The reporter has raised the following concerns regarding flight crew fatigue.
The reporter, an experienced flight crew member, states, '[Operator] is facing a flight crew fatigue crisis due to the ineffective regulation and administration of the fatigue risk management system (FRMS) which poses a significant risk to aviation safety'.
The reporter states that under the current FRMS, flight crew rosters are electronically compiled and then put through a biometric program, meaning they are not assessed by human eyes with very few being flagged as fatiguing. There is no ability for flight crew to bid for lifestyle preferences to be built into the roster in order to mitigate fatigue. For example, those that are mostly suited to mornings do not have the ability to bid for morning shifts, or those with young children that may have a preference for particular shifts to mitigate fatigue.
The reporter acknowledges the FRMS requires dual responsibility for flight crew to get sufficient rest prior to duty. The crew rest hotels in both [Location 1] and [Location 2], however, are not suitable due to unacceptable levels of noise resulting in crew operating with insufficient rest prior to sign on. The [Location 2] hotel is directly under the light aircraft flight path and as a result crew are woken early (0400 local time) and then potentially signing off at 2300 local time. [Operator] management has been made aware of these issues, however alternative hotels are not considered based on increased cost. Neither of the hotels are approved by the pilot representatives after having been inspected. Flight crew are regularly signing on for the 'red eye' out of [Location 1] with zero sleep prior and are effectively awake for 20 hours or more on arrival.
The reporter states that under the FRMS, the maximum flight crew duty time is 60 hours over a 7-day period. The reporter is concerned about the safety consequences of flight crew operating repeated long flight duty periods, potentially 5 x 12-hour days (examples provided) with minimal breaks to use the toilet, etc. The reporter further states, long flight duty periods when exposed to noise levels between 90-98 decibels along with very low humidity is highly fatiguing and unsafe.
The reporter advises that the last line of defence under the FRMS is for flight crew to remove themselves from duty when fatigued. Flight crew are reluctant to remove themselves from duty based on fatigue for the following reasons:
1. There is a perceived pressure from management creating a fear-based non-compliance.
2. Financial penalty - the reporter states there is an incentive payment above the base salary which does not apply if flight crew remove themselves from duty based on fatigue.
The reporter further states, 'the end result of our incentive driven salary is that pilots are flying around fatigued or sick because they can’t afford to lose the income. That is ridiculously unsafe but that’s the culture that has been created'.
Lastly, the reporter says that there have been 'numerous safety-related incidents that have fatigue as a mitigating factor and I have personally flown with pilots so exhausted they have made significant dynamic errors in critical phases of flight'.
[Operator] currently operates under a trial Fatigue Risk Management System (FRMS) in compliance with Civil Aviation Order 48.1 (CAO 48.1) Appendix 7. [Operator] FRMS is approved under the CASA trial.
Individual pairings and flight crew rosters are placed through biomathematical modelling (BMM) [program] prior to publishing to flight crew. Additional reviews are conducted prior to this via a pairing review process consisting of members from flight operations and the FRMS team which include pilot representatives. The pairing review process is designed to ensure individual pairings fall within FRMS parameters prior to being placed within flight crew rosters.
Flight crew have the ability to influence their rosters through the preferential bidding system (PBS), which includes lifestyle options. These bidding options provide flight crew with the ability to desire or avoid various pairing attributes such as; international operations, pairing lengths in days, check-in and checkout times (limited to day one of any duty length), leg durations, station turns, legs per duty period, pairing length in days (on days of the week), pairing layover requests, back of the clock pairings, and minimum home base rest requirements. The PBS provides a 'hard' option for crew to select a minimum of 15 hours rest at home base between duties.
These bids work with FRMS provisions, including limitations to consecutive early start protections that limit the number of early start duties in a row and work rules.
Flexible working arrangements are available and in place for team members on request and are reviewed as per the [Operator] flexible work policy.
As part of the hotel contracting process, [Operator] pilot representatives inspect each hotel that is being considered to ensure compliance with the EA and to identify potential issues. [Operator] also has a reporting system for crew to provide feedback on hotel quality or issues that may cause fatigue. These reports are shared with our third party hotel management company, safety systems and flight operations. The company has an open dialogue with all hotels through our third party hotel management company to resolve any complaints relating to reports that are submitted.
