GUIDELINES ON FATIGUE MANAGEMENT

IN ROSTERING SYSTEMS

Draft: 1.0
Draft date: 16-03-2022
Classification: Green
Reference nr: -

B
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DOCUMENT CONTROL

GUIDELINES ON FATIGUE MANAGEMENT IN ROSTERING

Document Title
SYSTEMS

Document Subtitle This field is automatically updated

Document Reference -

Draft Number 1.0

Draft Validity Date 16-03-2022

Classification Green

Status Released issue

Contact Person(s) Fabrice Drogoul

APPROVAL TABLE

Authority Date Signature

Prepared/Reviewed by:
Fabrice Drogoul – NMD/SAF
Una Mellett – NMD/SAF
Goran Pavlovic- NMD/ACD/OPL
Vladimir Jevtic – NMD/ACD/OPL
Philippe Cabon

Reviewed and endorsed by:

Mr. Antonio Licu
Head of Safety Unit, NMD/SAF

Approved by:
Mr Iacopo Prissinotti
Director NMD

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EDITION HISTORY

Edition No. Validity Date Author(s) Reason

1 NMD/SAF Drafting process

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Table of Contents
DOCUMENT CONTROL ...................................................................................................... I
APPROVAL TABLE .............................................................................................................. I
EDITION HISTORY .............................................................................................................II
1. INTRODUCTION ............................................................................................................. .V
2. SCIENTIFIC BASIS FATIGUE AND SHIFTWORK .................................................. .VI
3. REGULATION REQUIREMENTS & OTHER RECOGNISED AUTHORITIES ..... VII
3.1 Introduction..........................................................................................................................vii
3.2 EU working time directive 2003...........................................................................................vii
3.3 Regulation (EC) 2017/373 ....................................................................................................vii
3.4 ICAO Guidelines ................................................................................................................ viii
3.5 The International Labour Organisation (ILO) ..................................................................... x
3.6 EUROCONTROL References ............................................................................................... x
4. PROPOSED SHIFT WORK FATIGUE PRESCRIPTIVE LIMITS ............................. XI
4.1 Maximum consecutive working days with duty ...................................................................xi
4.2 Maximum hours per duty period ..........................................................................................xi
4.3 Maximum time providing air traffic control service without breaks ..................................xi
4.4 The ratio of duty periods to breaks when providing ATC service .......................................xi
4.5 Minimum Rest Periods..........................................................................................................xi
4.6 Maximum consecutive duty periods encroaching the night time, if applicable, depending
upon the operating hours of the air traffic control unit concerned ..........................................xii
4.7 Minimum rest period after a duty period encroaching the night time; ..............................xii
4.8 Minimum number of rest periods within a roster cycle ......................................................xii
5. ATC APPLICATION OF THE 8 PRINCIPLES ......................................................... XIII
5.1 (EC)2017/373 requirements & current rostering practices .............................................. xiii
5.2 Monthly roster cycle and condensed shifts ........................................................................ xiii
5.3 Seasonality .......................................................................................................................... xiii
5.4 Non Ops duties ................................................................................................................... xiii
5.5 Stand by Duties .................................................................................................................. xiii
5.6 Arrival times....................................................................................................................... xiii
5.7 Mandatory Training ........................................................................................................... xiv
6. ADDITIONAL CONSIDERATIONS ............................................................................. XV
6.1 Rostering and staffing .......................................................................................................... xv
6.2 Age…. ................................................................................................................................... xv
6.3 Sleeping after night shift ...................................................................................................... xv
6.4 Schedule stability.................................................................................................................. xv
6.5 Schedule predictability ......................................................................................................... xv
6.6 Shift Structure ...................................................................................................................... xv
6.7 Additional considerations ................................................................................................... xvi
7. CONCLUSIONS .......................................................................................................... XVII

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REFERENCES ...............................................................................................................XVIII
ACROYMNS AND ABBREVIATIONS ............................................................................ XX

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1. INTRODUCTION
The rules on fatigue can be interpreted differently. To improve fatigue management, there is a
need for standards/recommendations, which are embedded in the safety management and
rostering systems.

This document aims to facilitate/support the implementation of the fatigue operational

requirements in the Air Traffic Control (ATC) environment. A literature review was undertaken on
the shift work fatigue prescriptive limits according to European Commission (EC) Regulation
2017/373,guidance373, guidance based on scientific principles and guidelines from recognised
sources e.g.:
• European Union (EU) working time directive;
• International Civil Aviation Organisation (ICAO) manual for professional career of Air Traffic
Controller (ATCO) and Doc 9966;
• ICAO Eastern and Southern African (ESAF) recommendation on rostering;
• EUROCONTROL rostering best practices. Comment [VLS1]: Was CANSO an
Military sources also consulted? E.g
The following paragraphs describe the key requirements from these regulations/standards have best practices from other
together with suggestions on how the eight shift work fatigue prescriptive limits can be applied. industries been consulted (e.g.
maritime?)
It is planned that this document will be integrated into the main deliverable from the Operational
Excellence Programme - Work Stream 06 (Human Resources) - Topic on the Enhanced For example, we could make a
Rostering Practices, which will consider other aspects of the rostering system. Namely, the comparison against standard mariti
Topic will also address other aspects of the rostering systems leading up to better HR planning in rostering procedures as they may be
function of increasing the performance and productivity of an ANSP organization. more applicable than for example
pilot guidelines.

