Duty and Flight Times
 

CASA is going down the track of removing operators specific dispensations or variations they have to CAO 48 and asking them to develop their own fatigue management system.

The purpose is as stated by a CASA consultant is so CASA no longer has any legal responsibility for your operation in this area. You have an accident related to fatigue it rests and stops with the company itself. It would appear that in the process, CASA due to a lack of other fatigue management system are persuading operators to accept a program called FAID which was developed following research into truck drivers fatigue levels in South Australia.

It is based on the fact that since you are allowed to drive you car at .05 blood alcohol level and be legal then that is the fatigue level that you should be able to extend to. In their defense you don't have to use FAID but from what I understand nothing else exists or is acceptable to the CASA CONSULTANT.

When CAO 48 may limit you to 8-9 hours of flying when you use FAID starting a shift at 0700hrs could see you extend your duty/flying hours for 17-18 hours. For those not interested in CASA's character to "promote safe skies" would welcome this new system and find it very likeable. Think of how many pilots you could get rid off, how many more hours you could fly. For those who can see the bigger picture think of the potential short and long term problems from increase accident rates and potential fatalities. Wonder what the hull insurers will think?

It allows an EMS pilot who works a 4 on 4 off roster to do something like.

day 1 0800 to 1800 (10hours) and fly the whole period.(even fly up to 17-18yrs)
day 2 same again
night 1 1800hrs through to 0800 hrs next day. (14hours) fly the whole period.
night 2 1800hrs of the same day you just finished of that morning and still do another 10-12 hrs flying.

This is something like 200 -300%more than what most dispensations would allow you to do now, and certainly would have been thrown out by CASA if you had even proposed such before But as the CASA CONSULTANT states its better because it will manage your fatigue levels.

Any one out there who thinks they can be safe with this level of flying operations single pilot IFR, night scene primaries and the rest particularly at night??? How many crew will you find who want to fly with you???

If that doesn't spell stupidity in the first order I don't know what does!!!!!!!!!!! Maybe after CASA screw it up they may find out that NASA has already done all the work correctly via their Fatigue Countermeasures Group. No doubt commercial operators will love the concept, no more CAO 48 to worry about, but what will the paying passengers think when they find out their flight crew are aloud to do that level of duty/flying without a rest.

[ 18 December 2001: Message edited by: Nichosh ]

[ 18 December 2001: Message edited by: Nichosh ]

It would seem to benefit operators on the face of it, practically, it would be, based on your example, extremely dangerous.

An interesting example would be to compare the pilots who undertake repetitve lifting week after week, logging for example. When youre' busy and concentrating in cycles as they do, it can be quite manageable. When however, you are in deep REM at 3am, and five minutes later climbing out into the muck to LSALT, well, different situation.

My experience of it is the same as everyone, zzzzzzz, then heart attack when the phone goes, still sleeping as your strapping in so to speak.

As I understand, you have an input in to the proposed rule change, and all the concerns you have may be addressed that way.

With all things in EMS, you have the choice, don't go, if you are physically exhausted, the Captain has that discretion, the operator may not like it, but they will soon find any cut to staffing levels will end up with job knockbacks.

1st year interns experience the same type of extreme fatigue in their rediculous 48 hour shifts, they don't change it because the people who make the rules say "thats what I had to do".

Perhaps the consultant has never flown single pilot IFR, I suspect that may be the case, I also suspect that operators would not like to see their pilots sleeping during daylight hours when they could be working on administrative problems........

Nichosh
Please please please tell me CASA are not so STUPID!!

I have no experience of FAID but I would imagine that as it was based on road vehicle data that there was always the facility to pull over on the roadside and take rest if you felt the urgent need,
If you carry that over to a EMS or Police pilot suddenly deciding that he is to tired to continue, will they be able to land at thier discretion and take a power nap in a field or maybe on the top of a conveinient skyscraper I think not.
Another case of sloping shoulders from what should be a more responsible organization.

Nichosh, what is the point of posting all that, getting responses, then pulling your post. I may as well not put a comment at all, as my comment will make absolutely no sense to any reader.

Nico,
It may be helpful to re-enter your post, as a few of us are currently involved in flight and duty situations similar to yours.

I have received a reply from NASA, I have attached it because it provides an enormous amount of information on the topic via the links provided.

They make an interesting comment that to use any program that has not been validated is questionable. They state they are not aware of any progrmas that have yet be validated.
Maybe CASA are going down the right path but without the correct research and validation, too soon too quick.

Furthermore those that are going down the path feeling they have no option consider;
Many already have crew on base and operate under a stand by agreement with CASA, which when they are not flying and not doing work of the employer they are effectively resting, given that certain facilities are available.

Given those operators that roster their crew for 14 hour night shifts are concerned about losing their dispensation and having to go back to CAO 48 which does not allow, but surely the term "reserve time" in CAO 48 could be applied to those crews who are allowed to sleep etc, CASA are prepared to call it standby both under old dispensations and the new fatigue models and allow them to do 7 days of 24 hour standby. So doing 14 as reserve time which CAO 48 allows a maximum of 16 hours should be a non issue and the matter resolved. With that accepted, CAO 48 would be less restrictive then the dispensations because there is no restrictions on late night operations.

CONFUSED?????????


NASA REPLY
You're wise to
question the use of fatigue management software based on an industry
entirely different from yours. There are several models that are
being developed to address the issues of predicting fatigue in
aviation. The U.S. Army, Air Force, and other organizations are
working on the development of prediction tools. I don't know of any
fatigue management programs that have been validated (which is key
for any fatigue modeling software or management program that's
applied to the real world). Nothing is currently available for
application in an aviation setting.

