Fatigue Risk Management System (FRMS) Exemptions

Secondary reference. This is an operator-level regime, summarised here so you know what it means when a schedule runs on an FRMS exemption. The authoritative sources are CARs 700.200–700.259, AC 700-046 — FRMS Requirements, and AC 700-045 — Exemption and Safety Case Process.

What it is

The prescriptive rules — the 700.28 tables, rest periods, reserve limits and so on — are a one-size-fits-all safety net. An FRMS lets an operator depart from specific prescriptive limits for a defined flight, if it can show, with data and science, that the way that flight is actually run is no more fatiguing than the prescriptive limit would be.

“Flight” here also means a series of flights flown by the same crew in one or consecutive flight duty periods (CARs 700.201).

How an operator gets there (700.200, 700.206)

1. Establish and implement the two core FRMS components — the fatigue risk management plan and the fatigue risk management process — plus, over time, an FRMS promotion program and a quality assurance program.
2. Send a Notice of Intent to the Minister (700.206) stating that the plan and process are in place, describing the flight, listing the exact provisions to be departed from, describing the variance, and citing the scientific studies showing the variance won’t adversely affect crew fatigue and alertness.
3. On sending a compliant Notice of Intent, the initial exemption applies — the operator can begin flying the flight under the exemption.
4. Keep the required fatigue analysis available to the Minister for review every 90 days (or at the end of a shorter period).

Staying exempt (the safety case and audits)

The initial exemption is time-limited. To keep flying under it the operator must build and submit a safety case — the evidence that the variance is being managed — pass an initial audit, and then run continuing audits and variance monitoring for as long as the exemption is used. If the operator can’t keep the FRMS running to standard, the exemption stops and the flight reverts to the prescriptive limits.

What it means for a crew member

• Your operator can only depart from the specific provisions named in its Notice of Intent, and only for the specific flight it applies to — everything else still runs on the prescriptive rules.
• The exemption rests on the operator collecting and acting on fatigue data, including crew reports. An internal fatigue reporting route is part of the FRMS.
• You still have the 700.26 duty to declare when you’re not fit for duty, and the FRMS doesn’t change that.