U.S. Department

of Transportation

Federal Aviation

Administration

Advisory

Circular

Subject: Fatigue Training Date: DRAFT

Initiated by: AFS-200

AC No: AC-120-FT

Change:

1. PURPOSE. This advisory circular (AC) presents guidelines for developing and 

implementing a fatigue training module for flightcrew members and personnel involved in 

scheduling and managing flightcrew members. These guidelines apply to certificate holders 

conducting operations under Title 14 of the Code of Federal Regulations (14 CFR) parts 117 and 

121. This AC presents guidelines for certificate holders who operate with a FAA-approved 

fatigue risk management system (FRMS), or are requesting FAA approval for an FRMS on the 

development of an FRMS education and awareness training program. This AC presents 

acceptable means, but not necessarily the only means, that certificate holders may comply with 

fatigue training requirements prescribed in part 117, § 117.11.

2. DISCUSSION. Each certificate holder conducting operations under part 121 must have a 

Federal Aviation Administration (FAA)-approved fatigue training module as prescribed in 

§ 117.11. The training module must focus on the certificate holder and flightcrew member’s joint 

responsibility for ensuring that fatigue does not affect a flightcrew member’s ability to report to 

work fit for duty and to operate a flight, or series of flights, with safety.

3. AUDIENCE. This AC applies to all part 121 certificate holders, employees of the certificate 

holder responsible for administering the provisions of part 117 including flightcrew members, 

dispatchers, individuals involved in the scheduling of flightcrew members, individuals involved 

in operational control, and any employee providing management oversight of those areas.

4. RELATED REGULATORY REQUIREMENTS. Title 14 CFR part 91; §§ 117.7, 117.11; 

and part 121.

5. RELATED READING MATERIAL.

• AC 120-100, Basics of Aviation Fatigue.

• AC 120-103, Fatigue Risk Management Systems for Aviation Safety.

• “Proposed draft” AC 120-XX, Fitness for Duty.
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6. DEFINITIONS.

a. Fatigue. Fatigue is a physiological state of reduced mental or physical performance 

capability resulting from lack of sleep or increased physical activity that can reduce a 

crewmember’s alertness and ability to safely operate an aircraft or perform safety-related duties.

b. Fit for Duty. Fit for duty means being physiologically and mentally prepared and 

capable of performing assigned duties in-flight with the highest degree of safety. This function 

also assumes the flightcrew member is properly rested.

c. FRMS. The FRMS is a management system for operators to use for mitigating the effects 

of fatigue in their particular operations. It is a data-driven process and systematic method used to 

continuously monitor and manage safety risks associated with fatigue-related error.

7. BACKGROUND. The FAA believes fatigue-based training requirements are critical to 

mitigating the risk of fatigue by ensuring that both flightcrew members and certificate holders 

understand the effects of fatigue on the safety of flight.

a. Fatigue Education and Training Program. Each certificate holder must develop and 

implement a FAA-approved fatigue education and training program designed to ensure:

(1) Flightcrew members are educated to the degree that they are able to understand how 

their personal behavior can unwittingly lead to fatigue and how to adjust their behavior 

accordingly.

(2) Employees involved in operational control and the scheduling of 

flightcrew members, or any employee providing management oversight of those areas, must be 

educated to the degree that they understand the effects of fatigue on the safety of flight and 

modify their scheduling practices accordingly.

b. Additional Training Programs. If a certificate holder chooses to have a FAA-approved 

FRMS, an additional training program must be developed and implemented which would be 

designed to address an alternate means of fatigue mitigation tailored to a certificate holder’s 

specific operation that provides an equivalent level of safety.

8. RECOMMENDATIONS.

a. Fatigue Training Program. The fatigue training program module must be a part of a 

certificate holder’s approved ground training curriculum. This training module should provide 

instruction and information in the areas of general fatigue science and fatigue countermeasures 

and should contain sufficient elements or events to ensure that a student will receive adequate 

training and knowledge as prescribed in § 117.11. At a minimum, the fatigue training program 

must include the following subject areas:

(1) FAA regulatory requirements for flight, duty and rest, and National Transportation 

Safety Board (NTSB) recommendations on fatigue management;

(2) The basics of fatigue, including sleep fundamentals and circadian rhythms;
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(3) The causes of fatigue;

(4) The effect of fatigue on performance;

(5) Fatigue countermeasures, prevention, and mitigation;

(6) The influence of lifestyle, including nutrition, exercise, and family life, on fatigue;

(7) Familiarity with sleep disorders;

(8) The impact of commuting on fatigue;

(9) Flightcrew member responsibility for ensuring adequate rest and fitness for duty; 

and

(10) The effect of operating through and within multiple time zones.

b. Subject Areas (Required Elements). The subject areas listed above, which are the 

required elements, must be contained in the fatigue training module and will be expanded on to 

contain subsets of information related to each required element. The following include some 

examples:

(1) FAA regulatory requirements for flight, duty and rest, and NTSB recommendations 

on fatigue management.

• Review of applicable parts 91, 117, and 121.

• Review of NTSB safety recommendations regarding fatigue.

• Effects of fatigue on flight operations.

(2) Basics of fatigue.

