Advantages, disadvantages and opportunities of FRMS Dr Rob Hunter Head of Flight Safety

1. Advantages, disadvantages and opportunities of FRMSDr Rob HunterHead of Flight Safety

3. BALPA’s approach to safety planning; the identification of root contributors to risk • A practical point of intervention where it is most effective and efficient in delivering a safety benefit across most areas • Strategic threats • Tactical threats • Threats that are a consequence of innovation

4. “Actual” Pilot Error “Apparent” Pilot Error Commercial Pressure Inadequate Regulation

5. Advantages A non-proscriptive system (process) of managing one’s own unique constellation of risks in open collaboration with all the stakeholders involved in an intelligent monitored way that continuously actively identifies risk and mitigates it is a good thing that only becomes bad when all of the above does not happen.

6. Advantages It allows an unfettering of venture that can help industry to flourish. It can exist alongside prescriptive regulation. It has been developed in collaboration with IATA and IFALPA.

7. Disadvantages Requires an open non-jeopardy fatigue reporting system

8. Disadvantages Not suitable for deployment in a Druckerian economic environment - "The first duty of an organization is to survive".

9. Disadvantages Misuse of science Weak definition of the predictive power of "operational experience". Practice of commissioning research that is then owned and not subject to peer review “we’ve got science to show…”

10. Disadvantages Can turn risk into something that has been looked at rather than something that is perceived in a more general sense.

11. Disadvantages The language of FRMS Laden with unnecessary technical language. “A technocratic illusion of the management of risk” This technical language can make common sense appear more complicated and more new than it really is and it can also cover over concepts that can be naïve.

12. Disadvantages The language of FRMS Laden with declarations of good intent such as declarations of “management commitment”, which may be vacuous.

13. Disadvantages The language of FRMS: legal drafting Lack of legal certainty - Sentences that command that it is imperative that something nebulous is done

14. Disadvantages Regulatory bias Conflicting economic duties and safety duties vested in the same organization Funding of the CAA Regulatory Human Factors – transfer of liability to other parties regulatory responsibilities are poorly defined Hampton and deregulatory sentiment Making money from regulation

15. Disadvantages FRMS promoters - the FRMS consultancy band waggon and commercial interests. “BRMS” – that the interaction of senior management responsibility and the commercial interest of the SMS consultancy contrives to promote what is in effect a blame risk management system

16. Disadvantages – the assumption that we learn from incidents

17. Disadvantages-Insensitive to the historical experience of SMS and the development of Proscriptive regulation

18. Disadvantages- Weak evidential base of effectiveness

19. Disadvantages Can be used to patch inadequate prescriptive regulation

20. Disadvantages No definition of how tired is too tired

21. Opportunities Research to establish how tired is too tired Research needs - - a simulator based study of pilot performance in undertaking fatigue sensitive tasks. - an evaluation of objective measures of fatigue - an evaluation of the dependence of the risk of involuntary sleep on the sleep state of the other pilot in 2 crew operations - an evaluation of the hazard of driving home after long periods of wakefulness

22. Opportunities A fatigue science advisory panel that is independent of the regulator

23. Questions robhunter@balpa.org