“The DGCA’s proposal to introduce a parallel, ‘flexible’ FRMS framework via a subordinate instrument like an Operations Circular is deeply disconcerting,” the Federation of Indian Pilots said. File
| Photo Credit: The Hindu
Pilot unions and the aviation regulator are on the brink of another confrontation as the former have rejected a new airline-controlled data-driven approach for managing crew fatigue arguing that it undermines the duty hours mandated earlier this year by the Delhi High Court and was “dangerously premature” for a country with poor safety oversight.
The comments are part of replies submitted before the DGCA after its September 3 e-mail to airlines and pilot unions seeking their comments to a draft advisory on implementation of Fatigue Risk Management System (FRMS), which is a data-based approach that monitors and manages fatigue-related safety risks to ensure adequate alertness among crew. Each airline develops and monitors its own FRMS.
“The DGCA’s proposal to introduce a parallel, ‘flexible’ FRMS framework via a subordinate instrument like an Operations Circular is deeply disconcerting. The proper and legally mandated instrument for such a fundamental change in safety policy is a Civil Aviation Requirement (CAR), which ensures legislative rigour, transparency, and a statutory right for all stakeholders to be heard through a wide-body consultation process,” the Federation of Indian Pilots (FIP) wrote in its reply, which has been reviewed by The Hindu. It said such a step could result in “degradation of safety”.
They have objected to the introduction of FRMs months after Delhi High Court laid down new limits for duty and rest periods. In its February 24, 2025, order, the court mandated an increase in weekly rest pilots from 36 to 48 hours starting July 1. Airlines are required to also curtail night flying for pilots from November 1.
The FIP asserts that the FRMS is “dangerously premature” for the Indian aviation ecosystem as the UN aviation safety watchdog International Civil Aviation Organisation (ICAO) states that effective FRMS oversight demanded well-trained State inspectors and adequate resources and also warned that without robust prescriptive fatigue regulations and regulatory support, the safety benefits of FRMS may be jeopardised.
The Union demands that the DGCA must first demonstrate full compliance with the new Court-ordered norms which are yet to be fully implemented.
Another pilots’ body, Airlines’ Pilots Association of India has submitted that the airlines who will each develop their own FRMS tool had failed to demonstrate “just culture” at their organisation such as by re-classifying pilots who report fatigue as “sick”, amounting to a penalty as this results in loss of pay.
Both unions have said that statistical models used in FRMS tools that use scientific research on sleep and circadian rhythms to predict fatigue and alertness levels after combining organisational data such as shift length or rest periods with human biology can be manipulated by airlines who can easily select filters to control the outcome of the tools.
They have demanded that pilot unions be made part of the every airline’s Fatigue Safety Action Group (FSAG), and in all DGCA-level fatigue oversight committees and task forces as an airline- appointed senior pilot thwarts the goal of independent monitoring.
Published – September 16, 2025 06:58 am IST
