Fatigue Management Program: Good or Bad?
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I have read all the posts here and chuckle at the “honest” replies. It seems to me that no one here has never exceeded the F & D as set out in CAO 48.0, are we still talking about GA in Australia. 
CAO 48 is as open to abuse as is the FMS now called FRMS (fatigue risk management system).
It is interesting that the FAID score of 80 is still being quoted, as the upper limit on FRMS is now 70. Having said that the “R” in FRMS now means that you must consider the risk assw each operation. Therefore if it is a dark night, low cloud and p*ssing rain, single pilot ops then the risk management may produce an upper score of say 60 and that is the limit to task the pilot.
All systems are open to abuse by operators. If you have kept up to the NPRM’s you will notice that under the new Regs the choice will be FRMS or the new “CAO 48” whatever it will be called with no exemptions.
How many operators have exemptions against CAO 48 so you can “legally” work longer hours. I’m not for or against FRMS, but a balanced view would see that abuse is abuse, MTOW on aircraft but lets keep that for another debate!!!!!!!!!!!!!!
My two cents worth, RANT OFF.
CAO 48 is as open to abuse as is the FMS now called FRMS (fatigue risk management system).
It is interesting that the FAID score of 80 is still being quoted, as the upper limit on FRMS is now 70. Having said that the “R” in FRMS now means that you must consider the risk assw each operation. Therefore if it is a dark night, low cloud and p*ssing rain, single pilot ops then the risk management may produce an upper score of say 60 and that is the limit to task the pilot.
All systems are open to abuse by operators. If you have kept up to the NPRM’s you will notice that under the new Regs the choice will be FRMS or the new “CAO 48” whatever it will be called with no exemptions.
How many operators have exemptions against CAO 48 so you can “legally” work longer hours. I’m not for or against FRMS, but a balanced view would see that abuse is abuse, MTOW on aircraft but lets keep that for another debate!!!!!!!!!!!!!!
My two cents worth, RANT OFF.
Last edited by Nipper; 6th Aug 2004 at 03:47.
I liked compressor stall's call:
'bout sums it up really. Same as CAO 48 and thier various exemptions: no system will stop the 15 to 20% who will abuse ANY system.
But what fascinates me most about the FRMS is it's introduction. Firstly we had the NPRM. I will talk about the helicopter industry response as I am not familiar with the thrust of the fixed wing response. The overwhelming response was to reject the proposal that CASA put forward, which essentially was that they were suggesting that the shortfalls of CAO48 and exemptions should be addressed by "an operator devised" fatigue system that could be put up for approval by CASA.
As absolutely NO guidelines were provided other than that the operator would have to prove it's validity. There was no standard set by CASA, nothing to base your research on, nothing to judge methodology with, just a statement that CASA would decide if your suggestion was valid or not.
Suprise suprise, the helicopter industry suggested an overhaul of CAO48 and exemptions (because they were working) and totally rejected the individual operator designed system suggested. Further, it was stated that CASA, being the overall body responsible for such things as RULES and SAFETY might actually research and design a system for ALL operators so that individuals did not have to finance individual research projects with NO DEFINED SCOPE METHODOLOGY OR OUTCOMES so that CASA could pass subjective judgement.
What came out was dumbfounding. After industry rejected the individual designed system proposed and suggesting an overhaul of CAO48, CASA turned around and said that having fully consulted the industry and examined a large amount of response, the industry had rejected the current CAO48 and was therefore happy with the proposal to introduce an individually designed system. WTF?
They used the request for an overhaul of 48 as grounds to wash their hands of the responsibility of properly funding and researching fatigue issues, and requiring each individual operator to fork out itself. It then made the change over WITHOUT NOTICE effective from the next renewal of the operators AOC. This meant that those whom had just renewed thier AOC had three more years to use their exemptions, whilst if your renewal was the next day, your exemptions were all cancelled immediately regardless of existing contracts. Out on the same fire line it meant that some operators were restricted to CAO48, and others were still operating on the old standard industry exemptions and flying substantially more. What could be fairer than that?
Now we can pay a university mob to give us a truck drivers fatigue system and CASA are happy. I wonder what liability insurance that uni has? Are they fully aware of the ramifications of an aircraft accident as a result of their research into truck drivers?
A good tool in the right hands, a dangerous exploitative one in the wrong hands.
But what fascinates me most about the FRMS is it's introduction. Firstly we had the NPRM. I will talk about the helicopter industry response as I am not familiar with the thrust of the fixed wing response. The overwhelming response was to reject the proposal that CASA put forward, which essentially was that they were suggesting that the shortfalls of CAO48 and exemptions should be addressed by "an operator devised" fatigue system that could be put up for approval by CASA.
As absolutely NO guidelines were provided other than that the operator would have to prove it's validity. There was no standard set by CASA, nothing to base your research on, nothing to judge methodology with, just a statement that CASA would decide if your suggestion was valid or not.
Suprise suprise, the helicopter industry suggested an overhaul of CAO48 and exemptions (because they were working) and totally rejected the individual operator designed system suggested. Further, it was stated that CASA, being the overall body responsible for such things as RULES and SAFETY might actually research and design a system for ALL operators so that individuals did not have to finance individual research projects with NO DEFINED SCOPE METHODOLOGY OR OUTCOMES so that CASA could pass subjective judgement.
