Cao 48

[BK_Equalizer]

I would like to know the opinion of the industry on operators who force their employees to breach CAO 48. I am aware of a number of organisations within the SY basin doing this.

Personally, I think that an organisation that can force their employees to breach CAO 48 essentially to keep their jobs is really poor form.

I would like all who view this post to reply their honest feelings on the matter. :)

[sprucegoose]

Do these operators use the standard industry exemption? I can't see why you would force a breach of the CAO when you can get some additional flexibility simply by applying for the exemption. Silly operator really.

[Tazdevil]

I have worked for a number of organisations in both training and charter. All of these have operated within CAO 48.

However, there was a threat to my job if I did not attend the organisation six days a week even considering that one of the days was my 21st Birthday!!

Organisations who breach CAO 48 should be brought out into the open!

[Keg]

Interesting Spruce. My understanding is that CASA haven't granted exemptions to it for ages.

Considering they won't consider QF 767 drivers getting the same exemptions the 737 drivers operate under, I can't see how they can give them to anyone else either!

Spoke to an ex AN 767 driver though a couple of months back and he reckoned the exemptions were great for east coast domestic flying but downright dangerous for MEL-HKG. Perhaps we are best not having them anyway.

[BK_Equalizer]

Maybe I should have clarified myself a little more. I am talking about operators who do not have any exemptions to CAO 48. ie. a large number of training organisations!!

[sprucegoose]

I don't know Keg. Of course the move is towards each operator having it's own fatigue managment program which will do away with this CAO48 stuff. I find it interesting that CASA appear to be leaving this program up to the operators. Seems to me they have somewhat embraced the concept but have no idea how to manage it themselves so it will be up to each operator to design a program and then CASA will consider it for approval. Self regulation at its best/worst. Kind of like me taking over control of the 52nd airborne and telling the troops to report back to me on how they plan to wage the attack and I'll then decide if it's a good idea or not!

As for the exemption I think it was intended for domestic application but perhaps someone else here can clarify that. I wasn't aware that CASA were not issuing them anymore.

[sprucegoose]

Sorry BK, I am not trying to hijack the thread. For what it's worth there was a large GA operator in Kununurra who had a chief pilot that nudged his pilots quite firmly to blow out the CAO48 limits. His philosophy was you either "store" the time somewhere and log it when the flying is lean or go fly somewhere else.

[BK_Equalizer]

I have heard recently of an operator at BK "un-officially" informing the staff that they should attend six days a week and be on duty eleven hours a day.

I believe that they are not the only ones doing this, and it probably occurs ast other airports around the country.

A fatigue management system is of course an option, but I believe it is also limited/restrictive depending upon the pilots being honest about their out of work activities.

Can viewers give an indication if this practise is in fact occuring elsewhere??

[Dale Harris]

Sprucie,
Dunno about the airlines, but we just had our G.A Part V exemption reissued, and for 3 years! It appears the "push" towards the self administered regulation is not travelling too well. The principal proponent of it I believe did not get his contract renewed. Just a rumour tho....... Cheers

[I'm with stupid]

Ah, yes, the good old CAO48 exemption, rostered for 12 hours duty, can extend to 14, fly 9 hours.........
What was that ?? fatigue management programme?? oh yes, we are looking into that.....cheque's in the post, bla bla bla.:mad:

[Dale Harris]

Hey, we get up to 16 hrs..........

[BK_Equalizer]

I do not want to be rude, but I would like to redirect the thread to the occurences experienced by pilots within Australia with regard to the breaches of CAO 48 by organisations without exemptions or fatigue management systems.

I have spoken to a number of associates in the position where their job is on the line if they do not breach CAO 48! :eek:

[megle2]

Our dispensation lapsed as Casa would not renew without fatigue management programe.

Fortunately Part 48 suits us almost always. With Customers who accept the fact we can't do what we used to do, its not been a problem.

In any case who wan'ts to work the ridiculous under a dispensation with in many cases no extra pay!

The Casa approved dispensations with their fatigue m'ment programes that we have seen and heard about don't seem too popular with the troops.

