CAO 48

[Mr Proach]

Perusing the CAO instrument 2013 it is interesting that the cumulative flight time limit in 28 days for a two pilot RPT operation is 100hrs, yet it appears that for an aerial work operation for the same period the cumulative limit is a massive 70% higher at 170 hours. Is that interpretation correct? The previous limit set out in CAO 48 was 100 hours in 30 days. If the new CAO 48 is reportedly based on scientific facts how is it that a human being's resilience to fatigue varies by the category of operation. Some aerial work operations are physically and mentally very intensive, where does the instrument scientifically account for that? It has been suggested that the reason of "science" is just a label and the underpinning changes were essentially the product of involvement by industry management to achieve significant gains in productivity. Apparently some low calibre operators are taking advantage of the new arrangement to administer flight and duty periods by rostering flight crew to do many hours of work and not classifying it as duty time.

[AerocatS2A]

The simple answer is that F/D limits are not there to protect crews, they are there to protect fare paying passengers.

[Seaeagle109]

Mr Proach,

Sorry, I don't have time to peruse the entire document about any differences regarding aerial work(I'm just waiting for kickoff in the footy) but a quick view of the definitions in the 2013 Instrument reveals the following:

duty means any task that a person who is employed as an FCM is required to carry out associated with the business of an AOC holder.

duty period means a period of time which starts when an FCM is required by an AOC holder to report for duty, and ends when the FCM is free of all duties.

So, if your Company asks you to do anything for them then it's duty time, that whether it's paperwork, cleaning the hanger or answering phones.

[Derfred]

duty means any task that a person who is employed as an FCM is required to carry out associated with the business of an AOC holder.

If that has finally made it in there then that is excellent.

I do recall an incident investigated by the ATSB where it was uncovered that a certain management Captain had spent many hours working in the office prior to signing on to an 11 hour duty, and then stuffed up the landing.

[Oldmanemu]

Please dont mention anything to do with CASA (CAO48) and science in the same thread. I find it offensive.

[Mr Proach]

I find it odd that a regulator which has rules upon rules that extend into every minor and obscure facet of the industry effectively dismantles regulation over an element of the industry that you would expect would have high priority.
I think that it in the "real world" of the industry when hard limits are removed it provides more opportunity for managers to exploit the system and removes protection from individual crew leaving them in a very vulnerable position.
Operators whose business service the greater public I expect will apply some duty of care because of their exposure to civil litigation.
However for a very broad section of the industry it appears to be open slather.
In my opinion, moving the head of power from the regulations to the AOC deflects public scrutiny away the regulator in the event of any adverse findings regarding duty time as part of an accident investigation.
Those empowered should revoke this legislation and restore intregity to the regulation of F&D times so that it captures all aviation operations.
As you stated Seaeagle it is all about the traveling public, however, those who operate the machinery are also humans (for now anyway).

[Creampuff]

Such naïveté.

The 'safety' regulatory regime in Australia is as much about politics as it is safety. Probably even moreso with flight and duty time rules.

[Mr Proach]

Cream puff,
Do you mean that F&D time regulation has a lot to do with safety and politics or is it mostly about politics and little to do with safety?

[framer]

Hi f it had anything at all to do with safety crews wouldn't be signing on at 7pm and flying four + hours (to a port where the airline regularly overnights crew, ) doing a 1.5 hour turn around and then flying four hours back to land at about 6:30 am with nine hours stick time, all the while having the potential to divert at 6:30 am and have the whole thing push out to 10.5 hours stick time and 14 hours duty on the back of the clock.
From a safety perspective this is just dumb. From a commercial perspective it saves overnighting a crew and means that the airline can perpetually run with lower crew numbers. Ie, if it actually comes to safety v's commercial, the regulator allows the airlines to choose commercial.

[coaldemon]

We are talking about a set of rules that were written in an age more about DC-3's than B737's. Reality says that if the operation is fatiguing and it is all that you get the crew to do it will lead to a problem. The old "might happens" question is more for the operations people to work through than a set of Fatigue rules. CASA ain't going to tell you how to operate your fleet within the rules but they will hold you to the systems, checks and balances that you have for obvious problems like this. Will it stop Airlines or Freight Operations doing it. Probably not as they don't actually make much money out of this glamourous industry so most are just trying to get by. I always say that I would never roster crews for flights that I wouldn't do and I do have some sympathy for the concept of taking the roster People on trips they create that no one should fly.

[Popgun]

"Safety is Our Number 1 Priority!"

Now, once again children, this time with feeling!

PG

PS. Creampuff is bang on the money.

[Mr Proach]

It appears the scientific parameters on which the new rule is based is predominantly limited to one area, that being the subject of sleep patterns. There are many more factors that can influence the accumulation of fatigue. Workload and work environment are just two of so many more, I don't see where that is scientifically evaluated and applied. I don't believe that scientific criteria can be applied to cover every aspect of the matter which it supposed to govern. There are a number of areas in the new rules where statements or clauses appear to be based on the opinion of some party of a working group rather than scientific application. Opinions are not scientific and may be influenced by motives. Some of the statements appear to have no scientific basis, sometimes statements are made on the basis it is said therefore it must be true. In my opinion if you can not apply scientific criteria to the totality of subject matter then clearly defined real world limits should apply.
Those forefathers who created and developed CAO48 created a set of rules that were clear and effective and had just as much relevancy today as they did when there were introduced. It also provided a level playing field for (domestic) operators.