What came out was dumbfounding. After industry rejected the individual designed system proposed and suggesting an overhaul of CAO48, CASA turned around and said that having fully consulted the industry and examined a large amount of response, the industry had rejected the current CAO48 and was therefore happy with the proposal to introduce an individually designed system. WTF?
They used the request for an overhaul of 48 as grounds to wash their hands of the responsibility of properly funding and researching fatigue issues, and requiring each individual operator to fork out itself. It then made the change over WITHOUT NOTICE effective from the next renewal of the operators AOC. This meant that those whom had just renewed thier AOC had three more years to use their exemptions, whilst if your renewal was the next day, your exemptions were all cancelled immediately regardless of existing contracts. Out on the same fire line it meant that some operators were restricted to CAO48, and others were still operating on the old standard industry exemptions and flying substantially more. What could be fairer than that?
Now we can pay a university mob to give us a truck drivers fatigue system and CASA are happy. I wonder what liability insurance that uni has? Are they fully aware of the ramifications of an aircraft accident as a result of their research into truck drivers?
Grandpa Aerotart
Yup!!!
So typical of modern 'public servants'...When something is proven to be completely stupid make it mandatory and then spin, spin spin.
CASA = C**TS Against Safe Aviation.
Chuck.
So typical of modern 'public servants'...When something is proven to be completely stupid make it mandatory and then spin, spin spin.
CASA = C**TS Against Safe Aviation.
Chuck.
I have just read the DP on this issue : DP 0404OS-June 2004. It appears to be a cut and paste of the 1999 NPRM on the same subject. It passionately argues for the adoption of operator imagined FRMS, and consistnetly argues against all the other options offered. Perhaps it should be a "Justification Paper" for FRMS rather than a "discussion" paper to explore other options.
One gem in the paper (para 3.1.7) even states how a field study comissioned by CASA supported the viability of FRMS software. The study was carried out by the University of SA at the Centre for Sleep Research. The largest provider of FRMS software comes from the University of SA's Sleep Research Centre. Any suprises there?
or this one (para 3.4.7): "the world appears to be waiting for Australia's next step" Are we having a lend of ourselves here? And this one (para 3.4.8): "The benefits of operator-developed FRMSs include:.....less complex and easier to use than CAO 48"
The DP is a fait acompli, and CASA should correctly name it as a determination rather than as a discussion.
One gem in the paper (para 3.1.7) even states how a field study comissioned by CASA supported the viability of FRMS software. The study was carried out by the University of SA at the Centre for Sleep Research. The largest provider of FRMS software comes from the University of SA's Sleep Research Centre. Any suprises there?
or this one (para 3.4.7): "the world appears to be waiting for Australia's next step" Are we having a lend of ourselves here? And this one (para 3.4.8): "The benefits of operator-developed FRMSs include:.....less complex and easier to use than CAO 48"
The DP is a fait acompli, and CASA should correctly name it as a determination rather than as a discussion.
Liability
Liability was mentioned in one of the posts.
I believe CASA is trying to shift liability away from themselves to operators through FMS (fatigue management system).
This also applies in other areas where responsibility is being passes to operators such as SMS (safety management systems).
It also means less resources are needed by CASA and they can downsize costing the Government less $ in budgets.
I believe CASA is trying to shift liability away from themselves to operators through FMS (fatigue management system).
This also applies in other areas where responsibility is being passes to operators such as SMS (safety management systems).
It also means less resources are needed by CASA and they can downsize costing the Government less $ in budgets.
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Sick joke.
If CAO 48 meant anything at all there would be no requirement for exemptions or FMS.
It is SOP in many operations to work for months without a day off and pull 36 hour shifts. Some do longer. The touchy feely FMS etc angle is all lip service.
And be obliged to sign a flight/duty time roster indicating something quite legal at the end of it.
It is endemic, those that fight it tend to be unemployed.
If CAO 48 meant anything at all there would be no requirement for exemptions or FMS.
It is SOP in many operations to work for months without a day off and pull 36 hour shifts. Some do longer. The touchy feely FMS etc angle is all lip service.
And be obliged to sign a flight/duty time roster indicating something quite legal at the end of it.
It is endemic, those that fight it tend to be unemployed.
as an owner operator, i have a couple of periods per year where i come up against cao48 (with exemption) flight time limits(airwork). i.e 90hours/28days. i reckon an FMS would be heaps better in my situation. i can also see that it is open to abuse when not followed in spirit.
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I have worked with a FMS for a few years now - fantastic.
However, I am lucky enough to be working for a reputable company that has a fantastic safety ethic and FMS is not open to abuse.
While bean counters and CP's continue to undercut, take shortcuts, and/or try to manage undercapitalized GA outfits FMS will not work in GA. For FMS to work the company must embrace it 100%. Unfortunately very few CP's are even half decent managers.
However, I am lucky enough to be working for a reputable company that has a fantastic safety ethic and FMS is not open to abuse.
While bean counters and CP's continue to undercut, take shortcuts, and/or try to manage undercapitalized GA outfits FMS will not work in GA. For FMS to work the company must embrace it 100%. Unfortunately very few CP's are even half decent managers.
