The concern related to a rostered standby duty that could result in cabin crew being fatigued if they were called upon to work.
The reporter expressed a safety concern related to the rostered standby duty.
The reporter advised that on a number of occasions they have been rostered on a standby duty, with an early start, only to be called towards the end of the duty to do a back-of-clock (BOC) duty. This has meant that they have prepared themselves with appropriate rest, for duty – completed most of that time to then be called for a BOC duty with no time to take a sleep to ensure they can conduct the possibly 11-hour duty. This has been compounded as the [operator] and the Flight Attendants Association of Australia have reduced the required rest period during BOC duties on flights from the east coast of Australia.
This situation occurs regularly at the [Location 1] base and as such [operator] crewing should consider a standby duty which is specific to the BOC duties. This will allow the cabin crew to rest appropriately to cover this shift if required.
[Operator] takes the fatigue and safety of its cabin crew very seriously.
[Operator] currently operates a dual [Location 2] base (encompassing the airports of [Location 1] and [Location 2]). All cabin crew are informed at the time of joining the company, they may be required to fly from both [Location 1] and [Location 2] airports. We do however allow cabin crew to have a preference for their roster to be built predominantly from one airport or the other. Currently more cabin crew have a preference for [Location 1], than is required to fulfil the flying from this airport. This means that part of their roster will encompass flying from [Location 2].
Our Enterprise Agreement contains clauses which include specified home standby duty which encompass specified time spans. These standby clauses enable the company to call out a cabin crew member for a duty, with appropriate advance notice. [Operator] does in fact have a special rostered available span for BOC, which encompasses the hours 1400 and 2359. Where a cabin crew is required to be called off standby to operate a duty (including a BOC duty), the cabin crew’s airport preference is taken into account.
In addition, where passenger loads allow, up to a maximum of three seats in the last row are reserved as an area for crew rest.
Contained within [Operator] Airways Policy Manual is the overarching Fatigue Risk Management Policy ([Manual] – Section 3.3) that is applicable to the operations of the airline.
Specifically, the policy states that ‘workers are required to inform [operator] immediately prior to or during work if they know or suspect that they or another crew member are suffering from levels of fatigue which will prevent duties from being safely conducted.’
Further detail is contained within the cabin crew policy and procedure manual (Operations Manual – OM12, Section 3.3.13). This section contains specific references to the company’s intranet where there is a detailed guide in how to identify, avoid and manage fatigue. All cabin crew must comply with OM12 and have full accessibility to the intranet.
CASA has reviewed the REPCON and notes that there are currently no Australian civil aviation regulations governing duty times and rest requirements for cabin crew. [The operator’s] cabin crew duty limitations are set contractually. Nevertheless, CASA’s role is to assess the airline’s system, including documented policies and procedures, designed to manage cabin crew fatigue. Part of that role includes ascertaining that the safety concerns raised have been appropriately assessed and managed by [Operator]. The information provided to CASA will be examined in a forthcoming audit scheduled for April 2017.
CASA also notes the following aspects of the report:
- The report is not a report of fatigue, but of potential for fatigue. The reporter was too vague (“a number of occasions”) to get a sense of what the frequency of the back-of-clock (BOC) requirements are such that they are not standby but standard practice
- There was also no specific hours or total service (‘possibly 11-hour duty’) or if the time reported was consistent. While the occurrences appear to be associated with a particular airport (‘regularly at the [Location 1] base’) this could be a practice that is widespread or as the [operator] response appears to indicate is local due to the preference of crew for [Location 1]
- The reporter’s comment that ‘stand-by duty which is specific to BOC duties’ so cabin crew can rest appropriately seems a bit odd – if they are aware that there is a high likelihood of a BOC, why wouldn’t they prepare?
- Staff appear to be aware of fatigue. However, there is no indication that they are engaging any systematic countermeasures or if the countermeasures recommended by [operator] are possible as a potential mitigation strategy if rest is dictated by the passenger loads such that the 3 seats for rest may not always be available; and
- There are no indications in the report of performance decrement, no indications of countermeasures being engaged, and no indications of interventions being attempted by crew who may have experienced the fatigue (putting their hand up and asking for a break) or crew who may have observed the fatigued individuals. The report infers that a ‘norm’ of BOC is emerging at [Location 1], but one instance is not a trend.
With reference to the [operator] Operations Manual, please note the following CASA comments:
3.3.13 Fatigue Management – Fatigue is a physiological state of reduced mental or physical capability. It results from sleep loss or extended wakefulness and/or physical activity. It can impair a crew member’s alertness and ability to perform safety related duties.
CASA comments:
- Fatigue is a psychological condition that can result from illness and psychological distress
- The statement regarding impacting alertness appears to recognise the need for passenger management which relies on scanning and monitoring. Accordingly, reduced situational awareness, communication, and teamwork due to cognitive deterioration associated with fatigue is important to avoid and/or manage.
3.3.13.1 What to do if you are Fatigued prior to your duty – After consultation with your line manager, it may be required that you are cleared by a doctor prior to your next duty.
CASA comment:
- The potential requirement of a medical certificate may result in under-reporting. It is a positive to want to monitor and evaluate fatigue in the workplace, but requiring a medical certificate to validate fatigue is a consequence that may be interpreted as punitive and may inadvertently undermine the intent.
3.3.13.2 What to do if you are feeling Fatigued during your duty – If offload is required and you are not at your home base, you must contact crewing and follow the standard offload process. You must also contact your MCB. You must see a doctor to be cleared before operating your next duty. You must complete an [report].
CASA comment:
- Similar to the possible punitive perception noted above, requiring a medical clearance if offloaded due to fatigue may result in under-reporting. It is a positive to attempt countermeasures in conjunction with the CM prior to an offload. Nonetheless, any consequence that may be interpreted as punitive is likely to negatively impact reporting.