Originally Posted by
Euclideanplane
Based on this quote from page 105 of the report it may not have been deemed necessary:
"The analysis of compliance of the work and rest schedule within a record period (28
consecutive days) did not identify any violations. The crew had a sufficient amount of the preflight
rest. As per the submitted data, the Fatigue Management System is implemented in the airline. The
system encourages the fatigue-related confidential reports by the crewmembers for any stage of
the flight operations (the preflight, in-flight, post-flight one). For a number of quantitative
indicators the system goes beyond the national aviation legislation (that is it ensures the improved
conditions for the crewmembers). Since 2009, the airline has accumulated 450 000 flights with a
total flight time of more than 1 million hours. Within the period, 70 fatigue-related confidential
reports were submitted. The majority of them were proactive by nature – as the crewmembers
reported the fatigue presence and were removed from duty until they felt fit for flight operations."
What it doesn't say is that the board reviewed the actual FRMS data for the rosters of the two pilots in the weeks before the crash. How many back side of the clock flights did they do in the preceding weeks? One may be legal with regards to rest and still be suffering from the affects of cumulative or chronic fatigue. Those who have done back to back to back overnight flights know what one feels like after two or three in a row. I don't see this detailed in the report.