Multiple reporters have approached the ATSB to raise safety concerns in relation to inadequate cabin crew rest facilities onboard [Operator] [type 1] aircraft.
The reporters collectively state cabin crew are becoming fatigued with the lack of adequate rest facilities impairing their ability to safely perform standard operating procedures throughout the flight.
One reporter states that they are especially concerned when operating overnight sectors, of their impaired ability to 'act accordingly' during safety critical phases of flight. The reporter further states, 'Many sectors operated by the [type 1] aircraft include duties up to 14 hours which is the maximum duty allowed with 'upright' cabin crew rest facilities. Cabin crew with duties in excess of 14 hours are to be provided with horizontal rest facilities which are only available on [type 2] and [type 3] aircraft'.
The reporter has identified the following challenges with the cabin crew rest facilities onboard the [Operator] [type 1] aircraft:
- curtains that do not close and allow for noise and light to enter the rest area (photo supplied to the ATSB and CASA)
- uncomfortable and restrictive economy-class seating
- noisy and disruptive cabin environments (even with earplugs in) and insufficient recovery during scheduled in-flight rest periods
- inability to raise legs or recline very far (when the seats work properly) therefore not achieving any kind of sleep when sitting upright
- very close seating beside other staff therefore also restricting rest abilities with limited personal space
- being bumped by passengers when seated beside the aisle disrupting rest
- noisy environment (with rest area located in front of three toilets) including disruptions such as banging of toilet doors and flushing of toilets.
The reporter also states that there is a desperate need for lay flat rest areas with sufficient hard closed doors / barriers in order to achieve adequate rest.
Another reporter states, 'The absence of designated crew rest facilities poses a significant risk to safety. Fatigue impairs decision-making, situational awareness, and reaction times – all critical during flight operations. Without proper rest, I risk experiencing fatigue mid-flight, which compromises passenger safety'.
The reporters collectively state multiple safety reports have been submitted internally highlighting the broader safety implications of inadequate rest conditions onboard [type 1] aircraft for long-haul cabin crew.
[Operator] has considered the concerns raised in the REPCON and would like to thank the reporters for raising these concerns.
At [Operator], we have a strong culture of safety that has been built over decades. As a business, [Operator] is conservative and prioritises the safety of our aircraft, crew, customers and freight over commercial and other external pressures. Aviation is a complex industry and [Operator], like other international airlines, is a high reliability organisation that uses a comprehensive Safety Management System to manage hazards and risks. Fatigue is one of the many hazards present in aviation.
Risks are managed by identifying, analysing and introducing controls to mitigate the risk to as low as reasonably practicable. Given the highly regulated nature of the industry, many risks and hazards are addressed by legislation and guidance material produced by the Civil Aviation Safety Authority. Fatigue is one of the few areas where there is no prescriptive legislation that deals with the fatigue hazard for cabin crew. Despite this, [Operator] has invested in and is developing a robust Fatigue Risk Management Program for cabin crew which uses predictive, proactive and reactive risk identification.
Existing controls for fatigue management
In the cabin crew context, [Operator] utilises a range of fatigue risk controls to reduce the incidence of fatigue, including pattern planning, duty limitations, rostering rules, bio-mathematical fatigue modelling, fatigue education, pattern rest guides, provision of inflight rest, and use of suitable hotels whilst on duty. In lieu of a prescriptive ruleset, [Operator] uses data and experience for predictive fatigue modelling, a program called [Program name], that factors in duration of wakefulness, window of circadian low (adjusted for time zone shift), rest periods and workload to understand potential levels of fatigue in crew. This is completed when building rosters and pairings as well as once the roster has been completed.
For cabin crew the risk outcomes fatigue presents are predominantly health and safety risks. To ensure the safety and wellbeing of our crew and passengers we have implemented a range of initiatives to prevent adverse safety outcomes. Prior to duty, crew have the ability to swap duties, or report fatigued prior to commencement of duty. Once duty has commenced, crew are able to work with their onboard manager to review role allocation, plan onboard breaks, request additional onboard rest, as well as the ability to remove themselves from safety critical tasks. At the completion of duty, cabin crew who report being impacted by fatigue are able to access home transportation (additional to what is already included based on the enterprise agreement, or fatigue planning) or access hotel rest on arrival (in home port if the crew believe that their fatigue levels may affect their ability to drive or travel home following duty).
