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Mode Aviation
Reference No. AR201400088
Date reported 16 October 2014
Concern title Changes to the rosters which are likely to increase fatigue levels within the flying group
Concern summary

The concern relates to the changes which are being made to the flying roster and the possibility of increased fatigue due to these changes.

Industry / Operation affected Aviation: General aviation
Concern subject type Aviation: Flight crew

Reporter's concern

The reporter expressed a safety concern regarding the manner in which the aeromedical operator is approaching a change in rosters.

The reporter advised that after initial basic consultation with flight crews, management have failed to respond to ongoing concerns with likely increases in levels of fatigue.

The reporter also advised that the operator has never completed fatigue level benchmarking which is required in Part 3 (Fatigue Management) of the current operations manual. This section requires that flight crews are provided with questionnaires about fatigue levels and this data is then analysed by an external body to build a rostering tool to predict levels of fatigue and establish a fatigue benchmark.

Operator's response (Operator 1)

The reporter expressed a safety concern regarding the manner in which we are approaching change in rosters.

The reporter advised that after initial basic consultation with flight crews, management have failed to respond to ongoing concerns with likely increases in levels of fatigue.

The reporter also advised that the we have never completed fatigue level bench marking which is required in Part 3 (Fatigue Management) of the current operations manual. This section requires that flight crews are provided with questionnaires about fatigue levels and this data is then analysed by an external body to build a rostering tool to predict levels of fatigue and establish a fatigue bench mark.

The reported safety issue is ‘regarding the manner in which ...’

  • The reporter has not alleged that the operator’s rostering practices (before or after changes) create any safety or fatigue issue. Likewise, the company does not believe that the rostering practices (before or after changes) creates any safety or fatigue concerns.
  • The company has a strong policy regarding fatigue and requires pilots to complete a risk matrix prior to each flight, the first item of which is ‘pilot fatigue’. Any pilot who perceives that they are fatigued or tired immediately triggers a requirement to talk the issue through with the Operational Supervisory Pilot/Chief Pilot. The pilot is immediately stood down from duty if he/she indicates that they are tired or fatigued.

When pilots have called fatigue, it has never been due to our rostering practices. The following reasons are the most common, lack of sleep due to family issues either due to a sick partner or sick children, or lack of sleep due to external noises.

  • The Company is building a strong reporting culture. In the last two and a half years only five hazard/incident reports have been submitted (out of 500+ reports) that have ‘fatigue’ comments. None of these relate to rostering practices.
  • The ‘manner’ in which the organisation approaches changes to the roster is an industrial issue (mainly) and not a safety issue, this is a management communication issue. However, it is noted that industrial issues can create morale issues which can become safety issues if crew become ‘disgruntled’.

The two specific issues raised by the report were:

  1. The operator failed to respond to ongoing concerns.
  2. The operator never completed (required) fatigue level benchmarking and have this data analysed by an external body.

With regards to item 1, the company would respectfully disagree. The company has:

  • Sent out an email to the pilot body advising the need to change the roster to meet the ever increasing demand placed on the service and to ensure that rostered shifts were covered in the advent of unplanned leave.
  • Issued an invitation to the pilot body to attend a video conference for the regional based pilots and a face to face with the [location] based pilots to discuss the email sent out by the General Manager of Operations.
  • One of the [location] based line pilots spent considerable time and energy devising new rosters. This was presented to the pilot body to look at and make comment about the pros/cons of that particular set of rosters.
  • There was a timeline of 6 weeks given to the pilot body to come back to the company regarding the rosters. A number of pilots were not happy that they were going to lose a number of days off in the reorganisation of the roster. The number of days off never contravenes the current CAO 48 exemption that the service complies with or the additional days off given to the pilots by the service. The current roster has the pilots working 42 days in a 12 week period, the new roster would have the pilots working 45 days in that period, hardly adding to their fatigue levels as the shifts were reserve time at home. In the case of the present rostered reserve shifts as agreed by the pilots, these have only been utilised on average of two shifts in every two weeks. The pilot body is also encouraged to use these rostered reserve shifts to take accrued time off.
  • It is interesting to note that when the roster was changed in 2012, which favoured the pilots (work 42 days in 12 weeks) the respondent did not call for any fatigue benchmarking or for the roster to be audited by an independent outside body.

With regards to item 2, the company would agree with the statement that (the operator) ‘never completed (required) fatigue level benchmarking and had this data analysed by an external body’.  For a variety of reasons the survey and benchmarking has not been implemented:

  • As the pilots have not provided any fatigue reporting documents due to rostering practices the company has not proceeded with a survey of pilots.
  • The company commissioned a completely new operations manual suite which was nearing implementation at the time of these roster changes (the new manuals came into effect on 19th November 2014). The new manual did not utilise this notion of ‘fatigue questionnaire’ and thus the company did not choose to use that tool as part of the process of considering these changes to the rosters.
  • Neither the company, nor the reporter, considered the roster changes would have a detrimental effect on fatigue. The changes were targeted at moving resources to cover particular operational requirements.

Regulator's response (Regulator 1)

CASA has reviewed the REPCON and advises that during recent surveillance of the operator no indication of a breach of the conditions of CAO 48 was found. CASA is satisfied with the operator's response.

 
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Last update 15 May 2015