Fatigue Management Program: Good or Bad?

[LateNightOps]

Through the work undertaken by the authority in consultation with [name], Head of Sleep Research at Adelaide University, CASA is currently developing a trial fatigue management system with a specific intention of ensuring that operators consider all duties associated with a pilots employment when designing flight and duty time schedules.

As an outcome of this trial, CASA anticipates that identified fatigue management principles would not be restricted to situations where limited numbers of pilots were retained. CASA notes that the International Civil Aviation Organisation (ICA0) Operations Panel is also monitoring the outcomes of this trial, for possible reflection in ICAO flight and duty time requirements.


www.atsb.gov.au/aviation/rec/rec_detail.cfm?ID=256 (http://)

Now this sounds good in theory... but

Speaking to a friend currently working with a company who has recently implemented such a system, apparently he is now able to work from 0400-2200 three days in a row (no split duty)!

I dont see how that is an improvement in fatigue management.

I may just be cynical, but the abuse of CAO 48 in parts of GA is already bad enough. This seems to be empowering the operator to 'make the call' whether a pilot is fit to fly by taking away the letter of the law for employees.

I'm interested to hear opinons out there from anyone working for companies with this fatigue management system.

cheers
LNO

[drshmoo]

LNO - Are you worried that your day time TV schedule could be interupted? Jerry Jerry Jerry Jerry:}

[Chimbu chuckles]

While I was CP of an internaional Bizjet op, VH reg but based asia, CASA 'insisted' I set up an FMS (Fatigue Management System). Ultimately CASA CB did not approve it because "We had never intended it for international operations"...even after the CASA WA region had suggested it was now a requirement. Even after CASA CB denied the application (months of work and expence) CASA WA still insisted it was going to be a condition of AOC renewal!!!

I firmly believe that FMCs are a sick joke foisted on the industry by a :mad: from the University of SA.

In our operation even doing Singapore-Dhaka-Kathmandu-Dhaka-Singapore could be done (without exceeding the max allowed fatigue 'score') with one crew where we always did them heavy crewed under CAO48.

That was a VERY tiring long day...you arrived back totally shagged..even when using 3 pilots!!!

FMS, in my opinion, is a way for CASA to move liability for fatigue incidents from itself to individual companies.

They are a very bad idea!!!

They are open to gross abuse from companies!!!

Chuck.

[Woomera]

FMS, in my opinion, is a way for CASA to move liability for fatigue incidents from itself to individual companies.

Chuck, I was thinking more along the lines of them placing liability on individual crew members.........:mad:

[Chimbu chuckles]

Indeed !!

Chuck.

[compressor stall]

Yes....that one can work longer hours safely under CAO 48 is a given. The advent of reliable autopilots, GPS etc etc has made our workloads easier. FMS is one way of policing this, but there needs to be a responsible and understanding management involved, and no pressure explicit or implicit directed at the pilots to fly when fatigued.

Yep Woomera, it comes down to the pilot to turn around and say "no, I am fatigued, I cannot do this flight."

Imagine the reaction of the CP of say, Boonies Air Services Trading As Rural Discoveries! Pilot would be out of a job, never get called if casual, or get overlooked for the baron slot by a 210 driver sponsored by redheads matches.

A good tool in the right hands, a dangerous exploitative one in the wrong hands.

CS

[404 Titan]

Unfortunately most charter companies and airlines big and small are run by bean counters and they my friends are the most dangerous people in the world to be let loose with FMS and self regulation. They will be the first to abuse it. Mark my words. Taking regulation away from the governing authority and placing it in the hand of the operators is the most stupid thing I have seen and is going to lead to disaster.

[locusthunter]

"FMS, in my opinion, is a way for CASA to move liability for fatigue incidents from itself to individual companies."


"Taking regulation away from the governing authority and placing it in the hand of the operators is the most stupid thing I have seen and is going to lead to disaster."

"CASA is currently developing a trial fatigue management system with a specific intention of ensuring that operators consider all duties associated with a pilots employment when designing flight and duty time schedules. "


It is all a bad combination - CASA has motivation for doing it (avoid liability), operators have motivation for doing it (increased profits) and the "all duties associated" statement ... let's face it, the changing nature of the tasks involved can change the "duties associated" with any operation.


