The reporter has raised a safety concern relating to cabin crew fatigue. The concern specifically relates to [Location 1]-[Location 2]-[Location 3]-[Location 1] international flight pairings.
[Operator] operates [Flight A] and [Flight B] ([Location 1]-[Location 2]-[Location 3]) with a total duty time of between 12-14 hours. The reporter states, the sign on for this duty is 1300 local time and sign off in [Location 3] just prior to 0000 ([Location 1] time) with an additional 40 minutes for the crew transfer to the hotel. The reporter advised there is very little provision for cabin crew rest throughout these sectors with a maximum of 20 minutes seated in a galley seat which does not allow for effective rest.
The reporter states, the [Location 1]-[Location 2]-[Location 3]-[Location 1] sectors are always busy with high passenger demands and often involve passenger medical or volcanic ash related diversions. This schedule provides a crew rest time at [Location 3] of 15 hours. The reporter further states, they find it difficult to unwind at the hotel following two busy and demanding sectors. Furthermore, including the 40-minute transfer back to the airport the following day, the schedule provides insufficient time for adequate rest.
The reporter advised, as [Location 3] is not a crew base, cabin crew are under pressure not to report sick and or fatigued, as this may result in the cancellation of the return flight back to [Location 1]. The reporter further advised, they recently were not feeling fit for duty due to insufficient rest however were reluctant not to continue with fear of potential company reprisal as replacement crew were not available at [Location 3]. The reporter states, following another busy sector from [Location 3] to [Location 1], they were concerned about their safety when driving home after signing off. The reporter further believes the [Location 1]-[Location 2]-[Location 3]-[Location 1] trip does not adhere to the enterprise bargaining agreement (EBA) and company fatigue risk management principles.
The reporter is ultimately concerned that the current duties involving maximum duty times, minimum rest times mixed with time zone changes, highlight an operational safety hazard that requires immediate attention. There is a potential safety risk for the crew and passengers if cabin crew providing a safety critical role are fatigued and not fit for duty.
Thank you for forwarding the recent crew fatigue report concerning the two-day, [Location 1]-[Location 2]-[Location 3]-[Location 1] pairing operated under flight numbers [Flight A] and [Flight B]. As always, we appreciate the opportunity to respond and wish to acknowledge the concerns raised by the reporter.
[Operator] takes all fatigue related reports seriously and remains committed to maintaining a high standard of safety. We acknowledge the crew’s feedback regarding the nature of these sectors, including high passenger loads and operational complexities such as medical events and potential diversions. [Operator] acknowledges these can occur on occasion; however, controls are in place to manage situations, and diversions are not frequent as claimed by the reporter.
Following a review of the reported pairing / duty sequence, we wish to clarify the following:
Enterprise Bargaining Agreement (EBA) Compliance:
The pairing in question has been reviewed against the current EBA provisions and is confirmed to be compliant.
All duty and rest periods meet or exceed the minimum requirements outlined in the agreement. The maximum allowable duty time is 12 hours (planned) and 14 hours (unplanned). For this pairing, the duty on Day 1 is planned at 11 hours and 45 minutes. While the minimum required rest period is 12 hours and 30 minutes (planned), the scheduled rest period is 15 hours and 50 minutes.
Fatigue Risk Assessment:
Bio-mathematical modelling (BMM) conducted as part of our Fatigue Risk Management System (FRMS) does not indicate an elevated fatigue risk for these pairings. The modelling incorporates time zone changes, duty duration, and rest opportunities, and is regularly validated against operational data.
Workload Considerations:
Although current modelling does not indicate an increased fatigue risk, the operator recognises that workload intensity may still influence perceived fatigue on certain pairings. This is due to variability in workload driven by factors such as passenger load, time of day, and the nature of the flight (for example, leisure vs business). Measuring cabin crew workload using BMM presents limitations, therefore, the operator is considering a workload study, which has been identified as a potential future initiative within the strategic pipeline.
Fatigue Reporting Management:
The operator is committed to a strong safety culture that supports open and transparent fatigue reporting without fear of reprisal. Cabin crews are encouraged to report fatigue and are offered a range of support measures such as transport assistance or hotel accommodation to ensure crew can safely manage fatigue, regardless of location. When fatigue is assessed as work-related, crew may remove from duty with full pay, without the need to use personal leave entitlements. Ongoing communications remind crew to prioritise their wellbeing, including avoiding driving when experiencing fatigue and making use of the provisions offered.
After careful consideration of the concerns raised in this REPCON, the [Operator] remains confident that its proactive and reactive fatigue management processes exceed current Australian benchmarks. Continuous improvements are informed by data insights and guided by input from the fatigue committee, which includes cabin crew representatives, ensuring ongoing focus on system integrity.
Should further information be required, as always, we wish to engage collaboratively and welcome the opportunity to do so.
Thank you for the opportunity to review the REPCON.
CASA considers the matters contained within the REPCON to be a valid concern that may impact safety and acknowledge the Operator's immediate actions. CASA would like to highlight the requirements of CASR 91.520 regarding that crew members should not carry out any duties for a flight where they are, or likely to be, unfit to perform a duty on the flight or a duty that is related to the safety of the aircraft, persons or cargo on the aircraft. CASA will include the information provided within the REPCON in its oversight approach for the identified operator.