[Peetwo]

AIPA feedback submission to CAO 48.1 review report -  

CASA delays new fatigue rules, announces independent review
August 8, 2017 by australianaviation.com.au 1 Comment

& Bob's comment...

Bob says

August 8, 2017 at 4:23 pm

Why does that not surprise me . Useless regulator run by the airlines .

...If you want a perfect example of how an operator/airline can appear to tick all the boxes with a CASA approved FRMS, yet then have major issues of compliance and operability of that FRMS, go no further than the PelAir FRMS pre-ditching. Read & absorb Ben Cook's PelAir FRMS Special Audit Report - 09 CASA_Doc 10_Web

Update: Review report released - Finally!  

Again via Oz Aviation:

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 CASA releases final report of review of new fatigue rules
March 22, 2018 by australianaviation.com.au



Australia’s Civil Aviation Safety Authority (CASA) is seeking feedback in response to an independent review of its new fatigue risk management rules.

The review was announced in August 2017, when CASA deferred the introduction of Civil Aviation Order (CAO) 48.1 in response to feedback from the aviation community...

Via the Oz today:

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Pilots in for the long haul

12:00amANNABEL HEPWORTH
The Civil Aviation Safety Authority should ‘urgently’ outline rules for ultra-long-range flights, pilots say.

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Pilots in for the long haul on fatigue as CASA seeks input

The Civil Aviation Safety Authority should “urgently” outline rules on crew composition and rest requirements specific to ultra-long-range flights, the Australian and International Pilots Association has declared.

As consultations on an independent review prepared for CASA reignite debate about fatigue rules, the association has hit out at CASA for not having targeted the mega-long-haul area for regulation.

In response to the review, the association has said “we urgently require a rule set” that clearly defines ultra-long-range operations “and requires specific consideration of appropriate rest facilities, crew composition, preflight, on-board and post-flight rest requirements”.

The push comes after the review, which was led by Melbourne-based human factors and safety consultancy Dedale Asia Pacific, told CASA that it could be more explicit on guidance for in-flight rest facilities for ultra-long-range flights and noted that the regulations didn’t detail minimum standards for facilities such as bunks on mega-long journeys.

But AIPA says it is disappointed the review didn’t make a firm recommendation on the issue.

The push comes as, globally, the ultra-long-haul flight becomes more common.

Last month, Qantas made the inaugural direct flight from Perth to London. Qatar Airways flies Doha-Auckland, while United Airlines is doing Sydney-Houston and Los Angeles-Singapore. Singapore Airlines will resume direct flights to New York this year. Qantas has a “Project Sunrise” ambition of direct flights from the eastern states to New York, London, Rio de Janeiro and Cape Town by 2022 if the aeroplane manufacturing giants can rise to the challenge.

A Qantas spokesman said that given the nature of the carrier’s long-haul network and history of flying routes of significant distance, “we have a mature fatigue risk-management system in place”.

“All Qantas Group airlines manage fatigue and are working with the industry to see the eventual implementation of a standard fatigue risk system,” the spokesman said.

“As we look forward to Project Sunrise and our aim of operating flights from the east coast of Australia to London and New York, the ability for us to manage fatigue in co-operation with our employees and regulators is of course a heavy focus for us,” the Qantas spokesman said.

CASA chairman Jeff Boyd previously has said the report ­“provides a method to find an appropriate balance between fatigue risk and operational impact” and the board wanted input before finalising changes to the rules.

CASA has given stakeholders until Sunday to respond to the review.

After that, the authority will evaluate the feedback and decide on its final position.

The development of the proposed new rules, reflected in CAO 48.1, were prompted by recommendations from the UN agency known as the International Civil Aviation Organisation. This came after a series of accidents in which fatigue was considered to be a significant ­factor.

Unions have criticised delays in implementing the proposed rules. But Rex has said the proposed rules have the potential to drive up operating costs by more than $7 million annually.

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Here's a disturbing reminder and potted history of some of AIPA's advocacy, within the last two decades for a proper scientific based regulatory rule-set, tackling fatigue risk within the aviation industry: FRMS/SMS a lip service exercise - Part VII & Closing the FRMS safety loop? 

From pg 5:

ICAO recognises the importance of “operational experience”, but that is a tainted concept if it merely reflects what operators have been doing or what the regulator thinks they are doing.

In Australia, we have already seen how this concept is tainted - recent Senate inquiries that have touched upon Jetstar, Pel-air and Avtex/Skymaster fatigue management processes and largely exposed the gulf between sound fatigue risk management, what operators have really been doing and what the regulator didn’t really bother to see what they were doing. The CASA Special Audit conducted after the Pel-Air ditching revealed all three of those propositions, while explaining a lack of pilot complaints:

…The short planning period, lack of knowledge of possible destinations and lack of support provided by operations staff once doors closed appears to add to this fatigue. All crew interviewed stated that they felt there would be no issues in stating that they were fatigued and pulling out of duty but also felt that they had limited opportunities to fly and had to take these opportunities when they arose… 8

… Most crew interviewed stated that they had been part of a duty that was greater than 15 hours in length but evidence could not be identified that showed fatigue related extension of duty processes had been followed, safety reports had been written following the duty or that management follow-up was conducted as is required in the company FRMS manual. Several interviewees believed that there is a lack of management adherence to safety management requirements and the fatigue risk mitigation strategies as laid down in the company's FRMS manual…9

When CASA was asked about the significance of Jetstar requiring crews on the Darwin-Singapore-Darwin night flight to extend beyond their normal flight duty period (FDP) limits on 12 of 21 flights in January 2011, they responded:

CASA does not consider that these extensions require continual monitoring.
The duty extensions recorded in January 2011 by Jetstar were a result of flight crew agreeing to operate beyond the standard 12 hour initial limits as provided for within Civil Aviation Order 48 Exemption. No breaches of the 14 hour condition were recorded.10

Undoubtedly that is how CASA will regulate operations under the SIE until they expire in 2016, despite the fact that the same flights could not even be contemplated under The Instrument! Finally, from evidence given to the UK Parliament Transport Committee Inquiry into Flight Time Limitations in February 2012 (which we believe to be replicated in parts of the Australian industry):

7.6. More importantly: fatigue is significantly under-reported by the pilots themselves. This is because pilots do not file reports on an aspect that has become a ‘normal’ part of their daily work. Many are afraid their fatigue reports could have negative consequences for their professional future (i.e. reprisals by management) – a phenomenon that is growing – particularly when pilots refuse to fly because they are too fatigued. Indeed UK polling results show that 33% of pilots would not feel comfortable refusing to fly if fatigued, and of those who would, three quarters would have reservations. Once a pilot has decided they have no option but to fly, a fatigue report would be tantamount to writing the evidence for their own prosecution…11

This under-reporting by pilots is exacerbated by CASA being widely seen by the aviation community as having actively disengaged in any intelligent discussion about fatigue regulation for many years. It is highly unlikely that CASA has any defensible ‘regulatory experience’ other than superficial ‘tick and flick’ audit activities and, as such, cannot and should not rely on its perception of the current state of fatigue management to set aside the science or to replicate current rules.

Just saying -



MTF...P2