Comment [LD2]: We think there

should be more citing of academic
evidence; which studies exactly hav
been used?
Comment [LA3]: Yes we were in
contact + add all the ERA and EMSA
practices on fatigue received and
circulate them to the group

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2. SCIENTIFIC BASIS FATIGUE AND

SHIFTWORK
According to Dawson & Fletcher, 2001, fatigue is a consequence of many factors of the working Comment [LD4]: This is 21 yrs old
environment such as: nowadays more/other data would
• working times, probably be available;
• time of the day,
Comment [LA5]: Lea and Fabrice
• number of breaks, update (also check the FAA studies -
• resting time and Tony to make them available)
• how working time is arranged over months (i.e. shift schedules).
Comment [VLS6]: The paper is ol
The impacts of these factors on fatigue has a consequence on safety (Fletcher 2003), well-being however the basics are right. What
and health and this has been widely described in research literature (Costa, 2000; Folkard and missing are newer concepts such as
Tucker, 2012; Reinberg A, Smolensky MH 2015). ‘dynamic fatigue build up,’ ‘risk of
overload or underload,’ complexity
and workload requirements. Resear
The following are the main scientific findings from this research:
exists looking at these things and w
• Night Work: Working at night is not natural for humans and should be limited to the minimum could provide a more nuances
and not be repeated too often. Night shifts are common in ATC. methodology involving mediators
• Shift Type Mixture: Mixing the type of shifts, morning, day, afternoon, night is better for
Comment [LA7]: See above
fatigue.
• Early Morning shifts: The negative effects of early morning shifts and their impact on sleep Comment [LD8]: Clarify – “better
deprivation and sleepiness can be as severe as the impact night shift after repeated early for” fatigue; does it mean it is
morning shift. (Ackerstedt et al., 2004; Monk et al., 1996; Tucker et al, 1998). fostering fatigue or preventing
fatigue; it is not clear to me;
• Forward rotating shift and shift length: Forward rotating shifts and 8 hours shifts versus 12
hours shifts are associated with a lower sleep debt. (Monk, Folkard, Wedderburn, 1996). Comment [LA9]: "better" means
• Fast rotations: Fast rotations limit the exposure to night work and may prevent cumulative mitigating
effects. (Vetter, Fischer, Matera, Roenneberg, 2015). Comment [LD10]: ??? Clarificatio
of meaning needed – added value;
let´s re-write all of those statement
to be more clearer; circadian rythem
are challenged;
Comment [LA11]: To review -
Comment [LA12]: See also the
Roster Dashboard
Comment [LD13]: I need a
clarification for “fast forward rotatio
– is it meant like this: The original
schedule was forward rotating:
MMM – – EEE – NNN – – – (M =
morning, E = evening, N = night, –
day off). The new schedule was fas
forward rotating: MEN – – with 10
shifts.

Again this paper is from 1996;

Comment [LA14]: Put an example
of fast forward rotation
Comment [LA15]: Make a note th
for mitigating personal impacts rost
should accommodate individual
preferences

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3. REGULATION REQUIREMENTS & OTHER

Comment [LD16]: Whole section
RECOGNISED AUTHORITIES could be placed in some form of
Annex; it is not helpful at all in this
context here, but confuses while
3.1 Introduction reading
In designing any shiftwork practices or schedules a review of the regulatory requirements and
the legal framework that should be applied is required as it underpins the constraints that the
shift schedules needs to operate. It is necessary to understand and have an interpretation on:
• What EU Regulation should be applied?
• Are these regulations planned to be transposed into National Regulation?
• What national regulation and working agreements need to be considered?

In the case of EU Regulations, the following regulations needs to be considered:

