these processes conducted?
(BP) Are you aware of specific criteria for evaluating risk or identified fatigue-related hazards? How
does this relate to the level of risk you are willing to accept?
To employees:
(B,C) Explain how you would report a fatigue-related occurrence, concern, incident, accident,
occurrence, or safety concern. How is feedback given to those who report? Can you give me an
example where results of incident analyses were shared?
(BP) Are you comfortable reporting incidents, accidents and occurrences? Explain
(BP) Can you show me the form you would fill out in making this report and explain the process for
submitting this report?
(BP) Is it worth your time to communicate safety concerns and report fatigue-related occurrences?
Explain why (or why not) you make use of the reporting process.
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(K) Do you ever feel that fatigue-related patterns in occurrences, concerns, accident or incidents go
unnoticed? Does management heed your fatigue-related safety concerns and act accordingly? How
quickly?
(K,L) What does your manager do when a fatigue-related concern is raised? What do they do if there
has been an incident or accident? Can you give me an example of actions taken in response to a fatigue-
related safety event or identified concern? Did normal operating procedures change as a result of this
event? How?
(L) Do you feel that adequate corrective and preventive actions are generated in response to event
analysis? Are you confident that management is given the power and resources to take appropriate
actions when required? Explain how these powers are exercised.
(BP) How do you assess risk in your job? Are you aware of specific criteria for acceptable levels of
risk to your work or that of your work tem?
Note:
A fatigue occurrence is any instance where an employee reports their performance
may be impaired due to fatigue. This may be based on work hours, insufficient
sleep or experience of behavioural symptoms.
Element 3.3 Investigation and Analysis

Questions:
(A) Explain how investigations are conducted in response to fatigue related occurrences and
deficiencies.
(B) What measures exist to ensure all reported fatigue occurrences and deficiencies are analyzed?
(C) How do you ensure that fatigue related occurrences and deficiencies are reported and analyzed?
What is the goal of this analysis?
(D) Explain what and how actions are taken in response to event investigation and analysis.
(E) Explain how you select personnel to conduct investigations.
(F) What data is collected to analyze whether fatigue was a potential root cause to events?
(G,I) How are investigation analysis results communicated to appropriate managers? How are
appropriate managers identified? How do they decide what action to take?
(H) Describe the risk analysis process you take to determine the level of action required upon receipt
of investigation analysis results.
To employees:
(A) Explain how investigations are conducted within your department when fatigue related
occurrences and deficiencies are identified or reported.
(B) What measures are taken by management to ensure all reported fatigue related occurrences and
deficiencies are investigated?
(B) What measures are taken by staff to ensure all reported fatigue-related occurrences and
deficiencies are investigated?
(C) How do you know that occurrences and deficiencies are reported and analyzed? What are the
goals of this analysis? What role does the staff play in the analysis of fatigue-related occurrences and
deficiencies?
(D) Do you feel that adequate corrective and preventive actions are generated in response to event
investigation and analysis? Are you confident that management is given the power and resources to take
appropriate actions when required? Can you give me an example of changes to procedures or work
practices initiated as a result of an identified fatigue-related concern or hazard?
2008-10-15 27 of 45 SI SUR-007 Issue 01

Element 3.4 Risk Management

Questions:
To the accountable executive and upper level management:
(A) What is the process for the assessment of fatigue-related risk associated with identified hazards?
How is risk expressed in terms of severity, level of exposure and probability of occurrence?
(B) What are your criteria for evaluating risk? What is considered a tolerable level of risk and how is
this level determined?
(C) Outline the organization’s risk control strategy. What corrective/preventive action plans are in
place to prevent recurrence of reported occurrences and deficiencies?
(D) How is the effectiveness of implemented corrective/preventive measures evaluated? What
actions might be taken as a result of an unsatisfactory evaluation? What sort of timeline is associated
with conducting this evaluation and the implementation of further corrective actions?
(E) How are corrective/preventive actions documented? What type of information is included in this
documentation? (show me)
(F,G,H) Outline the organization’s fatigue risk classification system, and how it contributes to the ongoing
development of the FRMS.
(I) Describe how risk management processes are documented and recorded within your
organization.
(B) Are you aware of specific criteria for evaluating risk of identified hazards? How does this relate
to the level of risk you are willing to accept?
(C) Outline the risk control strategy employed to your department. What corrective/preventive action
plans are in place to prevent recurrence of reported occurrences and deficiencies? How does this relate
to the strategy and plans of the organization as a whole?
(D) How do you evaluate the effectiveness of implemented corrective/preventive measures? What
actions might you take as a result of an unsatisfactory evaluation? What sort of timeline is associated
with the conduct of this evaluation and the implementation of further corrective actions? What are the
critical factors affecting this timeline?
documentation? (show me) How often and for what purpose do you reference this documentation? How
and when is this documentation shared with upper level management or other departments?
To employees:
(B) Are you aware of specific criteria for evaluating risk of identified hazards? How does this relate to
the level of risk you are willing to accept?
(C) What approach do management take for the control of risk within your work environment? What
planning actions are taken by management to prevent recurrence of reported occurrences and
deficiencies? How are you involved in this process?
(D) What evidence do you see that indicates the effectiveness of implemented corrective/preventive
measures? What sort of timeline is associated with the conduct of this evaluation and the implementation
of further corrective actions?
documentation? (show me) How are you involved in the maintenance of this documentation? How often
and for what purpose do you reference this documentation?
2008-10-15 28 of 45 SI SUR-007 Issue 01

