.  Provide adequate resources for the continuing effectiveness of the FRMS
.  Provide mechanisms for ongoing consultation with stakeholders, the competent authority and crew representatives. Should include a Fatigue Management Steering Group to coordinate all fatigue management activities. e) “A commercial operator should work cooperatively with the competent authority.” 
What however is of note is that there is no guidance from ICAO or EASA on how to meet these requirements and to what standard. Also the operator must develop the components tools and processes for the management of fatigue-related risk and integrate these effectively into an operator’s SMS. The starting point before we address these other
S. Stewart, F. Koornneef, R. Akselsson, and C. Turner  - HILAS 2009
issues is to place the components of the FRMS, as outlined, into an ICAO SMS (9859 version 2, 2008) format that is readily understood by airlines.

1.10 ICAO SMS main components
ICAO has formulated a body of work (ICAO Safety Management Manual (SMM) Document 9859) that provides guidance for the development, training, documentation and communication of a Safety Management System into an Airline’s business model.
ICAO defines an SMS as:
safety, through the application of scientific principles based on human physiology and knowledge, determined from data collection, risk investigation and analysis. In doing so it allows greater operational flexibility of crew scheduling, in comparison with prescriptive limitations of flight and duty time. The FRMS thus forms an integral part of easyJet’s established Safety Management System (SMS). 
The FRMS has been adapted to manage the operational risk(s) of easyJets flight time specification scheme(s) for flight and duty time limitations and rest requirements.

S. Stewart, F. Koornneef, R. Akselsson, and C. Turner  - HILAS 2009
Fatigue Risk Management applies standard management control principles in order to mitigate fatigue risk in airline operations, through processes based on shared responsibility amongst management and crew members acting within a just culture. The component elements of FRMS from EASA NPA 2009c can now be represented against the SMS structural components (Table 1).

1.11 Management Framework for fatigue related risk based on ICAO
The essential elements of an FRMS based on the ICAO draft guidance and EASA NPA 2009c can be presented against the ICAO SMS framework (adapted from EASA NPA 2009c and ICAO 9859 (2008)) as in Table 1.

Table 1. FRMS Elements linked to an adapted ICAO SMS structure. 
The implementation of an FRMS capability requires the development of capability around the SMS structure for fatigue related risk.
S. Stewart, F. Koornneef, R. Akselsson, and C. Turner  - HILAS 2009
This structure links the core operational activities of a Safety Management System as defined by ICAO; namely safety risk management and safety assurance to processes for the detection, monitoring and mitigation of fatigue related risk. The next step is to focus on the precursors and consequences of fatigue related risk and develop a system model based on risk management process that can be used as a basis for an FRM system implementation.
　
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