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SRATCOH new rules

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Old 21st Nov 2019, 14:45
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SRATCOH new rules

Just heard that SRATCOH may will be scrapped next year. Can anyone confirm or deny this madness. ..and what will replace it....if any ?
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Old 21st Nov 2019, 15:54
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Originally Posted by chaka534
and what will replace it....if any ?
A sudden increase in fatigue related incidents?
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Old 21st Nov 2019, 17:09
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Originally Posted by chevvron
A sudden increase in fatigue related incidents?
agreed its worrying that this is even being talked about.
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Old 21st Nov 2019, 18:44
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Would the unions permit any major changes when making current SRATCOH rules part of unit rules?
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Old 22nd Nov 2019, 05:49
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My concern is that ...as far as I'm aware...every unit can do their own thing. Bloody stupid idea . I know smaller units will keep the pants out of it . That's the way its going to be irrespective of what SMS says.....limited breaks longer hours...time to retire lol
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Old 23rd Nov 2019, 20:07
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As far as I am aware there will be approved SCRATCOH from CAA (EASA?) which will if introduced be an 'acceptable means of compliance' however units will be able to modify to suit their own needs using the SMS and risk assessments etc. And yes I can see it will be open to abuse by less scrupulous operators.
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Old 23rd Nov 2019, 22:18
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Still will remain illegal for an atco to plug in when they know or suspect they are fatigued.

stupid irresponsible rostering - you have the power....
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Old 24th Nov 2019, 08:23
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As a retired ATCO, I have no axe to grind; but as a concerned ex professional, I cannot believe what I see & hear in these pages in regards to the continuing potential attrition of safety standards. On another forum, you have the suggestion that separation standards be abandoned in order for a/c to fly in formation & save fuel; & on this one, you have the suggestion that safety regulation should be watered down in order, apparently, to save money. I have to say that I resisted the imposition of SRATCOH for many years at Jersey - on the grounds that it would have left us working more often & at more unsociable times. We lost that battle & had to accept SRATCOH. But now, forget all the reasons why you had to adopt it chaps; it is no longer necessary because the operators find that it is too inflexible & costing them too much money. Or, have I got this wrong ?
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Old 24th Nov 2019, 13:45
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You are correct some airfields want cheap ATC to maximise profit....fair enough . But we have had protection for years now from fatigue thru sratcoh. Changing that in any way will allow unsafe practices to slide in under the radar....pardon the pun.
it's a shame that the authorities who come down hard on us for breaking these rules over the years have now capitulated to allow more flexible hours , which will undoubtedly cause safety issues.
Profit should never override peoples safety...let's hope not !
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Old 24th Nov 2019, 15:11
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Originally Posted by chaka534
You are correct some airfields want cheap ATC to maximise profit....fair enough . But we have had protection for years now from fatigue thru sratcoh. Changing that in any way will allow unsafe practices to slide in under the radar....pardon the pun.
it's a shame that the authorities who come down hard on us for breaking these rules over the years have now capitulated to allow more flexible hours , which will undoubtedly cause safety issues.
Profit should never override peoples safety...let's hope not !
As soon as there's profit involved safety takes second place.
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Old 24th Nov 2019, 15:14
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One of the problems is that SRATCOH is/was a very large sledgehammer to crack a very small nut. When the committee reported, they found ,overall, very little evidence of fatigue being a cause of incidents. But, having measures in place to prevent the possibility seemed sensible. Hence, we got SRATCOH. In the regulatory environment at the time, it was probably the best that they could do.
It is proof positive that one size can't fit all. As Keith rightly said, his unit worked harder (hmm) and longer under under the rules. Could quote several other units that suffered too. Wish I could list all the names I was called at the time for being the poor sod trying to implement it!

Theoretically, a good SMS system should allow units to tailor the requirements to better suit their operations. Interesting to see how that works.

Last thought; the regulatory regime these days is based on "hands off regulation", i.e the companies know their business better than the regulator and should be trusted to apply their SMS correctly and safely. Worked well at Boeing!
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Old 24th Nov 2019, 16:05
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Of course the cause has not been helped by the willingness for ATCO’s to do overtime ( AAVA’s if you work for the big one! )

Rgds
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Old 24th Nov 2019, 16:05
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Originally Posted by Dunregulatin
One of the problems is that SRATCOH is/was a very large sledgehammer to crack a very small nut. When the committee reported, they found ,overall, very little evidence of fatigue being a cause of incidents. But, having measures in place to prevent the possibility seemed sensible. Hence, we got SRATCOH. In the regulatory environment at the time, it was probably the best that they could do.
It is proof positive that one size can't fit all. As Keith rightly said, his unit worked harder (hmm) and longer under under the rules. Could quote several other units that suffered too. Wish I could list all the names I was called at the time for being the poor sod trying to implement it!

Theoretically, a good SMS system should allow units to tailor the requirements to better suit their operations. Interesting to see how that works.

