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FRMS Battlelines

Old 22nd Feb 2016, 00:19
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FRMS Battlelines

I notice that the Regional Airlines Association are already trash talking CAO 48.1 as being too restrictive and going to impose crippling costs on the industry. Reminiscent of the current debate in the US about FDL and hours requirements. The airlines in this country particularly the LCC have been exploiting the CAO48 exemption for too long and view the limits as targets. The only way pilots can start to get a semblance of lifestyle back into the job is through the prescriptive limits imposed by CAO48.1. No more exemptions, no more applying International rules to Domestic operations to circumvent late night ops, no more 11-12 hour duties when signing on before 6:00am, no more 5 days straight of 4 sector days, no more double WLG BOC, no more rostering duties to NZ then straight over to PTH and SIN. The airlines have already had it postponed by 12 months so they can't say it was sprung upon them. If Virgin can sign up to the prescriptive limits then so can the rest of them. Maybe the 30 yo beard wearing hipsters might just have to come up with better ideas to crew their aircraft rather than just flogging the ones they have.
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Old 22nd Feb 2016, 01:49
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Welcome to your GA career!
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Old 22nd Feb 2016, 03:35
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My current airline career is much more fatiguing than my GA career ever was.
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Old 22nd Feb 2016, 03:39
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The whole FRMS/CAO48.1 issue was about to have it's greatest test come April 1st, (yes April 1st!) this year. That was until CASA gave industry another extension. Three now by my counting.

As both CASA and the operators cannot get their collective acts together, I say put everyone on CAO48.1, and then we'll all be in the same boat.

Simple really!
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Old 22nd Feb 2016, 05:42
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There will never be any degree of willingness, on the part of the operators, while CASA keep backing away from the implementation date.
CASA needs to stand its ground and declare "from this date onwards, you will all operate under CAO48.1 with no exemptions or you will not be operating".
Consulting with operators is like consulting with prisoners; they will always suggest you hand them the key and then fvck off.


Spot on Lookleft, I am more rung out and fatigued now than I have ever been in my career to date.
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Old 22nd Feb 2016, 19:52
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You can't have an aviation law without exemptions. How else could CASA respond to political pressure - sorry, I mean produce the best safety outcomes based on its subjective opinions?

The exemptions always put the lie to the safety justification for the rule. Yes, I realise there are always a bunch of conditions and workarounds that purportedly achieve an equivalent level of safety. But if that's true, the exception should be built into the rule in the first place.

The primary aviation law in Australia is, in substance, the exemptions. CASA's primary regulatory activity is, in substance, granting exemptions.

Munted.
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Old 22nd Feb 2016, 21:03
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I suspect the problem is the difference in the original flight and duty time rules.

In Australia CAO48 was reasonably conservative, didn't allow too many extreme duties and generally speaking didn't result in too many people driving aeroplanes totally shagged.

Overseas some of the flight and duty rules were a lot less restrictive and as a result would allow some duties that here in oz we would look at with horrified faces. From memory the FAA and JAA rules allowed some huge days with not a lot of rest between.

Along comes "fatigue science" which is a misnomer given that fatigue is such an individual thing, nevertheless the brains trust decides to try and put some "science" around the very loose rules that some overseas regulators used and bring them closer to what would be considered reasonable. Not a bad idea...

Here in oz, because of our unending inferiority complex and inability to see that sometimes things invented here are actually better than overseas things I.e. Just because America or Europe designed something it isn't automatically better, we decide in our wisdom that we need one of those shiny new FRMS things as well, because if the big overseas regulators are doing it then it MUST be better.

So we end up taking rules that were quite conservative and went the wrong way by introducing FRMS when the overseas jurisdictions reigned in their flight and duty rules by applying FRMS.

Talk about clutching defeat from the jaws of victory!

We can now do some huge days with two crew, admittedly sometimes in a benign weather environment, but sometimes not and the crews end up completely knackered. You have a head cold and you can't take a codral because the damp police might get you, so you either go flying feeling like crap or go sick (and many go flying because they don't feel sick enough to take a sick leave or URTI day), you battle through all the bullshit imposed by security because they want to make everyone feel better with visible shows of ineffective security, you can't go for a leak without having a cabin crew member coming into the flight deck to babysit the remaining pilot..

Yep, we have made things safer.....

