601 # 2201 –"There are operators and providers who are developing procedures for the implementation of this as we write. If this is disallowed, there goes 2 months work for nothing"
To have an existing operation spending time and effort 'developing' new procedures for an ancient problem, clearly shows why an urgent change of regulatory reform attitude is so desperately needed. An operator forced to provide extensive written prescriptions to ensure compliance with the "rule", rather than make a small adjustment to existing company guidelines developed to combat fatigue. The guidelines are not there to provide 'compliance'. The reason for the rule is safety, the outcome should be minimised fatigue risk as an integral part of the overall safety equation, not some half assed notion of being 'seen' as in (subjective) compliance.
The 601 quote should be the title for the Senate 'short inquiry' into the reform process. For my two bob it defines the all of the issues and supports Creamies call for the government to govern. Perhaps, the important issue will finally be combating fatigue; not micro managing prescriptive the rules to a fare thee well, but a sensible, considered application of rule, providing a framework from which an operator can develop a 'tailor made', legally compliant policy, which will protect the public from exhausted crew. It is good to know that the Senate actually paid attention. Well done Sen. Rhiannon, nicely argued.
A decent rule set for fatigue (IMO) only need provide framework; in an ideal world the operators policy should reflect a system based on an in depth analysis of 'their' operation. Then when an amendment to the rule turns up, it is only a matter of fine tuning the existing operating policy to ensure compliance with any newly hatched, scientific or legally defined reason.
A problem for all is the individual, subjective nature of personal fatigue and defining when and how the fatigue chameleon will strike. Then, there are the human nature elements; on both sides, which will exploit any system to suit. Producing a 'system' which covers as many of the negative angles as possible is not a job for whoever happens to laying about office with the odd few moments to spare. Crew fatigue, presents, I believe, a very subtle, complex and oh so human series of closed loop equations.
Increased risk, associated with poorly managed fatigue issues cannot be resolved with a blunt instrument designed to ensure safe prosecution, rather than safe flight. If we are to have 'prescription', let it be to prevent 'human nature' exploiting the situation, prevent 'fatigue' being used as a 'sicky' (because some will) or being used to the maximum advantage obliging a fatigued crew to keep operating (because some will).
The subject is worthy of our best consideration and effort. Anyway – ramble over; well done the FawX team; perhaps we can now have a sensible, open, informed discussion on fatigue rather than having some pensioners home spun version, defining that 10 minutes over the arbitrary line in the sand is a heinous crime rammed down our collective throats.