Table C4—Training
Component 4. Training
Element 4.1 Training, Awareness and Competence
Questions:
To the accountable executive and upper management:
(C) Explain how training requirements are identified to ensure that personnel are competent in
managing fatigue-related risk. Is this process documented? (show me)
(D) How is the effectiveness of FRMS training evaluated?
(E) When do employees receive FRMS training? What follow-up training on FRMS is provided by the
organization and how do you determine who receives this training?
(F) Explain how and when FRMS training is provided to new employees.
(G) What do you consider to be human and organizational factors in the context of FRMS? Explain
how this is included in FRMS training delivered to employees at all levels.
(A) What fatigue awareness training do you have in place for employees? (Show me).
(B) What competency-based fatigue risk management training do you have in place for employees?
Show me.
(C) Are you confident in your knowledge and understanding of FRMS and your role and
responsibilities in respect to FRMS? Summarize the FRMS training you have received including the
context, timing and intensity of each session.
(E) How often is FRMS training available to your employees? How do you determine who receives
this training?
(F) What kind of FRMS training is provided to new employees? How soon after employment is it
delivered?
(F) Was FRMS in place when you joined the organization?
(if yes) How was FRMS presented to you when you joined the organization, and to what
extent was it discussed as part of orientation?
(if no) When did you first receive training about FRMS?
(G) What do you consider to be the human and organizational factors in the context of FRMS as it
affects your department? Explain how this is included in FRMS training delivered to employees in your
department.
(G) How were work environment, habits, procedures, workload and employee interaction discussed
as part of the FRMS training you received?
To employees:
(A,B) What sort of topics have you received training on in your fatigue awareness, and competency
based fatigue risk management training?
(C) Are you confident in your knowledge and understanding of FRMS and your role and
responsibilities in respect to FRMS? What kind of FRMS training have you received? What was the
context and intensity of these training session?
(E) How accessible is FRMS training information to you? Do you know how management determines
who receives training and when?
(E,F) Was FRMS in place when you joined this organization?
(if yes) How was FRMS presented to you when you joined the organization, and to what
extent was it discussed as part of orientation? Discuss any further training since that initial session. If
you wished to receive more FRMS training, how would you approach management about this issue?
(if no) When did you first receive training about FRMS?
(G) What do you consider to be human and organizational factors? Explain how this subject was
addressed in the FRMS training you received.
(G) How were your work environment, habits, procedures, workload and employee interaction
discussed as part of your FRMS training?
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Table C5—Documentation
Component 5. Documentation
Element 5.1 Identification and Maintenance of Applicable Regulations
Questions:
To management:
(B) What is the procedure for identifying applicable regulatory requirements? Show me where this is
documented.
(BP) How is pertinent technical and regulatory information accessible by personnel?
(B) How do you ensure that this documentation and information is in line with current regulations,
standards, exemptions and labour laws?
(BP) In what way does the organization participate in regulatory development activities?
To employees:
(BP) Where would you find pertinent technical and regulatory information?
(A,B) How are changes in regulatory requirements built into operations?
Element 5.2 FRMS Documentation
Questions:
(A,B) Is there consolidated documentation that describes the FRMS and the interrelationship between all
of its elements? (show me) Where else is this information located? What other documents, approved or
otherwise incorporate reference to this information? (show me)
(B) How is this documentation made available to personnel?
(D) Where can employees find FRMS information at both the corporate and operational levels? (show
me)
(F) How does documentation reflect functional coordination within the fatigue risk management
system?
(BP) How/where does documentation show lines of authority, accountability and responsibility at the
corporate level of management?
(E) What is the process for review of FRMS documentation over time?
(E) What is the process to identify changes within the organization that could affect organizational
documentation?
(BP) How do you ensure that changes to organizational documentation have been implemented?
To employees:
(A,B,BP) Where can you find an explanation of the FRMS and the interrelationships between its
elements? (show me)
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Element 5.3 Records Management

Questions:
(B) What records are necessary in support of operational and regulatory requirements?
(B) Explain how these records are generated and retained for documentation and support of
operational requirements.
(B) Explain how records are generated and retained for documentation and support of regulatory
requirements.
(B) What is the process for ensuring operational and regulatory requirements are sufficiently
supported?
(B) What are the FRMS control processes to ensure appropriate identification, legibility, storage,
protection, archiving, retrieval, retention time and disposition of records? Justify the presence of these
processes.
(C) What procedures are in place to ensure the FRMS is current, available and understood by all
relevant personnel?
(BP) How long are records, not specifically required by regulations, kept? What is the policy for retaining
records that are not specifically required by regulations?
To employees:
(B) What records are kept within your organization? Are these records sufficient to support operational
requirements?
(B) What records and/or documentation are most useful in support of your responsibilities to
operations? Is there a system in place to ensure you have or can easily obtain records and
documentation when needed?
6.0 EVALUATION
After the collection of assessment information (evidence) is complete, observations are prepared
by use of the notes taken during the assessment. The process of evaluation of the observations
makes use of FRMS element criteria outlined in Tables D0-D5.3.
6.1 Measurement Criteria
(1) Observations for each element are compared to the measurement criteria tables below. The
resulting measurement is then placed in the element measurement table shown in the
assessment guide from TC—this can be found in Table E.
(2) The roll up of the elements gives a FRMS component measurement, which when placed in a
similar table, is used to adjudge the overall assessment evaluation. This table is also found in
Table E .
(3) Section 5 gives the TC scoring rules which determine whether certificate holders meet the CARs
and the extent of follow up or other corrective action.
Table D0—Criteria : Fatigue Risk Management System

