Fatigue Regulation and Industrial Agreements covering hours of work
Generic manuals approved by the head office would make a lot of this compliance madness go away and go a long way to standardizing operations.
If they cannot accept CARs, CASRs and CAO which are law, how are they going to accept a generic manual that has only been accepted by higher up in CASA.
How many different interpretations have we had on Aerial Baiting including an "Aviation Rulings".
The problem is that there is no defined avenue to have an interpretation by a particular person reviewed or over-turned.
As for the AAAA OM, the last time I read one, it had a lot of incorrect references. I wonder if it has been updated in the last 4 years.
CASA did try to develop a standard OM. Their idea was to have all the standard text for an OM on a web site so you could develop the OM with reviews from an FOI. It never saw daylight.
Last edited by 601; 16th Jul 2013 at 23:55.
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fatigue is complicated, so is its management
Ned Gerblansky,
CAO 48.1 would not allow such a duty, simply because it limited flight time to 8 hours (para 1.4).
The SIEs attempted to deal with Chimbu's 'type of operation', but were driven by "micro-economic reform" - meaning bowing to commercial interests without constraint. It allowed 12 hours duty and 9.5 hours (perhaps even 10 hours) flight time (paras 2.1.1 and 2.4.1(a) or (b)).
CAO 48.1 Instrument 2013 will not allow such a duty under the prescriptive rules for two very sound reasons - the maximum duty is at that time of the day is 10 hours and the maximum flight time is 8 hours (Table 2.1).
Prescriptively, the Instrument is a scientifically valid improvement for this duty example.
However, CASA advertises FRMS as the mechanism to exceed those prescriptive limits. Unfortunately, there is no transparency about how FRMSs will be approved by CASA - such a duty may be allowed under an FRMS based on "operational experience" if there are no adverse fatigue reports in the operator's system. Given the operator's 'toughen up Princesses" attitude toward fatigue management and the openness of the flight operations management generally to all internally-generated criticism, it seems likely that few complaints exist.
Do not expect CASA to assist pilots getting a proper FRMS or ensuring that it runs as designed - that is far from their traditional orientation. This is one where practical experience is gold, since only the people flying the line can say whether the duty is unreasonably fatiguing or not. You need to ensure that you have a seat at the table for fatigue mitigation/management, not just hazard ID, and you need to formally speak up if the duties are fatiguing.
Your FRMS will be what you let it be...
Stay Alive,
JQ flew (flies?) CNS-PER-CNS back of the clock. 9.4 hours flight time in a 11 hour night. Previous duties and post duties may have been 0500 sign ons. The fact that it's pressurized, flight attendants to bring coffee and inedible in-flight meals does not belie the fact that it is outside of normal human tolerances. Sometimes we'd get whacked with two in a row!
The SIEs attempted to deal with Chimbu's 'type of operation', but were driven by "micro-economic reform" - meaning bowing to commercial interests without constraint. It allowed 12 hours duty and 9.5 hours (perhaps even 10 hours) flight time (paras 2.1.1 and 2.4.1(a) or (b)).
CAO 48.1 Instrument 2013 will not allow such a duty under the prescriptive rules for two very sound reasons - the maximum duty is at that time of the day is 10 hours and the maximum flight time is 8 hours (Table 2.1).
Prescriptively, the Instrument is a scientifically valid improvement for this duty example.
However, CASA advertises FRMS as the mechanism to exceed those prescriptive limits. Unfortunately, there is no transparency about how FRMSs will be approved by CASA - such a duty may be allowed under an FRMS based on "operational experience" if there are no adverse fatigue reports in the operator's system. Given the operator's 'toughen up Princesses" attitude toward fatigue management and the openness of the flight operations management generally to all internally-generated criticism, it seems likely that few complaints exist.
Do not expect CASA to assist pilots getting a proper FRMS or ensuring that it runs as designed - that is far from their traditional orientation. This is one where practical experience is gold, since only the people flying the line can say whether the duty is unreasonably fatiguing or not. You need to ensure that you have a seat at the table for fatigue mitigation/management, not just hazard ID, and you need to formally speak up if the duties are fatiguing.
Your FRMS will be what you let it be...
Stay Alive,
You hit the nail on the head 4dogs.
Probably too late for the good folk (line personal) at JQ, but for those who's employers are talking about going down the FRMS path, I have just one word of warning....
DON'T TRUST THEM!
Have a nice day.
Probably too late for the good folk (line personal) at JQ, but for those who's employers are talking about going down the FRMS path, I have just one word of warning....
DON'T TRUST THEM!
Have a nice day.
....and don't trust CASA to be responsible either. Operators could always apply for an exemption to one part of the original CAO 48, but had to offer something in return: e.g. if a particular trip required the roster to show 9 flight hours and 12.5 duty hours, provided the next 24 hours were free of duty and additional to normal days off, typically an exemption would be issued. Old-school FOIs were generally quite receptive to reasonable cases such as this. Maybe the current crop of FOIs don't have the authority or willingness to get involved with industry at this level, hence......
...... along came the 'Standard Industry Exemption'. What was CASA thinking to allow up to 60 hours of duty in a week? Or 100 in a fortnight? A train driver is not allowed to do that much.
The catch with the SIE, is that there is no mechanism to allow an exemption to something that is already an exemption. So the operators want more, and CASA look like they will be handing over more. Downright dangerous.
...... along came the 'Standard Industry Exemption'. What was CASA thinking to allow up to 60 hours of duty in a week? Or 100 in a fortnight? A train driver is not allowed to do that much.
The catch with the SIE, is that there is no mechanism to allow an exemption to something that is already an exemption. So the operators want more, and CASA look like they will be handing over more. Downright dangerous.
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...And the catch-all at the end is that it is the pilot's responsibility to ensure that he/she is fit for duty. So if someone does something on the ragged edge that can be even 1% attributed to fatigue, guess who's fault it is? Of course management approach, rostering and CASA oversight (you can't sue US anymore - we didn't 'approve' it) will have little to do with that...
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Whilst airlines continue to use FRMS as a productivity rather than fatigue management tool I will continue to support the inclusion of limiting clauses in enforceable awards/contracts.
