[Operator] not accurately recording duty times being conducted by flight crew and altering rostered periods of duty after-the-fact.
The reporter’s primary concern was that [Operator] are not accurately recording duty times being conducted by flight crew and also altering rostered periods of duty after-the-fact, enabling staff to be available for further duty in the future. In addition, a Standards Directive was issued removing the ability for flight crew to enter or edit their own flight and duty times in company approved software. At the time of reporting, duty times had not been entered for up to three weeks at a time.
The reporter stated there was a lack of clarity regarding which set of rules were being followed, after a recent decision to transition to CAO 48.1 Appendix 4, particularly with [Operator’s] differentiation of flight duty periods and duty periods. The reporter states that no internal training or communication was provided with the differences between the two most recent rule sets causing confusion among line pilots.
[Operator] Flight Operations Management did not believe the current work practices were in breach of their Fatigue Management System and CAO 48.1. Flight Operations Management acknowledge that significant changes have occurred including the introduction of a Fatigue Management System. On review of the information contained in the REPCON report, it has become evident that the change management process for the introduction of the FMS and subsequent training programs, despite being in-line with CASA syllabus, was inadequate and will require a review.
New protocols were established to ensure standardisation across the operation and to ensure flight and duty times are rostered and managed in accordance with the FMS.
[Operator] conducted a formal review of the FMS to:
1. Review and update the FMS in accordance with CAO 48.1 ‘in plain English’
2. Review policy statement, hazard identification, controls, communication protocols
3. Review, update and deliver training programs
Reporter's comments to responses:
Acknowledging the plan to “Provide training for FCMs”, the reporter notes that [Operator] failed to address the following concerns in their response:
• Duty hours not being entered in accordance with Standards Directive [Number]
• Insufficient pre/post flight rostering principles
• Altering of duty hours after the fact
• Removal of the ability of flight crew members to record actual duty hours conducted on any departmental documents/programs
CASA will be conducting a level 1 Audit of [Operator] as part of the normal surveillance program. They will assess the flight and duty records and process at the same time for this REPCON.