amendment of Annex 6 —Operation of Aircraft Part I — International Commercial Air Transport — Aeroplanes. 
The FRMS Subcommittee was comprised of experts in the field of fatigue research and operational fatigue management inclusive of Regulators (United States (FAA), United Kingdom (CAA), Transport Canada (TC) and France (DGAC)), the International Air Transport Association (IATA), easyJet Airline and Scientists (US, Sweden, New Zealand and France). Draft guidance was submitted from the committee as changes to the Standards and Recommended Practices (SARPs) of Annex 6, Part I in November 2008. It offered a new Appendix that provides guidance on FRMS. 
. Guidance on FRMS education and awareness training

The guidance developed was in structure based on the FRM conceptual framework by
Gander (2005) as shown in Figure 3 and included:
.
.
.
.
.
.

S. Stewart, F. Koornneef, R. Akselsson, and C. Turner  - HILAS 2009
Figure 3. FRMS Structural components by Gander (2005).
The ICAO draft document outlined the principle characteristics of an FRMS and the relationship to SMS inclusive of:
.  
Should be an integral part of an established SMS.

.  
Applies SMS principles and processes to proactively identify and continuously manage fatigue safety risk.

.  Data driven systems designed to identify risks.
.  Multi-layered defences to manage risk.
.  Shared responsibility among management & employees.
.  
Functions within a regulatory oversight framework.

.  
Can enhance safety within the envelope of prescriptive flight/duty time limits or as an alternative to prescriptive rules that provides at least an equivalent level of safety.

This ICAO draft document was used by EASA as the basis for new draft regulation due to come into effect in April 2012, pertaining to FTL and fatigue management (Figure 4) and outlined by EASA at the inaugural meeting of the International FRMS Forum (Valentukevicius, 2009).
Valentukevicius stated that EASA currently has no remit for issues relating to FTL and has recently released a Notice of Proposed Amendment (NPA) EASA NPA 2009c that sets the proposed framework for the FTL requirements (when EASA assumes competence for FTL in April 2012). He went on further to state that this framework is
S. Stewart, F. Koornneef, R. Akselsson, and C. Turner  - HILAS 2009

subject to the EASA rulemaking process including review and Regulatory Impact Assessment (RIA). The NPA contains Draft Opinion together with Certification Standards, Acceptable Means of Compliance and Guidance Material for operators. A significant addition in the proposed requirement for an FRMS was that it must be appropriate to the size and nature of the airlines operation (assumed basic compliance to the FRMS elements would not be sufficient for all operators).
　
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