ED Decision 2022/011/R
CONSIDERATION OF FATIGUE IN THE PLANNING OF MAINTENANCE
(a) The way and the extent to which the organisation should consider the threat of fatigue in the planning of tasks and organising of shifts will vary from one organisation to another and from one maintenance event to another, depending on what maintenance is to be carried out, how, where, when and by whom.
(b) Fatigue is one example of human factors issues which should be taken into account by the management system, particularly for the planning activity. In this respect, where the organisation activity is prone to fatigue issues, the organisation should:
(1) ensure that the safety policy required by point 145.A.200(a) gives due consideration to the aspects of fatigue;
(2) ensure that the internal safety reporting scheme required by point 145.A.202 enables the collection of fatigue issues;
(3) ensure that the threat of fatigue is adequately taken into account by the management system key processes (e.g. assessment, management, monitoring);
(4) provide safety promotion material and adapt safety training accordingly.
(c) The organising of shifts should consider good practices in the maintenance domain and applicable rules. The resulting shift schedule should be shared with the maintenance staff sufficiently in advance so they can plan adequate rest.
The established shift durations should not be exceeded merely for management convenience even when staff is willing to work extended hours.
(d) The organisation should have a procedure (including mitigations) to address cases where the working hours are to be significantly increased, or when the shift pattern is to be significantly modified, such as for urgent operational reasons. In cases not covered by that procedure, the organisation should perform a specific risk assessment and define additional mitigation actions, as applicable. Basic mitigations may include:
(1) additional supervision and independent inspection;
(2) limitation of maintenance tasks to non-critical tasks;
(3) use of additional rest breaks.
AMC1 145.A.47(b) guides organisations on integrating fatigue considerations into maintenance planning, shift scheduling, safety policy, reporting, and risk mitigation.
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