Fatigue in air traffic management

Functional Approach

Fatigue is a hazard in shift working environments and the regulations have been developed to mitigate the potential for harm. In support of compliance with the regulations, it is essential that ANSPs identify and address the presence of fatigue in a predictive, proactive, and reactive manner, and manage it accordingly within change management and safety management systems.

To do this effectively requires data collection, analysis, appropriate reporting and investigation and increased education at all levels of an organisation supported by a just culture.

More general information on fatigue management can be found on the UK CAA's Human Factors webpages. 

Regulatory Requirements

Fatigue is addressed within the regulatory requirements in a number of different ways.

Article 191 of Air Navigation Order 2016 related to an air traffic controller’s responsibility if they knew or suspected that they were suffering from, or were likely to suffer from, fatigue. However, that Article was withdrawn and the article’s intent is now captured within point (b) of ATCO.A.015 Exercise of the privileges of licences and provisional inability (contained within Annex I of Assimilated Regulation (EU) 2015/340)) copied below:

(b) Licence holders shall not exercise the privileges of their licence when having doubts of being able to safely exercise the privileges of the licence and shall in such cases immediately notify the relevant air navigation service provider of the provisional inability to exercise the privileges of their licence.

To assist in the management of fatigue and associated risks, it is important for individuals and ANSPs alike to understand the importance of identifying and reporting fatigue in self and others.

Assimilated Regulation (EU) 2017/373 requires all ANSPs to develop and maintain a policy for the management of controller fatigue. It continues to require the provision of information programmes on the prevention of fatigue, which should complement the content of unit training plans and competence schemes as per 2015/340 Annex I Subpart D Section 4 Continuation Training Requirements.

ANSPs should facilitate fatigue reporting, investigation, and analysis together with the identification and management of fatigue when considering the safety of operations in accordance with Annex IV ATS.OR.315 Fatigue.

The above is supported by the development and review of ATCO rostering systems in accordance with ATS.OR.320 Air traffic controllers’ rostering systems.

Air Traffic Controllers’ Rostering System(s)

For many years, the UK utilised the Scheme for the Regulation of Air Traffic Controllers’ Hours (SRATCOH) to provide the basis for a rostering system to manage the risks of occupational fatigue of air traffic controllers. However, ATS.OR.320 requires Air Traffic Control (ATC) service providers to develop, implement and monitor a rostering system, with its structure and values based on scientific principles, data gathered by the ATC service provider and best practices.

Whilst some UK ATC service providers can readily gain access to the appropriate resources to support this task, the Civil Aviation Authority (CAA) is cognisant that this may not be the case for all. Consequently, The CAA has developed specific policy and additional AMC and GM to guide and direct ATC service providers in complying with the requirements of ATS.OR.320.

The AMC and GM are not materially different from the provisions contained previously within SRATCOH; industry were required to incorporate the new policy, AMC and GM into their existing systems by 7 March 2022. 

Where an ATC service provider identifies the need to operate in a way that differs to the AMC (for example, the structure of or values used within their rostering system), they may follow the process (ATM/ANS.OR.A.020(a)) to develop and propose alternative Means of Compliance (MOC) for consideration and approval by the CAA.