• EU working time directive 2003 Comment [LD17]: What is it? We
• European Commission (EC) Regulation 2017/373 have not be able to locate this
document at all.
Other international standards especially in the non-EU context are: Comment [LA18]: Check the links
• EUROCONTROL Shift work Practices Study (2006) the end and add more for the docs
• ICAO manual for professional career of ATCO; the links are missing
• ICAO doc 9966 Comment [LD19]: We have not
• ICAO ESAF recommendation on rostering. been able to locate this
• The International Labour Organisation (ILO) recommendation Comment [LA20]: See above
Comment [VLS21]: This should a
3.2 EU Working Time Directive 2003 include the CANSO Human
Performance standards of excellenc
The EU working time directive 2003 (2003/88/EC) is intended to protect public and private and expanded guidance from Huma
sector workers from the health and safety risks associated with excessive or inappropriate Factors guidelines (e.g. light exposu
working hours. It requires EU countries to guarantee the following rights for all workers: ISO standards and national laws on
• Weekly working hours: A limit to weekly working hours, which must not exceed 48 Occupational Health and Safety
hours on average, including any overtime and a minimum daily rest period of 11
consecutive hours in every 24 hours. Comment [LD22]: Arbeitnehmers
utzgestetz, Arbeitsinspektorat; ISO
• Rest breaks: Gives rights to daily and weekly rest breaks and the right to a rest break 9241; not comprehensive listing;
during working time. document does not prepare us for
• Annual Leave: Paid annual leave of at least four weeks per year. SPO, Remote TWR OPS, …
• Night work: Extra protections for night workers such as :
Comment [LA23]: To add HP SoE
o Length of night work should not exceed an average of eight hours in any 24-hour the references
period;
o Night workers whose work involves special hazards or heavy physical or mental Comment [LD24]: Is this the reas
we have “Blockruhezeit” of 4hrs in o
strain do not work more than eight hours in any period of 24 hours during which they
night shifts or is it simply coincidenc
perform night work.
• On Call: The interpretation of the working time directive was clarified through a number Comment [LD25]: Lt. Markus
of rulings in the European Court of Justice. The “SIMAP and Jaeger” judgment indicates Winkler: AZG kein Problem für uns,
that any time in which a worker is 'on call' in the workplace and is ready to provide allerdings mit dieser Formulierung
wäre es ein Problem;
services, is counted as working time regardless of whether the worker is providing active
services during that time. Comment [LA26]: The comment
related to SPO - bring in the ref from
the selected issues during shift work
3.3 Regulation (EC) 2017/373
The requirement ATS.OR.320 requires that “Any air traffic control service provider shall Comment [LA27]: To add in the
develop, implement and monitor a rostering system in order to manage the risks of references all MSEA Docs including
occupational fatigue of air traffic controllers through a safe alternation of duty and rest the selected safety issues during shi
periods. Within the rostering system, the air traffic control service provider shall specify 8 and share with the group
elements for shift work fatigue prescriptive limits: Comment [LD28]: This paragraph
1. maximum consecutive working days with duty could be removed as it is confusing
2. maximum hours per duty period the context of what is presented lat

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3. maximum time providing air traffic control service without breaks

4. the ratio of duty periods to breaks when providing air traffic control service
5. minimum rest periods
6. maximum consecutive duty periods encroaching the night time, if applicable depending
upon the operating hours of the air traffic control unit concerned
7. minimum rest period after a duty period encroaching the night time
8. minimum number of rest periods within a roster cycle.

Rostering within the limits of these 8 factors, is considered a prescriptive

approach and provides the constraints to build a rostering system.

The selection and the regular revision of an appropriate structure and of appropriate
values of the rostering system, in accordance with ATS.OR.320(a) and which fit the
intended operations, should be based upon:
(1) scientific principles;
(2) data gathered by the air traffic control service provider; and
(3) best practices

• It is necessary to consider the scientific evidence when developing an effective

rostering system to prevent fatigue Comment [LD29]: ATS.OR.320(b)
• Training should be provided to be aware of the scientific principles affecting fatigue An air traffic control services provid
and sleep science to support developing a rostering system and staff consultation. shall consult those air traffic
controllers who will be subject to t
Another important part of the ATS.OR.320 is that “air traffic control services provider shall rostering system, or, as applicable,
consult those air traffic controllers who will be subject to the rostering system, or, as their representatives, during its
applicable, their representatives, during its development and its application”. development and its application, to
identify and mitigate risks concernin
Individual Preferences and Fatigue fatigue which could be due to the
Controllers working a statutory number of hours may prefer longer shifts in order to rostering system itself.
have longer continuous periods away from work, and rostering that results in Comment [LA30]: Ok to update
several consecutive days off duty at regular intervals is often highly prized. This with the words from the requireme
practice must not be achieved at the expense of severe fatigue.
Comment [LD31]: We have not
been able to locate this document.
We really would like to digest this.
3.4 ICAO Guidelines What about additional roles not
included here:
The ICAO Manual for Professional career for Air Traffic Controllers Guide‘, has ATSEPs/SUPs/MET/FDU/FISO
recommended the following working conditions for ATCO doing shift duty:
• Work shift cycles should be based on having at least 2 consecutive days free per Comment [LA32]: See references
week. but good comment to mention othe
personnel on shift like ATSEP
• Work shifts that include night work should have a morning, afternoon, and night
rotation system (forward rotation). Comment [VLS33]: Does this mea
• Consecutive night shifts are not recommended. ‚weekly average total hours‘ ?
• Shift systems should not include night work on the same day a morning shift ends. Comment [LA34]: Weekly averag
• At least 30 hours of rest are recommended after working a night shift.
Comment [LA35]: But indicate th
• With alternate shifts, there should be no more than 3 consecutive morning shifts per is derived from a total yearly amoun
week. and from other parameters of leave
• Operational time and its resting periods should not exceed 32 hours a week. max consecutive days/nights
• Each daytime shift or shift of intense activity should not exceed 8 hours including rest
Comment [LD36]: Wöchentliche
period. Durchschnittsarbeitszeit??? Oder w
• At least 12 consecutive hours of rest should be provided for between shifts. soll das sein?
• Operational controllers should spend no more than 2 consecutive hours at work (i.e
Comment [LA37]: Weekly averag
in position) and this period should be reduced to 90 minutes for controllers working in
Comment [LA38]: Many ANSPs
have an yearly total amount

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a radar environment. This operational time can be reduced according to the amount
of traffic being handled.
• Controllers should have at least 1 hour for meals in the morning and evening shifts
and 40 minutes in the case of shifts of less than 8 hours.
• Controllers working night shifts should have at least 1 hour of rest.

