PPRuNe Forums - View Single Post - Fatigue Regulation and Industrial Agreements covering hours of work
Old 17th Jul 2013, 06:10
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4dogs
 
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Danger fatigue is complicated, so is its management

Ned Gerblansky,

JQ flew (flies?) CNS-PER-CNS back of the clock. 9.4 hours flight time in a 11 hour night. Previous duties and post duties may have been 0500 sign ons. The fact that it's pressurized, flight attendants to bring coffee and inedible in-flight meals does not belie the fact that it is outside of normal human tolerances. Sometimes we'd get whacked with two in a row!
CAO 48.1 would not allow such a duty, simply because it limited flight time to 8 hours (para 1.4).

The SIEs attempted to deal with Chimbu's 'type of operation', but were driven by "micro-economic reform" - meaning bowing to commercial interests without constraint. It allowed 12 hours duty and 9.5 hours (perhaps even 10 hours) flight time (paras 2.1.1 and 2.4.1(a) or (b)).

CAO 48.1 Instrument 2013 will not allow such a duty under the prescriptive rules for two very sound reasons - the maximum duty is at that time of the day is 10 hours and the maximum flight time is 8 hours (Table 2.1).

Prescriptively, the Instrument is a scientifically valid improvement for this duty example.

However, CASA advertises FRMS as the mechanism to exceed those prescriptive limits. Unfortunately, there is no transparency about how FRMSs will be approved by CASA - such a duty may be allowed under an FRMS based on "operational experience" if there are no adverse fatigue reports in the operator's system. Given the operator's 'toughen up Princesses" attitude toward fatigue management and the openness of the flight operations management generally to all internally-generated criticism, it seems likely that few complaints exist.

Do not expect CASA to assist pilots getting a proper FRMS or ensuring that it runs as designed - that is far from their traditional orientation. This is one where practical experience is gold, since only the people flying the line can say whether the duty is unreasonably fatiguing or not. You need to ensure that you have a seat at the table for fatigue mitigation/management, not just hazard ID, and you need to formally speak up if the duties are fatiguing.

Your FRMS will be what you let it be...

Stay Alive,
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