[lackov]

Keg,

Rest assured, exemptions to 48 are still flowing thick and fast.

As to the initial poll question, there's probably a little more to it than meets the eye. The only ones in the industry able to publically 'out' comanies that disrespect CAO 48 or any of its exempting clauses, are those legally savvy enough to do so without landing themselves or others in the middle of a defamation case. Read this as being truly the sole domain of the incumbent regulator. Anyone else should submit reports through the proper channels before giving Mike Munro a call.

[megle2]

Just read a accident brief in Aviation International News, June 2002

B1900 Aug 99 Quebec Canada

Crew Duty prior to fatal non authorised GPS runway approach down to 100 ft - CFIT

Capt 7000 hrs 606 on type 127 hours previous 30 days

F O 2,600 179 on type 181 hours previous 30 days

preceding few days 12 - 14 hours duty 8 hours +
flight each day Last day off almost one month
prior.

Bad eh

[Dale Harris]

While not wishing to detract from the fact that such work practices may have contributed to the accident described above, I think you are drawing a long bow to intimate resonsibility here to duty/flight times. I think that given the previous workloads while being contributary to the accident, the "Non authorised GPS approach to 100 ft" kind of says a lot about the accident.

[Northern Chique]

Ive worked both for great companies and bosses Id rather not comment on... A good company looks after the staff who look after the company clients.

This includes a safe working environment with effective controls on fatigue management. Ive seen more than one pilot threatened, go to work against their better judgement, and then make an expensive mistake for which damages where docked out of their final paycheck. It is an attitude which is rife in GA.

Ive met some good operators, who pay well, rarely have problems with staff morale, and ironically no-body is recruited into these companies unless the company decides to expand or someone leaves. Everyone is happy, morale and comunication both benefit as well! :D

If the staff are happy, the clients have every chance of having their day go as well as can be expected barring unforeseen circumstances. The majority of the time the clients are well informed prior to departure what weather risks etc there may be so surprises are few and far between.

Any fatigue management program will encorporate some level of stress management. Pilots stressing about busted duty times, fudging log books and duty times so the evidence isnt conflicting, making sure MRs arent a dead giveaway.... yeap lying is a stressful and uneconmical way to effectively run shop. Tired, fatigued and stressed pilots are not going to be the wonderful people they could be to the clients. Loosing clients gets really expensive.

Fuelling errors, alternate errors, get-home-itis, poor airmanship are all mistakes made commonly enough by pilots under stress.

So to end my rave... compromising pilots by pushing them outside CAO 48 is bad management practice which has in the past contributed toward many fatilites, increased damage and heartache for those invloved...

[Dale Harris]

How very true N.C.

[compressor stall]

NC...reference your last comment about working outside CAO 48.

One of the current CASA approved FMS systems allows a 20+ hours duty period for any operation provided you have had the previous 2 days off. There is no flight time limit in this duty period and the flight may be single pilot IFR. In theory you may start at 0900 and finish at 0500 the next day. CASA's own physiological data states that being awake for more than 19 hours continuously impairs performance akin to having a couple of glasses of beer.

If the pilot thinks s/he will be fatigued, then it is up to s/he to advise the company the s/he will be unable to finish the flight.

Scary stuff in the hands of unscrupulous operators.

Also, the blame of an accident like the one listed above in Canada would be put fairly and squarely on the pilots for accepting the flight. Flightcrew are being asked to make judgements on their fatigue levels when they are fatigued and a by product of that is impaired judgement.

[Capt EFIS]

I would of thought that companies would of learnt after what came out from that accident in South Australia a few years ago.

If someone in the company was to have an accident, they will find that CASA will bring up all the recorded flight movements (ie. Sartimes, Controlled Airspace Ops) and start matching them with duty sheets. Its amazing what is recorded and how far back it goes.

In my opinion these companies exceeding flight and duty limits are the same ones that are not paying their pilots the correct wage.

It could be a lengthy process to sort through ATC records and compare it to company duty sheets, however, it might be time that some regulatory body went through the companies systematically and check if they are paying their pilots correctly. That could be an easy way to sort out the ones that might need further investigation into their operations.

