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.:ugh:
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Welcome to your GA career! :uhoh:
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My current airline career is much more fatiguing than my GA career ever was.:ok:
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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! |
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. |
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. |
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 bull**** 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? |
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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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 |
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 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 |
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 company 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 |
Don't think it could be summed up any better Ned :D
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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. |
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! |
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 We could potentially take out hundreds in one hit! |
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 |
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!! |
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. 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... |
Our responsibilities are to ourselves, primarily; to our fellow crew, secondarily; and lastly to the traveling public. 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 '. |
The problem nowadays is the "worlds best practise" "KPI stakeholder" management say "No, you are only tired, not fatigued." |
I often think about fatigue management and what thought process the people responsible go through. They seem to manage fatigue quite well :(
I would like to see the person responsible for oversight of fatigue management join me on a select series of flights, including signing on at the same time, "hanging around" for 4 hours during turnarounds after waking up at 2 ish to start the shift, and then completing the shift only to do it again Followed by some long sectors with late sin offs six days in a row. If that person closed theirs eyes during the duty period, their continued employment should be assed as they have obviously failed in their role. Damp testing on the 4th or 5th day would be prudent to ensure they weren't "popping pills" with the obvious consequences, also they can only eat the food provided to the flight crew. |
In addition, they should sit, buckled in, every second that you are. No wandering back to business for half an hour. And if we really want to make it realistic, have them answering super simple questions on an iPad app non stop while airborne every thirty seconds for the entire journey. Ie 1+1 = ? Then thirty seconds later what is the opposite of up? And if they miss one get them to turn up for tea and bickies to explain themselves. By the end of the second day they will be starting to rethink things I reckon.
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https://www.rt.com/news/336514-flydu...-fatigue-crash
I bet they don't have a fatigue problem there either. |
Lets hope the FRMS legislation has its focus on safe operations and not commercial imperative. Three things we already know about the Fly Dubai accident.
- It was a new aircraft - The crew had significant flying hours - The accident occurred early in the morning local time |
FRMS farce
The reality is that FRMS is just a tick box within a flawed SMS structure that has no resilience beyond the aircrew member. As pilots we have at least a little more clout than the CC who have virtually no respite provisions that do not automatically result in a performance management meeting.
We also need to be very conscious of the backdooring of the regs by pining a flag of convenience to an aircraft and its crew. The in-camera discussions at the Senate Inquiry were unambiguous and clearly identified the need to tie FRMS performance back through post day of ops processes Put simply a front end CAO that seeks to prevent a fatigue being a casual or contributing factor is worth jack if there is no tie back to management remedy and response. Have always said that if FRMS is given more consideration in AOC approval and continuity, then those in management who only ever experience flying in a J or P seat are likely adopt a very different approach. AT :E |
You are dead right that legislation is the only answer to the problem.
It has to be accepted that in today's highly competitive industry with executives that simply don't understand what they are managing ( how can you if you have never done it) the legal maximums are the target. We have to have sensible legal maximums in order to achieve sensible rosters. The efficiency of the systems in place will be quickly honed due to the power of the almighty dollar right up to whatever limit is set. |
As a testament to the single dimensional stupidity of management, I always carry more fuel, flex a little less, go a little slower and generally be a lot less lean when I am fatigued. I hope I am costing someone their bonus.
After all, your safety is our first priority, and if management won't walk the walk, I must :ugh: |
We also need to be very conscious of the backdooring of the regs by pining a flag of convenience to an aircraft and its crew.
