Reluctance to report cabin crew fatigue due fear of intimidation and disciplinary action

Thank you for passing the information on, as previously advised, [Operator] appreciates having the opportunity to respond to and provide clarity on matters. Below is a consolidated, de-identified, multi-departmental response for your review. 

The operator maintains a mature safety management system with a comprehensive fatigue risk management system in alignment and demonstrates a commitment to managing fatigue related issues with just culture at its core. Relating to the first concerns raised by the reporter, all cabin crew operations are subject to comprehensive proactive and reactive fatigue risk management processes, including biomathematical analysis, governance committees, which include industrial representatives and those responsible for creating rosters and pairings within the organisation. Further, a suite of reactive controls are provided in way of fatigue related provisions. For example, removal from duty, hotel accommodation or transport vouchers are provided to crew from a welfare first perspective. In circumstances where work related factors are identified as contributing to a requirement to remove from duty as a result of fatigue, crew have access to paid relief over and above their usual personal and other paid leave provisions. These provisions are provided on a non-jeopardy basis in the first instance and therefore require an element of trust that the usage of paid fatigue relief is genuine. In circumstances where usage is considered high, where patterns of usage are identified, or where it can be substantiated that access to fatigue relief is non-genuine, the organisation has a duty to meet with a crew member from both a welfare perspective, and to also understand if there are elements by which the organisation or individual can mitigate fatigue exposure. 

All cabin crew leadership undergo training to ensure any conversations with crew relating to fatigue is done so from a wellbeing perspective and maintain just culture view in mind. If, on the rare occasion, there is an instance where a leader identifies that there may be misuse of the fatigue provisions or suspect there may be underlying circumstances which could be leading to fatigue, then this will be investigated and the crew contacted. The operator maintains that crew members are always awarded procedural fairness throughout the process, it upholds just culture, and acknowledges that at rare times, crew may be provided with disciplinary outcomes if found to be misusing the system's provisions. On the other hand, the system is designed that when further investigation reveals circumstances whereby the crew member may need additional support or referral to the operators’ medical team, then the cabin crew leadership and management fully support the crew member through the process. 

The operator acknowledges the reporter's concerns, however, disagrees with the statement claiming a culture of retribution. Further, the reporter's claim that crew are reporting for duty fatigued is a concern for the operator, given the comprehensive fatigue risk management system and associated provisions, the dual responsibility associated with remaining fit for duty. To support the operator's view on this, a review of cabin crew fatigue reporting, provision usage (including pre-duty removals) was undertaken, over and above what is done monthly in the safety and risk governance forums. 

The operator considers reporting rates and provision usage, including pre-duty removals as healthy and reports on and reviews this data monthly in the [cabin crew fatigue meetings]. Moreover, the operator maintains a safety management system, which receives on average, [tens of thousands] reports per year. The safety system also features its own confidential reporting function which is reserved for sensitive concerns such as those claimed by the reporter and has a whistle blower type program. A subsequent review did not reveal any relevant reports on the reporters claims. 

Relating to the reporters comment on the [Location 1]/[Location 2]/[Location 1], transcontinental and short haul international flying. Firstly, the [Location 1]/[Location 2]/[Location 1] return pairing was re-introduced in [month/year] ([Roster A]). Fatigue reports were reported through the [committee involving cabin crew] regarding this pairing the same month. Amendments were made to the pairing in the following month ([Roster B]) to reduce the fatigue risk. Once further analysis was completed on the [Roster B] and [Roster C] pairings, the committee decided that the pairing should be removed from the rostering process and replaced with an overnight pairing. In the interim, while the changes to rostering parameters were amended, crew were provided with company provided transport (cab-charges) both prior to and after the duty to mitigate the potential for fatigue related risks during the commute to/from work. The governance structures worked as designed, basing decisions on reports, trends and data to ensure duties are monitored and amended/removed if required. Further, in relation to the transcontinental and short haul international duties, the operator would like to highlight these duties are continually monitored through biomathematical monitoring during pairing/roster creation and subsequently post roster, with actual duty times recorded. These are reported on and tracked in the [committee involving cabin crew]. 

The operator acknowledges the requirement to mitigate fatigue for cabin crew at the rostering stage, and act on concerns raised where necessary, in line with the procedures documented in the cabin crew fatigue risk management system. 

Lastly, the operator strongly disagrees with the statement that crew psychological safety is compromised or that crew feel frightened, bullied, and intimidated by the cabin crew leadership team when considering reporting fatigue, and that cabin crew are reluctant to declare fatigue due to a culture of retribution, where they are subjected to performance management. 

As previously responded, if, on rare occasions, there is an instance where a leader identifies there may be misuse of the fatigue provisions, then this will be investigated, and the crew member will be awarded procedural fairness throughout the process. 

The operator, albeit infrequently, may 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 of any discussion is from a welfare perspective and to better understand the factors that contribute to fatigue reporting. 

In summary, the operator maintains a mature safety management system, comprehensive fatigue risk management system and continues to work with individual crew, line operations and union representatives to monitor, escalate and react with objectivity to ensure fatigue risk is being assessed and managed appropriately. Importantly, the operator wishes to remain informed by its staff through its SMS and FRMS if there are concerns just culture is not being followed by the leaders in the organisation.