[Icarus2001]

Capt EFIS I agree. Isn't that the role of a safety authority? CASA perhaps?

Having experienced both flying school & charter ops inspections, they seem to be more interested in making sure there are sticky signs above each exit in your Cessna 172 saying that the door is an exit and ensuring that your CAO 20.11 training was conducted in a swimming pool on the first occasion. Something like deckchairs and the Titanic.

Meanwhile obvious fraud and deceipt in other areas is glossed over. As you say F&D records can (and should) be checked against the MR, Tower records, Censar, ATS etc.

[compressor stall]

Dale, just re-read your comment re the accident, and I respectfully disagree.

Do not under estimate the link that fatigue may place in the chain of an accident. As an experienced aviation person such as yourself, you would have no doubt read that every accident results as a chain of events, some longer than others, and if any link of the chain was missing, tragedy was avoided.

Now, with respect to the Canada crash, whilst I do not know anything specific about it, fatigue could have been a cause of the accident. The crew, perhaps being excessively fatiuged, may have elected to take a short cut to save time as they were sick and tired of being in the cockpit and wanted to get out and home. Their attention spans, ability to follow written checklists and tolerances of flight may have also been compromised due to fatigue.

I for one have noticed a degradation in my flying procedures, and tolerances when I have (legally) operated well beyond CAO 48. Generally is was a small amount of apathy, and missing checks like fuel pumps off after take-off, reduced vigilance and tolereance on climbing speeds, and forgetting things like position reports. Now these might seem insiginificant but they could be a link in a chain of events. It took a large amount of self discipline to recognise and correct these events.

If I flew an unauthorised GPS letdown into somewhere (which I do not, and do not advocate!) and my attention span was shortened due fatigue, then a CFIT accident could result. Unprofessionalism as a pilot may get blamed, however, if that pilot was not fatigued, then he would be alive today.

There is an excellent article on the insidious nature of fatigue in the last edition of Air and Space Magazine.

[Dale Harris]

C.S.
You make my point for me. By posting such an accident record here in this thread, the person is intimating "here look, an example for you of fatigue" As I said, I do not wish to detract from the fact that work practices here no doubt contributed. As you state, "the chain of events". It is obvious that one missing link may have saved the aircraft. Fatigue is but one of them. The approach, the weather, company attitudes, get home itis, you name it, it is in this one. Remember though, fatigue affects different people in different ways, and to blindly assume as some do that CAO 48 in itself will take care of that is bull****. I'm sure you have been around long enough to know that, so I am not having a dig at your good self..... I think we are in agreement somewhat, although I think from different ends of the question?

I might add tho, that you don't have to be fatigued to have a CFIT. Carrying out approaches like appears to have been done in this case will kill you eventually, fatigued or not.

[compressor stall]

Dale...yes, I see, we agree, I think... :confused:

I used to be indecisive, now I am not so sure.

CS

[compressor stall]

found the link and the following information...

1.18.7.2 Captain's Flight and Duty Times

The captain flew 127 hours in the last 30 days and 337 hours in the last 90 days. A monthly or quarterly flight time extension request for the captain could not be found in either his or TC's files. On the day of the accident, he had been on duty, first at his own company and then at Régionnair, for 16 hours. His logbook records indicate that from July 28, he flew every day for one or the other company (and sometimes for both on the same day) except for August 4, 5, and 10. His total flying hours for those 11 days were 73.5 hours, an average of 6.68 hours per day. It could not be determined how much time he spent daily performing administrative or operational tasks at his own company when he was not flying. The captain was required to report his Confortair flying times monthly to the Régionnair operations officer for tracking. His total flying times for both companies, from May 1 to July 21, were on record at Régionnair. Flying times after that date had not been reported.

