The reporter has raised a safety concern relating to international cabin crew rostering patterns contributing to fatigue.
The reporter advised the current rostering pattern for cabin crew operating international trips is illogical and provided an example of the roster as follows:
- 9 day trip followed by 3 days home-based rest, then
- 5 day trip followed by 6 days home-based rest, then
- 3 day trip followed by 6 days home-based rest.
The reporter acknowledged the roster pattern appears compliant with [Operator] fatigue risk management system (FRMS) however is concerned the pattern unnecessarily contributes to fatigue.
The reporter advised, the long-haul [Continent] flights can be particularly demanding and exhaustive trips and queries why the roster allows only 3 days rest after a 9-day long-haul trip, when there are 6 days rest provided after a shorter and less demanding 3 or 5 day trip?
The reporter states they are concerned for their personal health and safety along with that of other cabin crew members, most of whom are reluctant to submit reports.
At [Operator], we have a strong culture of safety that has been built over decades. 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.
[Operator] manages risks by identifying, analysing, and implementing controls to reduce them 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. However, fatigue remains an area without prescriptive regulation for cabin crew. Notwithstanding compliance with CASR 91.520, [Operator] has implemented a scientifically based, data-driven Fatigue Risk Management Program (FRMP) that uses predictive, proactive, and reactive risk identification. The program aligns with ICAO Doc 9966 guidance and CAO 48.1 principles to monitor and mitigate fatigue-related safety risks, ensuring cabin crew maintain adequate levels of alertness and performance.
The 9-day [Location 1] trip comprises total duty hours of 49 hours 25 minutes. This includes 50-hours [rest period] in [Location 1] and 50 hours 25 minutes [rest period] in [Location 2] (including three local nights) prior to operating back to [Location 3], providing adequate recovery time post duty. Additionally, three days off (including four local nights) following a back of the clock (BOC) service from [Location 2] ensures sufficient recovery, and this pattern meets the requirements of our FRMP by giving crew adequate rest after completing duties.
The [Location 1] trip remains the destination with the highest crew interest among ports, with [Country]-language speakers completing a maximum of two [Location 1] trips per 56-day roster period. For non-language speakers, it is unlikely they will receive a [Location 1] trip every roster period. Due to the sheer demand for the destination, 'lookback' has been deployed in the rostering system, which assesses how often crew have been to [Location 1], in order to fairly distribute the destination in line with crew expectations. In the past 12 months, only 1.8 per cent of the total reports submitted by international cabin crew related to the [Location 1] pattern, and just six reports mentioned demanding service or workload. Overall, demanding service or workload has not emerged as a main theme from fatigue reports.
Fatigue modelling outcomes of this roster and iterations of similar rosters do not show an increase in overall fatigue risk. Notwithstanding this, the operator recognises that variations in cabin crew workload may affect how fatigue is experienced on some duties. The variations can arise from differences in passenger numbers, operating periods, and flight characteristics. Given the limitation in biomathematical modelling accounting for workload-related effects, [Operator] is exploring the collection of workload data as part of its ongoing commitment to data-driven decision-making and continuous improvement.
In the cabin crew context, [Operator] utilises a range of fatigue risk controls to reduce the incidence of fatigue exposure, 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 operational experience and objective data from predictive fatigue modelling, that factors in duration of wakefulness, windows of circadian low (adjusted for time zone shift), rest periods and workload to understand potential levels of fatigue in crew. Pairings and rosters are analysed prior to publication, as well as once the roster has been completed.
For cabin crew, the risk outcomes that 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. Under the shared responsibility model, cabin crew have defined responsibilities to manage their personal fatigue. Crew have the ability to report fatigued prior to commencement of duty. Once the duty has commenced, crew are able to work with their onboard manager and fellow crew 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 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).
[Operator] takes a welfare focused, Just Culture approach to fatigue reporting. Crew are encouraged to report fatigue concerns or the adequacy of controls via the [program name] reporting platform. These reports are reviewed by the FRMP team and the [fatigue management panel] to identify emerging trends and opportunities for safety improvement. Similar in concept to the [flight operations safety group] under CAO 48.1, [fatigue management panel], a functional committee within the [Operator] Safety Management System, brings together cabin crew representatives, management, operations and workforce planning representatives and sleep and fatigue experts to collaboratively assess and advise on fatigue risk management.
Following a thorough review of the concerns raised in this REPCON, [Operator] remains confident that its fatigue risk management approach for cabin crew is ahead of current Australian standards. We continue to drive improvements through data analysis, particularly from fatigue reporting, and informed by the expertise of the [fatigue management panel]. Importantly we actively encourage our crew to report fatigue concerns to ensure ongoing safety enhancements.
If further information is required, we are committed to open collaboration and welcome further discussion.
CASA has reviewed the REPCON and operator response and have not identified any regulatory concerns, and notes that the reporter acknowledged the roster pattern appears compliant with the operator’s fatigue risk management program (FRMP).