Airservices Australia's Fatigue Risk Management System (FRMS) adherence

Airservices Australia response to REPCON 

We have given careful consideration to the matters outlined in the REPCON, consistent with our approach of treating all safety issues with the highest priority. We are committed to the continuous improvement of our FRMS and appreciate the value of feedback as a mechanism to identify improvement opportunities.

1. Shifts are being allocated to staff without regard for their current fatigue risk.

The reporter understands that any shift being filled would be given to the Air Traffic Controller with the lowest FRMS risk. Contrary to this, however, they believe that pressure on [supervisors] to ensure service continuity is causing them to disregard any fatigue risk when filling shifts.

Response

Airservices’ Fatigue Assessment and Control Tool (FACT) is the primary instrument used to manage fatigue risk in the tactical environment. Stage 1 of the FACT identifies the fatigue potential for the shift based on the characteristics of the shifts prior, considering factors including hours of work, night shifts, backwards rotation, and frequency of extended rest periods, among others.

When a shift needs to be covered using call-out of staff, Airservices’ rostering software is configured to present a call-out list in order from lowest predicted fatigue risk to the highest. The callout procedure requires that when looking for a person to cover a shift, the person with the lowest predicted fatigue risk is offered the shift first in all but exceptional circumstances (AA-PROC-SAF-0028, S4.6.1).

The procedure allows for people with higher predicted fatigue levels to be called in to cover a shift, granted the lower risk options have been exhausted. In all circumstances, the call-out can only be completed with the employee’s agreement. There is no obligation for the employee to work the shift.

If the employee called in to complete the shift has a predicted fatigue level of medium or higher, a tactical risk assessment is performed (Stage 2 of the FACT). Situational factors are evaluated and risk controls are assigned to be applied during the shift.

In all cases, supervisors must comply with the requirements in AA-PROC-SAF-0028 when calling out staff.

2. False or deliberately misleading shifts are being recorded to bypass the current FRMS.

The reporter notes that some operational staff are performing additional roles and tasks such as acting managers, project work, training or checking roles. This work is being done outside of their normal hours and sometimes offsite. They note that the additional hours are then being added to RDOs or to ends of shifts. As such, the current FRMS under-records the total hours worked by these staff. The reporter also notes that some operational staff are working on tasks in their own time, with the time on those tasks also not being captured by the FRMS. And further, the reporter states that the FRMS has no ability to record the hours worked by staff in an approved second job outside of ATC - leading the reporter to fear that the basic principles of rostering are not being followed on occasions where total worked hours across multiple jobs are not recorded.

Response:

All shifts performed by an Air Traffic Controller are managed through the Quintiq rostering tool. Task information is included for each shift, including project support, administration time, acting manager roles, training and checking admin, travel, classroom activities, and several other non-operational task types. The FRMS considers all task loading, including sick and carer’s leave, in calculating the predicted fatigue level for each shift.

Shift workers are required to prepare for rostered shifts to ensure fitness for duty as per AA-PROC-SAF-0028 Table 7 and ATS Mandatory Training – FRMS – Fitness for Duty (refer Appendix 1). It is expected that staff members manage any tasks completed in their own time, or as part of an approved second job outside of air traffic control, in acquitting this responsibility.

3. Some risk management strategies are just a ‘tick the box’ exercise.

The reporter states that a key example of this is the ‘increased number or length of breaks’. They believe that the reply from Airservices Australia will be ‘most controllers get more than the minimum break period in their shift’. They state that this is often correct, however they question why every shift does not then have a reduced fatigue risk? Further to this, the reporter posits that extra breaks are measured on what a person could expect to have, based on long term averages, not what’s required as a minimum. They believe that this measure is also used to reduce risk on those performing single staffed positions who are unable to take a full break. The reporter acknowledges that managing fatigue is a shared responsibility and believes the ATC cohort should feel comfortable reporting fatigue. They feel that the current environment [the named party] has created is causing people to report for duty when fatigued or sick. The reporter concludes by reiterating that a robust system protects the organisation, the public and the controller from themselves, and note that often the person is unaware how fatigued they are until it’s too late.

