Cabin crew fatigue as the result of recently introduced rostered duties

Below is [Operator]'s de-identified response, which we trust will provide sufficient context for the ATSB, regulator and reporter.

Relating to the concerns raised by the reporter, the operator maintains a mature, data driven and scientific backed fatigue risk management system (FRMS) for cabin crew, which runs in parallel to the flight crew FRMS. All cabin crew pairings and rosters are analysed through the operator's bio-mathematical model (BMM) interface, and a series of parameters have been set, in line with industry standard for the assessment of fatigue risk. This is undertaken at several stages, including post pairing and roster creation (ahead of roster publish) and post the roster period, analysing rosters as flown with real duty time information.

The 5-day pairing as referred to by the reporter was analysed through the BMM at all three stages, and despite transcontinental flying, post roster flown analysis did not show a high fatigue risk based upon the BMM. This also takes into account, the impacts of acclimatised time. The BMM is considered only one tool among other complimentary parts of the FRMS used in managing fatigue for both flight and cabin crew. In light, the operator does not agree to reported claim, that there is no consideration of minimum rest or fatigue, as the basis of the FRMS takes this into account. The operator does however acknowledge, that measuring workload through the BMM is not easily achieved for cabin crew, but has considered conducting a workload study, which is in the strategic pipeline.

The operator has reviewed the reported claims in more detail to the level it could, despite not having more information available through the REPCON system. In the operator’s roster period one instance of the 5-day-pairing was found, in which the following comments are made to clarify.

Duties including transcontinental flights should never exceed two sectors.

There are no restrictions contained within the operator’s cabin crew enterprise agreement (EA) or associated FRMS directives within the operator’s cabin crew FRMS manual stating transcontinental flights should be restricted to two sectors. It is important to note that the operators senior cabin crew, rostering, and safety management work with union delegates to mitigate fatigue risk through a comprehensive [committee]. The committee uses a data driven approach, however, also incorporates subjective data, as contained in fatigue reports in the operator’s safety management system interface.

The reporter provided an example of the daily pairings in a recently published cabin crew roster:

In light of having very limited information available through the REPCON system, the operator has clarified the actual duty times in the following pairing.

Day 1 - [Location 1]-[Location 2]-[Location 3] exceeding eight hours.
Actual duty time was [x] hours, [xx] minutes – 4 hours and 10 mins less than maximum duty length.

Day 2 - [Location 3]-[Location 4]-[Location 5] exceeding 10 hours.
Actual duty time was [xx] hours and [x] minutes – 2 hours below maximum duty length.

Day 3 - [Location 5]-[Location 4]-[Location 3] exceeding 10 hours.
Actual duty time was [x] hours and [xx] minutes – 2 hours and 10 minutes less than maximum duty length.

Day 4 - [Location 3]-[Location 1] 5 hours and 35 minutes
Actual duty time was [x] hours and [xx] minutes – 6 hours and 25 minutes less than maximum duty length.

Day 5 - [Location 1]-[Location 3]-[Location 1] 12 hours
Actual duty time was [xx] hours and [xx] minutes – 30 minutes less than maximum duty limit.

The reporter states, all days with the exception of one commenced [early morning] and with no consideration for minimum rest. The reporter further states, any duty exceeding 9 hours should only be for disruptions, not rostered duties.

The comment about the nine hour maximum duty length is considered the reporters opinion. For further clarity, the operator is not aware of any [carrier] that stipulates a maximum daily duty limit of nine hours. The duty hour limits stipulated by the operator are consistent with other [carriers] and cabin crew award limits. Notwithstanding the reporters’ personal views around an appropriate duty limit of nine hours, a review by the operator found 57 per cent of all duties rostered in [roster period] were below 9 hours.

The operator's current cabin crew EA has various restrictions associated with duty limitations, however in this case, when planned upon [x] sectors per duty day, the operator would like to correct this, being that a planned duty period cannot exceed [xx] hours, with a maximum unplanned duty limit of [xx] hours (which takes into account delays).

A BMM assessment of the example trip as flown with the attributes described did not return any notable fatigue risk scores, however rosters with those attributes are continually monitored and reported on by both safety and cabin crew management in the [fatigue forums].

An analysis of rest periods associated with the reported duties found the following:

• Actual rest after Day 1 was [xx] hours and [xx] minutes – 6 hours and 10 minutes above the minimum required rest.
• Actual rest after Day 2 was [xx] hours – this is the minimum rest period required for this duty.
• Actual rest after Day 3 was [xx] hours and [xx] minutes – 4 hours and 10 minutes above the minimum required rest.

It is not possible from the information provided to determine the actual rest achieved between Day 4 and Day 5. However, Days 1-4 formed a 4-day trip away from home base, meaning that Day 5 was a stand-alone day trip. The minimum required rest period at home base (that is the required rest at the end of Day 4) is 15 hours. Based on the sign-off time on Day 4, 15 hours rest would be achieved by [time] on Day 5, meaning that a rest period in excess of the required period, would have been achieved after Day 4.

The reporter is additionally concerned for the safety of cabin crew driving home after completing these newly created pairings when they are experiencing high levels of fatigue. The reporter finally states cabin crew are reluctant to report fatigued especially while on duty for fear of negative repercussions from management. The reporter also advised they have submitted fatigue reports with nil feedback aside from the standard automated reply.

The operator takes a welfare and just culture-based approach to managing fatigue reporting, including providing all cabin crew members with options including transport assistance or hotel accommodation at the end of any duty where fatigue is reported. Crew members can access fatigue provisions via removal from duty on full pay and without having to access personal leave entitlements where fatigue is found stemming from work related factors. Contrary to the reported claim, provision utilisation is closely tracked by the FRMS team and Operations Centre, and the operator considers provisions to be used by a healthy volume of crew (both flight and cabin). The operator has recently communicated through various mediums, reminding crew to avoid driving home if they suspect fatigue, and to make use of the provisions offered. In response to the reporters comment around automated feedback, each report is assessed by the FRMS team, and feedback is provided by the FRMS team, and importantly where feedback has been specifically requested, more detailed responses are provided where necessary.

All reports received through the operators safety management system associated with elevated driving risks are assessed by both the FRMS and cabin crew departments. The operator does not take a punitive approach to the management of individual fatigue usage, however must, albeit infrequently, enter discussions with crew members who fail to meet their fatigue reporting obligations after accessing fatigue relief, or where a pattern of excessive usage (or usage for personal reasons) suggests that there may be an underlying issue. The operator maintains, the objective is to always provide a duty of care and to better understand the factors that contribute to fatigue reporting.

Overall, the operator has carefully considered the reported claims of this REPCON, however remains confident the systems and processes employed to proactively and reactively mitigate cabin crew fatigue exceeds current benchmarks in Australia. Further, the operator is committed to continually strengthening its systems with high-fidelity data inputs and via the existing fatigue committee contributions and will continue to work collaboratively to rectify issues found to negatively impact system integrity.