Cabin crew operate duties of various lengths, including up to 19 hours on long-haul services such as [Location 1]-[Location 2]. As mentioned above, the provision of in-flight rest is a mitigator against fatigue, particularly on longer duties. In-flight rest facilities vary and include reserved cabin seating, reserved cabin seating with privacy curtain and dedicated lay-flat rest in private crew rest areas. The [type 1] aircraft outlined in the reporter’s submission contains reserved cabin seating with privacy curtain. As a result, this aircraft type is limited to a maximum planned duty time of 14 hours, with the majority of its long-haul operation being between Australia and [Continent] on sectors of 8-11 hours. For any duty planned to exceed 14 hours, an aircraft type with dedicated lay-flat rest in a private crew rest area is used.
The provision of cabin seating with privacy curtain is in alignment with the enterprise agreement and is incorporated into the predictive fatigue modelling used. In the modelling of fatigue for patterns on the [type 1] the model does not assume any sleep is achieved in this upright rest. The rest periods on such sectors provides an opportunity for the crew to get a break from cabin crew duties. Any meaningful rest achieved in this upright seating is additional to what is assumed in the planning or modelling of fatigue.
Additional steps have been undertaken to reduce disruptions to the crew whilst on their break, including separation between planned infant seating and the crew rest seats.
Fatigue Reporting
Where staff have concerns about fatigue, or the effectiveness or adequacy of the controls, [Operator] encourages crew to report the effects of fatigue via the [fatigue reporting platform]. These reports are reviewed by the [Fatigue team] and collated to identify emerging trends and opportunities for safety improvement.
[Fatigue panel]
As part of the [Operator] Safety Management System, a functional committee exists, that identifies, assesses and advises on the management of fatigue risks in a collaborative manner. The committee is made up of cabin crew management, cabin crew representatives, subject matter experts, human factors experts, operations and workforce planning representatives. The [Fatigue panel] feeds into the formal [safety committees] and is responsible for hazard identification, risk management, and developing strategies to manage fatigue for cabin crew. A summary of [Fatigue panel] data, actions, and meeting minutes is reported to the [Safety sub-committee].
[Fatigue panel] meetings occur on a bi-monthly basis. A data pack is generated monthly which encompasses all reports submitted by cabin crew operating on [Operator] registered aircraft.
Fatigue training
All [Operator] cabin crew are provided with fatigue training during their initial training. Additionally, fatigue management training refreshers are provided during annual Emergency Procedures training. The following topics are covered during these training sessions:
Cabin crew human factors (HF) initial – fatigue module
- define fatigue and explain why it is important to manage the risk of fatigue in aviation
- describe the causes, symptoms and effects of fatigue
- describe the importance of quality sleep in fatigue management
- describe the impact of sleep inertia, circadian rhythm and jetlag on performance
- identify strategies to reduce the impact of fatigue
- understand crew responsibilities when reporting unfit for duty due to fatigue.
Cabin crew HF Recurrent
- why fatigue is an issue
- practical strategies that can be used (napping, caffeine, sleep hygiene, exposure to light / exercise, nutrition)
- application of these strategies to a practical example
- reporting fatigue.
Summary
Fatigue management is a shared responsibility between the company ([Operator]) and the crew member. To manage the health and safety risks that fatigue presents [Operator] provides tools and resources to educate crew to be aware of the symptoms and effects of fatigue, and also the mechanisms to report fatigue or elect to not attend work due to fatigue. The in-flight rest provisions provided on the [type 1] aircraft are consistent with industrial agreements, industry standards, and are reflected in fatigue modelling and pattern planning to minimise the impacts of fatigue. [Operator] has a strong suite of controls to effectively manage the risks that may arise from cabin crew fatigue.
CASA reviewed the provided REPCON and the information provided in response. CASA considers a situation in which a crew member is not fit for duty due to fatigue to be a valid safety concern. CASA’s review of the REPCON has not identified evidence regarding a regulatory non-compliance (e.g., CASR 91.520 Crew members to be fit for duty, CASR 119.210 Compliance with exposition by operator). CASA will include the information provided within the REPCON in its oversight approach for the identified operator.