A Non-Intrusive Screening Architecture
to Strengthen Fatigue Risk Monitoring within ICAO-Aligned FRMS
This paper is intended to support technical discussion within IATA Safety & Flight Operations regarding emerging, non-diagnostic approaches to fatigue risk monitoring that align with ICAO Annexes 6 and 19, as well as ICAO Doc 9966.
The proposed architecture is explicitly framed as a screening and monitoring input within existing FRMS and SMS structures. It does not seek to introduce new certification requirements, medical determinations, or enforcement mechanisms, and is designed to remain compatible with Just Culture principles and airline governance practices.
Working Title:
A Non-Intrusive Screening Architecture to Strengthen Fatigue Risk Monitoring within ICAO-Aligned FRMS
Submitting Organization
ISSTA – International Sleep Science and Technology Association
Intended Audience
IATA Safety & Flight Operations, airline safety managers, FRMS program owners
Purpose
This technical working paper proposes a non-diagnostic, camera-based fatigue screening architecture intended to strengthen monitoring and safety assurance functions within ICAO-aligned Fatigue Risk Management Systems (FRMS).
The paper is submitted for technical discussion, not endorsement, certification, or operational mandate.
Problem Statement
While ICAO Doc 9966 emphasizes data-driven FRMS, airlines continue to face challenges in:
Continuous fatigue monitoring between roster design and post-event analysis
Non-intrusive data collection compatible with Just Culture
Scalable solutions that do not introduce new certification or medical determinations
Current approaches rely heavily on proxy indicators (duty time, sleep opportunity) that do not capture real-time fatigue manifestation during operations.
Proposed Contribution
Fast Screening Technology and Services (FSTS) is proposed as a supplementary FRMS monitoring input that:
Uses facial micro-features as physiological correlates of fatigue
Operates passively and non-intrusively
Produces probabilistic risk indicators, not fitness-for-duty decisions
Integrates with existing SMS / FRMS governance structures
Alignment with ICAO / IATA Frameworks
ICAO Annex 6 – supports safe operation through enhanced monitoring
ICAO Annex 19 – feeds hazard identification and safety assurance
ICAO Doc 9966 – strengthens FRMS monitoring and assurance pillars
IATA IOSA – provides supplementary evidence for fatigue risk controls
FSTS does not replace:
Flight Time Limitations (FTL)
Roster design
Aeromedical certification
Commander authority
Discussion Agenda
Clarify appropriate scope boundaries for fatigue screening technologies
Discuss acceptability criteria under Just Culture principles
Identify pathways for FRMS pilot programs under airline governance
Explicit Non-Claims
This paper does not propose:
Individual impairment determination
Medical or licensing decisions
Disciplinary or enforcement use
Replacement of existing FRMS controls
Global Policy and Regulation Committee, ISSTA
Global Headquarter: Luisenstrasse 55, 10117 Berlin, Germany
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