Never a truer word spoken. Unless the rules are applied equally to all operators, irrespective of the state of registry, we will simply see more local companies using "our Asian division" to operate arduous duties to and from Australian ports. Lest you think that this then becomes someone else's problem, consider that the aircraft trying to intercept the PRM ILS alongside you is flown by a very tired crew, who may be more prone to mis-programming the AFS, or slow to react to a TCAS RA. There is no point having a mandatory FRMS system unless it applies equally to all users of airspace. |
There is no point having a mandatory FRMS system unless it applies equally to all users of airspac Interestingly there is comment on the FZ981 crash thread in regard to the GCAA putting pressure on the Australian authorities to remove any reference to fatigue in the EK MEL incident. Yet if that was a VH registered airline the flight would have been illegal. |
The FRMS battlelines are really firing up (pun intended)! Easyjet pilots have had enough and are voting on strike action over the issue of fatigue
Easyjet pilots consider half-term strike action - BBC News and the head of the RAAA is still stating that there is nothing wrong with the current rules. There might be nothing wrong for seat warmers and pen pushers but the exemption is being used in ways that the original rules were never intended for. Of course the latest attempt at getting the rules deferred probably have nothing to do with the looming deadline to have an FRMS in place. The airlines and operators have had more than enough time to get their house in order. The rumour mill has it that Jetstar has had their FRMS knocked back 3 times because it doesn't meet the new rules. They have had a good run in maximising the productivity of the pilots, now its time to make the rostering legally sustainable. Lets hope the EasyJet pilots are successful. |
Problem is though that Virgin, which has had a successful FRMS since 2007 needs to make changes to meet the legislation (as best I can tell) and stuff that is ok now won't be and stuff that isn't ok now will be.
Why casa can't just leave them alone and let them get in with what they have been doing since 2007 is beyond me. |
Thats because SC it is an FRMS in name only and probably based on the CAO48 or its exemption. Jetstar also claims to have an FRMS currently but it is all smoke and mirrors as it uses FAID as its basis which is not a scientifically based program. Supposedly the person doing Jetstars FRMS was the same one that was trying to get Virgin's program up and running but it also got knocked back.
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If FAID is not "scientifically based", what is? Genuinely interested...
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Lookleft it is based on the British CAAP and works well. It is, and has been, the only airline FRMS operating in Australia for some time (since 2007) and bears no relationship to cao48 or the standard industry exemption.
The person running jetstar's FRMS who came from Virgin is excellent and very knowledgable but can only do so much. Being knocked back by casa isn't an indication of the efficacy of a FRMS, merely an indication that casa don't know what they want. Faid was the only tool available for some time. They are transitioning to FAST as we speak |
First FAID now FAST, will the next one be ASLEEP? :E
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If FAID is not "scientifically based", what is? Lookleft it is based on the British CAAP and works well. Being knocked back by casa isn't an indication of the efficacy of a FRMS, merely an indication that casa don't know what they want. |
Lookleft, can't speak for the Jetstar FRMS but the Virgin FRMS bears no relationship to the Cao 48 exemption and if you worked there you would know that.
No FRMS is perfect, and a FRMS is more than just the work rules, it is how you manage individual fatigue, how the business treats staff that go fatigued, how the business is proactive about ensuring pairings are not fatiguing and how the troops feel about reporting fatigue, even if they have not removed themselves from duty for fatigue reasons. None of those things are in the CAO 48 exemption and individuals react to different stressors in relation to fatigue differently, so what is fatiguing for me may not be for you. |
Read the RAAA article and did some research. In spite of the illusion, the RAAA does not represent QF or VA or any other big players. They only represent the smaller feeder airlines. Their argument seems more about the need for change, rather than the new 48.1?
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Aviation section in The Australian, states the RFDS WA Section will require an additional 17 pilots with the proposed changes to CAO 48.
Lots of experts on fatigue these days in our industry, but most of these people never seem to work past about 1630 in the afternoon, and 1530 on a Friday. But then again those three day weekends can be very fatiguing! |
Word on the street indicates JQ's FRMS application has been knocked back 3 times now and that a senior manager has been unfairly made to take the fall. The deadline for approval is nominally the end of next month for a 1 May 2017 implementation date.
I hear one of the reasons they are scrambling to recruit now is that many of the current crewing practices will not be permitted under the approved FRMS. There will likely be a need for significant numbers of extra pilots to crew A320 back of the clock flights as well as a third pilot on some more of the B787 sectors. Apparently the crew rest setup on the 787 (just a pax seat in cabin) has not met CASA requirements either. Rumours that options being looked at (cheapest cost) include fitting some kind of pre-fabricated box with a lie-flat seat in the forward economy cabin as the re-fitting of the manufacturer-designed pilot crew rest above the forward galley is very costly. I was told it could possibly be fitted as needed and then replaced with revenue seats on flights where it was not required. I can see the engineers really loving that on a 2 hour turnaround! With the FRMS application deadline looming, will CASA back down and gift them a further time extension to get their house in order? Or will JQ pilots finally get some safe and sensible limits imposed on their often dreadful, fatiguing rosters? PG |
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