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Regulation · ATS.OR.320

The eight elements your roster policy must specify.

Understand the eight elements your rostering system must specify. Read ATS.OR.320 in full, compare observed practice and explore the relevant SkyRoster rules.

The instrument

Regulation
(EU) 2017/373
Annex
IV, Part-ATS
Subpart
A, Section 3
Article
ATS.OR.320
Title
Air traffic controllers' rostering system(s)
In force
Applied from January 2020

The article, verbatim

(a) An air traffic control service provider shall develop, implement and monitor a rostering system in order to manage the risks of occupational fatigue of air traffic controllers through a safe alternation of duty and rest periods. Within the rostering system, the air traffic control service provider shall specify the following elements:

  1. maximum consecutive working days with duty;
  2. maximum hours per duty period;
  3. maximum time providing air traffic control service without breaks;
  4. the ratio of duty periods to breaks when providing air traffic control service;
  5. minimum rest periods;
  6. maximum consecutive duty periods encroaching the night time, if applicable, depending upon the operating hours of the air traffic control unit concerned;
  7. minimum rest period after a duty period encroaching the night time;
  8. minimum number of rest periods within a roster cycle.

(b) An air traffic control services provider shall consult those air traffic controllers who will be subject to the rostering system, or, as applicable, their representatives, during its development and its application, to identify and mitigate risks concerning fatigue which could be due to the rostering system itself.

ATS.OR.320, Regulation (EU) 2017/373, Annex IV (Part-ATS)

Read the consultation requirement in paragraph (b) atconsulting controllers on a rostering system →

Observed practice, not the rule

Compare the limits providers reported to EASA.

EASA’s survey records the values reported by participating providers, separated into area control centres and aerodromes. These observed values provide context; they are not recommended limits or a compliance test.

ElementACC averageACC std. dev.Aerodrome (TWR) averageTWR std. dev.
(1) Max. consecutive working days (days)5.91.45.81.7
(2) Max. hours per duty period (hours)9.23.010.52.7
(3) Max. time on ATC service without breaks (minutes)903815489
(4) Ratio of duty periods to breaks0.690.100.720.10
(5) Min. duration of rest periods (hours)11.65.312.05.1
(6) Max. consecutive duty periods encroaching night (days)2.31.02.91.2
(7) Min. rest after a duty period encroaching night (hours)22.519.517.815.5
(8) Min. number of rest periods within a roster cycle3.72.03.74.5

EASA, Study on the Analysis, Prevention and Management of Air Traffic Controller Fatigue, Table 2-1, p.25, final report, May 2024, 36 of 46 EASA-Member-State ATSPs surveyed

The standard deviations show substantial variation between providers. For ACC rest after night duty, the reported standard deviation is 19.5 hours. Assess any proposed limit in its operational and regulatory context.

How this shows up in a rostering system

Map each element to supported configuration.

Explore the rules relevant to each element and the areas that need further review. Configuration alone does not establish regulatory compliance.

Explore the rule catalogue for the current list of supported constraints.

FAQ

Common questions

Does ATS.OR.320 set the actual numeric limits, such as maximum hours per duty?

No. The article requires the ANSP to specify its own values for the eight elements. EASA's Acceptable Means of Compliance provide guidance on only one of them (AMC1 ATS.OR.320(a)(6);(7), which defines night time). Providers establish their limits within the applicable regulatory framework.

What does ATS.OR.320 require for controller consultation?

Consultation is required by the article. ATS.OR.320(b) states the ANSP “shall consult those air traffic controllers who will be subject to the rostering system, or, as applicable, their representatives, during its development and its application.”

What counts as night time under ATS.OR.320?

AMC1 ATS.OR.320(a)(6);(7) states: “Night time should be considered as the time between midnight and 05.59.”

Does ATS.OR.320 apply only to area control centres, or also to towers?

The article sits under ATS.OR.300 (Scope), which applies to the air traffic control service provider generally, with no carve-out for aerodrome towers. EASA's 2024 fatigue study reports separate observed values for Area Control Centres and Aerodromes, confirming both are in scope.

Do EUROCONTROL's rostering guidelines carry the same legal force as ATS.OR.320?

No. NMD/SAF/2653 and NMD/SAF/2611 are EUROCONTROL guidance documents, not EU law. ATS.OR.320 is a binding requirement under Regulation (EU) 2017/373; the guidelines are practical material an ANSP can draw on when deciding how to meet it.

Review your duty, rest and break requirements.

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