Understanding and Developing Risk Values
A “Deeper Look at the FRAT” is a three part series follow-up to the article, “Is the FRAT Undermining your Safety Initiatives?“. If you haven’t already read the article, you may wish to do so.
As I mentioned in the previous article, I no longer call the FRAT an assessment tool. I call it the Flight Risk Awareness Tool. The purpose of the FRAT is to quantify and evaluate the compounding risk (loss exposure) associated with the threat of multiple hazards, for a given flight or flight segment.
Understanding the relationship of the key elements is essential. In simplest terms, these elements are:
- Hazards are the things that can get us in trouble.
- Consequences are the troubles we manage to get ourselves into.
- Risk is how often we get in trouble and how much trouble we’re in once we get there.
- Analysis is the understanding of the hazard/consequence/risk relationship.
- Assessment is the acceptance or rejection of risk.
|The most important question, do the template values accurately represent your loss exposure?|
There are a number of FRAT templates available to operators. We will look at the FAA FRAT template (InFO 07015) and the FRAT template provided by International Business Aviation Council, via the IS-BAO Standard toolkit.
The intent of this article is not to compare and contrast, to pick your poison, as they say. The intent is to ensure an understanding of the tool design and to illustrate that risk values could vary, depending on the individual operational context. It will become obvious that FRAT templates do little to represent your actual risk.
The hazard and risk analysis process is beyond the scope of this article. Contact us for a copy of our animated PowerPoint, titled: “Understanding the Risk Analysis.” We will be happy to send you a copy.
FAA FRAT Template
|Pilot Qualifications and Experience|
|1||Captain with less than 200 hours in type HAZARD||5|
|2||First Officer with less than 200 hours in type||5|
|3||Single Pilot Flight||5|
|4||Captain with less than 100 hours last 90 days HAZARD (really)||3|
|5||First Officer with less than 200 hours in type||3|
|6||Duty day greater than 12 hours||4|
|7||Flight time (Greater than 8 hours in the duty day)||4|
|8||Crew Rest (Less than 10 hours prior to the duty day)||5|
|Total Factor Score – Section 1|
In the above template, the second column is an identified hazard. Column 3 is the value assigned, by the FAA in this case, that quantifies the risk in terms of frequency or probability of an event AND the severity of that event.
Consider the hazards from the FAA template. Do these risk values make sense for your operation?
Captain with less than 200 hours in type
The FAA has assigned a risk value of 5 to the hazard, “Captain with less than 200 hours in type.”
The risk value 5 is the highest level used by the FAA. Remembering that risk is how much trouble we’re in (severity) and how often (frequency) we get in trouble, you should be asking “risk of what.”
“Risk of what” is a three -part question:
- What are the potential consequences (outcomes) of exposure to the hazard?
- How often will the consequences occur (frequency or probability)?
- How bad will the consequences be (severity) if they come to fruition?
Keep this in mind, the exposure to a hazard rarely presents a single potential consequence. There are generally multiple consequences, all which need to be taken into account.
Use your imagination (hazard scenario). What could possibly go wrong during operations with a 200-hour in type captain? I’m certain you can come up with a few potential problems (consequences).
Each consequence derived from your imagination has a probability of occurrence and outcome severity. Are they the same? Probably not.
Risk values vary with the effectiveness of the connected risk controls. In the case of time in type, risk controls, such as, flight time (total time / PIC time); crew pairings; SOPs; operating limitations (weather / approach limitations); and training programs; etc., affect the equation.
Captain with less than 100 hours last 90 days
Think about this one a bit. Less than 100 hours in the last 90 days is a hazard. Really?
In your operation, how many hours of duty time does it take to fly 100 hours?
Considering pre- and post-flight duty and waiting time for the typical operator, 100 hours of flight time would generate 600 to 700 hours of duty time. We’re talking 50 to 60 duty-hours a week, every week, without a break.
Without a doubt, this is hazard is intended for scheduled air carrier crews. In the typical corporate or air taxi operation, an extended period of 100 hours of flight time in 90 days would be exhausting. Clearly, fatigue would be a hazard worth your consideration.
