Multiple reporters have approached the ATSB with a safety concern regarding inadequate cabin crew rest time when operating the [Location 2] - [Location 1] - [Location 2] ([Flight A] and [Flight B]) sectors. [Operator] operates flight [Flight A], [Location 2] to [Location 1], which is a night flight typically taking 14 hours to complete. The cabin crew have a 28-30 hour rest period in [Location 1] taking into account hotel transfers, check-in and meals before operating [Flight B] [Location 1] to [Location 2], again a night flight typically taking up to 15 hours to complete.
One reporter advises, 'The company states that to ensure we don’t acclimatise to the time in [Location 1] we only need maximum 28 hours rest at this destination'. Other reporters have advised that all other airlines operating to [Location 1] from [Location 2] will rest their crew for two nights in [Location 1]. The reporters state they do not feel adequately rested nor able to concentrate or stay alert after a single night for the return sector to [Location 2].
More than one reporter advises that [Operator] has amended the service on the [Location 1] to [Location 2] sector to include a full bar in all cabins. This has increased service length and workload with a subsequent reduction in rest time. The sector is night-time duty and cabin crew are having as little as 2 hours 15 minutes flat bed rest.
Multiple reporters state they have dozed off while seated in their jump seat and/or fallen asleep on the crew bus after landing.
A reporter states, 'I am now extremely worried given the Japan accident today and it just re-enforces that we are safety professionals first and foremost and this crew did a wonderful job getting everyone off. I’m concerned if this awful thing was to happen to us on the [Flight B and Flight A] flights from [Country 1], we wouldn’t be so lucky given the short rest and amount of work we are having to comply with'.
Multiple reporters state they are basically threatened with their jobs if they report the fatigue from these one-night trips to [Location 1]. They are often totally exhausted on the way back to [Location 2] but are heavily discouraged from reporting tiredness or fatigue to the company. Reason being, if they have two nights in [Location 1] the reporters state that they become too expensive, and [Operator] will close the [Location 2] base.
Multiple reporters state they also operate a [Location 3] flight which is only a few hours further with more rest during flight. There is an extra day of rest in [Location 3] and crew are also offered a hotel on return back to base, or a taxi to home within 30 miles of [Location 2]. None of this is offered for a [Location 1] flight with many crew expressing concerns for their long drives home.
A reporter advises that there is nothing in place to assist cabin crew arriving fatigued off the [Location 1] flight. The reporter provided an example of one morning having completed a duty in excess of 16 hours where a hotel was only available on request, however crew feel awkward to ask as it is not a standard practise. The crew are required to report fatigued before a hotel can be requested unless the duty is in excess of 18 hours. This process, especially if a room is not immediately available, further adds to the fatigue. Colleagues in [Country 2] on a shorter sector are offered taxis to and from the airport due to fatigue concerns. This reporter states that a lot of cabin crew actually feel more fatigued from a [Location 1] flight on arrival to [Location 2] than the [Location 3] flight, due to the [Location 3] flight having two rest breaks in place. Crew then drive home, fatigued. If a hotel was standard practise and it was not a special request only, this would be really beneficial from a safety perspective. It is a day rest hotel room and allows crew to get four hours sleep before driving.
Collectively the reporters are concerned that the single night slip in [Location 1], combined with the additional drinks service is resulting in increased levels of fatigue, exhaustion, illness and crews not feeling alert during safety critical stages of flight. Multiple experienced reporters have stated the inadequate rest is now becoming dangerous with levels of fatigue this high not experienced in the past. Despite multiple reporters advising they are discouraged from reporting fatigue, other reporters advise fatigue reports have been submitted through the company reporting system, yet it appears nothing is being done to address these concerns.
At [Operator], we have a strong culture of safety that has been built over the last [time frame]. As a business, [Operator] is conservative and prioritises the safety of our aircraft, crew, customers and cargo over commercial and other external pressures. Aviation is a complex industry and [Operator], like other international airlines, is a high reliability organisation that uses a comprehensive Safety Management System to manage hazards and risks. Fatigue is one of the many hazards present in aviation.
Risks are managed by identifying, analysing and introducing controls to mitigate the risk to as low as reasonably practicable. Given the highly regulated nature of the industry, many risks are addressed by legislation and guidance material produced by the Civil Aviation Safety Authority. Fatigue is one of the few areas where there is no prescriptive legislation that deals with the fatigue hazard in cabin crew. Despite this, [Operator] has invested in and is developing a robust Fatigue Risk Management Program for cabin crew which uses predictive, proactive and reactive risk identification.