Truck Masters? Anyone got the number for truck masters?
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Old 22nd Feb 2016, 23:00
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Snakecharma I agree with you that CAO48 was conservative but you missed the part about the CAO48 exemption which was introduced in the early 90's. Yes that allowed for some big duties like the ML-AD-AS-AYQ-AS-SY sectors we would do on occasions. What has changed is the likes of Jetstar and Virgin have turned that exemption on its head and roster duties of 10-12 hours regularly and view the limits as targets. So instead of 1000 hours in 365 allowing for the occasional surge in flying the LCC keep their establishment levels at a point that all pilots will be rostered to that limit. I can only agree with LBs cynicism about how CASA handle this but from what I can see the "exemption" is how airlines develop their FRMS that has to be approved by CASA. From my understanding Virgin ended up just going with the prescriptive limits and Jetstar have had theirs knocked back twice. I have no idea what Qantas are doing and I imagine that Tiger will just follow Virgin.
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Old 23rd Feb 2016, 00:26
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Look left, I have not operated under the exemption for some 15 years and mainline virgin have never used the exemption.

That all said you are correct, they use the limits as targets but why wouldn't they? It is the same as max takeoff weight, Max landing weight, Max zero fuel weight etc ...if you don't target the limits then you are leaving payload, productivity or whatever you want to look at behind.

Virgin has been using a FRMS quite successfully since 2007 ish and it works as well as can be expected.

We as pilots are still miles in front of junior doctors who works crushing shifts and they too have the power of life over death - doesn't make it right just making the observation
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Old 23rd Feb 2016, 00:39
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That all said you are correct, they use the limits as targets but why wouldn't they? It is the same as max takeoff weight, Max landing weight, Max zero fuel weight etc
People are not machines.

Virgin has been using a FRMS quite successfully since 2007 ish and it works as well as can be expected.
So does Jetstar allegedly. Its based on FAID which was built for the trucking industry and is not scientifically based.

We as pilots are still miles in front of junior doctors who works crushing shifts and they too have the power of life over death - doesn't make it right just making the observation
The medical profession kills way more people than aviation. Medicine is slowly waking up to that fact.
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Old 23rd Feb 2016, 03:52
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I'm so tired of the fatigue issue.

It is a part of law that a pilot will not fly when fatigued, yet we all do it, because our livelihood is threatened by management, we will lose our jobs if we will not comply.

Yet compliance within the law should and must override comp
any compliance. Our responsibilities are to ourselves, primarily; to our fellow crew, secondarily; and lastly to the traveling public. It is a simple fact that no human being can function when they are exhausted. Where is the regulation that allows my employer to fatigue me to dust? What do you do about it? Well, I punch, I kick and I leave, Life is too short for putting up with crap.

The idiot manager who invites you for tea and bikkies might have a second think if he's gonna lose all his teeth. Fight this! Night time is for sleeping = day time is for working.
Skates and CASA need to grow BALLS. Bean-counters have never historically dictated the progress of any industry, until 1984, and it's our bloody hard work that make the KPIs which are being fed to their fat bloated wives.

Pass CAO 48, get rid of exemptions, and get the airlines to Comply!
How can you have 3 simultaneous laws? High court will tell you that you can't.
What the fvck has CASA been doing, and when will we get an inquiry? Who took positions as "Head of Safety" of various airlines just after passing exemptions for those airlines? This is corruption, I am positively sick of an industry which bribes and corrupts its regulator in mafia style to achieve its individual monetary aims.

Industry? Ha! Bunch of crooks in suits.

Ned
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Old 23rd Feb 2016, 09:40
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Don't think it could be summed up any better Ned
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Old 23rd Feb 2016, 10:31
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Ned, you have summed it up wonderfully.

The new CASA CAO 48E is a well constructed and thought out document, which will add to the overall protection against fatigue which is driven by corporate greed. This is quite inconvenient for the managers of these companies, how can they possibly meet their KPIs if they are unable to continually reduce the number of pilots required to man the same number of flight hours. Something has to give sooner or later.

I would like to see CASA stand by their work, if they don't believe in themselves, why should we have any faith.

There are a few faux pas that we perpetuate as pilots that make it easy for the offending organisations :

* Don't call in sick, no matter how sick you are as you "will be letting down your fellow pilots", what a load of BS, this is a lie the company sells you to achieve their goals,
* Don't call in "Fatigue", as you will be letting your fellow pilots down, another load of steaming bovine excrement, if the offending organisation has adequate crewing levels, these genuine fatigue issues will be covered, both by reserve coverage and appropriate / sustainable rostering.
* Don't call in fatigue or you'll be grounded and sent to see a Doctor, and in one organisation, I have heard you will be docked "Sick Leave" for fatigue (All pilots fear loss of their medical certificate, I wonder if that is a management consideration when this occurs, you know, when pilots use the other F word).
* Being "Compliant" is doing everything your line manager tells you, "Compliant" was once ones ability to operate within the legislated frame work, which occasionally involved saying a big fat "NO" to over zealous managers and engineers. You say "NO" now and they will "Get You", sooner or later.


