The concern related to the fatigue management of cabin crew members.
The reporter expressed a safety concern regarding the operator’s fatigue management policy in regards to cabin crew member rostering.
The reporter advised that despite many reports of fatigue related issues, from multiple sources, when operating successive flights with back of the clock duties, consecutive back of the clock duties continue to be allocated at short notice. Management do not seem to be taking the matter seriously. Cabin crew members have reported that they have been asked to use sick leave when they do not feel that they are fit for work due to fatigue issues.
The reporter also advised that although the operator offers transport home or a hotel room to cabin crew members if they advise that they are too fatigued to drive home, cabin crew are reluctant to use the system due to the hassles and lengthy waits involved and will often sleep in their cars after signoff.
The airline takes fatigue management seriously and has controls in place to manage fatigue for cabin crew including duty hour limitations, minimum rest requirements, fatigue report monitoring and measures which our crew can use during and after work duties to manage fatigue risks, particularly in relation to “Back of clock” flying. Crew can request transport and hotel accommodation options, and should do so as soon as is feasible if fatigued, to avoid wait times that can be experienced when these services are arranged at short notice.
There are currently no prescriptive flight and duty limits for cabin crew members (CCMs). However that is being addressed and CASA expects a Notice of Proposed Rule Making for fatigue management for CCMs, prepared in collaboration with the joint-CASA/industry working group, to be released in the first half of 2014.
This REPCON lacks sufficient detail to comment on the degree of fatigue risk present and to what degree it would be addressed under the proposed CCM fatigue management rules. The operator’s Safety Management System (SMS) is required to have an effective reporting system that enables employees to draw attention to perceived or apparent hazards and to address identified hazards in a manner that reduces the risk to as low as reasonably practicable.
While the new prescriptive flight and duty rules for cabin crew are expected to be in force next year, it will still be up to the individual to determine fitness for duty and to make a report via the SMS where this is indicated under company procedures. CASA encourages airline employees to report potential safety concerns to the SMS, including fatigue events, in order to identify areas where the company should focus resources to reduce operational risk, including fatigue risk. The matter of the utilisation of sick leave and notice given for roster changes fall within the industrial agreement area and are not primarily related to CASA’s role as aviation safety regulator.
In response to the REPCON Brief, the reporter made the following comments which were forwarded to both the operator and CASA:
Thank you for the email. I noted in the response that the operator stated 'Crew can request transport and hotel accommodation options, and should do so as soon as is feasible if fatigued, to avoid wait times that can be experienced when these services are arranged at short notice'.
As far as I am aware we are no longer able to request transport or hotel accommodation until the completion of our duty at signoff. This was reiterated to me by one of my managers a couple of weeks ago. We used to be able to request these options in the air via ACARs - however this changed some time ago. So I am confused as to why this has been has been stated and whether there has been miscommunication along the lines.
This may be more of a union matter, however I thought it may be worth mentioning. I was questioned by my manager and bullied as to why I requested transport and told that I shouldn't have been so fatigued as it 'is not a fatiguing duty and nowhere near as long as a Los Angeles flight'. She also stated that she has never 'heard of crew requesting transport with this operator’ this is definitely not the case. Though I know that crew are now hesitant to request these days due to interrogation by management. I was made to feel as though I am incompetent at my job, and silly for thinking I was possibly fatigued.
There are several crew members in the Melbourne base that have recently had accidents during the drive home after these duties. Management were not at all concerned and did not want to know about it. Simply responding with 'hopefully this experience helps you better gauge your fatigue in the future'.
Could you please confirm with the company as to whether we are now able to request transport options prior to signoff via ACARs as this is not the most recent process that I or management are aware of - and currently can only call at signoff consequently being advised of extensive delays.
The operator did not respond to these further questions despite numerous requests.
CASA response:
Without further information CASA is unable to identify a non-compliance issue. However, the information will be reconciled for a forthcoming audit scope of the airline.