Safety and Fatigue Management
Joint ASL and AFAP discussion
Recently AFAP staff had a joint discussion with ASL Airlines Australia (ASLA) Director of Safety Robert Hardie. In attendance from the AFAP were me, Lachlan Gray (Safety and Technical Officer) and James Mattner (Senior Industrial Officer). It’s a small industry and Rob and I have previously met and collaborated on progressing safety interview support initiatives.
During this meeting, we candidly discussed a range of safety and fatigue related matters, both as they pertain to ASLA and more broadly to the wider aviation industry. This communication aims to share some of those discussions with you and provide further information to aid your involvement in safety and fatigue management initiatives.
Background to the Fatigue Management rules
The fatigue rules in Australia were revised a few years ago because of a global rethink and review, hosted by ICAO. With Australia being a signatory to the relevant convention, we have adopted those principles but not without challenges. Some of which the wider industry is still working through. ASLA is not alone or immune to the realities of progressing through these challenges.
Prescription, Flexibility, Hybrid Arrangements and Shared Responsibility
CASA has adopted the two main approaches to the management of flight crew fatigue, prescriptive and performance-based standards.
Appendix 7 (FRMS) is the main means of performance-based standards but in reality, the prescriptive approach includes risk/performance-based aspects too – I.e. a hybrid arrangement involving both prescriptive compliance and ongoing risk-based requirements.
Fatigue management at ASLA is through the prescriptive approach provided via Appendix 2 of CAO 48.1. However, in addition to this prescription, CAO 48.1 also includes the
Enhanced fatigue management obligations found at Clause 15. These enliven the hybrid obligation aspects I refer to above - necessary risk assessment and mitigation processes of a Safety Risk Management (SRM) type, which apply to ASLA.
FCM Share of the Safety and Fatigue Responsibility
Performance-based and SRM processes are reliant upon the provision of data, operational experience and other relevant information from Flight Crew Members (FCMs). This can come in the form of such things as fatigue reports, Samn-Pirelli rating scale inputs, FSAG inputs from FCM representatives etc. The content of fatigue reports are extremely important to explain the “why” to the “what” of the basic information. The manner in which you report and the words you use to explain the “why” in reports is important.
To aid with improved reporting, a useful resource to refer to is the
IFALPA Fatigue Reporting Guidance briefing leaflet. This paper encourages crew to be responsible with the use of when to call in fatigued, to avoid the use of emotive language and to instead utilise language suited to SMS and fatigue science. I.e. to speak the language of the safety system and the audience of the report.
Pilots are problem solvers by personality type and use these skills on every sector flown. However, the important perspective to hold with regards to problem solving through informing safety systems of hazards is that these may require more time and data points to help identify hot spots and risk tends. Think along the lines of engine data trending to reveal maintenance requirements.
FCMs are the fatigue data source and your input is imperative, and from a wide inclusion of crew.
There are many reasons why FCMs don’t report and the two most significant reasons are usually despondency with action following a report; and concerns about being on the receiving end of consequences from a negative safety culture. I personally believe that Rob is someone who you can trust and is professionally hungry for the provision of more data and reported details from ASLA FCMs.
Management Share of the Safety and Fatigue Responsibility
Our recent discussions included matters related to safety culture and the importance of top-down support for enabling positive safety culture behaviour (and the avoidance of disabling behaviour). Safety culture can be fragile and may even be influenced by perceptions held from when one worked at different operators.
CASA obliges operators to have continuous improvement via their SMS and the AFAP is keen to support those operators and management personnel who are endeavouring to progressively improve safety culture initiatives. The old fatigue rules bred a perspective of compliance equals safety. Clause 15 of the new fatigue rules is something that CASA is aware of as being widely overlooked and unfortunately misunderstood to be optional. See this:
presentation from CASA in 2023, which in part was aimed at shifting these old industry perceptions and culture on.
Cultural change can take time but this should not be an excuse for inaction. Inert SRM processes breed a culture of despondency, that is, a disabling feature when it comes to encouraging reports and data provision. Management should aim to avoid this situation causing harm to data provision.
Trust is a two way street. Management need to work towards trusting that FCMs only use fatigue call ins for genuine reasons. Pilots need to trust that such events are treated professionally. This can be a difficult relationship to progress, hence why organisational cultures are difficult to progress. All parties need to value the trust relationship and proactively endeavour to not undermine it.
Where examples exist of a lack of provision of data/reports, we encourage operators to proactively hazard identify safety culture based inhibitors via crew surveys, with an aim to reveal lessons for improvement initiatives. Certainly, situations of no initiatives to progress SRM related to Clause 15 of CAO 48.1 are not acceptable either.
The AFAP trusts that ASLA Director of Safety Rob Hardie has the right intent for protecting and progressing safety and fatigue management matters. We hope that others in ASLA (management and crew) are also aligned with the same positive safety culture intent and practices, and we remain ready to support positive safety culture initiatives.
Further Reading
There are many hyperlinked resources in the following document, which was provided to industry participants at the 2022 Fatigue Management Summit. The contents are arranged by topic area and as suggesting a good place to start is with the FMG for Airline Operators, as it provides a summary of some of the other content.
Fatigue Management Resources List
If you have any questions please contact me (Lachlan Gray) on
lachlan@afap.org.au.