AFAP SAFETY & TECHNICAL – DEC 2018

The AFAP is an association of professional air pilots as well as a Union. As an association of professionals, we maintain a focus on all aspects that affect our air pilot profession and for this reason, we are active in aviation safety and technical matters.

This S&T Briefing contains updates and information on our latest dealings with other aviation industry stakeholders. This includes with CASA and the regulatory reform process, the nature of our inputs to consultations and meetings, and any updates or recent changes of interest to our pilot members. The briefing also contains requests for inputs so to provide you, as working professional pilots, the opportunity to contribute and to have your opinions heard. This includes an opportunity to directly input to the CASA consultation on the Fatigue Rules and to participate in an international fatigue survey. We’d also like to hear from any members who are involved in your organisation’s Safety Action Group (SAG).

The AFAP Safety & Technical Team.

CAO 48.1 TWG Fatigue Issues - Fatigue Rules Review


YOU SHOULD HAVE YOUR SAY - Closes February 10, 2019

The AFAP Safety and Technical staff and representatives are currently preparing a comprehensive response to what we believe is this latest degradation of pilot fatigue rules. In the latest draft version of the rules, the regulator has increased maximum duty times, discarded flight times, cancelled late night operation protections and not provided regulatory mitigation against disrupted rosters. Industry self-regulation of fatigue is evidently inappropriate, however by watering down the fatigue rules even further, this is the direction CASA is headed. The recent UNSW pilot fatigue survey contained the following statement:

“The findings show that fatigue is a significant problem for Australian commercial pilots. Around half of pilots surveyed (52.4%) reported that fatigue is a substantial or major personal problem in their work. The majority had experienced fatigue both before or during duty at some stage in their flying career. Approaching half (46.1%) had experienced fatigue during half or more of their shifts”.

The AFAP is concerned with the following degradations to CAO 48.1.

  • Removal of the late-night operations definition and Inadequate definition of ‘local night’ that does not protect WOCL sleep opportunity and associated protection. The proposed CAO has no buffer around the WOCL (Window of Circadian Low) between 2:00am and 5:59am, which will result in even more fatiguing duties, and combinations of duties than we have now (see below for more on this)
  • Insufficient mitigation around disrupted rosters, i.e. early to late starts and late to early starts.
  • Expanding the number of consecutive Back Of Clock (BOC) duties to 5.
  • The use of class 3 rest that is no longer required to be ‘fit for purpose’ for sleep to extend FDL periods
  • The elimination of Flight Time Limits, in many cases, deferring to Flight Duty Period limits only - this will increase the length of long single sector night duties.

Regarding the removal of Flight Time Limitations (FTLs), ICAO ANNEX 6 chapter 4-10 outlines that States establish FTLs for the purposes of managing its fatigue-related safety risks. In CASA’s latest 48.1 draft, the current proposal to remove FTLs from most of Appendix 2 & 3, and all together from some other appendices, is therefore inconsistent with the ICAO SARPs and CASA’s original justifications and draft. Longer term FTLs will still need to be recorded (such as for 28 and 365 day limits), thus a justification to “simplify” the rules isn’t rational and nor is it based in fatigue science.

Regarding the removal of Late Night Operations (LNOs) protections: The introduction of a Window of Circadian Low (WOCL) definition and associated protections is a positive and necessary enhancement to FCM fatigue mitigation however the removal of the requirements associated with LNOs is a mistake and a degradation. These two aspects aren’t interchangeable and CASA seems to have misunderstood the TWG’s input to this area when it wanted to introduce WOCL provisions. It was not agreed that this should mean that they remove LNO provisions instead!

The period of the WOCL is the most crucial and sensitive part of the circadian cycle but it is not the only crucial and sensitive part of this cycle. Protection covered by LNOs in the 2013 CAO 48.1 Instrument remain an important set of provisions to help mitigate the fatigue effects of alternating early / late patterns and during LNOs duties and this is supported by CASA’s own position provided in their Explanatory Statement: CASA Explanatory Statement on the 2013 version of CAO 48.1

This is not to say that we aren’t concerned with other areas of the fatigue rules but we chose to highlight the above areas now as these are some of the most concerning current changes proposed within the current draft rules. To read about our earlier raised concerns, click here: AFAP Submission on the Fatigue Rules (April 2018)

Within the current phase of this consultation, CASA have only provided a comparison graph for 1-2 sectors duties and only for Appendix 2 and 3 operations. Here is the 4 sector graph comparison of the FDL limits for the same appendices, which is not available from the CASA Consultation Hub.



