In recognition of these additional challenges on a State's prescriptive FTDLs, consideration of the following areas on crew fatigue should also be demonstrated by the operator and reviewed during oversight activities. Operators should:
develop planning buffers to prevent scheduling up to the limits of the prescriptive requirements;
risk assess the impact of extended recency and proficiency checks, medicals and other alleviations on fatigue;
closely monitor of any trends in the use of pilot discretion and take steps to minimize its use;
monitor and seek to mitigate disruption to aircrew's planned duties, especially at short notice;
share workload across available crew, particularly management pilots and aircrew trainers who may also be working in the simulator;
have a process for monitoring the use of controlled rest in the flight deck (when legal under State regulations) to prevent it becoming seen as planning tool instead of an emergency procedure;
include the importance of "crew health/fatigue checks" as part of pre-flight briefings;
take account of increased times at airports (queuing and COVID testing) in pre and post FDP duties;
assess layover conditions to protect crew's physical and mental health;
assess the impact of organizational changes and restructuring, such as redundancies and the potential effect that this may have on crew and their ability to fully rested and fit for duty;
actively encourage crew to report fatigue-related occurrences and concerns they may have;
assess the additional workload associated with the wearing of PPE and other additional passenger procedures on cabin crew.
Finally, all airlines are reminded that they need to track the performance of their fatigue management approaches through a set of assurance activities. Therefore, not only do they need to have enough flight and cabin crew, but they also need to have sufficient competent office-based personnel to carry out the necessary support activities for effective operational fatigue management.
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