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SRATCOH new rules

Old 21st Nov 2019, 15:45
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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, 16:54
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Originally Posted by chaka534 View Post
and what will replace it....if any ?
A sudden increase in fatigue related incidents?
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Old 21st Nov 2019, 18:09
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Originally Posted by chevvron View Post
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, 19:17
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Originally Posted by chaka534
and what will replace it....if any ?
Probably incorporated into safety management systems more generally or, if it is to remain as a separate 'system', it will be a fatigue risk management system. See ATS.OR.315 and ICAO Fatigue Management Guide - Doc 9966 ATS supplement if you can get it.

Please note - I don't necessarily think it's a good move, but this is what will replace it, in law, from 2 January next year.
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Old 21st Nov 2019, 19:44
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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, 06:49
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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, 21:07
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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, 23:18
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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, 09:23
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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, 14:45
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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, 16:11
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Originally Posted by chaka534 View Post
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, 16:14
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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, 17:05
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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
AyrTC
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Old 24th Nov 2019, 17:05
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Originally Posted by Dunregulatin View Post
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, 21:57
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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 09:45. Reason: spelling
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Old 24th Nov 2019, 23:04
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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, 09:50
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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, 11:48
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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, 12:22
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Originally Posted by Brian 48nav View Post
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, 12:38
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As Dunregulatin/G says, SRACOH was a bit of a sledgehammer, a one-size-fits-all solution that needed to work at LATCC and Heathrow, and also at somewhere like Land’s End (no disrespect intended, but they are very different types of operation). As a consequence, it didn’t suit any faculty perfectly, and I think there were plenty of people who complained when it was introduced. And now it’s going people complain - there’s just no pleasing some people, as they say!

in truth, some did not want it because it limited flexibility for controllers, some did not want it because it would increase ATC costs with little benefit. As ever, a good boss would manage controllers’ hours well, and a duff boss would try to cut corners. I suppose the one good thing that it got rid of was morning/night splits, but even that shift system had it’s good points at some units.

Sadly, SRATCOH, never really dealt with fatigue because the causes are far more likely to be related to circumstances away from work. And as G points out, there was (and probably still is) little evidence that fatigue is a significant contributor to many incidents.

The new rules might be seen as a step forward, especially if read along with the AMC and guidance, because it offers flexibility to design a system that fits the local situation.

As is common, the ATC unit will have to justify/argue why what they want to do meets the rules and will ensure that controllers will not work if they are fatigued. And regulators will have to assess these arguments for their compliance and completeness - challenging the proposed arrangements, where necessary (and that means if they do not make sense). Whilst references to Boeing and the FAA may be easy to make, I guess we’ll have to wait and see where the official investigations believe system failed, but the signs currently suggest that the regulator, in this case, did not review and challenge the safety arguments and evidence put forward by Boeing when, it seems, there were questionable decisions (and not just with the benefit of hindsight) taken, or not taken, during the design process.

Back to fatigue, and what is disappointing to me is that in the material currently being used to support the implementation of this new there often is little distinction made between tiredness, which everyone suffers from at times, and fatigue, which I think is rather different. I make this comment based on my personal, limited experience when a doc told me I was starting to show signs of fatigue and stress.
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