Score Criteria
1 The organization has no aspects of FRMS in place.
2 (3) less some aspects
3 A. The organization has a FRMS, which has defined components that are established,
maintained and adhered to.
B. The FRMS management system is appropriate to the size and complexity of the
organization.
4 All of (3) plus some aspects of (5)
5 The organization is a recognized leader in FRMS within the aviation industry.
A single FRMS is established for holders of multiple operator’s certificates with integrated
operations, and is coordinated with the FRMSs of organizations providing services.
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Table D1.1—Fatigue Risk Management Plan—Safety Policy

Score Criteria
1 Senior Management does no demonstrate commitment to a FRMS. Fatigue Risk
Management Policies are not well developed, and most personnel are not involved in FRMS.
3 A. A fatigue risk management policy is in existence and appropriate to the size and complexity
of the organization.
B. The organization has based its fatigue risk management system on the fatigue risk
management policy.
C. The fatigue risk management policy is approved by the accountable executive.
D. The fatigue risk management policy is promoted by the accountable executive.
E. The fatigue risk management policy is reviewed periodically.
F. The fatigue risk management policy is communicated to all employees with the intent that
they are made aware of their individual safety obligations.
G. There is a clear declaration of commitment to managing fatigue-related risk.
H. The fatigue risk management policy states the organization’s intentions, management
principles and commitment to continuous improvement in managing fatigue-related risk.
I. Senior Management have a clear commitment to managing fatigue-related risk and
demonstrates it through active and visible participation in the fatigue risk management system.
J. Personnel at all levels are involved in the establishment and maintenance of the fatigue risk
management system.
K. The policy is implemented at all levels of the organization.
L. The policy is clearly visible to all personnel and particularly throughout the safety critical
areas of the organization.
5 All of 3, plus all of the following:
The policy is included in key documentation and communication media.
Senior managers clearly articulate the importance of managing fatigue-related risk when
addressing personnel.
Verification that personnel have understood the message.
Commitment of the organization’s senior executives to the development and ongoing
improvement of the fatigue risk management system.
Table D1.2—Fatigue Risk Management Plan—Roles and Responsibilities

Score Criteria
1 No formal designation of authorities, responsibilities and accountabilities exist for the fatigue
risk management system. A management representative has not bee appointed to ensure the
FRMS is implemented. Fatigue risk management mandates are not widely disseminated and
personnel’s awareness of their role in the FRMS is limited.
3 A. A person has been appointed to manage the operation of the FRMS.
B. The person managing the operation of the FRMS fulfils the required job functions and
responsibilities.
C. Fatigue risk management authorities, responsibilities and accountabilities are promulgated
to all personnel in key documentation and communication media.
D. Fatigue risk management authorities, responsibilities and accountabilities of personnel and
partners at all levels of the organization are defined and documented. The role of the
Certificate Holders, Applicant and Delegate should also be defined where applicable.
E. There are documented organizational diagrams, including names, positions, specific FRMS
responsibilities and duties and job descriptions.
F. Fatigue risk management imperatives are clearly described in senior management duties
and responsibilities.
G. Evidence that FRMS procedures have penetrated all levels of the organization.
H. All personnel understand their authorities, responsibilities and accountabilities in regards to
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all fatigue risk management processes, decisions and actions.

Fatigue risk management authorities, responsibilities and accountabilities are reviewed after
any significant organizational change.
There is clear evidence that the accountable executive not only understands that he or she
has ultimate responsibility for fatigue risk management within the organization, but that he or
she demonstrates this commitment on a daily basis.
There is a logical flow within organizational authorities, responsibilities and accountabilities for
fatigue risk management.
Senior management recognizes the significance of contributions from all levels of the
organization for the establishment and maintenance of the system.
Employee involvement and consultation arrangements are documented.
Employee sign-off on FRMS policy and procedures document stating they have understood
and agree to apply the FRMS to their work practices.
Table D1.3—Fatigue Risk Management Plan—Communication and Consultation

Score Criteria
1 The general exchange of information throughout the organization does not permit the FRMS
to function effectively. The organizational communication network does not include all
personnel, out-stations and outsource functions.
Organizational personnel are not consulted regarding FRMS operation or review.
3 A. There are communication processes in place within the organization that permit the FRMS
to function effectively.
B. Communication processes (written, meetings, electronic, etc.) are commensurate with the
size and scope of the organization.
C. Information is established and maintained in a suitable medium that provides direction in
related documents.
D. There is a process for the dissemination of fatigue risk management information throughout
the organization and a means of monitoring the effectiveness of this process.
Organization wide, uncomplicated, reciprocal communication and consultation related to
fatigue risk management issues are plainly evident.
All areas, including out-stations and outsource functions, are included in the communication
and consultation network of the organization.
There is an established means of inter-departmental communication to spread information on
FRMS related matters.
There exists a formal means of communicating with experts in FRMS so that advice can easily
and quickly be obtained by personnel. The documentation should indicate where these
experts could be located.
All personnel are informed as to who is their primary contact for fatigue related matters.
There is a process for communication strategy that includes electronic communication,
frequent meetings, FRMS award systems, employee recognition system, FRMS bulletins, etc.
There is a process for sharing fatigue related information with outside sources that might be
impacted by this information.
Organizational personnel are actively involved in determining details of FRMS operation and
review.
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Table D2.1—FRMS Controls—Work Hours & Sleep Opportunity

