Fatigue risk management in aviation

Flight crew fatigue is a hazard that can contribute to aviation incidents. Fatigue risk management refers to the methods used by air operators to address flight crew fatigue.

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Approaches to fatigue management

New requirements for managing flight crew fatigue were published on December 2018 in the Canada Gazette, Part II with a delayed coming into force date. The amended regulations include 2 approaches to fatigue management: prescriptive and performance-based. Once the regulations are in effect, the Department of Justice will publish them in the consolidated version of the CARs.

You can find a summary of changes in 9 key areas of the regulations in Annex A of the Regulatory Impact Analysis Statement.


Under the prescriptive approach, air operators and flight crew comply with set requirements that define:

  • maximum hours of work, flight time, and flight duty periods
  • minimum rest periods and time free from duty for flight crew members

In addition, air operators who are subject to Subpart 705 of the Canadian Aviation Regulations must manage fatigue risks under their Safety Management System.


This approach allows air operators to vary from specific flight, duty, or rest provisions of the prescriptive requirements for a flight or series of flights using a fatigue risk management system (FRMS) to predict and prevent flight crew fatigue.

Transport Canada will not approve the FRMS, however safety cases will require approval in order to use a continuing exemption.

The Division V FRMS regulations do not apply to an air operator who complies with the prescriptive flight, duty and rest requirements.

An FRMS has 4 components:

  1. The plan – the operator explains how their FRMS works, who is responsible for it in their organization, and how the FRMS will be measured and monitored.
  2. The process – the operator documents and uses a data-driven process to identify, assess, and mitigate fatigue risk in their operations.
  3. The promotion program – the operator promotes fatigue risk management through competency-based training and communicating fatigue-related information.
  4. The quality assurance program – the operator audits and reviews their FRMS to improve its effectiveness and maintain compliance with the regulations.

Applying the new regulations

Different requirements apply depending on which approach to fatigue management you use.

Table 1: New requirements under the CARs Part VII operating rules implementation
CAR Part VII Operating Rule Prescriptive approach Performance-based approach
Subpart 702 (Aerial Work) New Division X Optional – comes into force December 12, 2020
Subpart 703 (Air Taxi Operations) New requirements come into force December 12, 2022 Optional – comes into force December 12, 2022
Subpart 704 (Commuter Operations) New requirements come into force December 12, 2022 Optional – comes into force December 12, 2022
Subpart 705 (Airline Operations) New requirements come into force December 12, 2020 Optional – comes into force December 12, 2020
Medevac Flights New Division IV Optional – coming-into-force date depends on operating rule

You can find workbooks, guides and presentations in the Fatigue Risk Management System Toolbox.

Advisory Circulars (ACs)

Key references

Other fatigue management resources

Contact us

Email: TC.FCFM-GFEC.TC@tc.gc.ca