A Part 121 operator wants to implement a data-driven fatigue management approach that would allow flight duty periods exceeding the prescriptive limits in 14 CFR Part 117 Subparts B through D for certain routes. What must the operator do under 14 CFR 117.19?
- AObtain FAA approval of a scientifically validated Fatigue Risk Management System (FRMS) that provides an equivalent level of safety to the prescriptive rules
- BSimply notify the FAA in writing 30 days before implementation
- CPetition Congress for an exemption from Part 117 entirely
- DNothing is required as long as the crew consents in writing
Show answer & explanationAnswer & explanation
Correct answer: A. Obtain FAA approval of a scientifically validated Fatigue Risk Management System (FRMS) that provides an equivalent level of safety to the prescriptive rules
14 CFR 117.19 permits an operator to exceed the flight duty period limits of Part 117 only through an FAA-approved Fatigue Risk Management System (FRMS), which must be based on scientific principles and methods, and must be demonstrated to provide an equivalent level of safety to the prescriptive requirements.
Why the other options are wrong
- B. A simple notification does not satisfy the approval requirement; FAA review and approval of the FRMS is required.
- C. No congressional exemption process exists; the FAA itself approves FRMS programs administratively.
- D. Crew consent alone does not substitute for the required scientific validation and FAA approval.
Fatigue Risk Management System (117.19)
14 CFR 117.19 allows an operator to deviate from Part 117's prescriptive FDP/rest limits only through an FAA-approved FRMS, a scientifically validated program providing an equivalent level of safety.
- Alternative to prescriptive Subparts B-D limits
- Must be based on scientific principles
- Requires FAA approval and ongoing data monitoring
Memory trick: Science replaces the stopwatch only if the FAA signs off first.