Doc 9966 mentions the following typical values:

• The duty period may not exceed 12 hours.
• The aggregate of duty period hours may not exceed 200 hours within a defined
period of 720 consecutive hours or 30 consecutive days.
• There must be at least 12 hours between the end of one duty period and the
beginning of the next.
• No more than 6 consecutive days of duty shall be worked.
• If the maximum number of consecutive days of duty is rostered, there shall be a
minimum interval of 60 hours between the end of one consecutive period of duty days
and the next.
• No period of operational duty shall exceed 2 hours.
• No operational duty shall exceed 2 hours without there being a break taken during or
at the end of that period.
• A break should total not less than 30 minutes.
• A duty which covers all or part of the period of night duty shall not exceed 10 hours.
• No more than 3 consecutive duties shall be worked which cover all or part of the
period of night duty.
• A minimum period of 54 hours shall occur between the end of duties which cover all
or part of the period of night duty and the commencement of the next period of duty.
• No more than 3 on-call duties shall be worked in a 7 day period.
• The maximum length of on call period of duty where the ATCO does not attend the
place of work shall be 20 hours. Comment [VLS39]: Perhaps we
could put these in a table – for
ICAO ESAF has proposed in 2016 the following rostering guidelines and reminded States example see presentation from Lea
that these limits shall not exceed other applicable legal obligations with regards to first day of meetings.
working time limitations
• Maximum hours per duty period should not exceed 8 hours: It shall not exceed Comment [LA40]: Lea - can you
12 hours, provided that the extension is validated by a safety risk assessment. please go ahead on this and make a
table
• Maximum consecutive working days with duties: Recommended consecutive
working days should not exceed 5 days.
• Where applicable, fixed forward rotating roster principles should be applied, e.g.
morning shifts, followed by afternoon shifts, ending with night shifts and off days.
• Maximum consecutive ATCO duty periods encroaching Windows of Circadian
Low (WOCL): The number of consecutive early morning shifts shall not exceed two.
In such cases, it shall be ensured that the minimum rest period thereafter it is 24
hours before commencement of the next shift. This is applicable to shifts encroaching
the WOCL starting before 7am.
• Minimum rest period: The average rest period after a duty period should be 11
hours in order to allow for adequate time that includes rest, sleep, meals, preparing
for sleep and life admin.
• The ratio of duty periods to breaks: Breaks within a duty period should be planned
according to workload, complexity of ATC provision, time of the day, type of rostering
system. The minimum duration of a break should be 30 minutes.
• Maximum time providing ATC service without breaks: The maximum time
providing ATC service should be 2 hours for personnel providing ATC service working
with visual terminals and/or radar displays. Intervals can be reviewed periodically or
when an increase in traffic load was experienced. ATSUs experiencing low traffic
loads for prolonged periods of time may extend shift sessions to 3 hours.

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• Night duty: Maximum consecutive ATCO duty periods encroaching the WOCL, such
as night shifts, should not exceed 2, provided that they are followed by at least a 48-
hour rest period by the end of the second ATCO duty period encroaching the WOCL.
Upon the conclusion of a period of night duty, any ATC personnel shall be rostered a
day off.
• Late PM shift followed by an early AM shift: Rostering an individual for a late
afternoon shift followed by an early morning shift should be avoided where possible
or alternatively be limited to a single occasion per individual per cycle.
• Off days in a cycle: Operational staff shall be rostered for a minimum 2 sets of 2 or
more consecutive days off per cycle. Where possible, 3 sets of 2 consecutive days off
per cycle is recommended.

3.5 The International Labour Organisation (ILO)

The ILO recommendation state that “the maximum hours of attendance at the place of work
per week by ATCOs should normally be less than the generally accepted number of
attendance per week completed by other workers in civil aviation in the state concerned.”

3.6 EUROCONTROL References

The EUROCONTROL Shift work Practices Study (2006) is the document highlighted as
guidance material related to the Regulation (EC) 2017/373 requirements. This study
highlighted the following:
• Ideal shift solution – three important elements
• forward rotation,
• need for extended free time after night shift,
• reduction in the number of successive nights.
• Efficiency: Research indicates that there is a growing trend towards individual rostering
in staff planning and allocation
• ATCO Involvement: The involvement of ATCOs in the definition of rostering systems is
described.
• Minimum of Consecutive Days: Operational staff shall be rostered for a minimum 2 sets
of 2 or more consecutive days off per cycle. Where possible, 3 sets of 2 consecutive days
off per cycle is recommended.
• Free time: Minimum 2 free evenings/week.

