The reporter expressed a safety concern related to the management of fatigue risk at Airservices Australia.
Where a controller is assessed as requiring a stage 2 fatigue assessment then management at Airservices should be ensuring that the appropriate risk mitigation has been selected and applied. The fatigue assessment control tool (FACT) will allow the assessment to be approved without appropriate risk controls being selected in the system. This allows supervisors to skip this section without giving the controls to be implemented any real consideration.
There is also no way of ensuring that the controls, if selected, were actually applied.
Reporter’s comment: An audit of all FRMS FACTS should occur to establish the extent of the problem and whether further education is required and/or software changes to enhance the risk control processes and monitoring of the risk.
Named party response:
Airservices Australia (Airservices) appreciates the opportunity to respond to the reported safety concern related to the management of fatigue risk at Airservices Australia.
The REPCON advises that its possible for a supervisor to undertake a risk assessment without risk controls being applied. Airservices clarifies that the risk assessment process is enacted via a workflow in Airservices ATC rostering system. The system is set up so that all stages of the risk assessment process are visible to the supervisor completing the assessment. As such, a supervisor cannot "skip a section" as stated in the REPCON.
Notwithstanding, Airservices acknowledges that on occasion, a supervisor may not be able to identify any suitable controls which can have a material impact on an individual's fatigue level. In such cases, a risk assessment would be approved without controls being applied but critically the initial and the residual fatigue level would not have been changed. Elevated level of fatigue assessed must be endorsed by an appropriate level of management. Any risk controls to be applied are printed on the 'day shift' which is available to those supervising ATC units. Additionally, there is a dual responsibility between the ATC and the supervisor to ensure that they are enacted.
Airservices and Civil Air are currently undertaking a review of the approach to fatigue risk management. The Terms of Reference require the team to address the operational implementation of the system. While the review outcomes are not yet published, it has been recognised that Airservices training approach needs to be tailored to the roles which staff undertake in supporting our FRMS. Additionally, the review found that ATCs should take a more active role in the tactical risk assessment process and the selection of controls.
Finally, Airservices confirms that fatigue related aspects are reviewed as part of internal Part 172 A TS audits.
Regulator's response (Regulator 1)
CASA regulates Air Traffic Control under CASR Part 172 which requires Airservices to have sufficiently trained personnel at all times to provide air traffic services in accordance with the regulations and Annex 11. Part 172 and its subordinate manual of standards do not require Airservices to have a fatigue risk management system (FRMS). Airservices has a safety management system (SMS) in place which includes procedures to manage fatigue risk- however this is voluntary and the procedures are not regulated.
The REPCON lacks sufficient detail for CASA to be able to investigate the report.
The ATSB received comment from the reporter to these responses and a further question was sent to Airservices.
The reporter thanks Air Services for their response and looks forward to viewing the Terms of Reference of the operational implementation of the system. The reporter welcomes that the review found that ATC’s should take a more active role in the tactical risk assessment process and selection of controls and has asked if consideration has been given to include individual ATC’s signing off on the controls and also signing off that the controls have been applied?
Airservices clarifies that controllers will not be signing off controls. Airservices will however be driving a more consultative and inclusive approach to the identification of controls. This is one of the recommendations which will flow from the FRMS Review which is being finalised with Civil Air and ANS management.