Fatigue Risk Management System Components and FAA Approval

Getting FAA approval for a fatigue risk management system means satisfying 14 CFR 117.7: an aviation certificate holder must build a program with six specific components, document it with operational and scientific data, and clear a multi-phase FAA review that ends in an Operations Specification A318 authorization. Approval lets the operator exceed the standard flight-time and duty-period limits in Part 117, but only where the FAA agrees the system delivers “at least an equivalent level of safety against fatigue-related accidents or incidents” as the prescriptive rules it replaces.¹

The Six Components Your FRMS Must Contain

Section 117.7 lists six required elements, and an application missing any of them will not move forward.

A fatigue risk management policy issued by senior leadership that sets the program’s objectives and assigns shared responsibility between the organization and its crew members.
Education and awareness training covering sleep fundamentals, circadian rhythms, nutrition’s effect on alertness, fatigue countermeasures, and how to recognize impairment in yourself and coworkers.²
A fatigue reporting system that lets crew members flag exhaustion concerns without fear of discipline.
A monitoring system that tracks flightcrew fatigue through operational data, surveys, or objective measurements.
An incident reporting process that captures fatigue-related events and near-misses for pattern analysis.
A performance evaluation process that regularly checks whether the FRMS is meeting its safety targets and adjusts when it is not.¹

The regulation is not asking for policies on paper alone. Monitoring, incident reporting, and performance evaluation together create a feedback loop: if the data shows a spike in fatigue-related events, the organization has to investigate and change something. That self-correcting design is what distinguishes an approvable FRMS from a static safety manual.

Building the Application Package

Preparation is where most of the work sits. The organization has to compile evidence that its proposed system will manage fatigue at least as safely as the prescriptive rules it wants to displace. That means gathering actual duty schedules, sleep-wake data from crew members, historical fatigue reports, and any incident records where exhaustion played a role.

Biomathematical fatigue models often carry significant weight in that record. FAA Advisory Circular 120-103A describes these as commercially available computer programs that estimate alertness based on sleep history, circadian timing, and duty schedule information. Using a model is not required, but the AC treats it as a valuable tool for rapidly estimating fatigue when evaluating new routes or schedule changes. Operators who use modeling must justify the choice of model and define all assumptions and parameters, and the AC is explicit that a model is one component of an FRMS, not a substitute for the whole system.³

The package also has to identify the specific risk assessment tools the organization will use. Some operators incorporate the Psychomotor Vigilance Task, a reaction-time test that objectively measures alertness deficits, though the FAA does not mandate any single instrument. Everything else in the file should describe the operational environment, the mitigation strategies, and the procedures the organization will follow once the system is running.

How the FAA Reviews and Approves the System

The FAA works through a five-phase evaluation described in AC 120-103A. Each phase must be completed satisfactorily before the next begins.³ Reviewers examine the scientific basis of the proposal, validate any biomathematical modeling, and test whether the system can genuinely maintain safety when duty-time limits are exceeded. Expect requests for additional information along the way, particularly around how the program will handle operational disruptions and irregular schedules.

When the FAA is satisfied, authorization is issued through Operations Specification A318. That OpSpec formally permits the certificate holder to conduct flight operations under its FRMS for the specific regulatory provisions identified in the approval, and it carries limitations and conditions tailored to that operation.³ The FAA sets the duration of the OpSpec, and the authorization requires the certificate holder to amend its operations manual so that schedulers, dispatchers, and crew members all follow FRMS procedures whenever the system applies to a flight.⁴

Reporting Protections the FAA Expects to See

An FRMS only functions if crew members actually report when they are too tired to fly safely. The reporting channel required by 14 CFR 117.7 must let them do that, and the FRMS policy should state clearly that reporting does not trigger discipline.¹

Many operators layer the Aviation Safety Action Program on top of that requirement. ASAP is a partnership between the FAA, the certificate holder, and typically a labor organization, with an Event Review Committee that handles reported safety issues on the principle that problems are not resolved through punishment.⁵ ASAP provides enforcement-related incentives that encourage voluntary reporting, and submitted information is protected from public disclosure.⁶ Without protections like these, the data feeding the FRMS dries up and the system becomes a formality.

Keeping the Approval Once You Have It

Approval is the beginning of the obligation. The performance evaluation component requires ongoing assessment of whether the fatigue controls are working: regular internal audits, review of safety performance indicators, and revisions when the data shows problems. Rising fatigue-related incidents call for investigation and corrective action by the operator, not a wait for regulator attention.

Records matter here. Operators must maintain fatigue reports, data logs, audit findings, and corrective actions. Specific retention periods and record-keeping requirements are defined in each organization’s approved FRMS plan and any conditions attached to its OpSpec A318. Any deviation from the approved plan needs to be documented immediately, along with the corrective steps taken.

The cost of drifting out of compliance is concrete. FAA civil penalty amounts are adjusted annually for inflation. As of 2025, a certificate holder that is not an individual or small business faces penalties of up to $75,000 per violation, while individuals and small businesses face up to $17,062 per violation depending on the nature of the offense.⁷ Beyond fines, the FAA sets the duration of each OpSpec A318 and can revoke it if the certificate holder fails to meet the conditions of approval. Losing the authorization means reverting immediately to the standard prescriptive limits under Part 117, which can force significant schedule changes overnight.

A Note on Other Modes

This approval pathway is aviation-specific. Railroads work under a separate Fatigue Risk Management Program regime in 49 CFR Parts 270 and 271, with its own plan submission and consultation rules.⁸ Commercial trucking has no equivalent: FMCSA governs driver fatigue almost entirely through prescriptive hours-of-service limits, and there is no regulatory pathway for a carrier to receive an approved FRMS in place of those limits.⁹ If you are outside aviation, the process on this page will not apply to your operation.

1
eCFR. 14 CFR 117.7 – Fatigue Risk Management System
2
Federal Aviation Administration. Advisory Circular AC-120-FT – Fatigue Training
3
Federal Aviation Administration. Advisory Circular 120-103A – Fatigue Risk Management Systems for Aviation Safety
4
Federal Aviation Administration. N 8900.346 – OpSpec A318, Approval of a Fatigue Risk Management System (FRMS)
5
Federal Aviation Administration. AC 120-66B – Aviation Safety Action Program (ASAP)
6
Federal Aviation Administration. Aviation Safety Action Program
7
Federal Register. Revisions to Civil Penalty Amounts, 2025
8
eCFR. 49 CFR Part 271 Subpart G – Fatigue Risk Management Programs
9
Federal Motor Carrier Safety Administration. Hours of Service (HOS)