Submission - Independent Pilots Association

117.7 Fatigue Risk Management System (FRMS)Section 117.7(b) needs to be amended to include the following items:• The FRMS must be an equal partnership that includes the FAA, thecertificate holder and non-management pilot representative.• FRMS does not replace the regulatory scheme, its purpose is tosupplement adequate prescriptive rules.• Any FRMS must provide an equivalent or better level of safety and becentrally approved by the FAA. (One office at FAA headquarters should beresponsible for approving FRMS. This is the only way to provide a uniformFRMS approval scheme.)• FRMS should be limited to specific certificate holders’ data and scheduledcity pairs, which must be scientifically and then operationally validated byall stakeholders.• FRMS, like SMS, requires a commitment from the certificate holder’s seniormanagement team and a specified line of accountability in the organization.117.9 Schedule Reliability§ 117.9(a) Change 60 days to 30 days(a)(1)(modified) Its system-wide flight duty periods if the total actual flight dutyperiods exceed the scheduled flight duty periods by more than 15 minutes more than5 percent of the time, and(a)(2)(modified) Any scheduled flight segment that is shown to actually exceedthe schedule 20 percent of the time.35