In many places the limits are now greater than the CAO 48 Standard Industry Exemptions (SIEs). CASA’s own studies have determined that the SIEs are inappropriate and dangerous. https://www.casa.gov.au/files/fatigue-management-2015-scientific-support-briefpdf

In view of our concerns, we ask all members to review the proposed rules (Draft CAO 48.1 Instrument 2019) against your most taxing or fatiguing roster and see whether the proposed rules do in fact mitigate or exacerbate fatigue. Please then go to the CASA Consultation Hub and enter your findings in the questionnaire. Could you also please copy your answers to us at technical@afap.org.au Please get in touch with us if you have any further input and feedback.

Visit the Consultation Hub to provide your feedback by the 10 February 2019 deadline. CASA Consultation Hub - Fatigue Rules Review


CASA Consultative Business

RAPAC Meetings

Do you want to learn more about RAPAC and these meetings? CASA RAPAC Page

VIC RAPAC meeting

Members of the VIC RAPAC raised concerns as to the safety outcomes related to the decision to alter the Melbourne VTC - VFR Lane under the controlled airspace step. Effectively, the suggested transit altitudes were contrary to the normal choices for east and west bound flight. The CASA Office of Airspace Regulation considered this feedback to be valid. Unfortunately though, the charts had already been published and amended charts aren’t available until May 2019. Therefore a Sup (AIP Supplement) has been issued and pilots who are likely to utilise this transit route should familiarise themselves with it. Which is available here: H132/18.

At the SA RAPAC meeting

AusALPA proposed that the upper Spencer Gulf aerodromes all come under one CTAF Broadcast area. In the upper Spencer Gulf region, there are four aerodromes in relative proximity to each other (Port Augusta, Port Pirie, Whyalla and Stirling North). Aircraft for these aerodromes are often traffic for each other and the restricted areas on the NW side of the gulf help to increase the likely proximity of transiting aircraft to each other. The SA RAPAC discussed this initiative and it was well received by the meeting participants.

Further consultation would be required prior to progress of the proposed change being enacted. If this proposal is successful, it is unlikely to be ready for the May 2019 AIRAC publication release.

TAS RAPAC meeting

Safety and Technical Officer Lachlan Gray attended this meeting via video link. At the April 2018 TAS RAPAC meeting, AusALPA raised proposal for the inclusion of Visual Arrivals and STARs with Visual Terminations for Hobart. In summary, the proposal was for an increase in approach options, particularly for arrivals to RWY 30. Airservices have been considering this and are also proposing the introduction of STARs from the NE to better aid the arrival of flights from Sydney, Brisbane and the Gold Coast. Furthermore, there is talk of STARs with Visual Terminations too.

Feedback to us from pilots has been that visual approach requests are rarely granted however at this meeting, Airservices informed us that if a pilot requests a visual approach, and it’s available, the Hobart TWR should give it. I.e. Airservices reiterated that there is no moratorium on disallowing Visual Approaches at Hobart so this should be a currently available approach option and that development of other STARs is currently being considered.

Technical Working Groups (TWGs) CASA TWGs

CASA has wrapped up most of the work for the “6 pack” of flight operations CASR Parts. All active pilots will be affected by at least some of these regulations. There is still some work to do, such as for the Manual of Standards (MOS) associated with Part 121, however all the regulations have now been signed into law by the Federal Parliament. The rules won’t commence until March 2021 and note: the MOS and guidance material for each Part aren’t subject to the requirement for Parliamentary approval. The “6 Pack” includes:

  • Part 91 - General Operating and Flight Rules (Private and Commercial Ops)
  • Part 119 - Air Transport Operators (AOC holder obligations)
  • Part 121 - Air Transport Operations (Large fixed wing aircraft)
  • Part 133 - Air Transport Operations (Rotorcraft)
  • Part 135 - Air Transport Operations (Small fixed wing aircraft)
  • Part 138 - Aerial Work Operations (Aeroplanes and Rotorcraft)

The Safety and Technical team (including many reps) have contributed a great deal of time and input to these consultation processes and CASR outcomes. Whilst some further work is definitely still required, it remains a good step forward in placing many CARs, CAOs, Exemption Instruments and other material into single locations, whilst also taking the opportunity to update some outdated areas.


Maintenance Guide for Pilots



The paperwork and procedures for maintenance and aircraft daily inspections are a key part of the aviation safety system. In an effort to help pilots with aircraft airworthiness assessments and Maintenance Release (MR) paperwork, CASA has produced guidance material. This guide also includes references to the associated rules and regulations.

This information will be of use to our student members, those early in their flying careers and any pilot looking for a refresher or to retain a reference guide for MR related material.

CASA Maintenance Guide Link Hard copies can be requested from CASA too.