Score Criteria
1 There is no system in place to monitor sleep opportunity and hours of work.
3 A. Work scheduled and rosters are planned and recorded for easy access by the organization,
employees and TC. Controlled copies are kept on file in chronological date order by the
accountable executive.
B. Actual work hours are recorded and are easily accessible by the organization, employees
and TC. They are simply coded for ease of understanding. Records should include the
employee name, type of work being performed (e.g. trip log, type of maintenance duties, etc.),
start and finish time of shift, and the date. Controlled copies of actual work hours are kept on
file in chronological order by the accountable executive.
C. The organization has a validated process or system for ensuring that both planned and
actual work hours provide sufficient sleep opportunity for employees.
D. All planned work schedules and rosters are analyzed for sleep opportunity prior to releasing
them to employees.
E. A sample of worst-case actual work hours are analyzed for sleep opportunity at minimum
on a monthly basis (see note).
F. Reporting systems and required actions upon discovering insufficient sleep opportunity
within a given roster are clearly defined (see note).
G. All analyses are documented, reported and kept on file in chronological order for review by
the organization, employees and TC.
H. Employees are provided with guidelines of what they are expected to do if their shift runs
over their rostered period to ensure they still obtain sufficient sleep opportunity.
I. The process or system for assessing sleep opportunity is reviewed on a regular basis to
ensure it is operating effectively.
Work schedules and rosters are recorded in a manner that is easy to understand by the
organization, employees and TC.
They are simply coded for ease of understanding.
Employees are consulted about work schedules and rosters. Names and dates of those
present during the consultation are recorded and kept on file.
The organization risk manages maximum amounts of work performed by any employee.
The organization has a program that ‘flags’ rosters, schedules and actual work hours that
have provided employees with insufficient sleep opportunity.
There is evidence of reports that have been generated and circulated to relevant managers
and employees when actual work hours were shown to have provided insufficient sleep
opportunity.
There is a management process in place to ensure that all casual employees and contractors
are obtain sufficient sleep opportunity.
Note:
The most extreme work hours should be selected and analyzed using fatigue
modeling software. Examples of extreme work hours would include long work
shifts, more than 2 night shifts worked in a row, more than 2 early morning starts in
a row, breaks of 12 hours or less between shifts, long blocks of shifts and few days
off. If these analyses indicate that sufficient sleep opportunity was provided, with a
fatigue score within an appropriate pre-defined range, it can be assumed that the
remainder of work shifts will also be compliant. If any of the analyses indicate
insufficient sleep opportunity was provided, the organization should have
documented actions to prevent reoccurrence, and further analyses of other
recorded work hours should be undertaken to determine the extent of the problem.
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Note:
For example, if an analysis of planned rosters indicates the employee (s) will
receive insufficient sleep opportunity, there should be a clear process to report the
analysis results, and documented actions to either manage the risk of elevated
fatigue likelihood, or to change the roster to ensure the employee (s) does get
sufficient sleep opportunity. Similarly, if retrospective analysis of work hours
indicates an employee (s) received insufficient sleep opportunity, there should be a
clear process to document the results, and take action to prevent the likelihood of
reoccurrence.
Table D2.3—FRMS Controls—Personal Fitness for Duty—Prior Sleep and Wake

Score Criteria
1 There is no system in place to monitor actual sleep obtained by employees and relative fitness
for duty. Employees are not informed of minimum sleep requirements to be fit for work.
3 A. The organization has a set of validated parameters defining minimum sleep and maximum
wake thresholds required for the average employee to be considered fit for work.
B. There is evidence of employee consultation during the development and review of these
parameters.
C. The prior sleep and wake thresholds are reviewed periodically to determine whether they
are effective.
D. Reporting procedures are clearly defined for occasions when employees obtain insufficient
sleep or experience extended wakefulness. Employees are provided with guidelines of what
they are expected to do in these circumstances.
E. Prior sleep and wake data is taken into account during the FRMS review and audit process.
F. Reports of insufficient sleep are dealt with in a just manner.
All of (3) plus some aspects of (5)
All of 3, plus all of the following:
The organization has an employee assistance program in place to refer employees who
consistently have trouble obtaining sufficient sleep.
Employees actively discuss action plans with a supervisor prior to commencing any work after
obtaining insufficient sleep.
The organization documents actual sleep records for all employees on a regular basis for
review and audit purposes.
The organization has provided easy reference tools for employees to determine whether they
have obtained sufficient sleep.
Table D2.3—FRMS Controls—Personal Fitness for Duty—Symptoms and Behaviours

Score Criteria
1 There is no system in place to monitor fatigue-related symptoms and behaviours. No training
or education has been provided to employees to assist them in identifying fatigue-related
3 A. The organization has provided easy reference tools for employees to assess fatigue-related
B. Reporting procedures and required actions are clearly defined for occasions when
employees exhibit fatigue-related symptoms, or observe fatigue-related symptoms in a
colleague.
C. Reports of fatigue-related symptoms and behaviours are dealt with in a just manner.
D. Fatigue-related symptom and behaviour data is collected from employees on a periodic
basis for review and audit purposes.
Employees actively discuss action plans with a supervisor prior to commencing any work
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when experiencing significant fatigue-related symptoms and behaviours.