The AIRLOG that we developed is strictly an electronic survey data
collection device used to help us collect subjective information from
participants in our studies concerning sleep/wake times, sleep
quality, duty segment schedules, etc. It's not what you're looking
for.

This is a very important issue that you bring up. Our group has been
working on scientific countermeasures to assist in alertness
management for many years. Guidelines have been developed to assist
with duty/rest scheduling and are available on our web site at: http://human-factors.arc.nasa.gov/zt.../FCP.pubs.html under the
Policy link. The title of the publication is Principles and
Guidelines for Duty and Rest Scheduling in Commercial Aviation. If
you have any questions about the content, please don't hesitate to
contact me or our principle investigator, Dr. Melissa Mallis.
Although naps on the flight deck are not sanctioned in the U.S., it
may be an option for your organization: http://human-factors.arc.nasa.gov/zt...story-crs.html
...verify with the Australian Aviation Authority about this topic.
Quantas allows for cockpit napping in their SOPs. Activity breaks
may be another option: http://human-factors.arc.nasa.gov/zt...MES1/AMES1.htm

Unfortunately there's no quick answer or solution to your question.
It will take the effort of the operators, management, and unions (if
applicable to your situation) to work out the rules that balance the
economic bottom line and safety of the operators and the general
public. The idea that software can solve the problems or provide the
clear answers should be examined with a careful eye...as you have
already surmised.

Good luck in your efforts to make your environment a safer place,

Have tried posting here but with no success until today jopefully, I think my server actually times out. Have started this thread on the Helicopter Association of Australia site as well, as CASA also need to be reading your thoughts guys otherwise your opinion will not matter.
Here is a copy of my post on the HAA site.

Currently there is a thread on <a href="http://www.pprune.org" target="_blank">http://www.pprune.org</a> about flight and duty times in Australia, worth a look. be nice if some of those comments could come over to here so CASA gets to hear what we are thinking.
For my part here is my reply to the last post on pprune

Interesting thoughts.
Regardless of what your opinion is the fact remains that the current flight and duty regime stipulated by CASA is completly unworkable, unenforceable (spelling is not my strong point) and in my opinion actually adds to the individual pilots stress levels.
The current regime was made for the airline industry and there it should stay.
Each operation has its own merits for more or less time. For example the Ag industry, they may do 600 hours a year but its all in 3 months, or how about fighting fires where you work a 7 hour flying day then Mrs Jones house starts to burn but you have to go home because you are out of hours and if you bust your hours CASA will prosecute, or mustering where you live in your helicopter for 9 months of the year, or.........
In my opinion flight and duty times should exist and be set for charter and RPT operations, for aerial work operations it should merely be a work place health and safety agreement between the operator and his/her employees.
I think CASA may be on the right track here, this allows the industry to be self regulating and keeps them out of our hair.
Bottom line is this - if you are fatiqued you should be able to land and have a zzzzzzz (even if that is after only 30 minutes in the cockpit) conversely if you are having a power day, and can fly 10 hours you should be able to.
I like the way the Americans do their flight and duty times for aerial work ops.
You can fly 8 hours a day as long as you have 14 days off within a 3 month period (per quarter)
Basically you can do 8 hours a day every day with 1 day off a week. No duty time.
OSCAR

As an aside the Helicopter Association of Australasia (www.haa.net.au) is looking for comments and threads like this as CASA actually read the pages and your opinions can then go towards industry consultation. You may actually effect change that you want

After seeing all of the mail generated by this discussion I have been sitting patiently waiting for someone to bring up the obvious. Just because the Government allows a shop to be opened for 24 hours a day doesn't mean that a clerk has to work 24 hours a day. The time allowed by law is just a legal thing,the time that we as pilots work is a contractual thing, so lets get our heads out of our a*** and decide how much work we are willing to do and for how much money.
Many years ago when I flew sightseeing in NYC the "heavy equipment operators union" (guys who drove the cranes and big cats) tried to organize helicopter pilots. They were earning about $100 per hour and I was on $15, but the comment from so many of my workmates was "I'm a pilot not a construction worker" it sounded stupid then and it sounds stupid now. Please guys let's stick together and earn a salary that equates with our responsibility. If you feel fatiqued don't work but if it is just a matter of money let's negotiate.

The biggest problem with 'Flight & Duty' Limitations is that (particularly something like CAO 48)they tend to be considered as the defacto "standard working hours" unlike everybody else in the "real world" who has say a 36 to 40 hour working week and perhaps an RDO (rostered day off)and then "Overtime Payments" for hours worked over those as set down as 'normal' we "Aviators" are taken advantage of by the industry.....and yes I know the industry line of "we couldn't afford it" will probably be mentioned...but in fact if our industry is to survive and continue to attract the type of educated person to it as career aviators it will have to offer working conditions that at least meet ILO or similar standards for normal working conditions .... nobody really wants to slave or be taken advantage of! we wait for future developments ( perhaps for a long time!!!).

I have read the recent replies and the issues that I am making are not financially related, although I identify the helo pilot as a poorly paid individual, given his skills, qualifications, responsibility and experience etc.

The concerns really should be the long term future of the industry and safety. One industry specific group in the USA went through a disastrous accident rate as their industry grew so quickly without appropriate control and legislation.

By making duty times now operator controlled is a huge commercial benefit. However is it in the best interest of the industry which I predict does not have the maturity to manage fatigue over commercial needs. Furthermore the last person to know a pilot is fatigued is the pilot. Sure he identifies he is fatigued when he reaches the extreme levels. But should he be operating at the extreme levels when at any time he is faced with the need to have to make a complex decision or deal with a difficult emergency.

I belive that if the issue of duty times is thrown wide open and you can do what you like and stop when you are tired will result in a substanial increase in the accident rate. Maybe not tommorrow but soon or later it will catch up with us all and is that good for our industry?