Skip to content
SkyRosterBook a discovery call

Regulation · ATS.OR.315

Understand the fatigue-policy requirements.

Put ATS.OR.315 in context. Read the fatigue-policy and training requirements, then see where rostering software can support your organisation’s process.

The instrument

Regulation
(EU) 2017/373
Annex
IV, Part-ATS
Subpart
A, Section 3
Article
ATS.OR.315
Title
Fatigue
In force
Applied from January 2020

The article, verbatim

In accordance with point ATS.OR.200 (Safety Management System), an air traffic control service provider shall:

(a) develop and maintain a policy for the management of air traffic controllers' fatigue;

(b) provide air traffic controllers with information programmes on the prevention of fatigue, complementing human factors training provided in accordance with Sections 3 and 4 of Subpart D of Annex I to Regulation (EU) 2015/340.

ATS.OR.315, Regulation (EU) 2017/373, Annex IV (Part-ATS)

AMC1 ATS.OR.315(a), Fatigue Management Policy, verbatim

(a) The air traffic controllers' fatigue management policy should:

  1. declare the commitment to proactively and systematically monitor and manage fatigue and describe the expected benefits for the safety of operations;
  2. be signed by the accountable manager;
  3. address the mitigation of the operational impact of air traffic controllers' fatigue;
  4. be communicated, with visible endorsement, throughout the air traffic control service provider;
  5. include a commitment to:
    1. consider the best practices;
    2. provide appropriate resources; and
    3. enforce fatigue management as a responsibility of managers, staff involved in fatigue management procedures and air traffic controllers;
  6. be periodically reviewed to ensure it remains relevant and appropriate.

(b) In accordance with the policy in point (a), the air traffic control service provider should establish and implement:

  1. principles and procedures to enable fatigue reporting;
  2. principles and procedures for occurrence investigation and analysis to consider fatigue as contributing factor;
  3. procedures for the identification and management of the effect of fatigue on the safety of operations.
AMC1 ATS.OR.315(a), Acceptable Means of Compliance to Part-ATS

How this shows up in a rostering system

Identify the workflows that support your policy.

See which workflows can support the policy. Your organisation retains responsibility for policy ownership, safety management and regulatory assessment.

  • AMC1 ATS.OR.315(a)(1)

    Declare the commitment and describe the expected safety benefits

    An organisational commitment documented in the fatigue policy.

    Not a rostering-system function

  • AMC1 ATS.OR.315(a)(2)

    Signed by the accountable manager

    Signature and accountability sit with a named person in the organisation, not with any system.

    Not a rostering-system function

  • AMC1 ATS.OR.315(a)(3)

    Address the mitigation of the operational impact of fatigue

    Configured duty and rest limits can support the mitigation measures established through the organisation’s fatigue-management process.

    Configurable ATS.OR.320, the eight elements →

  • AMC1 ATS.OR.315(a)(4)

    Be communicated, with visible endorsement, throughout the organisation

    Internal communication and management endorsement. Not a system function.

    Not a rostering-system function

  • AMC1 ATS.OR.315(a)(5)

    Commit to best practice, resources, and enforcement as a shared responsibility

    The closest a rostering system gets to “enforcement” is refusing to let a shift swap stand if it would break a configured rule, enforcement of the numbers, not of the policy commitment itself.

    Configurable Shift swaps, checked automatically →

  • AMC1 ATS.OR.315(a)(6)

    Be periodically reviewed to stay relevant and appropriate

    Reviewing a roster against revised rule settings can help assess the operational effect of a proposed policy change.

    Configurable Check Solution →

  • AMC1 ATS.OR.315(a)(b)(1)

    Principles and procedures to enable fatigue reporting

    A safety-reporting workflow. SkyRoster does not provide an occurrence-reporting system.

    Not a rostering-system function

  • AMC1 ATS.OR.315(a)(b)(2)

    Occurrence investigation and analysis considering fatigue as a factor

    An investigation needs the actual duty history, not the intended one: who was on duty, on what pattern, with how much rest, before the event.

    Configurable Attendance and roster reporting →

  • AMC1 ATS.OR.315(a)(b)(3)

    Procedures for identifying and managing the effect of fatigue on safety

    A safety-management-system process that sits above any single roster. This process is outside SkyRoster’s rostering scope.

    Not a rostering-system function

FAQ

Common questions

Is a rostering system enough, on its own, to satisfy ATS.OR.315?

No. ATS.OR.315 is mostly a policy and training obligation on the ANSP: a documented fatigue management policy signed by the accountable manager, plus information programmes on fatigue prevention. A rostering system does not produce a policy document or deliver training. What it operationalises is the numeric side of the policy, which lives in ATS.OR.320.

What is the relationship between ATS.OR.315 and ATS.OR.320?

ATS.OR.315 requires the fatigue management policy. ATS.OR.320 requires the rostering system that gives that policy operational teeth, in the form of eight elements the ANSP must define and enforce.

Does ATS.OR.315 require fatigue-reporting software?

It requires principles and procedures to enable fatigue reporting, under AMC1 ATS.OR.315(a)(b)(1). That is a process requirement, not a named piece of software. How the ANSP tools that process is left open.

Who has to sign the fatigue management policy?

AMC1 ATS.OR.315(a) states the policy should be signed by the accountable manager.

Does fatigue-prevention training happen under ATS.OR.315 or under the ATCO licensing regulation?

Both are linked. ATS.OR.315(b) requires ATCO fatigue information programmes complementing human factors training provided in accordance with Sections 3 and 4 of Subpart D of Annex I to Regulation (EU) 2015/340, the licensing regulation.

Assess where software supports your fatigue policy.

Use a 20-minute discovery call to outline your rostering process. We’ll identify relevant workflows for a tailored demo or evaluation, alongside the responsibilities your organisation retains.