Peer- and supervisor-monitoring for fatigue-related symptoms that may indicate performance
impairment is actively promoted within the organization.
The organization has a sleep-disorder screening program in place for employees who exhibit
fatigue-related symptoms and behaviours on a regular basis (see note).
Note:
Common sleep disorders the organization may screen for (and refer for treatment)
include sleep apnea, restless leg syndrome and insomnia.
Table D2.4—FRMS Controls—Fatigue Proofing Strategies

Score Criteria
1 There are no defined fatigue proofing strategies for use by employees within the organization.
3 A. The organization has a set of clearly defined fatigue proofing strategies for use by
employees when experiencing mild or moderate levels of fatigue.
B. There is evidence of employee consultation in defining the use of fatigue proofing
strategies.
C. The availability of fatigue proofing strategies is decided using a risk-based process.
D. Employees receive competency-based training about the use and application of fatigue
proofing strategies.
E. Fatigue proofing strategies are periodically reviewed to determine their effectiveness.
The organization has quiet, temperature controlled napping facilities available for employees.
The organization has a napping policy, describing where and when to nap, as well as the
caution required when suffering from sleep inertia.
The organization provides individual assistance to employees who regularly suffer from fatigue
and require regular use of fatigue-proofing strategies.
The organization consults fatigue risk management experts to discuss the effectiveness of
fatigue-proofing strategies in different circumstances.
Table D3.1—Fatigue Risk Management Oversight—Hazard Identification and Reporting Processes

Score Criteria
1 The reporting processes do not ensure the capture of fatigue-related information, nor do they
promote voluntary reporting of observed fatigue-related occurrences or deficiencies. Fatigue-
related reports are not reviewed at the appropriate level of management.
3 A. The FRMS reporting system is non-punitive. Employees are promoted to report any
fatigue-related hazard or event without fear of unfair retribution.
B. The organization has a process or system that provides for the capture of fatigue-related
information including fatigue-related hazards, fatigue occurrences, incidents, accidents or
other data relevant to the FRMS.
C. The reporting system is simple, accessible and commensurate with the size of the
organization.
D. Reports are reviewed at the appropriate level of management.
E. There is a feedback process to notify contributors that their reports have been received and
to share the results of the analysis.
F. There is a process in place to monitor and analyze trends documented.
G. The organization has planned self-evaluation processes, such as regularly scheduled
reviews, evaluations, surveys, operational audits and assessments.
H. The organization has identified primary sources of information for fatigue risk assessment,
including reports from employees, accident and incident data, performance on flight data
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monitoring programs (FDM) or Line Operations Safety Audits (LOSA), reports of fatigue-
related symptoms and behaviours, individual sleep and wake data from employees, and
analysis of rosters and actual work hours.
I. The organization has documented corrective and preventative actions to respond to event
analysis.
J. There are data collection processes throughout the safety critical areas of the organization
to permit organization wide analysis of fatigue risk management issues.
K. There is a process in place to investigate and analyze reported events.
L. Corrective and preventative actions are generated in response to hazard and event
analysis.
M. The organization conducts formal hazard analyses for:
- Introduction of new shift/roster systems
- Introduction of new long range or ultra long range operations
- Long duty hours for maintenance personnel
- Changes in manning for high-risk tasks
- Any work being performed between 2100hrs and 0600hrs
The organization has a process in place to ensure confidentiality as requested.
The range and scope of fatigue related hazards, occurrences or deficiencies that must be
reported are explained and defined.
There is a process to ensure that information contained in reports is validated for accuracy
prior to analysis.
All reports are subjected to a risk analysis process to determine the extent and priority of
further action.
Personnel involved in the reporting process are empowered to suggest corrective actions.
The report form(s) is (are) simple, standardized and accessible across the organization.
There is a process to ensure that information is received from all areas of the organization
within the scope of the FRMS.
Participation in industry, operational and fatigue risk management activities such as
conferences, symposia and other fatigue-related meetings is a priority.
Table D3.2—Fatigue Risk Management Oversight—Investigation and Analysis

Score Criteria
1 The organization does not routinely conduct investigation and analysis of fatigue-related
occurrences and deficiencies.
3 A. There are procedures in place for the conduct of investigations (Part V & VII only).
B. Measures exist that ensure all reported occurrences and deficiencies are investigated.
C. There is a process to ensure that occurrences and deficiencies reported are analyzed to
identify contributing and root causes.
D. Corrective and preventative actions are generated in response to event investigation and
analysis.
E. The organization has a staff of technically competent investigators commensurate with the
size and complexity of its operation.
F. When identifying contributing and root causes, the organization considers multiple aspects
of how fatigue may have been related.
G. Results of the analysis are communicated to the responsible manager for
corrective/preventative action and to other relevant managers for their information.
H. All reactive reports are subjected to a risk analysis process to determine the extent and
priority of further action.
I. Responsibility and timelines are established for each corrective action.
Where fatigue is found as a contributing factor or root cause of an error, incident, or accident,
Investigation results are collated and shared with the wider aviation community.
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Table D3.3—Fatigue Risk Management Oversight—Risk Management