1.18.7.3 First Officer's Flight and Duty Times

The first officer flew 181 hours in the last 30 days and 368 hours in the last 90 days. Like the captain, a monthly or quarterly flight time extension request for him could not be found in either his or TC's files. On the day of the accident, he had been on duty, first at Confortair and then at Régionnair, for 18 hours. The first officer's logbook indicates that he had been on duty and flew for one or the other company every day since July 14, except for August 1. His total flying times for both companies, from June 6 to July 31, were on record at Régionnair. Total flying times for August had not been reported. Neither the regulator nor Régionnair was aware that both pilots were exceeding their flight and duty time limitations.

1.18.7.4 Pilot Fatigue

Researchers at the Defence and Civil Institute of Environmental Medicine found that after 18 hours awake, people showed a 30% decrement in performance on cognitive and vigilance tasks. After 48 hours, the impairment averaged 60%. Researchers at the Centre for Sleep Research at the University of South Australia found that after 18 hours without sleep, students performed as poorly on performance tests as they had with a blood alcohol concentration of 0.05%. After 24 hours without sleep, their performance decreased to that of a person with a blood alcohol concentration of 0.096%.(5)

As a commuter operation, conducted under Section 704 of the CARs, the company had to provide either 36 consecutive hours free from duty requirements within each 7 consecutive days or 3 consecutive calendar days within each 17 consecutive days. Neither crew member was provided with this time off specified in CAR 700.12(a). Operationally, it is important that recovery periods be scheduled to provide an opportunity to acquire recovery sleep and to re-establish normal levels of performance and alertness. Frequent recovery periods are important. More frequent recovery periods reduce cumulative fatigue more effectively than less frequent ones. For example, weekly recovery periods afford a higher likelihood of relieving acute and cumulative fatigue than monthly recovery periods.(6)

Fatigue can lead to forgetting or ignoring normal checks or procedures and reversion to old habits. Fatigue can also reduce attention, causing one to overlook or misplace sequential task elements, become preoccupied with a single task, and be less vigilant. When alertness is impaired, one may focus on a minor problem (even when there is risk of a major problem), fail to anticipate danger, and display automatic behaviour syndrome. Problem solving can also be affected and may lead to inappropriate actions.


http://www.tsb.gc.ca/ENG/reports/air/1999/a99q0151/ea99q0151.htm

[downwind]

How does this new fatigue management system work??? I know PEL AIR 22 hr dutys!!!

[Northern Chique]

All is well and good if the company will back the pilot if all is going well and the pilot says "look guys, its been a hard week and I need a bit of extra time off."

Ive seen it happen and the pilots are happy to go to the boss and ask. Other companies will not pay properly, thus putting financial strains on the pilot and posssiblely his family. He / she tends to take risks including flying while fatigued.

On the other side of the coin, the fatigue management controls which some companies have put into place invlove some on duty sleeping and structured rest periods.

[megle2]

Yes I mentioned the Canadian accident because fatigue played a part.

The flight and duty times were high, a risk by themselves, but were coupled with difficult weather and a dangerous approach at the end of their day.

There were other contributing factors which coupled with the above made a sad ending highly probable.

[scramjet]

What is the story, we got our exemption signed 9 July 2002, thought the whole thing was going to fatigue management systems?

[lucky boris]

I hear that AS at BK is having discussions about this, also that their theory presentation methods are being reviewed.

[BK_Equalizer]

From what I have heard, AS is not thinking about it, they issued a letter to their staff indicating 11 hours a day 6 days a week. They are clever though, the letter was not on company letter head nor was it signed by management.

It also apparently had a qualifier on it advising staff to remain within CAO 48.

HOW CAN THE STAFF BE EXPECTED TO DO BOTH!!! Are they supposed to forget hours of duty each week??

As previously stated, they are not the only organisation doing this at BK.

[twentyelevens]

Icurus, you are spot on.

Certain FOI's turn blind eyes to astoundingly obvious breeches of 48. While making sure that the t's are crossed and the i's dotted on trivial matters.

The sense of rage that many pilots feel at having to breech 48 (no work no job) is compounded by the lack of it would appear,ANY CASA help or recognition regarding these obvious breeches of 48.

