Recently released answers to 'Questions on Notice' show the tick-a-box mentality that is enshrined within Fort Fumble:
Question no.: 100
Program: n/a
Division/Agency: (CASA) Civil Aviation Safety Authority
Topic: Fatigue Risk Management Systems
Proof Hansard Page/s: Written
Senator XENOPHON asked:
Fatigue Risk Management Systems (FRMS), whether prescriptive or enterprise-specific, have been in place for pilots for many years. It has been recently suggested that cabin crew fatigue is adequately managed through AOC holders’ safety management systems (SMS) and, where they exist, their FRMS.
1. What guidelines do CASA inspectors use to judge the effectiveness of these controls and to require AOC holders to amend those controls?
2. What formal training do CASA Inspectors undergo in terms of the assessment and monitoring of fatigue risk management schemes?
3. The UK CAA runs courses for all comers on the interpretation and implementation of their fatigue management legislation. (a) Does CASA offer any equivalent training for Australian stakeholders? (b) Is there any intention to do so?
4. What plans does CASA have to introduce FRMS requirements for aircraft maintenance workers?
5. In a broader context, CASA introduced the concept of a Safety Sensitive Aviation Activity (SSAA) in Part 99 “Drug and alcohol management plans and testing” of the Civil Aviation Safety Regulations (CASR) 1998. Given that the consequences of fatigue are often described in similar terms to the effects of drugs and alcohol, does CASA have any plans to require FRMSs to include SSAA employees?
Answer:
1. All Regular Public Transport operators are required by Civil Aviation Order (CAO) 82.3 and 82.5 to have and use a Safety Management System (SMS) that is approved by the Civil Aviation Safety Authority (CASA). In order to be approved, an organisation’s SMS must include, among other things, documented details on the hazard identification processes and risk assessment and mitigation processes that will be used by the organisation. CASA inspectors are required to assess the effectiveness of these documented processes at various stages of the regulatory oversight process. CASA inspectors refer to the relevant legislation and advisory material and, in the case of SMS, to the requirements of CAO 82.3/82.5, the material contained within the Civil Aviation Advisory Publication SMS package and the processes documented in the CASA Air Operator Certification Manual. The
practical application of these documented processes is then assessed during CASA’s ongoing surveillance activities utilising the auditing techniques as documented in the CASA Surveillance Procedures Manual.
2. CASA inspectors undergo a variety of formal specialist training courses that are directly applicable to the assessment of Fatigue Risk Management Systems (FRMS) and which equip them to effectively assess an organisation’s FRMS.
3. (a) and (b) CASA has published a package of guidance material designed to provide operators and individuals with information necessary to meet their obligations under the proposed standards for fatigue management. CASA’s Aviation Safety Advisors are also preparing a fatigue component for inclusion within their safety seminars, which are run nationwide.
CASA encourages participation from all industry sectors in these seminars.
4. The CASA requirements for approved maintenance organisations currently include a system which takes into account human performance limitations, of which fatigue is included as an element. Further requirements for the management of fatigue in those performing aircraft maintenance will be included as a later stage of the standards development project dealing
with fatigue management for aviation personnel.
5. CASA acknowledges the importance of fatigue in aviation personnel and is undertaking a phased approach to requiring fatigue management in aviation organisations. Extending the requirements for fatigue management to all Safety Sensitive Aviation Activity (SSAA) personnel requires careful consideration and analysis and consultation with all affected stakeholders noting that the International Civil Aviation Organization (ICAO) does not require member States to have in place requirements for fatigue management for SSAA personnel,
other than for flight crew and cabin crew.
However the 'reality' of this system of administration of air safety in Oz has been perfectly highlighted by the CASA oversight of Pelair, (as "K" points out) Airtex, Alligator, Skytrans, AR, Transair, Kick-a-tin-along Airlines etc..etc..etc
