[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.   

Fatigue rules put pilots at risk, union warn

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.

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 -

As some of the initial findings with the tragic FlyDubai 737-800 prang in Rostov-on-Don Russia filter out, it would appear that fatigue may well be a factor in the causal chain.

 "significant and obvious risk"

The knock on effect of course is that fatigue & the relationship to aviation safety suddenly becomes topical in the MSM. Which also happens to be coincidental because FRMS & the controversial CASA CAO 48.1 is currently topical in the Australian aviation safety stakeholder scene (above & - To Disallow or not to Disallow; that is the Q?) 

Therefore I found the following article from the AFAP's official legal counsel Joseph Wheeler of particular interest because he not only joins the dots between fatigue but other safety issues related to the travelling public's love affair with LCCs...

Montreal Convention needs universal support

Had a thought all this 'fatigue' & LCCs etc..etc; hasn't this now gone full circle since the 2010-11 when Senator Xenophon initiated the - Pilot training and airline safety; and Consideration of the Transport Safety Investigation Amendment (Incident Reports) Bill 2010 - Senate inquiry? Yet another example of the powers to be obfuscating their responsibilities for 'air safety' - FFS!     

Excellent article from Jamie Freed (via SMH) on the latest on the long running saga of fatigue and the CASA rule set on FRMS (i.e. CAO 48.1):

Flying tired: airline pilots on tough rosters battle fatigue

Date April 15, 2016 - 6:47PM

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Jamie Freed
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Pilot fatigue is an unresolved issue but different airlines have very different rules.

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Tired pilots struggle through Australia's fatiguing flights

"Sometimes you look over and the other guy is asleep". How tired your pilot is depends on the flight - and the airline.

For passengers, the 5am flight from Brisbane to Sydney during daylight saving time in NSW is hardly a pleasant experience. But spare a thought for the two pilots who have probably woken up about 2:30am to make the 4am sign-on and may then have to make four flights over an 11 to 12-hour period.

"Back-to-back of these is very, very fatiguing," says a Qantas 737 pilot.

Everything is legal of course. But we are not machines. 

Or consider the late evening flight from Sydney to Perth.


In some situations, pilots are allowed to nap on the flight deck to alleviate fatigue. Photo: Jim Rice

The passengers arrive in Perth after midnight local time, but at Jetstar and Tigerair Australia, the two pilots on board will head straight back to Sydney, arriving just in time to battle peak-hour traffic before they can make it home to rest.

"It is pretty hard to make the case that you are on your A-game at the top of descent [into Sydney] on the return leg," a Jetstar A320 pilot says.

"There are duties you do at Jetstar that wouldn't be entertained at Qantas. A low-cost carrier is more intense in terms of the rostering requirements."

Australian and International Pilots Association president Nathan Safe.

Many industries fatigued

Pilots are hardly the only workers in Australia with exhausting shifts. Truck drivers, miners, doctors, nurses and others also work long shifts with hours that can   disrupt the biological clock. 

"By and large, pilots are at the low end of the fatigue scale in terms of other industries," says Professor Drew Dawson, a sleep and fatigue specialist at CQUniversity Australia. "At the other end, they are at the high end of the consequence scale."

The crash of a Flydubai 737 at Rostov-on-Don, Russia, last month that killed all 62 passengers and crew on board has reignited discussion of fatigue management within aviation circles at a time when Australia is close to introducing new fatigue regulations.
The accident is still being investigated and whether fatigue was definitely a factor is unknown. But the crash occurred in tough circumstances at 3:50am local time (4:50am Dubai time), after two hours of circling due to bad weather and two aborted landing attempts. Scientific studies show mental alertness can be at its poorest during the "window of circadian low" between 2am and 5am.

Emirates' tiring schedule

The airline, like fellow Dubai-based carrier Emirates, is known among pilots for having rosters that are within the United Arab Emirates legal limits but nonetheless very tiring.

In the UAE, the maximum flying time is 100 hours per 28 days versus 100 hours per 30 days in Australia. On an annual basis, UAE pilots can fly 1000 hours a year versus 900 a year here.

"The point about regulation is you can have flight-duty time limitations in which you can produce two compliant rosters but one can be extremely friendly and low fatigue risk and one can be extremely high fatigue risk," says CQUniversity associate professor and sleep expert Matthew Thomas.

He says as a rough guide, research shows if a pilot has less than five hours sleep in the 24 hours before flying, twice as many errors may occur. 

Pilot fatigue has been cited as a factor in at least 12 accidents and 64 near misses globally over the past 10 years, according to the Australian Transport Safety Bureau. But more than half of all accidents are caused by pilot errors and it is possible fatigue is understated as a factor in official reporting.

'We are not machines'

The ATSB report on one of Australia's worst-ever accidents, the Emirates flight 407 runway overrun and tail strike at Melbourne Airport in 2009, said fatigue was unlikely to have been a factor, but the flight's captain told media he was sleep-deprived.

The error that caused the EK407 incident was the input of the aircraft's weight as 100 tonnes lighter than it actually was. 

A former Emirates 777 captain said he had once made a similar mistake when flying for the Dubai-based carrier as a result of fatigue, but luckily it had been caught by another pilot before take-off.

"Everything is legal of course," he said of the Emirates rosters. "But we are not machines."

Pilots at many airlines are allowed what is called "controlled rest on the flight deck", which means they can put their head back and nap in their chair for short periods, typically under 40 minutes, as long as the other pilot is retaining a close watch over the flight during the cruise period.