Score Criteria
1 The organization does not have a process for evaluating and managing fatigue related risk.
3 A. There is a structured process for the assessment of fatigue-related risk associated with
identified hazards, expressed in terms of severity, level of exposure and probability of
occurrence.
B. There are criteria for evaluating fatigue-related risk and the tolerable level of risk the
organization is willing to accept.
C. The organization has risk control strategies that include corrective/preventative action plans
to prevent recurrence of reported occurrences and deficiencies.
D. The organization has a process for evaluating the effectiveness of the corrective/preventive
measures that have been developed.
E. Corrective/preventive actions, including timelines, are documented.
F. There is a fatigue risk classification system that guides the organization in developing
fatigue related risk control strategies.
G. The organization uses its fatigue risk assessment results to develop best practice
guidelines that it shares with the industry.
H. The results of the fatigue risk assessment program are built into the organization’s methods
and procedures.
I. The organization is able to demonstrate the fatigue risk management process through
records and is able to show periodic review documentation.
The organization runs formal fatigue risk management workshops with all personnel
performing safety-critical tasks.
The organization has developed key performance indictors to evaluate their FRMS and
determine whether fatigue-related risk has increased or decreased over periodic risk
assessments
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Table D4.1—Training: Training, Awareness and Competence

Score Criteria
1 Training requirements are not documented, nor does the organization incorporate FRMS
training into indoctrination training.
3 A. The organization has a Fatigue Risk Awareness training program in place that covers:
- A basic overview of sleep, why we need it, and what happens if we don’t get it;
- Definition of fatigue and fatigue-related risk;
- Examples of the consequences of fatigue, including performance, health and lifestyle factors;
- An overview of the reasons why fatigue-related risk needs to be managed—including legal
liabilities;
- Personal fatigue risk management strategies—such as sleep hygiene, lifestyle, diet,
stimulants, exercise and relaxation.
B. The organization has a competency-based Fatigue Risk Management training program in
place that covers:
- A synopsis of the information covered in fatigue risk awareness training;
- An overview of the organization’s FRMS;
- Organizational and individual responsibilities in managing fatigue-related risk;
- A detailed explanation of each of the FRMS controls and management strategies;
- Fatigue-Reporting systems and expectations;
- Fatigue-risk management problem shooting
C. There is a documented process to identify training requirements so that personnel are
competent to manage fatigue related risk.
D. There is a validation process that measures the effectiveness of training.
E. The training includes initial, recurrent and update training as applicable.
F. The organization’s fatigue risk management training is incorporated into indoctrination
training upon employment.
G. Training includes human and organizational factors.
There is a formal and objective training needs analysis.
Training requirements are documented for each area of activity within the organization,
including areas where training requirements are not defined by regulations. The attendance of
symposiums outside of FRMS should also be considered.
A training file is developed for each employee, including management, to assist in identifying
and tracking employee training requirements and verifying that the personnel have received
the planned training. This file should be completed in accordance with the training guidelines
that are developed.
Training needs are included as part of the performance appraisal process.
Management recognizes and uses informal opportunities to instruct employees on fatigue risk
management.
Continued occupational competency is maintained.
Evidence exists that management supports fatigue risk management training initiatives.
The training exercises and methods are kept current to reflect new techniques, technologies,
results of investigations and corrective actions and regulatory changes.
The organization keeps an up-to-date fatigue risk management library for employee access.
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Table D5.1—Documentation—Identification and Maintenance of Applicable Regulations

Score Criteria
1 There is no system for the identification and maintenance of applicable fatigue-related
regulations.
3 A. A documented procedure has been established and maintained for identifying applicable
fatigue-related regulatory requirements (parts VI, VII only).
B. Fatigue-related regulations, standards, exemptions and labour laws are periodically
reviewed to ensure that the most current information is available (parts VI, VII only).
All pertinent fatigue-related technical and regulatory information is readily accessible by
personnel.
The organization has defined specific triggers that would lead to a review of the organizational
documentation.
Table D5.2—Documentation—FRMS Documentation

Score Criteria
1 FRMS documentation is incomplete and maintenance procedures are not well established.
3 A. There is consolidated documentation that describes the FRMS and the interrelationship
between all of its elements.
B. This information resides or is incorporated by reference into approved documentation, such
as DAPM/EPM, Organization Operations Manual, Maintenance Control Manual, as applicable,
and where these approved documents are not required by regulation, the organization
includes the information in a separate, controlled document.
C. Manuals or controlled electronic media are used to document the system.
D. The consolidated documentation is readily accessible by personnel.
E. There is a process to periodically review FRMS documentation to ensure its continuing
suitability, adequacy and effectiveness, and that changes to organizational documentation
have been implemented.
F. Documentation reflects functional coordination within the management system that ensures
the organization works as a system and not as a group of separate or fragmented units.
The system is documented in suitable organizational media at both corporate and operational
levels.
Documents show lines of authority, accountability and responsibility at the corporate level of
management. This documentation also indicates the authority within the Organization and the
authority granted by the regulator.
Acceptable means of documentation include, but are not limited to, organizational charts, job
descriptions and other descriptive written material that define and clearly delineate the system
of authority and responsibility within the organization for ensuring safe operation.
The organization has a process to identify changes within the organization that could affect
Organizational documentation.
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Table D5.3—Documentation—Records Management

