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Fatigue Rules Finally here?

Old 23rd Mar 2018, 13:45
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Fatigue Rules Finally here?

On the 20th of March 2018 CASA finally released the much anticipated review in to the new CAO 48.1 FRMS legislation.

https://www.casa.gov.au/standard-pag...ors-and-pilots

Will we finally see a regulator willing to regulate the interests of safety? Discuss.
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Old 23rd Mar 2018, 14:22
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Unlikely!!
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Old 23rd Mar 2018, 22:49
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Key Recommendations From the Final Report

Introducing a standardised approval process (other than an FRMS) to offer limited flexibility for operators to operate beyond the prescriptive limits with specific fatigue risk mitigation measures in place.
.................

Nothing will change. That (above quote) is THE get out of jail free card for the majors. The smaller operators will probably get screwed over though.
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Old 23rd Mar 2018, 23:01
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If it’s anything like my companies FRM system the onus will be on the pilot to cram in a fatigue assessment using the program to find a point along your scheduled duty where you exceed the threshold. Naturally it isn’t accurate unless you’ve accurately entered your sleep pattern for the previous few days. The program is glitchy and bogs down and you are still required to arrive, assess weather and notams for the flight, check loading and order fuel within your standard 90 minute callout. It’s hopeless..just thinking about it fatigues me
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Old 24th Mar 2018, 02:09
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One pilot with commercial experience and seven boffins, what can go wrong

All the onus and pressure back on the pilot with very little protections. Major operators will continue to try exploit loop holes and push their resources to the limits. It’s all about the $$$
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Old 24th Mar 2018, 02:37
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The fatigue rules have been under “review” for decades, and will continue to be so for decades.

It’s like classification of operations.

The required decisions are political, not technical.
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Old 24th Mar 2018, 03:01
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Report recommendation number 1: develop a “fatigue-related safety occurrence” definition with th ATSB to ensure more definitive data is published on fatigue related safety events in future....

This report seems to be copying less restrictive FDP measures from competing global authorities simply because that’s the way it’s being done now. The report seems more commercially driven than safety-focused and even admits that it is difficult to create a new CAO due to the complex nature of fatigue. Therefore, how can it recommend ‘less restictive’ FDP measures.

Perhaps some of the specialists involved should undertake some real-world fatigue performance analysis onboard some aircraft? Might I suggest they themselves subject each other to the testing? A long term test, say 12 months should provide some accurate data...
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Old 24th Mar 2018, 06:50
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The fatigue rules have been under “review” for decades, and will continue to be so for decades.

It’s like classification of operations.

The required decisions are political, not technical.



As Sir Humphrey so eloquently stated when discussing the role of government and the bureaucracy:

"Two basic rules of government. One, never look into anything you don't have to. Two, never set up an enquiry unless you know in advance what its findings will be"

A bit of digging into the little consultancy involved is an interesting insight into motivation..

Last edited by Rated De; 26th Mar 2018 at 00:42.
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Old 24th Mar 2018, 11:34
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Sir Humphrey did indeed say:

Two basic rules of government. One, never look into anything you don't have to. Two, never set up an enquiry unless you know in advance what its findings will be
I’m not quite so cynical as Sir Humphrey. It does seem however that despite what appears to be an apparent gutlessness to in fact act in the interests of safety, CASA does seem to be attempting to walk the fine line between that and the commercial imperative.

It’s a little bit concerning that the process of consulting is to begin now when surely the specific concerns of the industry, legitimate or otherwise, have been sitting on the desk for some time now.

As flight crew we’re always encouraged and in many cases required by the act to choose the most conservative course of action when there is some doubt as to the safest choice in the decisions we make. The term double standard comes to mind. The review appears indeed to indicate some genuine concerns regarding safety in respect of the status quo and yet all I see at this point is the can being yet again, kicked down the road albeit now CASA have at least acknowledged empirically a problem exists that needs to be addressed. It’s not yet a solution, perhaps it’s a start.
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Old 24th Mar 2018, 14:04
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I’m not quite so cynical as Sir Humphrey.
Willie,
You should be.
The first meeting I attended re. amending (then) ANO 48, based on "scientific principles and research", was around late 1967 or early 1968.
Nothing of substance has been achieved since, despite the expenditure of mucho time and resources.
Tootle pip!!
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Old 24th Mar 2018, 18:41
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It’s a disgrace really. The whole rule set is a disgrace. Lord knows what people from overseas think when they loook at our regs.
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Old 24th Mar 2018, 22:53
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You don’t need to appeal to any deity. Everybody knows that Australia is the only third world aviation nation in which you can drink the tap water.
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Old 25th Mar 2018, 01:00
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CASA know which side their bread is buttered on. Any time fatigue is brought up, the airlines immediately bleat about it making them uncompetitive, or making their business unviable. Of course the airlines will want to maintain the illusion of being safety first though. Hope CASA like their toast extra crispy, it's coming!!
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Old 25th Mar 2018, 02:36
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Fatalities required for traffic light installation

Originally Posted by framer View Post
It’s a disgrace really.
Indeed it is. No one believes we'll see any substantive change to the current CASA flight and duty limits (i.e. management targets) unless there are a couple (perhaps several) fatal accidents where the primary causal factor was crew tiredness or fatigue.