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Comment [PB41]: At DSNA no

4. PROPOSED SHIFT WORK FATIGUE problem to implement those values

PRESCRIPTIVE LIMITS Comment [LD42]: At Austro

Control: 46hrs rest after max of 7
This chapter provides a set of recommendations for each of the 8 shiftwork fatigue days/max 60hrs per week;
prescriptive limits indicated in (EC) 2017/373 based on the review of the regulation 4 shifts in a line, max 5 shifts in a lin
requirements /standards outlined in chapters 2 and 3. It is important to state that these incl. a nightshift; SOLL (DRAFT) Plan
recommendations are cumulative and non-exclusive.
IST (ACTUAL) Plan: up to 7 days in a
4.1 Maximum consecutive working days with duty row, extended rest period of 4x47h
The standard should be either per month
• 5 days or less duties there are no extra constraints on the number of rest days.
Comment [LA43]: Tks for the
• or a maximum 6 duty days, allowing 54 hours of rest (2 consecutive nights and no duty
starting before 9.00). Comment [VLS44]: What would b
Comment [LA45]: To be tested th
The recommendation:
• takes into account the need for regular nights without constraint and the need to socialize Comment [PB46]: Does it concer
and rest at the same ratio of days at work and days off as other workers. Comment [LA47]: From fatigue
• should not be averaged over the year. In the case of seasonal traffic, having 3 days off
Comment [LA48]: Some ANSPs th
every 4 days in winter and autumns does not justify one day off every 10 days for the
summer. Comment [VLS49]: What should
Comment [LA50]: To provide som
4.2 Maximum hours per duty period Comment [LA51]: To be balanced
• The maximum hours per duty period should not exceed 8 hours.
• If the maximum hours per duty period is over 8 hours, it should be validated by a safety Comment [PB52]: Does it include
risk assessment and the length of a duty period should never exceed 12 hours. Comment [LA53]: The change ov
• The safety risk assessment in this case needs to concretely demonstrate that the
Comment [LA54]: At night we co
increased working time over 8 hours is not increasing the fatigue risk (i.e. demonstration
of low exposure due to low workload or effective mitigation in place…). Comment [LA55]: See study on th
Comment [LA56]: At night to allo
4.3 Maximum time providing air traffic control service without breaks Comment [VLS57]: There are too
• The maximum time providing ATC service should be 2 hours for wpersonnel providing Comment [LA58]: Tks for the
ATC service working with visual terminals and/or radar displays.
Comment [VLS59]: Is this really
• The break intervals should be reviewed periodically or when an increase in traffic load is
experienced. Air Traffic Services Units (ATSUs) experiencing low traffic loads for Comment [LA60]: Let's keep 120
prolonged periods, may extend shift sessions to 3 hours. Comment [LA61]: The guidelines
Comment [LA62]: With Safety
4.4 The ratio of duty periods to breaks when providing ATC service
Comment [LA63]: Lower tfc dens
• Breaks within a duty period should be planned according to expected workload,
Comment [PB64]: At DSNA we us
complexity of ATC provision, time of the day, type of rostering system. The minimum
duration of a break should be 30 minutes. Comment [LD65]: Beforehands to
• Breaks should be more frequent during night shift (and may be shorter) Comment [LA66]: This sentence
• Beyond the need for a 30-minute break, the enforcement of a specific ratio of duty period
to break is not as essential as it relates heavily to the length of service. Comment [PB67]: This value will
• For fatigue it is better a shift of 4h30 with 2h of sector time and break of 30 minutes and Comment [LA68]: To investigate
2h of sector time (ratio of 80% work and 20 % break) rather than an enforcement of 25 %
Comment [LA69]: And should be
break on a shift of 11h.
Comment [PB70]: We use this va
4.5 Minimum Rest Periods Comment [LD71]: We don´t do th

• The rest period after a duty period should be 11 hours to allow for adequate time that Comment [LA72]: Example for
includes rest, sleep, meals, preparing for sleep and personal administration. Comment [VLS73]: At Austro
Comment [PB74]: We use this va

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• It is recommended that this principle should not be deviated from which often occurs in
Comment [LD75]: Not in ACG – w
practice e.g. allowing ATCOs to decide if they want a shorter recuperation time. With
allow shorter recuperation times.
commuting, meals… etc… this is generally not enough to ensure 8 hours sleep. The
motivation of extra income or condensed shift allowing longer period off after a cycle are Comment [LA76]: The comment
not good trade-offs against fatigue and it is better to enforce a strict rule. clarified - it can be reduced only by
ATCOs in ACG

4.6 Maximum consecutive duty periods encroaching the night time, if Comment [LA77]: ENAV did a
scientific study that reduced the 11
applicable, depending upon the operating hours of the air traffic 8h
control unit concerned Comment [LA78]: The initial roste
plan is at 11 but allows the local
• Maximum consecutive ATCO duty periods encroaching the night period (00h to 6 as rostering to go down to 8h
described by European Aviation Safety Agency (EASA), should not exceed 2, provided
that they are followed by at least a 48-hour rest period by the end of the second ATCO Comment [LD79]: SOLL Plan Wie
duty period encroaching the night time. When is only 1 duty period (day vs night) shift ….. max 2 nightshifts
IST Plan Wien: max. 3 nightshifts
• Some ANSPs would argue that they encroach the night-time just for 30 minutes or an
SOLL Plan GIKLS: nicht geregelt;
hour and this limitation is extreme for them but in the development of good practice and IST Plan GIKLS: max. 3 Dienste, die i
the introduction of Fatigue Risk Management System (FRMS) the first step of prescriptive die Nacht hineinreichen dürfen
limits need to be absolute. Later on when data capture will be in place, an optimal FRMS GIKLS: Öffnungszeiten ab 05:30am
could be put in place, which demonstrates the acceptable level of derogation. und Dienstzeiterweiterungen bis na
Mitternacht;