Last thought; the regulatory regime these days is based on "hands off regulation", i.e the companies know their business better than the regulator and should be trusted to apply their SMS correctly and safely. Worked well at Boeing!
I obviously know you - but not under your moniker. Anyway, well said, especially the Boeing reference. I just resent being told to do things because they are “absolutely necessary”; & then which suddenly become unnecessary when it suits those, who made the order in the first place , to change their minds. One other thing, you obviously know Jersey well with your “work harder” comment !
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Old 24th Nov 2019, 20:57
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Dunregulatin

Were you my mentor on the 'wings' at LATCC on LIC, DTY and CLN plus FIR in '74. If so, you have so much to answer for!!! If not - beg your pardon! Brian W.

Keith

If I remember rightly GATCO pressed for hours regulation after finding that some poor sods at some airfields, particularly in SW England, were working 70hrs plus a week due to staff shortages. Personally at LL I hated the introduction of Scratcoh - it took away the flexibility to do duty swaps, particularly for long distance commuters like me i.e. I sometimes did an afternoon duty then slept at the tower and did the following morning as it saved travelling up and down the A303/M3.

Ayr TC

I'm always bo**ocking the off-spring and his wife for doing overtime at Swanwick - pays for more holidays they say!

Last edited by Brian 48nav; 25th Nov 2019 at 08:45. Reason: spelling
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Old 24th Nov 2019, 22:04
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Brian48
I'm afraid it was me. I've probably done my penance for that!
Still a few other sins to answer for tho'
G
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Old 25th Nov 2019, 08:50
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dunregulatin

Good to hear from you G - I've thought of another sin to add to your penance collection - you did my one day LCE course at LL! As I recall 4 of the candidates were ex-LATCC C Watch, Ray and Mary ( sadly both no longer with us ) and Brian Jones.

I've never forgotten your stories about the Barnsley QNH factory! Rivetting!

All the best

BW
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Old 25th Nov 2019, 10:48
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Brian, I totally agree with you. There can be no doubt that some units needed (& still do) SRATCOH protection - no argument there. But at others (as in my case), ATCOS ruled the roost & fatigue protection was never anywhere near required. In my case, the unit was staffed for very busy Summer weekends. That left an excess of staff at other times. Basically, we had 9 rostered on Sat/Sun & 7 on weekdays. Only a max of 5 were required during the week, so EGs & duties in name only were plentiful. We worked rostered split morn/eve shifts - but it was very rare to work both; & if you did, you came in late & went home early. My record was 8 & a half hours one 7 day period. The average working week was in the region of 25 hrs. No day duties & we finished a duty period (5 days) on an am duty , having started on a pm every other cycle. There was absolutely no barrier to swaps. No wonder no one wanted SRATCOH - which resulted in lots of day duties, no swaps, no EGs & much longer shifts. In the end, we had to accept it because SRG said that they were no longer prepared to license & regulate the aerodrome unless we did. Now, as a result of an apparent whim, ATC can go back to the old system. Good luck to them.
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Old 25th Nov 2019, 11:22
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Originally Posted by Brian 48nav
If I remember rightly GATCO pressed for hours regulation after finding that some poor sods at some airfields, particularly in SW England, were working 70hrs plus a week due to staff shortages. Personally at LL I hated the introduction of Scratcoh - it took away the flexibility to do duty swaps, particularly for long distance commuters like me i.e. I sometimes did an afternoon duty then slept at the tower and did the following morning as it saved travelling up and down the A303/M3.
I was told years ago theat one particular ANSP always required it's controllers to work more than rostered SRATCOH compliant hours and 'covered' themselves by insisting they fill in a 'modification' form every shift; wonder if SRG ever twigged and took any action.
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Old 25th Nov 2019, 16:23
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Someone correct me if I'm wrong but are unit ORs not determined by the calculation as listed in CAP670? This lists the positions to be manned and the hours etc. In the smaller units management will now be able to say that less staff are needed and therefore the unit OR can be reduced. Voila - current ATCO shortage cured overnight - simples! The larger ANSP in the UK has various agreements with its staff, starting at certain times for morning shifts restricts the number of hours that individual can work for example. If SRATCOH disappears then I'm sure Prospect will be happy to give up the various agreements that were brought in to prevent fatigue and ensure controllers were fresh for duty. This will be a wet dream for management and bean counters!
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Old 29th Nov 2019, 18:43
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Guys, you need to read the organisation requirements in Annex IV 'Part-ATS to Implementing Regulation (EU) No 2017/373. I think that it's the' 300 series' organisation requirements which cover fatigue and rostering.

The EU will require ATC service providers to develop a fatigue risk management policy and associated watch rostering system. The CAA plans to publish a new 'human performance' CAP which will include, amongst other items, most of the content of SRATCOH from CAP 670. The plan (as someone mentioned earlier) is that this will act as guidance material for service providers. If they base their policies on the guidance in the new CAP then it gets the rubber stamp. If they want to develop something new then they can but it will be subject to greater scrutiny.

As mentioned earlier, SRATCOH was designed to deal with the Heathrows of this world, in other places it's too heavy handed. The challenge will be for the inspectors to keep an eye on those who might seek to use this as an opportunity for skullduggery.
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