What can seem good on paper can be completely different to reality. Something that most bean counters forget when there is a dollar to be made or saved.

As my old senior sargent uncle used to say...

This whole system needs to be treated with suspicion.


:suspect:

[kimwestt]

locusthunter (aka bugsmasher??)
Your comments in regards to the "consider all employment in connection with pilots duties" is almost halfway correct.
You will find that, as you either get closer to, or get a job with an FMS approved operator, that ALL work, regardless of the how or where, (because what you do, and who you do it for is very definitately your own business) will have to be declared onto the FMS system. A smart move on an operators part would be to require a Statutory Declaration from a pilot, wherein the pilots guarantees that he/she (the pilot) will declare ALL their work hours to the employer. Both parties are then protected, especially at audit time, and at any (god forbid) enquiry.
Operators are free to put their own boundaries into the system, and CASA encourage them to do that. ie no more than a 12 hour day without a 4 hour break at "suitable accomodation". The biggest hurdle for the pilots to jump is to say no to a request to go flying if the pilot is tired or fatigued. And once having said no, that is the end of the request.
Properly implemented, and correctly managed, FMS is an excellent system.
BUT.... it is only as good as those who use it, on both side of the fence.

[Night Watch]

FMS is a joke..... My big problem with it is, the system keeps the pilot in the dark, and assumes that the pilot will speak up when he/she is tired. From experiense.... this just does not happen. The system that I have worked under was operated by management, and and spat out a fatigue score that determined whether or not you could be rostered for a flight. Now no two nights are the same..... if you signed on at 10pm and off at 6am on a beautiful night with not a cloud in the sky, your score would be the same as 10 til 6 on the worlds most crap night with 6 hand flown approaches to the minima with en-route thunderstorms and ice. However the computer will still says the same... this pilot is fine even though he/she has flown 4 of those crap nights in a row.

I could go on about this forever.... but it's just going to give me the :mad: as I think of the inevitable accident these Fatigue management systems are going to cause.

[dingo084]

I have to agree with the contention that FMS is open to many subtle and some not so, abuses and "novel interpretations".

I can think of a number of people that I have had to work with in the past that would have killed for the ability to implement a FMS rather than comply with CAO48.

Fatigue most certainly must be managed but not in a way that is open to abuse by either party.

I am quite frankly sick of management types that mouth the word "safety" but are actually thinking "profit". Two faced and not to be trusted springs to mind.

ding

:*

[Chimbu chuckles]

And make sure you declare all sporting activities carried out in your own time...or decline to fly after a mornings cardiovascular exercise....

That is how stupid this system is. As usual the career acedemics don't take into account 'life'.

In an FMS all you have is 'work' and 'non work'. They seem to believe that you, as an employee of the great benefactor, will be able to factor in every form of activity that creates fatigue.

Running around paying bills,game of rugby, mowing the lawn etc etc.

So what's is the likelyhood of retaining your employment after telling ops you can't fly the rostered days 'work' after taking into account every activity you have been required to perform in the last x days due to being a member of the human race!!?

"Sorry boss can't do todays flying because I've been moonlighting as a barman to help pay my rent/flying loan/car loan/, and yesterday I was running around all afternoon paying bills, this morning I went for a 2 k jog to keep fit etc"

All the above theoretically has a fatigue 'score' as doesthe rostered flying 'work'. If the total score exceeds the approved maximum (85 odd fatigue units) you cannot be asked to perform that 'work'.

Do we honestly think this is a system that will work in the real world as opposed to a Uni Lab?

Does ANYBODY believe that employers are going to be able (let alone willing) to keep track of all the 'work' outside of 'work' an average person is required to do in order to survive life?

CAO 48 may not be perfect but by design or fluke it does leave some fat in the system to allow you to be flown max hours and duty while having a fighting chance at getting meaningfull rest as well as having a life!!!

Given the above we must assume CASA are either:

1/. To stupid to realise the above is going to happen or

2/. To dishonest to acknowledge the above is going to happen or

3/. Don't care as long as they can't be blamed.

After dealing with these morons for in excess of 20 years I believe answer 2/. & 3/. are the most likely ones.


Chuck.

[locusthunter]

Kimwestt
quote:

"Your comments in regards to the "consider all employment in connection with pilots duties" is almost halfway correct.