4.7 Minimum rest period after a duty period encroaching the night time; HF RL 00053
• Upon the conclusion of a period of night duty, any ATC personnel shall be rostered a Comment [LA80]: In Vienna base
sleeping day and. on ATCO will is allowed to have 3
o After 1 night shift: next day shift 1 night free from duty (no duty starting before Comment [LA81]: It is under
9.00) Next shift should start after one free night and not before 9 (safety exceptional condition
assessment should define if 9 is replaced by diff hour e.g. 8)
Comment [LA82]: Fabrice to clari
o After 2 or 3 consecutive nightshifts or more: Minimum 2 nights free from duty
- is it rec also after 1night shift 48H
(no duty starting before 9.00) and no morning shift before 72 hours of rest.
o Comment [LA83]: To receive from
• The sleeping day is not a day off. After a night shift ending at 7 or 8 AM the period from 7 Alberto ENAV no that are diff for da
or 8 till the next morning is just to recover for a sleep deprivation for the night duty. The Comment [LD84]: We don´t do th
day off will start day + 1 of the ending time of the night shift.
Comment [LA85]: It is allowed bu
through the swap
4.8 Minimum number of rest periods within a roster cycle
Comment [LA86]: We need to
• Operational staff shall be rostered for a minimum 2 sets of 2 or more consecutive days off clarify because it looks like you do n
per cycle. Where possible, 3 sets of 2 consecutive days off per cycle is recommended. Comment [LD87]: What does this
• It is important to ensure regular weekends are embedded in roster cycle to enable the mean – pls explain!? Is it assuming o
ATCO to unwind and recover from fatigue. Formatted: Indent: Left: 3.17 cm
No bullets or numbering
Comment [LA88]: Maybe we put
visually all the bullet points to bette
Comment [LA89]: The duty roste
clarification (see discussion on
Comment [LD90]: 4x47h per mon
in the planned shifts (not the actual
Comment [LA91]: The plan is
respecting - during swaps it can
Comment [VLS92]: A lot of this
seems arbitrary. What about return
Comment [LA93]: Good question
but not for this doc (you have the 60

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5. ATC APPLICATION OF THE 8

PRINCIPLES
5.1 (EC) 2017/373 requirements & current rostering practices
In different countries when fatigue is based on national laws and collective
agreement, this sets the limits for a prescriptive approach. Consequently, ANSPs’
rostering systems/practices will fall short of the requirements of the (EC) 2017/373.

5.2 Monthly roster cycle and condensed shifts

When there is only a monthly limit of hours and a person takes the second half of the
month as holidays, the person may have many shifts for the first two weeks. This
nd
Comment [LD94]: We do allow th
does not align with the 8 principles because holidays are foreseen for 2 half of the in ACG – swapping shifts is only
months does not mean more work can be scheduled and will not impact fatigue. restricted as mentioned in HF RL 00
so it would be possible to have a
bunch of shifts in the first half of the
5.3 Seasonality month on minimum rest periods;

ATC contexts experiencing high seasonal variability, ATCOs have less workload in
the winter because of less traffic and in the summer, workload is higher because of
increased traffic. In cases of seasonal traffic, having for example 3 days off every 4
days in winter and autumns does not justify only one day off every 10 days for the
summer. Hours needed to work or days off should not be averaged over the year
although the average may be within the limits.

5.4 Non Ops duties

ATCOs are often tasked for safety duties, management duties, training and Comment [LD95]: This poses a
operational project development. Some ANSPs are not rostering ATCOs for these problem to the LAUs – we don´t hav
tasks and not ensuring the 8 principles are taken into account before allocating the the people there to assign extra non
other duties time. Once the operational roster is issued, the time off is filled with ops shifts for every duty.
several hours for other services. It is recommended, that non-ops duties are included
as part roster to ensure that the fatigue principles are respected.

What we want to say (and rephrase) is that other non ops duties need to be planned
in the roster.

5.5 Stand by Duties

Comment [VLS96]: In 2021, Aust
When there are staff shortages, to be able to cover all sectors, stand by duties are Control followed exactly this. It did
often seen as a possible solution. ATCOs are rostered for several standby shifts a not work and resulted in burn out,
month and on the day there is a dynamic management of available staff and workload overloads and a much more stretch
so only a few are called. The standby shifts done or not done are considered as duty work force.
times when designing the roster.If the standby is not carried out then its not affecting
Comment [LA97]: Adjusted to
the fatigue At the end of the month, only the realized standby are counted as working
reflect the correct way to use stand
to respect the rostering limits. Science has demonstrated that unrealized on-call
shifts
duties are producing fatigue and should be counted as well. (Wuyts, J 2012). Stand
by duties should be part of a risk assessment to demonstrate how to count them. We Comment [LD98]: Austro Control
recommend only one stand by shift per month per ATCO. did not utilise a safety assessment f
this, but we should have. We agree
On call duties on site or at home are however accounted into the fatigue limits. that they are needed. A standardise
matrix could be used.
Comment [VLS99]: See Operatio
Risk Matrix device example (from Le

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5.6 Arrival times

ATCOs are rostered and arrive at the ATSU and they may be released, as they are
not required to work as planned. It is recommended that these planned duty hours
although not working hours should be counted.

