The reporter has raised a safety concern with the procedures being employed by [Operator] to record and monitor flight and duty times.
The reporter's primary concern is that [Operator] is encouraging staff to falsify duty times to comply with fatigue management regulations. Pilot rosters are generated using a program that ensures compliance with the company’s fatigue management policy (CAO 48.1 – Appendix 4). During induction training, pilots are instructed to record their flight and duty times in the company’s operational management program as it appears on the roster and not record the hours that the pilot is actually at work. There is a reported expectation that pilots will be present from the first flight to the last flight regardless of flying duties. This is described as a ‘one in, all in’ mentality that is pushed upon the staff with pilots rostered for early morning flights being required to stay back to assist with additional duties until the last aircraft has returned at the end of the day. This practice results in staff members working duty periods that exceed the prescribed limits in the relevant appendix of CAO 48.1.
Additionally, pilots conducting in command under supervision (ICUS) training are told that they are not eligible for rostered days off until they are operationally checked to line, often working 7 days a week until training is complete. During this time, the reporter advises that pilots are required to work up to 14 hours a day. To avoid ‘red-flagging’ the operational management program, pilots are advised to mark certain days as days off but to still enter the flight and duty details. The program will not count this duty towards the cumulative total, nor will it flag a breach of the relevant fatigue rules. The reporter queries whether the appropriate settings have been selected in the company-approved software to allow these sorts of breaches to go undetected.
The reporter is concerned that these practices increase the potential for a fatigue-related incident. These matters have been raised internally, and to date, there has been no action by [Operator].
[Operator] strongly refutes the claim that staff are encouraged to falsify duty times to comply with fatigue management regulations.
Company Rosters
[Operator] rosters every flight crew member (FCM) in accordance with the 2020 Pilot Award and CAO 48.1.
[Operator] uses the following applications to compile flight crew rosters:
Air Maestro - used to roster a set 14-day periods, indicating days on/off.
Flight Schedule Pro - details each daily programme for the company.
Rosters are promulgated to cover a 14-day period and are released to the company no later than seven days prior to that roster taking affect. The published fortnightly roster does not publish duty sign on/off times, instead indicating rostered days on or off. The rosters are stored live on Air Maestro, and via a summary released to the WhatsApp messaging group once published.
Daily taskings are published the day prior to the company WhatsApp messaging group. Pilots also have accounts with our scheduling application, Flight Schedule Pro, so they can have real time access to the daily programme on their devices. Two-week rosters do not display FDP sign on or off times, nor do we find it necessary or reasonable to do so. Due to the nature of our operation, which includes predominately bookings being made in the days prior to the flight, it is impractical to schedule sign on times in advance. Our operations team (who are pilots themselves) compile the daily programme with flight and duty limits being adhered to, and in accordance company manuals. Pilots are required to raise any concerns they might have with what they've been allocated, to the Senior Base Pilot or Chief Pilot.
Pilots conducting in command under supervision (ICUS) training
Upon joining the company, new pilots complete an induction process which typically spans 2-3 days. As part of the induction process, flight crew are briefed on, and are signed off on having being introduced to various manuals. These manuals include the [Operator] Operations Manual, Safety Management System (SMS), CAO 48.1, the Base Procedures Manual and others.
A large component of the induction process explores the following regarding fatigue:
- Understanding fatigue
- Causes and contributors
- Signs and symptoms
- Methods to reduce or manage fatigue
It is also mentioned that fatigue can occur well and truly before any limits prescribed in CAO 48.1 are met, and that pilots are strongly encouraged to discuss concerns regarding fatigue they may have within the appropriate channels.
Following completion of the induction process, new pilots commence line training. From their first day of employment, every pilot is allocated days off in the rosters described above. This is regardless as to whether they are undergoing ICUS training or not. However, what we do mention and encourage to new pilots, is to be flexible with days on/off during their ICUS training if they can. There may not always be training opportunities, so it is beneficial to capitalise on them when they exist. If a new pilot's days off get altered, it is done in accordance with the 2020 Pilot Award. Further, subsequent days off are allocated in a manner as to not breach any limitations set out in CAO 48.1. Every pilot receives their required number of days off.
Once the roster is published, rostered days off are only changed with:
- Approval from both parties
- A subsequent day off being rostered, without breaching CAO 48.1 or company manuals limitations
- A rostered day off allowance claim
Recording of flight and duty
[Operator] uses Air Maestro to record and monitor flight crew flight and duty times. An internal review of flight and duty records cannot locate any particular day where flight and duty details were recorded yet marked as a day off. Air Maestro provides flight crew the ability to see the cumulative totals of their flight and duty, and to easily spot any potential problems in the future based on what has been rostered.
In accordance with the group Fatigue Management Manual, pilots have the responsibility to accurately record actual flight and duty times within 24 hours of the flight duty period and notify the Chief Pilot as soon as flight and duty limits might be exceeded.
Breaches of duty
The operator provided the ATSB with a discretion report lodged by an employee who has recently left the company. The daily flying programme that was published for the day prior was also provided.
In this occurrence, Air Maestro flagged a breach with CAO 48.1 and the system mandated that a discretion report to be filed. This report was filed on [date].
Investigation in these three reports found that:
- The pilot had failed to update their flight & duty timesheets across the 3 days in accordance with the defined time period.
- The pilot had failed to raise any concerns over approaching CAO 48.1 cumulative limits with the relevant parties.
- The pilot reported their sign on at 0600, however first tasking scheduled at 0830.
This pilot was without a personal vehicle at the time and was carpooling with colleagues to and from work. As a result, they were arriving at work at 0600 to then relax in the crew room, only commencing work before their first tasking later in the day. The pilot logged their duty period as having commenced at 0600 during these instances. It is not the company's obligation to supply a FCM with a means to their work location, nor is it considered duty if the FCM does not perform any task associated with their employment. However, the pilot did not inform the Chief Pilot of their situation, and if a concern was mentioned, alternative solutions could have been explored.
CASA has a Level 2 unscheduled surveillance event already approved for [Operator]. This surveillance was raised in response to similar complaints CASA received.