• Basic terms and definitions related to the science of fatigue.

• Basic sleep fundamentals.

• Overview of circadian rhythms.

• Signs and symptoms of fatigue.

(3) Causes of fatigue.

• Shift work.

• Workload.

• Cumulative duty.
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• Time zone changes.

• Illness and stress.

(4) The effect of fatigue on performance.

• Judgment error.

• Loss of situational awareness/reduced attention.

• Degradation of performance.

• Increased reaction time.

• Diminished memory.

(5) Fatigue countermeasures.

• Prevention.

• Adequate rest.

• Nutrition.

(6) Mitigation.

• Rest management.

• Rest facilities.

• Scheduling practices.

(7) Lifestyle influences.

• Nutrition.

• Exercise.

• Family life.

• Alcohol and stimulants.

(8) Familiarity with sleep disorders.

• Insomnia.

• Sleep apnea.
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• Restless legs syndrome.

(9) The impact of commuting on fatigue.

• Responsible commuting and acceptable commuting practices.

• Travel delays.

• Lack of adequate rest.

(10) Flightcrew member and certificate holder’s responsibility for ensuring adequate rest 

and fitness for duty.

(a) Flightcrew member responsibility.

• Responsibility in accordance with § 117.5.

• Rest accommodations and quality of rest.

• Personal strategies for preventing and managing fatigue risk.

• Responsibility to report fatigue.

• Fatigue recognition, personal assessment of fatigue, and identifying signs of 

fatigue in others.

(b) Certificate holder’s responsibility.

• Responsibility in accordance with § 117.5.

• Evaluation of flightcrew member’s fitness for duty.

• Actions in the event of a flightcrew member’s report of fatigue.

(11) The effect of operating through and within multiple time zones.

• Sleep phase shift.

• Circadian rhythm disruption (“jet lag”).

• Operations in westerly directions.

• Operations in easterly directions.

• Acclimation.

c. Fatigue Risk Management Training Program. Certificate holders who have a

FAA-approved FRMS, or are requesting FAA approval for an FRMS, must have an education 
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and awareness training program in accordance with § 117.7(a)(2). Like the training program 

prescribed in paragraph 7a, the FRMS training program module must be part of a certificate 

holder’s approved ground training curriculum. This training module should contain in-depth 

information and instruction regarding the certificate holder’s methods for fatigue prevention and 

mitigation. Below is a list of minimum subject areas along with subset information that should be 

contained in a certificate holder’s FAA-approved FRMS training program:

(1) Overview of the FRMS concept.

• Definition.

• Purpose.

• Structural components.

• Relationship to Safety Management System.

• AC 120-100, Basics of Aviation Fatigue.

• AC 120-103, Fatigue Risk Management Systems for Aviation Safety.

(2) Tools for an effective FRMS.

• Fatigue analysis methods.

• Identification and management of aviation fatigue drivers.

• Fatigue mitigation approaches.

• Positive safety culture.

(3) Components of an FRMS.

• Fatigue risk management policy.

• Education and awareness training.

• Fatigue analysis and reporting system.

• Fatigue monitoring methods.

• Fatigue-related incident reporting process.

• FRMS performance evaluation.

• Continuous improvement process.

(4) Roles and responsibilities.
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• Certificate holder responsibilities.

• Crewmember/employee responsibilities.

• FAA responsibilities.

(5) FRMS implementation.

• Policies and procedures.

• Organization and personnel.

• Fatigue Management Steering Committee.

• Tools and methods.

• Training and awareness.

(6) Safe scheduling policies and procedures.

• Proactive and adaptive fatigue mitigation.

• Work schedule oversight and monitoring.

• Crew augmentation.

• Circumstance beyond the control of the certificate holder.

(7) Records and reports.

• Schedule accuracy.

• Reports of fatigue by flightcrew members.

• Fatigue-related events.

(8) Continuous performance improvement process.

• FRMS performance evaluation.

• Work schedule modeling and fatigue risk analysis.

• Management and mitigation of fatigue risk.

• Assessment, feedback, and corrective action.

d. Training Requirement. The minimum prescribed training hours for a certificate holder’s 

approved fatigue training program, in accordance with § 117.11 are:
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• Five hours for initial training.

• Two hours for recurrent training.

NOTE: For certificate holder’s who have obtained or requesting FAA 

approval for an FRMS, the minimum training hours for the FRMS training 

program should be no less than those listed above (as prescribed by 

§ 117.11).

e. Continued Adequacy. The FAA recognizes that the study of fatigue and fatigue 

mitigation is ongoing. Changes may need to be made to training programs even after approval by 

the FAA. Accordingly, whenever the Administrator finds that revisions are necessary for the 

continued adequacy of an approved fatigue education and training program, the certificate holder 

must, after notification, make any changes in the program that are deemed necessary by the 

Administrator. The FAA anticipates that such changes would be implemented through the 

agency’s operations specifications as provided by § 119.51, which would give carriers an 

opportunity to provide input and appeal rights.

9. CONTACT INFORMATION. For more information about this AC, please contact the 

Air Transportation Division, AFS-200, at (202) 267-6188.

John. M. Allen

Director, Flight Standards Service