AusALPA Safety & Technical Updates

AusALPA is a safety and technical partnership between the AFAP and AIPA. In line with the committees of IFALPA, AusALPA focuses its attention and work through the Committees AAP, ADO, AGE, ATS, HUPER, LEG/PGA, SEC/DG. Various working pilots have volunteered to contribute to the progress of safety and technical matters through becoming a S&T rep. Reps help to provide a broader perspective on matters than would otherwise be the case through the S&T staff alone. We thank these dedicated aviation professionals for their contributions and insight. Professional development, networking opportunities and the ability to affect positive change are all reasons cited by the S&T reps as benefits of being part of the S&T team.
For more information, contact the S&T team by emailing: technical@afap.org.au


Accident Analysis & Prevention (AAP)

IFALPA AAP Committee Meeting



AusALPA hosted the IFALPA AAP committee meeting in November in Sydney. Delegates from many nations attended including from: Australia, Austria, Bangladesh, Brazil, Denmark, Finland, Germany, Israel, Japan, Malta, Morocco, Netherlands, New Zealand, Norway, Singapore, South Africa, South Korea, Spain, Thailand, United Kingdom and the United States. A number of AusALPA reps from both the AFAP and AIPA attended this meeting.

Many recent aviation incidents and accidents were discussed and some of the committee members as well as manufacturer representatives gave presentations and exclusive information on findings. Some Lion Air 737 Max fatal accident findings were unfolding during this meeting and were discussed in detail, including the appropriateness of common-type rating training, and system differences such as the MAX’s MCAS.

Safety Action Groups

Are you a member of your organisation’s Safety Action Group (SAG)? Would you like to contribute to SMS matters in a more meaningful way? We’d like to hear from you. ICAO has recently updated its guidance material for SMSs including for SAGs. At some point in the not too distant future, CASA will introduce clearer regulation in relation to AOC holder’s SMSs (CASR Part 119). Also, CASA will draft a CASR (Part 5) to better align Australia with the ICAO SARPs on SMS (Related to ICAO Annex 19).

If you are an AFAP member and are involved in your organisation’s SAG, please email technical@afap.org.au


Aircraft Design & Operations (ADO)

Fuel Rules

CASA is providing existing AOC and Part 141 certificate holders more time to comply with the new fuel requirements under the CAR 234 amendment, by issuing a new exemption.

You will now have until 28 February 2019 to comply with the requirements of the new regulation and CASA Instrument 29/18 (the Fuel Instrument). To read more about these changes, click here: Fuel and Alternate Requirements Project


Aerodrome & Ground Environment (AGE)

Local Runway Safety Team meetings


Moorabbin Meeting


AFAP S&T Officer Julian Smibert attended the Moorabbin Airport Runway and Flying Safety Meeting on the 21st of November. This meeting covered incidents on the airport and a rundown of current building and development operations on the airport presented by ASA and MAC respectively.

Operators were particularly vocal regarding the apparent lack of operator input sought prior to building works in the vicinity of runway 35 threshold and the turbulence which this has caused. This issue is an ongoing hot topic for the S&T team.

Buildings in the Vicinity of Airports

Essendon Airport


The operators of Essendon Airport have again expressed an interest in reducing the runway strip width on RWY 08/26. They have participated in recent meetings including at the Victorian RAPAC meeting. There was vocal concern from many meeting participants as to the future implication of such a proposal and how this was quite inconsistent with international standards and the intent of the local regulations. The S&T team have increasing concerns with the process of applications to build within the vicinity of an airport and airspace intrusions are handled. The ATSB has also flagged these concerns in a report on the topic earlier in 2018, which can be read here: AI-2013-102.

A safety action remains open and pending for the Department of Infrastructure, Regional Development and Cities to address from this investigation. Also currently open and pending is the ATSB investigation into the same topic area under the investigation AI-2018-010. This investigation report is flagged for early 2019 and is a spinoff from the Kingair accident at Essendon in February 2017. The protection of airspace around our airports is a position the AFAP considers to be of significant importance.

Canberra Airport

AusALPA has written to Canberra airport encouraging their development proposals to assess wind and turbulence considerations with contemporary science and data. This letter also covers Australia wide legislation and the development approval process at airports. Building induced turbulence is a topic specifically addressed in the National Airports Safeguarding Framework (NASF) and is one which is still inadequately addressed.


Human Performance (HUPER)

PACDEFF & AAvPA Symposium - CRM and Aviation Human Factors Conference 2018



The AFAP was again a principal sponsor of this event. The premier conference of its kind in the region, PACDEFF/AAvPA showcased the latest in human factors development, practice, and research in the aviation and other industries. This year featured topics such as:

  • Systems Safety, fatigue & reporting culture
  • Human Factors design integration
  • Social, clinical, & applied psychology, mindfulness
  • New and emerging technologies such as eye tracking, virtual reality
  • Welfare and Peer Support
  • CRM operational integration & evidence-based training
The archive of program and presentations can be found here and further detail via the AusALPA report is available upon request.




