The concern related to the operator’s reporting requirements and follow-up process for cabin crew members reporting fatigue.
The reporter has expressed a safety concern regarding [Operator] discouraging cabin crew reporting fatigue.
The reporter advises that the process for cabin crew to report fatigue is different to the requirements of flight crew. Cabin crew are required to complete a detailed fatigue questionnaire following reporting fatigue, that flight crew who report fatigue are not required to do.
The reporter states that the perception of providing answers to the comprehensive checklist is to enable [Operator] to attempt to attribute fatigue to factors outside of the control of the airline. The reporter states that if the questionnaire was best practice for assessing, monitoring and analysing fatigue, flight crew should also be completing the questionnaire. The reporter has questioned what [Operator’s] process is for analysing cabin crew fatigue reports and if it differs to the process for analsying flight crew fatigue reports.
The reporter further states that when cabin crew report fatigue, they receive a welfare call from a cabin base manager. The reporter states that the tone of these phone calls, and the subsequent meeting to complete the fatigue questionnaire, are perceived to be disciplinary and intimidating rather than a concern for the member’s welfare.
The reporter further advises that on occasion, transport home arranged by [Operator] following cabin crew reporting fatigue is delayed or does not arrive at all. Not only does this increase the symptoms of fatigue, itis perceived as another tactic to discourage fatigue reporting.
The reporter stated that 12-hour shifts are regularly extended out to 15-hour shifts due to flight delays, and cabin crew are returning to their home at 2330 at night experiencing headaches, dizziness and dehydration, and needing to awake at 0530 to complete the same schedule.
The management of risk associated with fatigue hazards is paramount in our overall commitment to the [Operator’s} Safety Management System (SMS). Accordingly, [Operator] welcomes the opportunity to comment on REPCON AR201900030.
The [Operator’s] Fatigue Risk Management (FRM) processes are one element of the broader SMS, designed to pro-actively identify, analyse, and control risks associated with fatigue, in ensuring that the highest standards of safety are maintained.
[Operator] welcomes the REPCON (Aviation Safety Confidential Reporting Scheme) report, dated 23rd May 2019, by viewing it as another tool that provides the organisation an opportunity to continually review and improve our safety systems, in conjunction with information obtained via our Occurrence Reporting system [report name] operational knowledge and bio-mathematical modelling used for the assessment of fatigue of flight and cabin crew.
The safety objectives of [Operator’s] FRM involves systematic processes to identify and examine fatigue hazards and it effects. These safety objectives are:
- Using fatigue data collection, reporting and analysis to anticipate and mitigate fatigue hazards;
- To implement fatigue management communications and education programs such that a culture of fatigue self-reporting is encouraged; and
- To reduce fatigue-related risks in operations.
To support the [Operator’s] SMS, a Fatigue Management Working Group - Cabin Crew, has been established with responsibility for the oversight of the FRM processes. This working group, continually monitors front-line activities to identify and address fatigue trends and systemic risks, as they relate to cabin crew with an escalation pathway to [Operator’s] Airline Safety Committee (ASC) as required, which is chaired by the airline’s accountable manager.
In addressing the specific concerns raised by the reporter, a review of Cabin Crew fatigue reporting rates was conducted, which indicated a healthy reporting culture within cabin and flight crew across the business. Analysis was also undertaken in relation to the number of duty extensions to 15 hours due to flight delays. For the past five months; less than 1% of duties (due to operational reasons) were extended beyond 12 hours, with extensions beyond 14 hours considered rare. Monthly analysis of Cabin Crew related [reports] enables continuous monitoring of fatigue reporting trends.
Furthermore, as part of [Operator’s] risk management framework, each operational business unit has its own documented risk register, which identifies key risks facing the operation, controls that are in place to mitigate any risks and action plans to further improve safety and risk controls. With respect to fatigue, [Operator’s] cabin crew department has, over a number of years, worked to address all identified medium risks with a large variety of controls implemented. At present there are no residual medium risks on the Cabin Crew Fatigue risk register.
In relation to concerns raised regarding the requirements of fatigue reporting, we note; that if a Cabin Crew member has undertaken a fatigue-mitigating action, directly affecting the operation or conduct of duty, the submission of a fatigue [report] is a mandatory company requirement. This includes any removal from planned duty, or accessing a hotel or transport home post-duty. This company policy is applicable to both Flight and Cabin Crew members. In accordance with company policy (Crew management), in any instance where a Flight or Cabin Crew member has removed themselves from a planned duty as a result of fatigue impairment, crew management may contact the crew member to gather further information.
Contact with the crew member is undertaken in accordance with the [Operator] Just Culture policy. In order to assist with these discussions, crew managers may at their discretion, use the Fatigue Discussion Checklist. The Fatigue Discussion Checklist is designed to assist managers and crew with a comprehensive set of topics to explore in a discussion following a fatigue-related removal from duty. The discussion supports line managers and crew to identify potential factors contributing to fatigue and how it was or could be managed in the future. This supports ongoing fatigue management development, by identifying improvements that can be made by the business and by the individual recognising that fatigue management is a dual responsibility.
The follow-up with a crew member is not to apportion blame to a fatigue event, and where fatigue is identified as not ‘company related’, the crew manager will acknowledge that the crew member has acted in the correct fashion by removing themselves from duty. Notwithstanding the above, direct line managers have been given guidance from the People Team and the Customer Experience Leadership Team on how to conduct these welfare calls.
Crew transportation concerns were also noted in the REPCON. The current [Operator] policy is that all crew members who do not believe they can transport themselves home post a duty, will be offered either transport home as soon as possible (and returning to the airport to retrieve their vehicle) or will be provided a hotel room in close proximity to the applicable arrival airport, thereby enabling adequate rest. [Operator] acknowledges that on occasions due to transportation logistics, time taken for transportation arrival can be longer than expected. In these instances, crew members are able to make their own way home via taxi or rideshare and claim the expense back.
The reporter noted that Cabin Crew are returning to their home base at 2330 at night experiencing headaches, dizziness and dehydration, and need to awake at 0530 to complete the same schedule. Without further specific information on the above, [Operator] is unable to comment specifically on this matter.
Broadly speaking, [Operator] is industrially required to give a minimum rest requirement of 10 hours at home base. If the Cabin Crew member in this instance did sign off at 2330 on Day one at home base, they would have a full 30 hours between duties, as they would not sign back on until 0530 Day three. Notwithstanding the above, in accordance with company policy if a Cabin Crew member feels that they are unable to undertake their duty due to fatigue, they must advise accordingly that they are unfit for duty and is a process that is fully supported by the airline.
We would like to state our gratitude to the ATSB for allowing the opportunity to comment on this REPCON and to reiterate our commitment to a robust Fatigue Risk Management process.
The Operator subsequently advised that they have arranged to discuss and reiterate the need for Cabin Crew Managers (CCM) to adequately manage and display the required level of empathy when dealing with fatigue related matters, at the next monthly Cabin Safety Working Group.
CASA is currently completing a surveillance event that involves reviewing data from the Operator and conducting of interviews of personnel in rostering and cabin crew. CASA will take [Operator’s] comments into account when reviewing the surveillance findings.