AusALPA Fatigue position papers

AusALPA has published two new position papers on fatigue related issues:

  • Sick leave and fatigue data. The paper highlights importance of separating fatigue data from sick leave allocation and urges operators to foster a positive safety culture that encourages flight crew to report fatigue risks without resorting to sick leave.
  • Workload-related fatigue in rotary wing operations. AusALPA advocates for reforms in FCM fatigue management regulations.

Unforeseen Operational Circumstances (UOC) update – AusALPA has expressed concerns over CASA's approval of Jetstar's FRMS significant changes, highlighting potential safety risks and the need for proper consultation with pilots.

Sick Leave and Fatigue Data – a new AusALPA Position Paper

AusALPA emphasizes the importance of separating fatigue data from sick leave allocation in order to achieve effective safety outcomes.

A number of reasons for pilots opting for sick leave over reporting fatigue has been identified, including inappropriate practices such as disciplinary events, loss of pay and/or leave entitlements, and threats (implicit or explicit) to career progression.

AusALPA calls for air transport operators to foster a Positive Safety Culture, urging them to prevent fatigue data concealment by discouraging the use of sick leave as the primary option for flight crew experiencing unsafe fatigue levels, emphasizing the crucial role of this data in optimizing fatigue risk management outcomes. [PDF document – AusALPA sick leave and fatigue data]

Positive trend in pilot fatigue data received

The Safety and Technical (S&T) team has been receiving an increasing amount of fatigue reports and data. This includes significant AFAP fatigue surveying at several operators with trial FRMS.

Many members operating under an FRMS are sending their fatigue reports to S&T and their fatigue reps for analysis. S&T collate and assess this data for further representation to operators and the regulator, encouraging all members to participate by sending their fatigue reports to a dedicated email All collected data will be de-identified.

Fatigue Reporting Guidance Leaflet

The AFAP and IFALPA have produced a new position paper on Operational Experience in Fatigue Management Decision Making in July 2023.

Experience has demonstrated that there is insufficient utilization of flight crew operational experience in fatigue management approaches. IFALPA recognises that flight crew are the primary fatigue management data source. As such, they should be actively involved in fatigue management discussions and decisions, which is believed to be the intent of the ICAO standards. Where flight crew at an operator are represented by an association, flight crew representatives should be drawn from the association. [PDF document – IFALPA Position Paper July 13, 2023]

Fatigue Management of Workload in Helicopter Operations – a new AusALPA Position Paper

The CAO 48.1 definition for sectors has an exclusion for rotary wing ops. Aside from some guidance related to breaks, a reduction in FDP with an increase in sectors is the only mitigation related to Workload, but this only applies to fixed wing operations.

AusALPA’s position is that the current FCM fatigue management regulations require reform to rectify the absence of fatigue risk management of workload in rotary wing operations. These reforms should draw upon examples of how workload related fatigue risks have been managed in other jurisdictions and other parts of the aviation industry.

All rotary wing fatigue management tripartite stakeholders (i.e. regulator, operators and pilots) have a shared responsibility to ensure FCM fatigue management standards include all four ICAO Scientific Principles (Workload is the fourth), and that they do so for all types of flying. The ICAO documents do not state that workload related fatigue is absent for rotary wing operations, they merely point out that it is different and more continuous in many instances. [PDF document – AusALPA fatigue mngt of workload in heli ops]

Unforeseen operational circumstances (UOC) – regulatory update

Since the AFAP made its resolution on the use of UOC and extensions, there has been a significant change approved by CASA to Jetstar’s FRMS.

In summary, CASA has allowed Jetstar to delete the concept and definition of UOC and extensions and allowed a new “discretionary change to FDP limits” after sign on. This change to limits can be for any operational reason.

CASA has acknowledged it was an oversight to allow the UOC definition to be changed in the 2021 Jetstar trial FRMS approval and admitted that there might be some regulatory risk in allowing definitions to be changed and new concepts added. However, they also maintain that they are satisfied that the expanded discretionary limits do not increase fatigue risk based on Jetstar's safety indicators.

The AFAP has expressed strong opposition to this significant as we believe that it undermines flight safety. We have also made an FOI application to find out CASA’s reasons for the approval decision.


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