Please find our responses to the points raised in this REPCON.
- rosters are not processed through a fatigue management system
Roster design and shift work have the potential to introduce fatigue and as such, our base rosters are periodically assessed using [InterDynamics] FAID [Fatigue Assessment Tool] software analysis. This analysis is undertaken with full oversight of the responsible manager who is part of the operator’s safety team.
- There can be changes to published rosters, such as those introduced by shift swaps and overtime. As such we ensure a shared responsibility to ensure that these changes do not result in fatigue.
- The current roster design attempts to match circadian rhythms and other elements try to ensure staff get the maximum recovery time between shifts and time off between rostered blocks of shifts.
- staff members are now rostered for no more than 4 night shifts in a row, but if a staff member requests to do more than the four night shifts this is normally approved
Staff members are normally only rostered a maximum of three consecutive night shifts. These blocks of three night shifts are then worked on average once per month. We can confirm that if an individual requests or swaps to work additional night duties, this is normally approved. However, all rosters are subject to a number of protocols designed to prevent the onset of fatigue (i.e. max 7 consecutive shifts).
- duty managers raise concerns to management, but no changes are observed
There is no information to support this statement. In addition, the author does not state the nature of the concerns.
- there are no replacement staff available when someone is on leave
2015 did see a higher than normal staff turnover, however, an increase in staffing levels was approved in 2015 and at the time of this response all rosters are fully populated meaning there is ample annual leave, sick leave and staff training coverage available.
The operations centre is subject to rigorous CASA and internal audits by our flight operations area. Staffing levels have featured in previous years but all findings and observations have been fully satisfied.
- staff are not reporting issues for fear of retribution
Again, there is no information to support this statement. In addition, the author does not state the nature of the issues. All operations and operations centre staff know how to submit an incident report in the SMS and there is a ‘confidential’ option available to them. The submitting of incident reports is fully encouraged by all levels of management. Additionally, the operations centre managers actively support healthy discussions and one to one conversations with their team members.
- after working long hours, unreported incidents are occurring while driving home including falling asleep at the wheel and minor car accidents
There is no information to support this statement and we are unaware of any such instances being reported either formally or informally.
- concerns have been raised with management, but as there is no CASA regulation relating to fatigue management in this area, fatigue is not seen as an operational safety issue
This statement contradicts at least one of the previous made. Contrary to the views of the author, management take fatigue management very seriously in both the operations centre and the airline. The operations centre rosters are constructed will within the guidelines of the latest airline and union agreement, that is pursuant to s.54, s.183, s.185 and ss.186, 187 & 188 of the Fair Work Act 2009
- the concerns are seen as industrial related issues
As previously stated, the operations centre management team go to great lengths to ensure any and all valid concerns are alleviated to the total satisfaction of the person(s) raising them. Without further context, we are unable to comment on the statement regarding concerns being industrial related.
- high turnover of staff and management has allowed this issue to continue
As previously stated - 2015 did see a higher than normal staff turnover, however, an increase in staffing levels was approved in 2015 and at the time of this response all operations centre rosters are fully populated. This means that staff turnover/attrition has been fully arrested and now sits at normal levels. All departments in the centre enjoy a clear career progression path, junior/entry level positions to support this progression and there is no shortage of applicants for available positions.
Furthermore, some staff have been recruited from overseas in 2015/2016 to help maintain experience and roster/manpower levels. It can be clearly demonstrated that the operations centre has well in excess of the minimum required staffing levels to acquit a safe and compliant operation that includes staff rosters, annual/sick leave and staff training.