5.7 Mandatory Training

ATCOs are required to follow several mandatory training and internal session such as
TRM, CISM refreshers etc. It can be the case, to respect the limits when ATCOs are
taking those courses in busy periods and consequently exceed the monthly limits at
that time. This may result in counting the training at favorable times in winter or next
to holidays even if they are realized at other periods.
It is recommended, that mandatory training is treated not as an administrative task
but as a safety task and that, fatigue management principles are respected to ensure
staff are fit for duty.

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Comment [LA100]: See what we

6. ADDITIONAL CONSIDERATIONS can add for OJTIs
The following are some additional guidelines to take into account when managing shift Comment [LA101]: 50/50 for OJT
schedules and are based on good practice in the European ANSP Community. in NATS
Comment [LA102]: Mahiri to pas
6.1 Rostering and staffing the NATS practice

Rostering and staffing are closely linked. The implementation of a rostering system should be Comment [LD103]: Do we have a
done to improve safety, limit fatigue, and not hide staff shortages. Several recommendations method for arriving at a baseline?
are not possible if a severe shortage of staff exists. Even if not specified in the (EC) 2017/373, Where are we starting from? Is ther
an evaluation and assessment of appropriate staffing levels should be the first step before a formula? For example, number of
implementing a rostering system. staff for xx% of MV plus xx% for leav
and training etc?
6.2 Age
Comment [LA104]: Check old
Age should be considered as older controllers may become more tired from shift work. Less LAMPS/CHAMPS formulae
night shift may be advisable as controllers approach retirement age. Age amenities
(reduction of night shift) should be envisaged. Comment [VLS105]: Is there an a
specified here? Evidence ranges
across the board and we could
probably amalgamate this to produ
6.3 Sleeping after night shift some recommended guidelines

Priority should be given to sleeping after a night shift. Part of the education on fatigue and Comment [LA106]: I do not know
sleep should support this factor. A night shift worker has a natural tendency to do other things there are various ages thresholds in
before thinking about sleeping. In addition, to the priority to sleep, the longer a person is different ANSPs
awake after sleep deprivation, the less efficient will be his/her sleep. Calling the day Comment [LA107]: There are no
immediately following the night shift a sleeping day also helps to remember the priority of studies to relate age to the cognitiv
sleep. abilities (or I do not know them) _ if
Sleeping day: Always indicate the sleeping day in a roster (it is a daytime for sleeping) and yes of course we add in here
not a day-off as the deprivation of sleep at night has to be recovered.
Comment [VLS108]: This should
expanded more. A large issue aroun
fatigue is the burden of in-stability.
6.4 Schedule stability We have further information and
ideas in this regard
Avoid as much as possible changes in the schedule.
Comment [VLS109]: Ideally, it
should be predictable up to 3-4
6.5 Schedule predictability months in advance so as to plan
holidays and extended periods away
Time of day for potential duty should be predictable and consistent and the number of Can we be more specific about how
consecutive days that an individual may be subject to be assigned unscheduled duties should ANSPs could resolve this? Perhaps
be limited. with advice on disruption
Comment [LD110]: Exactly! I wou
6.6 Shift Structure love to have a “fully implemented
roster” (don´t know the correct term
• Fixed forward Rotating: Where applicable, fixed forward rotating roster principles should for that) – where you already know
be applied, e.g. Morning shifts, followed by afternoon shifts, ending with night shifts and
off days (Cabon et al, 2002, Cruz 2002). Backward rotation should be prohibited. Comment [LA111]: 6 months
• Fast rotation: fast rotation between shift should be favour Comment [LA112]: I will look how
• Number of consecutive morning shifts should also be controlled: we can straiten it up
o Starting between 4.00 and 6.00: Maximum 2 and Maximum 3 if the duty start time
Comment [LD113]: We still allow
is delayed of at least 1 hr compared to the day before them to do this – It is not designed i
o Starting between 6.00 and 9.00= maximum 3
o Starting between 4.00 and 9.00: Maximum 4 starting later every day (1 hour of Comment [LD114]: We should
evaluate if we could change to a fixe
delay at least per day)
fast forward rotating roster – or wh
• Rest after morning shifts: 1 night minimum free of duty before an afternoon or a night
shift Comment [LD115]: We don´t do
• Rest time between 2 consecutive morning shifts: Should not be lower than 24hrs. this – we only look if the at least 11
are in between. But you can also do

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6.7 Additional considerations

Comment [VLS116]: I feel like the
The following are some additional considerations based on good practice within the European are some additional considerations
ANSP community. not mentiond:
• Only one night shift in a row
1.How can ANSPs monitor Fatigue
• All stand by duties (realised or not) counted 100% of service time.
2.Should guidance be issued abou
• Night shift no longer planned after a certain age without financial impact. best practice for capturing this
• Swap and exchange of shift only possible with another ATCO in the same condition of information?
resting and shift exposure. 3.There is not proactive guidance
• Always one real weekend (Saturday Sunday) per month completely free from duty on the use of team resource
embedded in the planning of ATCOs. management skills or on the use
data analysis
4.Time in Position tools should be
mandated and linked to other
information
5.What happens ‘within a shift’ is
not specified so well other than
‘maximum 2 hours’
Comment [LA117]: Good points -
Alberto - maybe we limit the scope
monitor with the roster is bringing
fatigues or not
Comment [LA118]: Anything Lea
(or anyone else) that you can sugge
is welcomed
Comment [VLS119]: Do we need
special section governing ‘single
person operations’ in towers?? I fee
like this is almost completely ignore
Comment [LD120]: True and yes,
we should have that – there must b
other considerations when you are
completely alone; e.g. shorter time
Comment [VLS121]: Rules
governing the limits on overtime?
Although mentioned often some of
should be banished outright or at le
Comment [LD122]: For the
moment we are (still) dependent on
people doing overtime (sad to say…
and probably a lot of other ANSPs
have the same dilemma – so it wou
Comment [LA123]: The monitori
of time in position is important
through a tool
Comment [VLS124]: Additional
duties such as OJTI or Supervisor? C
we expand to cover these roles?
Comment [LD125]: Could be
mentioned, but makes no difference
in my opinion for duty rostering. Th
same rules should apply to all
Comment [LA126]: Yes agree - w
focus on ATCOs at the moment - I w
capture others SUP etc, ATSEP, AIS i
a broder statement in the doc