"You will find that, as you either get closer to, or get a job with an FMS approved operator, that ALL work, regardless of the how or where, (because what you do, and who you do it for is very definitately your own business) will have to be declared onto the FMS system. "

...and here is 'almost half' the essence of the problem...it is O.K. to implement these systems in large companies where certain jobs are clearly defined and you can employ x number of people to manage such a system... but what about all the extra paperwork for the small operators (and their employees)...An FMS is good on paper, but when it is applied to smaller operators where job tasks are sometimes more difficult to define, where the success of the business and its employees is not always secure, where commercial pressures start taking precedence over fancy FMS programs (regardless of what is written on paper).

quote:
"A smart move on an operators part would be to require a Statutory Declaration from a pilot, wherein the pilots guarantees that he/she (the pilot) will declare ALL their work hours to the employer."

...and so now we have to have a Stat Dec...and what has actually been achieved. Sure FMS is fine for large operators and I'm sure that there is some fantastic research happening- but let us not forget that practical reality means more than any system. At the moment there is an 'almost half' uniform lid on what an operator can legally ask a pilot to do.

quote:
"The biggest hurdle for the pilots to jump is to say no to a request to go flying if the pilot is tired or fatigued. "

...and here lies another 'almost half' a problem - and so the theory of the system quickly starts unravelling against the practical reality of the GA industry.

...but hey, the system is 'almost half' right...and that's probably good enough for 'almost half' of us...



:ugh:

[Night Watch]

Chuck couldn't agree with you more!!

Personally I think option 3 is the CASA viewpoint

3/. Don't care as long as they can't be blamed

Night Watch

[The Hedge]

"A smart move on an operators part would be to require a Statutory Declaration from a pilot, wherein the pilots guarantees that he/she (the pilot) will declare ALL their work hours to the employer."


I work an extra 25-30 hours a week on top of a full time GA job, as it is to only way to make a half decent living. Kind of makes a mockery of Flight and Duty limits, but what I do in my spare time is up to me.

So what is work then? Mowing the lawn, fixing up the kitchen for the Missus, or an extra job?
My other job consists of sitting in front of a computer and is about as taxing as sitting on the couch watching TV.

A mate of mine works under FMS and cant get a p/t job as it has to be entered on the computer and affects his FMS score.

FMS is also not exactly in compliance with the GA Award (http://www.wagenet.gov.au/Wagenet/Search/view.asp?docid=234464&query=(PILOTS%20GENERAL%20AVIATION)&page=15&quickview=Y) either

[LateNightOps]

My very first job in GA involved driving a minivan, washing aircraft(and minivan), helping engineers in the hanger, loading/unloading freight, gardening, giving guided tours to punters, sometimes driving a 400km round trip in a coaster bus for tourists.... oh and logging about 70hours per month.
Plus when i first started and not paid during ICUS i was working nights behind the bar at the local hotel!

I can see the scenerio now, the operator 'implys' to the pilots that he/she will not be logging anything other than normal flying duties...and as a result his/her fatigue managment score is consistantly low, enabling the employer to work the pilots over 100 flight hours per month.

Doesnt CASA realise without proper mediation its an accident waiting to happen!!!

[Chimbu chuckles]

Exactly the point...and I can assure you they do 'realise' because I told em in words of one syllable...and I mean the people in CB...and guess what?

They AGREED with me!!!!

But still this utter BS goes on!!!

That's the power of the Lawyers now effectively running CASA. "We don't care as long as we're not liable".

Chuck.

[Jet_A_Knight]

I have worked under FMS for the past 2 1/2 years. Fortunately it has been for an honest and realistic operator. I have always had the option of knocking back a mission if I was too tired, and also addressing the rostering that I was issued on the basis of the FMS if it wore me out. I have knocked back a mission VERY late in the piece due to a very poor sleep that left me feeling very poorly and fatigued. The company was not crazy about such a late disruption, bat that is the reality of the system, and they called another driver in at the last minute. There were no repercussions as a result of that.

The FMS allows you more operational flexibility, especially when dealing with unscheduled changes, unforeseen delays, or missions that under CAO48 would have been illegal, yet safe to conduct.