In fact one FOI was heard to mention to management after an audit "well the flight and duty times have been falsified correctly"

One not even need to plough through MR's and tower logs to spot the discrepencies between actual duty and logged duty. Simply look at the booking system in many of these places and look for the hours rubbed out with an eraser. Some pilots in these places do thier flight and duties with thier sheet in one hand, and the booking sheet and eraser in another. Funny how they are always just under 90 hours duty.


Some organisations I have heard have gone through so many audits without compliaint about thier flight and duty times, that compliance to 48 is a non entity, they simply don't bother trying to hide it anymore. Why bother? In these orgainisations this obvious non compliance is about the only thing that the operators do to reduce pilot workload (refer above, flight and duties in one hand, booking sheet and eraser in another).

As we are told time and time again, a breech of safety, accident or incident is never caused by a single factor. Many things contribute. This rife and it would appear sanctioned breeches of 48 are to be a large cog in the wheel that will eventually bring a lot of people down. I hope this discracefull behaviour by the operators and certain other individuals in a position to do something about it stops before the wheel falls off.

[Chimbu chuckles]

And Casa's answer to the thorny problem of Duty Hours is an FMS. There is no such thing as duty hours in an FMS...just 'work' and 'non work'...but I guess it absolves CASA from one more regulatory oversight process that steadily increasing budge cuts from Govt make impossible anway!

But when you ring up the boss before a hugely long period of work starting at 0700LT after a nights 'non work' interrupted by your sick toddler, construction work outside the hotel or simply the fact that you couldn't get to sleep after sleeping most of the day away the day before because you were shattered after a very long period of 'work', and tell him you are unfit for duty and he explodes down the phone at you....well you can take comfort from the fact that instead of doing 11 hours of duty (which in your present state you might just sqeeze through) you could be out there for 16 or 20...man as long as you fatigue score doesn't hit 80 odd who givsa fark?

The Howard Viels of this world don't!

And you know why? Because when you fark up and die taking a bunch of punters with you fatigue won't even make it to the report...hell you had a good nights sleep...didn't you? Hell you just had 36 hours of 'non work' since your last body clock shattering period of 'work'...and of course your kids are trained to creep around the house and not wake up Daddy, your apartment/house is hermetically sealed to ensure you can sleep when your body clock says "WAKE UP SUCKER!", you haven't had to race out and pay bills/go to the dentist...ohh and that game of rugger you enjoy playing on your one day off...you know that period of intense cardio excercise which is good for you...well forget it because that's 'work'!

What the 'professionals' at U of SA failed to allow for was 'life'. Life can be lived in its, almost, normal fashion under 48 and it's derivatives...under a Fatigue Management System that's not the case...it doesn't have the buffers for real life...only the ones you get in a University Classroom.

Chuck.

[compressor stall]

I would agree with most of your catharsis Chuckles, except that if you had a fatigue related accident then it will be deemed to be YOUR fault as the pilot because it explicitly says in the FMS nomenclature that you alone are responsible for not accepting work if you are fatigued.
:mad: :mad:

PS. Did you get my email about 10 days ago?

[Chimbu chuckles]

Of course it's your fault:rolleyes: ;) ......and of course there is FAID monitoring software that someone in the office will ensure is programmed correctly with every bit of info required to get an accurate fatigue score:rolleyes:

I don't know what the ultimate answer is, but, CASA this aint it...it's a duck & shove!

Good companies may well go to extraordinary lengths to ensure as accurate a record as possible......but!!!

Chuck.

PS yes I did....didn't I answer it?...if not send again:D

[BK_Equalizer]

I think the pole speaks for itself. I would like to appologise if this post has created any discomfort for those in the position of breaching CAO 48. :(

The main idea is to try and bring this problem into focus and find the industry opinion on the matter. The attached poll has had a number of replies indicating the thoughts of those who have viewed it.

How do we now take this information and find a solution that will protect the employees and yet expose the companies in breach??? :eek:

[5 Left & Right]

Is it a flying school you are talking about??

I was CFI of a busy flying school and managed to opetate within CAO 48 without any problems.

Any operator who threatens your job if you don't deliberately breach CAO 48 doesnt deserve to have an AOC and should be reported to the relevant 'authority'.