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SPO – add in something (On call etc)

7. CONCLUSIONS
The rules on fatigue can be interpreted differently. To improve fatigue management, there is a Comment [LD127]: ??? We alrea
know what EU regulations shall be
need for standards/recommendations, on rostering practices. These guidelines have taken
applied – I don´t get the point??? W
into account the key requirements from these regulations/standards together with suggestions
have the national legislation, the EU
on how the eight shift work fatigue prescriptive limits could be applied. legislation and then the internation
SARPs from ICAO???
In designing any shift work, practices or schedules an understanding of the regulatory
requirements and the legal framework, that should be applied, is required as it underpins the Comment [LA128]: Valid comme
constraints that the shift schedules needs to operate. It is necessary to understand and have we will clarify - see below also
an interpretation on: Comment [VLS129]: The questio
• What EU Regulation should be applied? is valid. 373 tells us to use ICAO 996
• Are these regulations transposed into National Regulation? as a guide. But it does not tell us tha
• What national regulation and working agreements needs to be considered? we must apply it. 373 only tells us to
demonstrate an FRMS exists.
Rostering within the limits of the 8 shiftwork fatigue prescriptive limits indicated in (EC) Comment [LD130]: They don´t ha
2017/373 should shall be considered a prescriptive approach and provides the constraints to be transposed as they are directly
to build a rostering system. In addition, the following considerations should be taken into applicable – right?
account:
o It is necessary to consider the scientific evidence when developing a fatigue efficient Comment [LD131]: This is not a
rostering system. suggestion – this is hard law, isn´t it
o Training should be provided to be aware of the scientific principles affecting fatigue and Comment [VLS132]: Yes I believe
sleep science to support developing a rostering system and staff consultation. the intention was to make this a har
o The selection and the regular revision of an appropriate structure and values of the law
rostering system. Comment [LD133]: Pls provide us
o Consultation with staff who will be subject to the rostering system, or, as applicable, with scientific papers and studies in
their representatives, during its development and its application. this regard.
Comment [VLS134]: We have a
In addition to operational knowledge, scientific principles used to construct ATC rosters and in
considerable collection and planned
applying prescriptive limits should provide evidence that those limits are not exceeded and
research to contribute.
that requirements are met. The process should be data driven from their own real and local
data. Collection of data and demonstration of the impact of fatigue risk in the Safety Comment [LD135]: Already
Management System(SMS) will enable ATSUs on a second step to adjust those limits and mentioned in ATS.OR.320(b) – no
move towards an optional FRMS. need to double prescribe it here
Comment [LA136]: ok
Comment [VLS137]: General
comment:

Can we have a section about

recommended guidelines for off-
setting boredom/monotony or
mention the use of fatigue coping
mechanisms such as use of digital
devices?

I think we should have more

recommendations for where in an
organisation an FRMS should exist (
Safety? Governing all operational
departments etc?

We need this to apply further than

just ATCOs.

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Wuyts, J., De Valck, E., Vandekerchove, M., Pattyn, N., Exadaktylos, V. Haex, B., Verbraecken, J.
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CURRENT HTML LINKS REGULATIONS etc.

Regulation Link
Working https://eur-
Time lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2003:041:0026:0032:EN:PDF
Directive
SIMAP and https://eur-lex.europa.eu/legal-
Jaeger content/EN/TXT/PDF/?uri=CELEX:62002CJ0151&from=IT”
judgement:
2017/373 https://www.easa.europa.eu/downloads/125141/en
ICAO ESAF https://www.icao.int/ESAF/Documents/meetings/2016/Air%20Traffic%20Services%20
recommend System%20Capacity%202016/ATNS-
ations: Guidelines%20to%20reduce%20fatigue%20in%20operational%20environment.pdf

ICAO doc https://www.icao.int/safety/fatiguemanagement/FRMS%20Tools/Doc%209966.FRMS.

9966: 2016%20Edition.en.pdf

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ACROYMNS AND ABBREVIATIONS

ATC Air Traffic Control

ATCO Air Traffic Controller
ATSUs Air Traffic Services Units
EASA European Aviation Safety Agency
EC European Commission
ESAF Eastern and Southern African
EU European Union
FRMS Fatigue Risk Management System
ICAO International Civil Aviation Organisation
ILO International Labour Organisation
SMS Safety Management System
WOCL Windows of Circadian Low

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 2019

1.1