It works both ways too. As a casual/sub-contract pilot, it allows a pilot to do more days and subsequently earn more money, especially in the bank run type operations where under CAO48, all that rest time spent in bed during the day, is counted on duty. You could feel quite fine about flyingthe next day, but 48 precludes this. So that's another day you can't fly, even though you're fit enough to. Most of the exemptions against 48 that allowed rest time to be counted as 50% duty have been removed.

If you are a full time employee, be prepared to be worked bloody harder than you would have under 48 and there will be battles when you are too tired to fly (the computer says you can!).

The biggest flaw in the system is the way that the FAID program doesn't take into account the intensity of work. For the system to be reasonably accurate, this needs to be addressed by the Centre for Sleep Research.

Just about anything in aviation is open to abuse - not just the FMS on it's own. Abuse of the FMS should be addressed as part of the whole problem of abuse of the aviation system. (Now that's a massive thread on it's own!)

In summary.....if you work for a good operator, it provides alot of operational flexibility, increased productivity (within reason) the chance to make more money as a sub-contractor, and the ability to conduct missions that once upon a time were safe, but not legal; but if you work for a shonk or a slave driver.........you poor b@stards:{

[AerocatS2A]

FMS is also not exactly in compliance with the GA Award either

That's irrelevant really. One is a safety document, the other is an industrial relations document. They don't have to agree with each other. Which ever one that becomes limiting first, is the one used for the particular situation.

E.g. you've flown 70 hours for the month but have a FAID of 80, FMS says you can't fly tomorrow. Or, you've got a FAID of 55 but you've flown 100 hours for the month, then the Award dictates that you can't fly tomorrow.

This is why it is important to have the working hours dictated by your AWA, Award, EBA etc. CAO48 used to be an effective industrial relations document, even though it wasn't intended to be one, the FMS is not.

I agree that one of the main problems with using the FAID score is that it only calculates fatigue based on how much sleep it assumes you are getting, derived by your hours of work. If you are getting less sleep then the FAID will be wrong. It does not take into account work related physical/mental stress. Doesn't matter if you're sitting in a 2 crew cockpit with your feet up reading the paper all day, or in a single pilot cockpit working your butt off making numerous bad weather instrument approaches on short sectors, you'll still end up with the same FAID score if your working hours were the same.

[locusthunter]

And that's it...chimbu, LNO, the Hedge...I agree with you all...
FMS is just not practical and too easy for the operator to abuse. At least CAO 48 shuts the door on ridiculous behaviour- FMS does not.

[Nipper]

I have read all the posts here and chuckle at the “honest” replies. It seems to me that no one here has never exceeded the F & D as set out in CAO 48.0, are we still talking about GA in Australia. :confused:

CAO 48 is as open to abuse as is the FMS now called FRMS (fatigue risk management system).

It is interesting that the FAID score of 80 is still being quoted, as the upper limit on FRMS is now 70. Having said that the “R” in FRMS now means that you must consider the risk assw each operation. Therefore if it is a dark night, low cloud and p*ssing rain, single pilot ops then the risk management may produce an upper score of say 60 and that is the limit to task the pilot.

All systems are open to abuse by operators. If you have kept up to the NPRM’s you will notice that under the new Regs the choice will be FRMS or the new “CAO 48” whatever it will be called with no exemptions.

How many operators have exemptions against CAO 48 so you can “legally” work longer hours. I’m not for or against FRMS, but a balanced view would see that abuse is abuse, MTOW on aircraft but lets keep that for another debate!!!!!!!!!!!!!!

My two cents worth, RANT OFF.

[helmet fire]

I liked compressor stall's call:
A good tool in the right hands, a dangerous exploitative one in the wrong hands.

'bout sums it up really. Same as CAO 48 and thier various exemptions: no system will stop the 15 to 20% who will abuse ANY system.

But what fascinates me most about the FRMS is it's introduction. Firstly we had the NPRM. I will talk about the helicopter industry response as I am not familiar with the thrust of the fixed wing response. The overwhelming response was to reject the proposal that CASA put forward, which essentially was that they were suggesting that the shortfalls of CAO48 and exemptions should be addressed by "an operator devised" fatigue system that could be put up for approval by CASA.

As absolutely NO guidelines were provided other than that the operator would have to prove it's validity. There was no standard set by CASA, nothing to base your research on, nothing to judge methodology with, just a statement that CASA would decide if your suggestion was valid or not.