[Operator] has received reports in relation to the [Location 1] hotel based on noise and renovations being completed. Once aware, [Operator] worked with the hotel to relocate crew into a different area of the hotel. Discussions between flight operations management and [Location 1] hotel management on [date], and more recently in conjunction with the pilot union representatives on [date], resulted in additional controls being identified to assist in addressing such rest concerns raised within the reports.
There were no reports in relation to the [Location 2] hotels until [date]. Flight operations management has not received any recent reports via our reporting system relating to the [Location 2] hotel, however have recently raised concerns mentioned with the [Location 2] hotel management. All controls will be actioned as soon as practical.
Both [Location 1] and [Location 2] hotels were inspected by our pilot union representatives on [date] and deemed EA compliant. Further to this, the [Location 1] hotel is also utilised by other Australian operators.
[Operator] expectations are that pilots do not sign-on with 'zero sleep' under the dual responsibility requirements of the FRMS, with training and guidance on achieving rest and recognising fatigue provided. Communications were issued to flight crew on [date], via the FRMS bulletin, to provide guidance on managing the results of individual [program] scores conducted at sign-on.
Rosters are built to a maximum of 55 hours in a 7-day period, which may only increase to 60 hours in the event of unforeseen delays to the rostered duty (i.e. flight crew cannot be assigned a duty that would exceed the maximum of 55 hours).
The reporter states that five [Location 3] - [Location 4] return trips could be rostered. The FDP for this duty is in excess of 12 hours and therefore is limited to a sign on after 0800 acclimatised time. Furthermore, the same schedule cannot be operated on consecutive days due to the FDP and rest requirements totalling more than 24 hours. The current [Operator] schedule would only permit a maximum of two [Location 3] - [Location 4] return flights to be operated consecutively. Pilots are permitted to access controlled rest when flight time is over three hours. Flight crew are able to leave the flight deck to use toilets and stretch their legs throughout the flights with the exception of take-off, landing, and the sterile flight deck phases of flight.
All [Operator] aircraft are equipped with headphones [brands] which are fitted with active or passive noise cancelling functions. Flight crew are required to wear these headphones throughout their flight duty with communications between crew made through the intercom function.
Flight crew are provided sustenance throughout their duties (i.e. meals during identified breakfast, lunch and dinner flights, snacks on all flights, flights above three hours have a meal and snacks). Flight crew are also encouraged to review their rosters and to bring or purchase on board their own snacks and/or meals if they feel the sustenance provided is inadequate for their requirements.
[Operator] has not received any reports in relation to flight crew management discouraging the appropriate use of the FRMS provisions. Instead, [Operator] sees a healthy safety and fatigue reporting culture.
Sick and fatigue leave removals are comparable to those from [year], indicating that the perceived financial penalty is not impacting removal rates.
[Operator] provides crew a minimum guarantee of credit earned each roster period. This is not reduced should pilots elect to remove from a duty due to fatigue or sickness. If pilots are provided rosters that result in credits being earned that are in excess of the minimum credit guarantee (overtime), then credit associated with the removed duty is reduced, but not less than the minimum guaranteed credit. The company supports and encourages crew to access the fatigue removal provisions if crew are fatigued. Furthermore, the company provides crew with access to hotels for rest or transport home should they consider themselves fatigued post-duty in their home base.
All fatigue reports received by [Operator] are risk assessed. If a safety investigation following a safety incident states that a crew member has indicated fatigue as a contributing factor, then the roster is reviewed through FRMS processes to analyse actual fatigue scores based on the roster and data provided by flight crew members to determine a fatigue score.
Pairing review and Fatigue Safety Action Group (FSAG) review data as part of the overall FRMS and provide recommendations, and where required directives, to improved fatigue mitigation.
CASA has reviewed the REPCON. As identified in response to REPCON RA2023-00096, the [Operator] FRMS is currently approved on a trial basis as per the requirements of CAO 48.1 Appendix 7. CASA is actively monitoring the development and progress of the operator’s processes, procedures, data gathering and fatigue risk modelling.