FAA / IBAC Template Comparison
The compare and contrast between the FAA and IBAC templates does not represent the respective FRAT templates in their entirety. I have extracted hazards from the FAA and IBAC templates where the risk values are significantly different.
I do not suggest or recommend the use of the hazards and risk values from this discussion, nor do I represent that the FAA or IBAC recommends the use of these values. The FAA and IBAC provide their FRAT as examples.
Looking at sample FRAT values in the following table, we can see some differences:
- Hazards identified by one entity are not identified by the other.
- IS-BAO has various levels to a hazard where the FAA has only one.
- Risk values vary for identical hazards.
|Pilot Qualifications and Experience|
|Captain with less than 200 hours in type||5|
|Low time Captain||3|
|First Officer with less than 200 hours in type||5|
|SIC has less than 50 hours in type||2|
|Duty day greater than 12 hours||4|
|Duty Day greater than 12 hours less than 13||2|
|Duty Day greater than 13 hours less than 14||3|
|Flight time (Greater than 8 hours in the duty day)||4||n/a|
|Crew Rest (Less than 10 hours prior to the duty day||5||n/a|
|High Density Airport High Density Airport||n/a||3|
|Stopping distance greater than 80% of available runway||5|
|Useable Runway Length < 5000 ft||5|
|Useable Runway Length > 5000 ft but < 5500 ft||3|
|No weather reporting at destination||5||4|
|Thunderstorms at departure and/or destination||4||3|
|Turbulence – Severe||5||4|
|Turbulence – Moderate||n/a||2|
|Ceiling & visibility at destination less than 500 ft. / 2 sm||3||3|
|Ceiling & Vis < 1000/3, > 500/2||2|
|Ceiling & Vis < 300/1||5|
|Rain – Heavy (departure and/or destination)||5||5|
|Rain – Moderate (departure and/or destination)||3|
|Rain – Light (departure and/or destination)||1|
|Frozen precipitation (departure and/or destination)||3|
|Snow or sleet – Heavy||5|
|Snow or sleet – Moderate||3|
|Snow or sleet – Light||1|
|Icing – Severe||5|
|Icing – Moderate||3|
|Icing – Light||1|
|Surface winds greater than 30 knots||4||3|
|Crosswinds greater than 15 knots||4||n/a|
|Runway braking action – Less than good||5|
|Runway braking action – Fair||1|
|Runway braking action – Poor||3|
|Runway braking action – Nil||5|
|Repositioning flight (no passengers or cargo)||5||n/a|
|Special flight limitations based on AFM equipment limitations||2|
|NOTAMS (more risk = higher score)||0 – 5|
Understanding the Risk Values
The differing risk values in the above tables raise the questions:
- Why are the values different?
- What supports their premise?
- Are the risk values addressing different consequences, frequencies, or severities?
- What risk controls, if any, are applied to manage the risk?
The most important question, do the template values accurately represent your loss exposure?
FRAT Design Philosophy
Consider your safety performance goals and how the FRAT will support them. Consider how the tool is to be deployed in the day-to-day operating environment.
Is capturing the high-level risk exposure sufficient, or do you need the fine-grain risk values, such as presented in the IBAC template?
At first glance, the variations in IFR ceiling/visibility, snow intensity, icing intensity, etc., appear logical. When considering the actual risk, are these differences significant enough to affect the frequency or probability of an event? Do they change the potential severity if an event were to occur?
Bottom line, FRAT templates do not represent your loss exposure. You are not safe to assume the risk values applied by an outside organization apply to your organization in an identical manner.
Arbitrarily assigning or accepting an unsubstantiated risk value is difficult to defend and potentially undermines your safety initiatives as whole.
For the FRAT to correspond to your loss exposure, risk values must be based on your hazard identification, your risk analysis processes, and supported by your risk controls (policies, procedures, equipment, training, etc.).
The focus in this article has been on the risk values assigned to individual hazards. In Part 2 of this series, the discussion will center on your risk threshold. Risk threshold is your organization’s individual tolerance for the combined risk of the flight or flight segment.