Professional Pilot Fatigue Survey "Working Conditions, Fatigue and Wellbeing”

The AFAP has been asked to help disseminate an online survey focused on effects of commercial pilots’ working conditions on fatigue and wellbeing. The research team specifically want to assess pilot fatigue, actual flight and duty times, as it relates to your health and wellbeing.

The intention is to go further than prior research by avoiding a focus on safety culture, but rather, on your relationship with fatigue and your wellbeing. The intention is to use the data to develop new and reliable scales to measure and predict fatigue in more valid and reliable models. Please follow the survey link: Pilot Fatigue and Wellness Survey

This survey takes approximately 20-25 minutes and Australian Pilot input will help provide a broader qualitative data set, which will add to the data already being collected from pilots internationally.

Controlled Airspace Steps - Do they contribute to your descent being “lumpy”?

We asked for your input on this topic in our last Briefing. Thank you to those who responded. See the Airservices update below on the Airspace Modernisation Proposal for further on this topic.

Hamilton Island Ground Based Navaids (C-VOR/DME) - We Surveyed You

In 2017 tropical cyclone Debbie damaged the C-VOR and DME equipment at Hamilton Island. In late September this year, Airservices asked industry stakeholders for feedback on a proposal to permanently decommission these Navaids. These Navaids form part of the industry-agreed Backup Navigation Network (BNN) and as such, may not be decommissioned without completing a safety and risk assessment. A decision from Airservices is not yet forthcoming and Airservices is consulting further on this matter, until January 29. If you have further to add, please contact us: technical@afap.org.au


BOM News



GAF information

With the introduction of the GAFs, some pilots have found it difficult to correlate the associated locations referenced in forecasts with the weather information in the GAFs. The BOM provides PCA type charts so that this can be achieved. The locations are marked with the grid pattern overlaid so that each GPWT area can be matched to the locations.

These charts can be found in the Aviation Weather Services section of the BOM website.

Airservices News

Airspace Modernisation Proposal

AusALPA provided a submission on Airservices Proposal for Airspace Modernisation Link to Proposal Details

Airservices is proposing two alterations. One is the transfer of TWR control responsibility at Class D locations to be uniform with an upper limit TWR control at A045. The other proposal is to alter the vertical limits of the airspace classification architecture as depicted by these diagrams.



Lateral limits and CTA Steps:

In our last S&T Briefing, we asked you to have your say and to provide feedback as to descent and approach problems associated with remaining within CTA. This was quite fortuitous and timely because we were able to include this feedback in the submission on this matter. Effectively we supported most of the Airservices Proposal but also asserted that this current review was an opportunity to also consider and amend the aspects of controlled airspace steps, in addition to the vertical aspects of the airspace architecture.



IFALPA’s InterPilot Magazine:

In this latest issue of InterPilot, the AFAP has an article outlining our involvement in early stages of IFALPA as well as a feature on Captain (Ret) Ron Stacey’s work. InterPilot 2018 Issue 4

IFALPA Regional Meeting - Kuala Lumpur

The annual IFALPA Asia-Pacific Regional Meeting was held in Kuala Lumpur 2-4th October 2018, hosted by the Malaysian Airlines Pilots Association, and was attended by AusALPA representatives from both AFAP and AIPA. The first day featured a number of presentations from Singapore ATC, Malaysian Airlines, as well as the AFAP’s Safety & Technical Manager Marcus Diamond, giving an overview of the development of fatigue regulation in Australia. Impressively, the day was also attended by Malaysia’s transport minister who took the opportunity to invite MAPA to a permanent seat on the nation’s transport advisory board - a level of recognition for professional pilots that we are yet to achieve in Australia. Days 2 and 3 contained discussions on regional issues including airspace and airport deficiencies, FRMS and the expansion of safety and reporting culture.

IFALPA Positions

IFALPA Position Paper: Use of Social Media by Pilots

IFALPA is extremely concerned with the potential risk taken by pilots who are unknowingly putting their own flying career – and that of their colleagues – in jeopardy. Although this is not a new problem, the extent at which this has grown as an issue is unprecedented. This one page position paper can be downloaded by clicking here: Download

Cabin Air Quality discussion and position paper

For most modern transport category aircraft, cabin air is taken directly from compressors in the engine compartments without filtering. Occasionally, oil fumes from the hot section of the engine and/or APU leak into this air, resulting in what is known as a fume event. A fume event may result in incapacitation of crew members and jeopardise flight safety, but some of the consequences of such leaks are still subject to debate. More information on Cabin Fume events can be found in the IFALPA Cabin Fumes Briefing Leaflet or Position Paper.

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