The reporters expressed a safety concern relating to the fatigue being experienced by flight crews when operating for [operator 1] flying for [operator 2].
The reporters advised that they are regularly rostered to fly duties, which are known to cause serious fatigue. These duties involves a sign-on time on the first day of 10:55am. The flight crew then operate 5 sectors with no rest or meal breaks, and sign-off at an outport at 8.00pm (provided there are no delays). The crew only receive a maximum of a 10-hour break during which they travel to and from the hotel and eat – so they have minimum rest at the hotel room (generally 5 hours sleep are achieved). They will then sign-on at 6am and fly 5 sectors, finishing at 3pm at their home base. This duty involves 5.5 hours flight time the first day and 5.5 hours flight time the second day. Crew are regularly rostered two or three of these fatiguing duties back-to-back over a five or six day period. Flight crews are regularly rostered to fly over 80 flight hours per roster with up to 12 of these overnight duties per roster. The practice of rostering consecutive overnights away from home base where only five hours rest is attainable is conducive of flight crew becoming chronically fatigue.
Although the rest period provided complies with CAO 48.1, there is a requirement for operators to identify risks and hazards and multiple fatigue reports have been submitted by different flight crews in relation to this rostered duty. Section 14.1 states ‘[...] an AOC holder must not require a [flight crew member] FCM to operate an aircraft if [...] the holder has reason to believe that the FCM [...] is likely to suffer from fatigue which may so impair the FCM’s performance that the safety of the operation may be affected.’
As such, CAO 48.1 requires that the operator should not require a flight crew to operate a roster, which has been identified as being fatiguing, and in this case multiple flight crews have on multiple occasions reported being fatigued to a level which is unsafe. It is reported that no crew have ever received any feedback regarding these reports.
Reporters comment: Flight crews are generally mentally exhausted for the second half of the last day flying and the risk of incidents or accidents is greatly increased. As the ability to respond to normal situations is reduced, the ability to respond to an abnormal situation is a very significant safety threat.
The reporter has suggested that the number of sectors on the second day should be reduced or the minimum rest period between the duties should be increased.
Operator's response (Operator 1)
We take crew fatigue seriously and operate in compliance with the relevant Australian and New Zealand Aviation legislative framework. In addition to this, we also comply with work health and safety legislation. As noted the within the REPCON the indicated roster pattern complies fully with the Australian Civil Aviation Orders section 48.1.
Our governance around fatigue is managed through our safety management system, along with an established fatigue safety committee, which review all cases of reported fatigue by flight crew. Each roster is built and checked around fatigue management principles, including input by an approved fatigue risk model that identifies increased fatigue risk.
Feedback is provided through our electronic reporting system and personally through the crew's line management. Fatigue is also monitored and reported through to the [operator] airline safety committee.
Our confidential reporting system is also available to staff to report any matters involving the safety of our operations.
We acknowledge that the management of fatigue is a joint responsibility between the company and employee. Should an employee feel that they are potentially or are fatigued prior to starting shift and or during their shift the employee has the responsibility to report this matter to their management for immediate attention.
We accept that fatigue can impact a crew member differently based on the employee's unique circumstances outside of work. We encourage employees to approach the company if they believe they have unique circumstances with which their working environment may impact their individual fatigue.
Operator's response (Operator 2)
CASA has reviewed the REPCON and encourages the reporter to utilise the operator’s confidential reporting system referred to in the operator’s response if they encounter fatigue symptoms or concerns. CASA has discussed the matter with the operator who have indicated they may implement changes to reduce the fatigue risk.