Score Criteria
1 There are no processes in place for managing FRMS output.
3 A. The organization has a records system that ensures the generation and retention of all
records necessary to document and support FRMS requirements, and is in accordance with
applicable regulatory requirements.
B. The system shall provide the control processes necessary to ensure appropriate
identification, legibility, storage, protection, archiving, retrieval, retention time, and disposition
of records.
C. Master copies of current FRMS policy and procedures documents contain a page with
signatures of all relevant personnel stating they have read and understood the document.
The organization has a policy that defines how long FRMS records that are not specifically
required by regulations are kept.
7.0 FATIGUE RISK MANAGEMENT SYSTEM ASSESSMENT SCORING RULES
7.1 Scoring Award Level

(1) Scoring award levels are based on a set of defined expectations. The expectations relate to an
element being assessed. For example, a fatigue risk management plan must contain a fatigue
risk management policy. An expectation of the fatigue risk management policy is that it should
contain a clear declaration of commitment and objectives. As FRMSs are progressive in their
development, we expect to see continuous improvement in the system; we also expect to see a
variation in the type of safety policy we see. Expectations are intended to provide a guide for the
types of thing that would make-up a good response. They are not intended as a checklist, nor
are they all-inclusive. They are provided as indicators for understanding what a good element
might contain and for standardizing the assessment process.
(2) Each assessed element will be assigned a score from (1) to (5) based on a set of specific criteria.
The assessed score shall be in increments of no smaller than 0.5. The criteria are to be used as
guidelines for scoring the various elements.
(3) Scoring awards are assessed in the following manner:
(a) A score of (1) is considered to be not documented and not implemented.
(b) A score of (1.5), (2.0) or (2.5) is considered to be partially implemented but not effective.
In other words, the organization does not have all of the criteria required for an award
level of (3).
(c) A score of (3) is considered as meeting the minimum acceptable standard of
assessment. As such, to be considered as having an acceptable level, required
elements have to be rated as per the criteria at an award level of (3). The score of (3) in
all criteria reflects only the minimum requirements of the CARs. Any additional
requirements and best practices in the guideline protocol represent bonus points in
addition to the (3) award level.
(d) A score of (3.5), (4.0) or (4.5) is considered to exceed the minimum acceptable standard
of assessment. To receive this award level, the element is considered to meet all of (3)
plus some aspects of (5).
(e) A score of (5) is considered to meet all of the criteria for an award level of (3) plus all of
the additional requirements listed under the criteria for that element. To achieve an
award level of (5), an organization would have to meet the regulatory requirements as
well as demonstrate industry best practices at a very high level.
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7.2 Optional Components

Until such time that the regulations are fully amended to reflect the Civil Aviation Fatigue Risk
Management System Model, Transport Canada will not assess component or elements not
required by the regulation. Nevertheless, organizations are encouraged to incorporate all FRMS
components or elements described in this guide’s FRMS framework in anticipation of future rule
changes. Organizations that do not incorporate optional components or elements shall not be
penalized and those component element scores shall not be factored into the overall FRMS
score.
7.3 Failure to Meet Minimum Requirements
A failure to achieve a minimum score of (3) on any of the required elements will result in the
following action:
(a) Where the element is assessed at an award level of (1.0), (1.5) or (2.0), a 30-day
corrective action notice will be issued. The delegated officer responsible for the
certificate will have 30-days to either accept the corrective action or to suspend the
operator’s certificate.
(b) Where the element is assessed at an award level of (2.5), a 90-day corrective action
notice will be issued. The delegated officer responsible for the certificate will have 90-
days to either accept the corrective action or to suspend the operator’s certificate.
7.4 Scoring Using the Criteria
(1) When awarding an assessment score to an element, the assessor should consider whether the
element meets the established criteria. Within specific ranges, there is flexibility for interpretation.
The assessor should consider all of the expectations and apply the scoring criteria to determine
the award level for that element. The assessor should also consider, and give credit where
appropriate, for features that are not contained in the expectations.
(2) The example shown in the table below demonstrates how the assessment tool works. The
component is “fatigue risk management system”. These expectations (what you would expect to
see) are shown in the first table below and the criteria (what should be there) for assessing the
award level are shown in the following table.

Element
Questions
(A) Has a FRMS been established for your organization?
(A) How do you maintain it?
(A) How do you ensure that it is adhered to?
(BP) Are you a multiple certificate holder? If so, explain how you have established a single FRMS with
integrated operations.
(B) How do you ensure that your FRMS procedures are appropriate to the size and complexity of your
organization?