Be thankful if you happen to work for a company (e.g. QF) where your contractural limits are well short of the CASA mandated limits (e.g. JQ).

I really wish I was wrong, but like the previous posters, I don't see any change to the current situation any time soon. The airline business lobbying of our politicians and regulator is highly effective and the union counter-punch completely overwhelmed and inadequate.

So, failing terrible, fatigue-related crashes, crew members will continue to fight back with the only effective weapon they have; calling in sick or fatigued.

PG
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Old 25th Mar 2018, 03:00
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Will the ATSB ever be allowed to allocate fatigue as a PRIMARY causal factor? If fatigue is ever involved, the ATSB will find that the crew had an option to refuse the duty, but didn’t. They will then assert that the pilots abandoned their responsibility to maintain a safety first approach. The CEO of the “victim” airline will then appear on TV in a tear jerking, lament laden press conference and rhetorically question how this could ever happen. Naaaaaa, there could be a dozen hull losses with thousands of lives lost, but while CASA is so “accessible” to the airlines, nothing will change. There is big money involved and a willing scapegoat, the future of fatigue management is very safe......and in the airlines favor.
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Old 25th Mar 2018, 05:23
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The work is already done!

Australia already has at least three well prepared and suggested templates. The first is SafeWork Australia with every State and Territory on board, so it is effectively the Australia wide accepted policy. For the vast majority of Operators in Australia it would be Simple, Accountable and Effective. It would save hundreds of thousands of dollars, and let us get on with Business. A ready made solution.

https://www.safeworkaustralia.gov.au...-workers-guide

The Rail Authority and Heavy Trucking Industry also have one. Look at how simply the trucking industry tackled it

https://www.nhvr.gov.au/safety-accre.../basic-fatigue

I appreciate that there is a lot of self interest pulling in a lot of different directions, but Really?
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Old 26th Mar 2018, 00:42
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The CEO of the “victim” airline will then appear on TV in a tear jerking, lament laden press conference and rhetorically question how this could ever happen. Naaaaaa, there could be a dozen hull losses with thousands of lives lost, but while CASA is so “accessible” to the airlines, nothing will change. There is big money involved and a willing scapegoat, the future of fatigue management is very safe......and in the airlines favor.
That is the most erudite comment I have ever read.

It is exactly how the system is set up to preserve the status quo.

Until pilots realise that the onus is all theirs and the strict liability is theirs too nothing will change.

To airline managers regulation limits are targets. They will push pilots knowing smugly that the pilot bears all the risk
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Old 26th Mar 2018, 01:34
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To airline managers regulation limits are targets. They will push pilots knowing smugly that the pilot bears all the risk
And while this dichotomy exists there can be no real progress in the area of safety with regards to fatigue management. As I have stated elsewhere, it really should be a joint responsibility but in reality it isn't. There is something about this that is ethically and morally wrong and yet entirely 'acceptable.'

Aviation managers can tell pilots 'don't fly fatigued' until they are blue in the face and yet at the same time they spend their efforts lobbying for regulation framework and structures that endeavour to extract 'maximum efficiency' (one could also read that as 'burn them out'). For all this effort, when something goes wrong, essentially they get to wash their hands of innocent blood (like Pilate of old) and walk away...
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Old 26th Mar 2018, 01:39
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Not in my 'neck of the woods' Mate!
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Old 26th Mar 2018, 02:01
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Aviation managers can tell pilots 'don't fly fatigued' until they are blue in the face and yet at the same time they spend their efforts lobbying for regulation framework and structures that endeavour to extract 'maximum efficiency' (one could also read that as 'burn them out'). For all this effort, when something goes wrong, essentially they get to wash their hands of innocent blood (like Pilate of old) and walk away...
Yes and I would argue this is by design.

Pilots play their role in this as enablers. They do not understand strict liability and I can recall numerous excuses from loss of income, it will encroach on a day off to impact on sick leave to continue. They refuse to acknowledge, or simply are not aware that in keeping the show on the road, they bear the risk. This is precisely why the statute stipulates strict liability.

As Ryan air executives stated " The idea was to recruit a vibrant start-up team, burn them out, then get rid of them and put in a fresh team"

Mr Joyce said largely the same thing to an audience in the Stamford hotel circa 2004, when queried about staffing including pilots when appointed to JQ management by Geoff Dixon.

Where 'efficiency is maximised' destroying and burning out human capital, then clearly the Regulator must regulate. In Australia this will not occur until such time as the trail of bodies necessitates more action than talk.
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