Response

The FRMS design assumes that controllers get the minimum Enterprise Agreement (EA) breaks during the shift. This design assumption was applied in recognition that the structure of breaks within a shift varies substantially between units due to differing operational demands. As such, achieving breaks beyond the minimums specified in the EA is a valid control in reducing fatigue risk exposure considering the design assumptions in the FRMS. Time in position and break durations are monitored by the Fatigue Safety Assurance Group.

It is the responsibility of the sign-off authority on the FACT to determine that the risk controls selected for the shift are applicable. An absence of available controls is reflected in elevated Residual Fatigue Potential, which in turn requires escalation through sign-off authority to accept the residual fatigue risk.

All Air Traffic Controllers are encouraged to report fatigue through the Human Performance Reporting portal. This is made salient through ATS Mandatory Training – FRMS (refer Appendix 2) as well as the FRMS intranet site. Access to the Human Performance Reporting portal is provided as a shortcut from the Airservices intranet homepage. Details about the triage process and visibility of the report after submission are provided.

Appendix 1: Extract from ATS Mandatory Training – FRMS – Fitness for Duty (supplied to the ATSB and CASA)

Appendix 2 – Reporting Fatigue (supplied to the ATSB and CASA)

Reporter feedback and Named Party subsequent response

The ATSB received reporter feedback relating to the initial Airservices Australia response. This feedback was provided to Airservices who subsequently provided the following additional response.

Concern 1 

They have simply replied with what should be happening and what procedures they have in place to follow FRMS. They have not acknowledged or investigated my concerns at all. This is still happening across the country with the ‘fill any blank’ direction coming from the executive. An example of this is when shifts are filled weeks/months in advance by the first taker - it proves my point that no concern is given to the fatigue levels.

Airservices' response:

In the event a shift needs to be tactically filled weeks/months in advance, as per the reporter’s example, the FRMS still applies. For example, if a new shift is tactically entered into a person’s roster several weeks in advance, Quintiq calculates the fatigue potential for the new shift, as well as all other shifts in the roster that the change may have impact on. 

Concern 2

Again, they have simply replied with what should be happening with a complete disregard for my concerns raised. I agree with their response that an ATC should be aware and managing their own fatigue. My unaddressed concern is a system managing fatigue should capture working hours accurately (which it is not) and secondly, secondary employment is not captured at all in our current FRMS system.

Airservices' response:

We have not seen evidence of this practice; however, this issue will be escalated to the Fatigue Safety Assurance Group for consideration. 

Concern 3

As I questioned and what went unanswered in the response, if most shifts by design get more breaks than the EA, then the control of ‘more breaks’ to lower fatigue risks should be on every shift regardless; making that measure pointless. Principles of rostering state an ATC shouldn’t be working for over 2 hours without a break. If that is followed, then by default extra breaks as per the EA are afforded to ATCs. My report made reference to ATC having a fear of reporting fatigue and for their response to say that online training encourages ATCs to report fatigue again completely avoids a response to my concern of the real fear of reporting.

In summary I feel AsA have simply proven my point about how they view fatigue. I have stated concerns about them not following their own procedures and processes. They have simply stated what they ‘should’ be doing showing no respect to my concerns.

Further information should be provided around what data the fatigue safety assurance group is measuring and they should be aware as I’ve raised, data is Quintiq does not accurately reflect every employee's actual hours worked.

I value the confidentiality of the REPCON process and due to its limitations on identifying individuals involved, I’m unable to provide specific examples to prove my concerns are accurate.

Airservices' response:

The Fatigue Assessment and Control Tool (FACT) process that is applied during tactical rostering is being reviewed as part of Airservices submission to CASA for approval of our FRMS. Items within the current process, for example, the effectiveness of different controls, is being reviewed as part of this process to ensure that the process offers users valuable fatigue risk control strategies.