(BP) Is your organization a multiple certificate holder? If so, explain how you have integrated FRMS
activities with departments under other certificates.
(BP) How are your FRMS activities coordinated with the FRMSs of organizations providing services?
To employees:
(A) What is your understanding of your organization’s FRMS?
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Score Criteria
1 The organization has no aspects of FRMS in place.
3 A. The organization has a FRMS, which has defined components that are established,
maintained and adhered to.
B. The FRMS management system is appropriate to the size and complexity of the
organization.
5 The organization is a recognized leader in FRMS within the aviation industry.
A single FRMS is established for holders of multiple operator’s certificates with integrated
operations, and is coordinated with the FRMSs of organizations providing services.
(3) Certificate holders failing to make an award level (3) on any of the elements required within a
component will fail that particular component. If the award level is 2.5, the organization must
provide a corrective action within 90-days. If the award level is below 2.5, the organization must
provide a corrective action within 30-days.
7.5 Suspension of the Operating Certificate
In cases where a component is non compliant and is assessed as being not effective, the
operating certificate may be suspended based on the grounds that the certificate ceases to meet
the qualifications necessary for the issuance of the document or to fulfill the conditions to which
the document was issued.
8.0 COMPLIANCE WITH THE CARS REQUIREMENTS
(1) Compliance with the CARs FRMS requirements is based on a certificate holder having
documented policies and procedures to support the FRMS components and elements the
certificate holder is required to have in place, as well as an effective system. Compliance will be
determined upon completion of the assessment exercise.
(2) An assessment of effectiveness will only be conducted after the certificate holder has
demonstrated to Transport Canada’s satisfaction that the organization’s FRMS documentation is
in place. Where an organization is found not to have the supporting documentation for a
particular FRMS component, the procedure will not be validated during the physical assessment
nor will it be assessed for effectiveness. Where CASI feels that the lack of documentation is
significant enough to warrant not conducting an assessment, the Certificate Holder will be subject
to Transport Canada enforcement action. Companies found in non-compliance with the CARs
will be advised and administrative action will be taken by Transport Canada. Only those
components with the required documentation will be assessed.
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Component ELEMENT CAR ELEMENT Component

Compliant SCORE Score
1.1 Fatigue Risk Management Policy Y / N
1. Fatigue Risk Management Plan 1.2 Roles, Responsibilities and Employee Involvement Y / N
1.3 Communication and Consultation Y / N
Total : +3 →

Complian SCORE Score
t
2.1 Work hours & Sleep Opportunity Y / N
2. Fatigue Risk Management 2.2 Personal Fitness for Duty—Prior Sleep and Wake Y / N
Controls 2.3 Personal Fitness for Duty—Symptoms and Behaviours Y / N
2.4 Fatigue Proofing Strategies Y / N
Total : +4 →

3.1 Hazard Identification and Reporting Processes Y / N
3 Fatigue Risk Management
3.3 Investigation and Analysis Y / N
Oversight
3.4 Risk Management Y / N
Total : +3 →

4. Training 4.1 Training, Awareness and Competence Y / N
Total : +1 →

5.1 Identification and Maintenance of Applicable Regulations Y / N
5. Documentation 5.2 FRMS Documentation Y / N
5.3 Records Management Y / N
Total : +3 →
Component Score Total:

Overall FRMS Score (Component Score Total / # of Components)
* Optional for CAR 705 Operations** Optional for CAR 573 Operations
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9.0 CONTACT OFFICE
For more information please contact:

Standards Coordinator (AART)
Phone: 613-990-8234
Facsimile: 613-996-9178
E-mail: CAIRS_NCR@tc.gc.ca
Suggestions for amendment to this document are invited and should be submitted via the
Transport Canada Civil Aviation Issues Reporting System (CAIRS) at the following
Internet address:
www.tc.gc.ca/CAIRS
or by e-mail at: CAIRS_NCR@tc.gc.ca
D.B. Sherritt
Director, Standards, Civil Aviation
2008-10-15 45 of 45 SI SUR-007 Issue 01

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Subject: Fatigue Risk Management System Assessment Guide

2.0 REFERENCES AND REQUIREMENTS

2.1 Reference Documents

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(v) Risk means a calculation of consequence (potential loss) and likelihood

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4.0 FRMS ASSESSMENT PROCESS

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4.1 Determine Assessment Scope

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5.0 MASTER PROTOCOL

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5.2 FRMS Expectations

Table B0—Fatigue Risk Management System

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Table B1—Fatigue Risk Management Plan

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Element 1.3 Communication and Consultation

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Table B2—Fatigue Risk Management Controls

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Element 2.2 Personal Fitness for Duty—Prior Sleep and Wake

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Table B3—Safety Oversight

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Element 3.2 Investigation and Analysis

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5.3 FRMS Questions

Table C0—Questions : Fatigue Risk Management System

To the functional department heads:

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Table C1—Fatigue Risk Management Plan

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Element 1.2 Roles, Responsibilities and Employee Involvement

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Element 1.3 Communication and Consultation

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Table C2—Fatigue Risk Management Controls

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Element 2.3 Personal Fitness for Duty—Symptoms and Behaviours

Table C3—Fatigue Risk Management Oversight

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Element 3.3 Investigation and Analysis

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Element 3.4 Risk Management

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Element 5.3 Records Management

Table D0—Criteria : Fatigue Risk Management System

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Table D1.1—Fatigue Risk Management Plan—Safety Policy

Table D1.2—Fatigue Risk Management Plan—Roles and Responsibilities

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all fatigue risk management processes, decisions and actions.

Table D1.3—Fatigue Risk Management Plan—Communication and Consultation

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