The reporter has raised a concern regarding administration staff managing controller shift staff shortages.
The reporter states that approximately 12 months ago, a change was made to allow administration staff to have responsibility for managing shift replacements due to illness and other absences.
The reporter states that this is not in compliance with the fatigue risk management system (FRMS) procedure that documents, 'selection of an eligible worker must be made by the manager or supervisor'.
The reporter further states that previously all roster changes were made by experienced shift supervisors who were better suited to account for factors such as fatigue levels.
Airservices appreciates the opportunity to respond to the concerns raised in the REPCON. We understand the concern is regarding administrative staff having responsibility for controller shift replacements and not shift supervisors, and consequently impacts on the management of fatigue risk.
The fatigue risk management procedure describes the tactical roster management process including application of the Fatigue Assessment and Control Tool (FACT) which is used for tactical management of fatigue risk. FACT is embedded within the rostering system and provides a means of assessing fatigue-related risk, applying appropriate controls and recording information about changes to the published work schedule. This is a two stage process; stage one aims to identify the most suitable individual for allocation to a required shift and stage two aims to ensure that any fatigue related risk has been identified, assessed, controlled, signed off by the appropriate level of management and the process documented.
In stage one, eligible controllers for the shift will be ranked automatically by the FACT tool and the controller with the lowest likelihood of fatigue will be presented first. Subsequent eligible candidates will be ranked according to a variety of fatigue factors as well as the total number of additional duty hours worked in the past 365 days. This selection process is based on predicted fatigue risk and must be followed when identifying potential controllers and offering shifts. Stage one can be conducted by operational administrative staff as directly stated in the procedure.
Stage two, which includes the application of controls and sign-off by an accountable supervisor/manager, where required, must be conducted by a manager or supervisor. This stage relies for the most part on the professional judgement and experience of the manager or supervisor.
Review of the REPCON has identified an inconsistency in the fatigue risk management procedure in terms of who is able to perform stage one of the tactical process. We will resolve this inconsistency in the next revision of the procedure, clarifying that stage one can be conducted by administrative staff or the supervisor/manager. The accountability for conducting each stage of the FACT process is based on the level of decision making and competencies required for each.
In response to this REPCON, CASA agrees with the Airservices summary and corrective action. Recent CASA surveillance highlighted that administrative staff, where available, are completing the first stage of staff call-out based on coverage requirements and fatigue with shift manager oversight of the selection.