CASA, please show some fortitude, you've done the research, written the policy, now please make it law ASAP.
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Old 23rd Feb 2016, 11:20
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Does anyone seriously believe that they won't still be rostered to the limit just because of the new rules?

Does anyone honestly believe that they won't get fatigued under the new limits?


Honestly I feel better under my FRMS than I did under the old 48 and I reckon I would feel under any of the new Annexes. But not all FRMS are the same and I reckon I've got a good one backed by good management.


I agree that the new rules are very limiting, but when you've got a safe operation currently that has to change because of the new rules, it does create an annoyance. My biggest gripe is that it is very difficult to follow, especially if you need to operate between annexes because you can't lump your entire operation into one (one aspect will suffer as a result).


Very interesting to see support for CASA for once too!
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Old 3rd Mar 2016, 08:21
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We as pilots are still miles in front of junior doctors who works crushing shifts and they too have the power of life over death
Yes, but they only kill one person at a time!
We could potentially take out hundreds in one hit!
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Old 18th Mar 2016, 09:32
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An end to corruption and fatigue

Hi folks!

We are now "celebrating" over 10 years without prescriptive fatigue laws governing Australian pilots. Also, no fatigue laws for flight attendants in Australian airspace. CASA had for years buried its head in a hole.

One cannot complain against one's company for rostering, legally at the time, shifts that were very difficult to comply with. One had to perform and fly. Is it reasonable to require a pilot to fly 43.5 hours of airborne time in 5 days? It is certainly legal, under the "trial" exemption of CAO 48. I did it! and boy was I knackered at the end! The last 9.5 hours was all in darkness.

Prescriptive fatigue laws give protection to the over-worked and under-rested, and they give ammunition to the guns one fires at idiot management. When CASA removes the ammunition, it becomes an instrument of fatigue.

Have you ever suffered from fatigue? I know people whose
cars have left the road on the drive home, I know people who have been burnt out, simply due to fatigue. Would you join in a class action against CASA? 10 years is far too long.

[email protected]

See you there,

Ned
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Old 19th Mar 2016, 07:19
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Folks,
My very first airline representative job was to represent OSB of the AFAP on a study to rewrite CAO 48, 1968 version. I am the only one left alive of that sub-committee.
Many complaints about 20+ years of regulation reform ----- this is now 48 years for CAO 48, and no agreed result (except to change B707 to "turbojet")
Ain't regulatory reform grand!!!???
Tootle pip!!
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Old 19th Mar 2016, 09:41
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I was told the reason CASA changed things to FRMS was so that Pilot's had the responsibility to call fatigued which wasn't an option under the old CAO.
A pilot must not operate an aircraft unless, at the commencement of the duty
period:
(a) the pilot has had the required minimum rest period free of duty; and
(b) the pilot has had the opportunity to take adequate sustenance; and
(c) the pilot is free of any fatigue, illness, injury, medication or drug which
could affect the safe exercise of his or her licence privileges.
2.15 An operator must not require or permit a pilot to operate an aircraft unless, at
the commencement of the duty period:
(a) the pilot has had the required minimum rest period free of duty; and
(b) the pilot has had the opportunity to take adequate sustenance; and
(c) the pilot is free of any fatigue, illness, injury, medication or drug which
could affect the safe exercise of his or her licence privileges.
It has always been pretty clear to me that I have a responsibility to call "fatgue" under CAO 48.

The problem nowadays is the "worlds best practise" "KPI stakeholder" management say "No, you are only tired, not fatigued."

Tell me where the line between the two lies...
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Old 20th Mar 2016, 08:35
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Our responsibilities are to ourselves, primarily; to our fellow crew, secondarily; and lastly to the traveling public.
Not for me. I feel my primary responsibility is to the passengers, secondarily to my wife and children , and lastly to my fellow crew. Not that it matters much as long as we are both able to make tough calls to keep people safe when the pressure comes on.
I am interested to know if we actually do fly worse shift patterns now days compared to say the 60's 70's and 80's.
Does anyone know?
Personally I am flirting with having to make a fatigued call at some stage unless things become more 'gentalmanly '.
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Old 20th Mar 2016, 23:58
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The problem nowadays is the "worlds best practise" "KPI stakeholder" management say "No, you are only tired, not fatigued."
And exactly what qualification does said manager have that allows him/her to better determine your fatigue fitness? Only one person can make a decision on your fitness to fly when fatigue becomes a determinant.
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