Both asleep

However, the former Emirates captain said pilots were often so tired that one would allow the other to sleep for two to three hours at a time. On occasion, the pilot supposed to be watching the controls would accidentally fall asleep for a few minutes, meaning if a sudden incident occurred mid-air, the reaction times of both would be slowed.

"I have flown with guys that have woken up mid-flight and the other pilot has been asleep mid-flight between Dubai and London," says a Qantas A380 pilot. "This should not happen as the cabin crew are supposed to call up every 30 minutes but some crews may call them and say do not call as one of the pilots is having a controlled rest."

For airlines, adding more pilots on sectors or changing rosters could come at a financial cost. The carriers naturally want to maximise their profitability by having their highly paid pilots fly as many hours as possible within the rules. But they are also interested in safety, as serious incidents and crashes cause brand damage and lawsuits they want to avoid.

Another potential problem is that pilot fatigue is probably underreported by the pilots themselves, albeit more so at some carriers than others depending on the company culture.  Reporting fatigue requires the pilot to fill out a form with an explanation and takes longer than ringing in sick.

Open culture call

"What we want is an open reporting culture," says Australian Federation of Air Pilots executive director Simon Lutton. "They shouldn't be doing a flight if they are not in a fit state to do it."

Pilots at major Australian carriers said there was no punishment for reporting fatigue and in some cases it led the airline to take steps to fix the situation, if it was due to a factor such as a noisy lay-over hotel.

Airlines have also changed some rosters over time as a result of pilots reporting fatigue. When Virgin changed the timing of its Sydney-Los Angeles flight by nearly four hours, it first assessed potential fatigue hazards for pilots. Qantas is reviewing the possibility of rostering on a third pilot on the QF2 flight from London to Dubai as a result of feedback.

"My experience with Qantas has been very positive," a 737 pilot said. "If you need time off and you ask for it, then the company has always been able to arrange that."

The situation differs in other parts of the world, where there are no unions or Western-style seniority system. 

"There are all sorts of ways you can put pressure on pilots," a Virgin 737 pilot says of situation in the Middle East. "If you don't like it, all you can really do is leave."

Fatigue 'taken seriously'

A current Emirates pilot said reporting fatigue often led to sleep apnoea testing and at least a temporary grounding. The former Emirates captain said his high use of sick days, mostly when fatigued, was noticed by management and delayed his promotion from first officer to captain for months. 

An Emirates spokeswoman would not say whether taking reporting illness or fatigue could affect promotion, but said the airline maintained "the highest standards" when considering a promotion to captain.

"Flight fatigue is an issue we take seriously," she says. "If pilots feel that Emirates has not addressed their concerns, they also have recourse of addressing this with the regulator, the General Civil Aviation Authority (GCAA)."

The president of GCAA, Sheikh Ahmed bin Saeed Al Maktoum, is also the chairman and chief executive of Emirates and the chairman of Flydubai.

Australia's new rules

Locally, the Civil Aviation Safety Authority in 2013 introduced new rules for pilot fatigue management. They were initially supposed to take effect this month, but the deadline was moved to May 2017 to give airlines more time to develop new systems.

The old fatigue rules defined flight and duty time limitations in a rigid way with no regard to the science behind fatigue, including whether pilots are acclimatised to the time zone. The new rules provide more flexibility for individual airlines, but each fatigue risk management system will require CASA's approval. 

Australian and International Pilots Association president Nathan Safe, whose union represents Qantas pilots, says the new science-based approach to flight-time limitations based on factors including circadian lows was welcome, but the real test will be in how it is implemented and operated.

For the major commercial airlines, the new system could result in less flying rather than more flying in many cases.

Regional Express last year claimed the new rules could cost it more than $4 million a year and might make some routes unviable.

CASA will be taking a much firmer approach to extensions of duty, with airlines required to monitor weather and airspace patterns statistically before calculating duty periods.

"Operators need to be more realistic about the possible delays in the system and ensure that if there are foreseeable delays, they can be incorporated into the maximum allowable duty period and don't result in an extension," a CASA spokesman said.

A Qantas 737 pilot says the change is welcome. "It will mean that Qantas will no longer be able to schedule near 12-hour day patterns," he says.

Since 2007, Virgin has operated a data-driven fatigue risk management. Qantas, Jetstar and Tigerair are still developing their systems ahead of next May's deadline.

It is unclear whether Jetstar and Tigerair will end the tiring Sydney-Perth-Sydney night shifts under the new system.

Qantas and Virgin say the reason these shifts aren't done at the main carriers is because they are prohibited in the unionised employment agreements, rather than because of fatigue concerns.

Qantas Group medical director Dr Ian Hosegood​ said the group's airlines have robust systems in place to manage fatigue, including a fatigue management committee which includes pilots, safety specialists and crew planners.

"We closely monitor fatigue risk on all shifts, particularly longer and late night shifts," he says.

For example, Qantas recently changed its rostering after the Tokyo-Brisbane route, which lands at 6:45am in Brisbane after 10 hours of duty. The pilots now start their duties the following day at a later time with a reduced workload of one to two short domestic sectors.

Dr Dawson, the fatigue specialist, says pilots must also bear some responsibility, and try to limit distractions at home and partying on the road to ensure they are rested before flights.

And after more than a decade of studying fatigue in the aviation industry, he says the issue doesn't particularly worry him when he takes a flight.

"The number of flights that crash is less than one in a million," Dr Dawson says. "I've got more chance being killed on the way to the airport than in an airplane


Read more: http://www.smh.com.au/business/aviation/flying-tired-airline-pilots-on-tough-rosters-battle-fatigue-20160413-go5fmo.html#ixzz45x0dYL5j
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