ATC866

Although the Scheme for Regulation of Air Traffic Controllers’ Hours (SRATCOH), previously in Part D of CAP670, is no longer included as a requirement (following publication of ORS 9 Decision 6), it is still available as guidance, and most ANSPs use it. The purpose of SRATCOH is to ensure, so far as is reasonably possible, that controller fatigue does not endanger aircraft and thereby to assist controllers and ANSPs to provide a safe and effective service. The adjustment in regulations allows ANSPs to develop bespoke fatigue risk management systems if they wish. We would expect that any fatigue risk management system would (like SRATCOH did/does) allow for discretionary extension of duties (when a controller is not fatigued) similar to the discretion applied to flight crews. However, current FRM systems in ATC have historically been perceived as somewhat ‘rigid’, with an unjustified assumption that the CAA will take licensing action as a result of each and every any fatigue risk management breach. In reality the CAA reviews every breach report but will only take action where breaches are systemic or excessively repetitive, or where there is an indication that a controller may have continued to provide services whilst fatigued. The CAA recognises that that there will sometimes be circumstances when (for example) extending a duty is a sensible and pragmatic decision provided the controller does not feel fatigued. Example situations include facilitating a landing aircraft that would otherwise need to be diverted, or that was operating on a medical evacuation / organ transfer flight. Provided the event is reported with a clear explanation for the breach and includes reasonable and safe decision making, then the CAA will be sympathetic; licencing action is highly unlikely. Ultimately, it is the responsibility of each individual ATCO not to control when fatigued, but there is always scope for being flexible and adaptable when it is sensible to do so.