[Peetwo]

The Feds come out swinging on CAO48.1 - Another day, another long drawn out saga on the ASRR/CASA Regulatory Reform Program. First some background off the CASA meets the Press post #113:

AFAP - Strange dichotomy on CAO48.1??  

CASA ‘caved in’ on new pilot flight rules  

Submission on CAO 48.1 Appendix 4B.

...Our submission is based on feedback from members working in the emergency medical services field and the views of the Federation’s Technical Committee, made up of working airline and commercial pilots under the direction of the AFAP’s Technical Director.

As a professional association, the members and staff of the Federation are active in promoting flight safety and improving Australian and global aviation standards. The Federation’s diverse pilot membership base places it in a strong position to comment on the proposed changes to Flight Time Limitations.

Owing to the short timeline, our submission should not be regarded as comprehensive. We would welcome the opportunity to further explain and supplement our submission via discussion with all interested parties...

..I am writing to express our concern about the proposed Medical Transport & Emergency Service Operations Appendix to CAO 48.1, 2013.

The Federation was not involved in the original working group to develop the proposal & it was only through our members that we were made aware of the draft. Following representation to CASA we were invited to attend the most recent working group. As we made clear at the meeting, we have no concern about operators conducting emergency retrieval services, search & rescue, rig & range safety or the myriad other low rate operations, where Crew Members are on standby for extended periods, under the proposed Appendix 4b. These crew members would be rarely if ever subject to cumulative fatigue however, we are very concerned about the crew members who are involved primarily in patient transfer services.

The majority of these patients are not in need of urgent medical attention, they are being transported because the services they require are not available at their local hospital.

These patients are frequently accompanied by family members & it is not appropriate to be unnecessarily exposing these passengers to the elevated fatigue risk associated with Appendix 4b.

The crew members with these operators are averaging 500 to 700 flight hours a year & would typically be rostered between 35 to 45 duty hours a week (5 x 8 hour duty periods). This is on a par with any regional airline operating under Appendix 3 or 4. They are doing this generally single pilot, in complex aircraft, flying multiple sectors in all weather conditions. The majority of these flights are into regional airports with limited facilities primarily outside the protection of controlled airspace.

The proposed Appendix is not suitable for this type of operation; it allows a crew member to be rostered for up to 12 days duty with the only restriction being a maximum of 40 hours flight time or 60 hours duty in 7 days. The standby provisions allow an aeromedical pilot who may have already done 4 or 5 days duty to spend up to 24hours on standby then be called in for an 11 hour duty. Repetitive, long days like these without adequate rest can lead to high cumulative fatigue levels.

In accordance with our original submission we propose that medical transport services(MTS) be conducted under Appendix 3 or 4 , If these crewmembers are then tasked with an Aeromedical evacuation this can be conducted under Appendix 4b if required.

The definitions of these terms are included in our original submission. “Submission on Civil Aviation Order 48.1 Appendix 4b”, dated 9th June 2015. A copy of which is attached.

Yours sincerely,

Captain David Booth

President

   

Okay & today in the Oz by Binger..

Fatigue rules put pilots at risk, union warn

• Mitchell Bingemann
  
• The Australian
  
• March 4, 2016 12:00AM
  

The Australian Federation of Air Pilots says it has been left out of the crucial discussions.

The nation’s largest pilot union has warned that new fatigue management rules for medical transport operations lean too far towards the financial interests of commercial air operators and will put pilots’ health at risk.

The Australian Federation of Air Pilots president David Booth has written to the Civil Aviation Safety Authority to complain that it has been left out of the crucial discussions, which propose to move the fatigue management for medical transport operations from the aerial work category to a classification incorporating passenger transport standards.
In his letter, Captain Booth said the new fatigue management rules — which will be applied to Medical Transport Services — mean pilots will have to work longer flight duty periods when conducting routine patient transfer services.

“In other words, their employers will maximise their productivity under the guise of ‘emergency’ provisions in the new regulations. We believe this is unconscionable and unsafe,” he said.

A spokesman for CASA said it was finalising its response to the letter from the AFAP that was dated February 22.

“CASA is looking carefully at the comments made by the union and will consider the issues which have been raised,” he said.

CASA said the new rules would modernise the management of fatigue in aviation. They were developed to address known fatigue hazards, it said.

The proposed changes cover a broad spectrum of both aircraft and helicopter operations from low rate types such as range and rig safety through medical retrieval services up to high rate types such as patient transfer services.

But the AFAP says the same rules should not apply to pilots who have long standby periods between emergency flights, and pilots who fly regular patient transfer flights which are much more like typical passenger flights in frequency, and thus require greater fatigue protections.

“These operations are completely different in their scope and cannot all be safely conducted under the (new rules),” Captain Booth said.

About time the Alphabets realised that OST (AVM retired) is just another former RAAF, self interested,  bench warming, RAEs glove puppet, with NFI; & who is only interested in topping up his already bloated superfund by providing top cover for the Murky Mandarin & the Iron ring.

Harden up Alphabets, play hardball & follow the Scott McMillan (Alliance Airlines MD) lead, it is probably the only thing 'Malcolm in the muddle' & Minister Chester may actually understand -


MTF..P2