Monitoring Time Zone Differences CS FTL.1.235(b)(5): Does the requirement to monitor combinations of rotations require FRM in accordance with ORO.FTL.120?
No. FRM is not required. However, CS FTL.1.235 (b)(5) requires that fatigue risks arising from combinations of rotations be monitored under the operator’s management system.
The techniques described in the ICAO Fatigue Management Guide for Airline Operators (associated to ICAO Doc 9966) may be useful reference to assist operators developing their approach.