Night duties CS FTL.1.205(a)(2), (see also GM1 CS FTL1.205 (a)(2)): Is it necessary to have an ‘approved’ FRM to operate long night duties (FDP over 10hrs)?
No, for night duties of over 10 hours an appropriate fatigue risk management applies. Guidance for that is provided in GM1 CS FTL1.205 (a) (2).
A FRM compliant with ORO.FTL.120 is only required in two cases: reduced rest and crew members in unknown state of acclimatisation on a longer FDP.
Additionally, the approval of FRM is not a stand-alone approval. FRM, if required, is approved as a constituent part of the IFTSS approval.