The concern related to the delay in implementing a FRMS.
The reporter expressed a safety concern related to the time it is taking the [location 1] Port Authority to implement a Fatigue Risk Management system for pilots operating at the port of [location 2].
The reporter advised that the current fatigue management system was designed using the InterDynamics FAID Fatigue Assessment Tool and accepted a FAID fatigue score of 80 as being safe. This score is the equivalent of a blood alcohol (BAC) reading of 0.05 [grams/100 millilitres] but the Port Authority of [location 1] Drug and Alcohol policy now has an allowable limit of only 0.02 BAC.
Early in 2015, the pilots and the Port Authority met and agreed that a new policy was required. The new fatigue management policy is now available and over October and November of 2015 all Port Authority employees received training in how to apply it. To this date, the new policy has not been implemented.
Reporter comment: We do not believe the current roster rules are sufficient to meet the requirements of the Pilotage Code nor are the new proposed roster rules unless they are integrated into a proper fatigue management system.
Safety is of critical importance to the Port Authority of [location 1].
The Port Authority and its employee pilots have committed to a process to implement a new fatigue management plan as soon as possible. The discussions in this regard commenced in late 2015 and some progress was made including consultation, engagement of specialist consultants, pilot survey, pilot training in the area of fatigue management and the development of a draft policy. However, as a result of change in personnel, this process stalled for a number of months. Recently, the process has been re-invigorated by both the Port Authority and the pilot group. Pilot representatives have been nominated by the pilot group and those representatives and the Port Authority met last Thursday as part of this process and future meetings planned. In this process, we will consult and carefully consider views of our pilot group. It is important to note that the current roster and rules were agreed to by the pilot group and the Port Authority.
Further, the Port Authority is subject to annual audits, which specifically cover the safety of port operations and we operate systems that encourage and provide for the reporting of operational and personal incidents and accidents. We believe that the process we are currently engaged in will provide an appropriate review of the current system and address the apparent concerns forwarded by you.
Transport for NSW (TfNSW) monitors safety audits of the Port Safety Operating Licence (PSOL) issued to the Port Authority of [location 1], which has, as one of its port safety functions, the operation of a safe pilotage service. TfNSW also issues the NSW Marine Pilotage Code.
In a recent PSOL audit at [location 2], no safety breaches of the PSOL were observed by the independent auditor. A fit-for-purpose fatigue management system for pilots is in place which complies with the NSW Marine Pilotage Code part 4B. As the Regulator, TfNSW has not issued any further guidelines to the Port Authority with respect to policy and safety matters concerning their fatigue management systems for pilots.
TfNSW does not consider this to be a valid safety concern for the Regulator and would expect the roster issue to be managed by the Port Authority as part of its normal business.