Suprise suprise, the helicopter industry suggested an overhaul of CAO48 and exemptions (because they were working) and totally rejected the individual operator designed system suggested. Further, it was stated that CASA, being the overall body responsible for such things as RULES and SAFETY might actually research and design a system for ALL operators so that individuals did not have to finance individual research projects with NO DEFINED SCOPE METHODOLOGY OR OUTCOMES so that CASA could pass subjective judgement.

What came out was dumbfounding. After industry rejected the individual designed system proposed and suggesting an overhaul of CAO48, CASA turned around and said that having fully consulted the industry and examined a large amount of response, the industry had rejected the current CAO48 and was therefore happy with the proposal to introduce an individually designed system. WTF?

They used the request for an overhaul of 48 as grounds to wash their hands of the responsibility of properly funding and researching fatigue issues, and requiring each individual operator to fork out itself. It then made the change over WITHOUT NOTICE effective from the next renewal of the operators AOC. This meant that those whom had just renewed thier AOC had three more years to use their exemptions, whilst if your renewal was the next day, your exemptions were all cancelled immediately regardless of existing contracts. Out on the same fire line it meant that some operators were restricted to CAO48, and others were still operating on the old standard industry exemptions and flying substantially more. What could be fairer than that?

Now we can pay a university mob to give us a truck drivers fatigue system and CASA are happy. I wonder what liability insurance that uni has? Are they fully aware of the ramifications of an aircraft accident as a result of their research into truck drivers?
:confused:

[Chimbu chuckles]

Yup!!!

So typical of modern 'public servants'...When something is proven to be completely stupid make it mandatory and then spin, spin spin.

CASA = C**TS Against Safe Aviation.

Chuck.

[helmet fire]

I have just read the DP on this issue : DP 0404OS-June 2004. It appears to be a cut and paste of the 1999 NPRM on the same subject. It passionately argues for the adoption of operator imagined FRMS, and consistnetly argues against all the other options offered. Perhaps it should be a "Justification Paper" for FRMS rather than a "discussion" paper to explore other options.

One gem in the paper (para 3.1.7) even states how a field study comissioned by CASA supported the viability of FRMS software. The study was carried out by the University of SA at the Centre for Sleep Research. The largest provider of FRMS software comes from the University of SA's Sleep Research Centre. Any suprises there?

or this one (para 3.4.7): "the world appears to be waiting for Australia's next step" Are we having a lend of ourselves here? And this one (para 3.4.8): "The benefits of operator-developed FRMSs include:.....less complex and easier to use than CAO 48"

The DP is a fait acompli, and CASA should correctly name it as a determination rather than as a discussion.

[CockpitJunkie]

Liability was mentioned in one of the posts.

I believe CASA is trying to shift liability away from themselves to operators through FMS (fatigue management system).

This also applies in other areas where responsibility is being passes to operators such as SMS (safety management systems).

It also means less resources are needed by CASA and they can downsize costing the Government less $ in budgets.

[currawong]

Sick joke.

If CAO 48 meant anything at all there would be no requirement for exemptions or FMS.

It is SOP in many operations to work for months without a day off and pull 36 hour shifts. Some do longer. The touchy feely FMS etc angle is all lip service.

And be obliged to sign a flight/duty time roster indicating something quite legal at the end of it.

It is endemic, those that fight it tend to be unemployed.

[currawong]

Yep.

Thought so.

State a fact and no one will touch it with a barge pole.

;)

[185skywagon]

as an owner operator, i have a couple of periods per year where i come up against cao48 (with exemption) flight time limits(airwork). i.e 90hours/28days. i reckon an FMS would be heaps better in my situation. i can also see that it is open to abuse when not followed in spirit.

[currawong]

185, is your aerial work ag work?

If so you should be good for 170 hrs per 28 days.

[185skywagon]

no, it is animal baiting and low level animal survey. some clown got baiting taken out of air ag.

[hurlingham]

I have worked with a FMS for a few years now - fantastic.

However, I am lucky enough to be working for a reputable company that has a fantastic safety ethic and FMS is not open to abuse.

While bean counters and CP's continue to undercut, take shortcuts, and/or try to manage undercapitalized GA outfits FMS will not work in GA. For FMS to work the company must embrace it 100%. Unfortunately very few CP's are even half decent managers.