We have noted an increase in fatigue hazard reporting from the [Operator] cabin crew [Country 1] workforce since the change in meal service policy that occurred on [date]. Previously the crew would deliver a supper service to customers when departing [Location 2] which has been replaced by a more substantial meal and drink service which takes longer to deliver. As a result, there is a small reduction in available rest time onboard the [Flight A] for crew, most notably for crew providing the business class service. Whilst the increase in reporting has been referenced by the reporter(s) as conclusive of an increase to the risk level, I note that we have not seen an increase to the rate of consequences as a result of fatigue on the flight or pattern pairing (injury/illness, SOP non-conformance or negative customer interactions). Fatigue hazard reports (last 24 months)-[Country 1] base provided to the ATSB.
Crew receive training in the submission of safety reports and [Operator] 'Just Culture' on commencement with the company and on a recurrent basis. Cabin crew are excellent at reporting hazards and risks in the operation with a monthly average of [number] reports received across cabin crew. The incidents and hazard trends allow the business to target areas of concern and to monitor the effectiveness of controls over time.
A number of fatigue risk controls exist for the cabin crew including pattern planning, onboard rest, and home transportation or hotel rest on arrival (in home port if the crew believe that their fatigue levels may affect their ability to drive or travel home following duty).
In lieu of a prescriptive ruleset, [Operator] uses data and experience for predictive fatigue modelling, a program called [fatigue monitoring program], that factors in duration of wakefulness, window of circadian low (adjusted for time zone shift), rest periods and workload to understand potential levels of fatigue in crew when building rosters and once the roster has been completed, for operational delays and changes. We believe that it is the [fatigue monitoring program] fatigue modelling that the reporter(s) may be referring to in the report when they reference the slip times in [Location 1].
Many operators in [Continent] use a prescriptive flight and duty time limit to determine rest and rostering of flights. CASA has no prescriptive rules for cabin crew so [Operator] has applied the same provisions as the [Flight crew fatigue system] (which has been approved by CASA) to cabin crew across our network. This evidence-based approach to fatigue risk management can result in slip times that are longer in some ports and shorter in others when compared to planned slip times based on prescriptive rules. The system also takes into consideration rest before and during the duty to give an average level of effectiveness at different times throughout the flight. We acknowledge that the modelling cannot account for all crew variations and have added additional fatigue risk controls where crew have been unable to rest or feel excessively fatigued.
After considering the points raised by the reporter(s), [Operator] has committed to accelerating the current review of the business class meal service. This review will take into account the timing of the meal service acknowledging the feedback that the service is too long. The new service will be shorter in duration and will allow additional sleep opportunity and decrease workload for crew.
Additionally, the managers of the [Operator] cabin crew [Country 1] workforce will communicate the provisions of the Fatigue Risk Management Program with their crew. This will include a reminder of the controls available for the crew if they feel the effects of fatigue before, during and after flight. The nonpunitive nature of our Safety Management System and the importance of reporting will also be reiterated in the communications. As part of the Fatigue Risk Management Program, every month [Operator] meets with the [Country 1] [panel] which consists of cabin crew members, safety, health and safety representatives, roster allocation staff and union members to discuss observations and trends on fatigue risks from fatigue reports and enhance or develop mitigations if required.
Finally, the business is considering the introduction of a trial of home transport provisions for locally based crew returning on the [Flight B], similar to the provisions available on the [Flight C].
Once again, we thank you for the opportunity to respond to the REPCON report and we will continue to monitor trends in reporting where they present.
Existing legislation requires cabin crew to be fit for the requisite duties to which they are assigned – refer extract: Civil Aviation Safety Regulation (CASR) 91.520 Crew members to be fit for duty.
CASR 91.520(4)(a)(b)(c)
(4) The operator of an aircraft for a flight contravenes this sub regulation if:
a. the operator believes on reasonable grounds that a crew member is unfit to perform a duty on the flight; and
b. the duty relates to the safety of the aircraft or of the persons on the aircraft or cargo on the aircraft; and
c. the operator assigns the crew member to duty for the flight.
CASR 91.520(8)(a)
(8) Without limiting sub regulation (1) or (4), a crew member is taken to be, or is taken to be likely to be, unfit to perform a duty if:
(a) the crew member is fatigued to the extent that the crew member’s ability to safely perform the duty is reduced or likely to be reduced.
Requirements relating to an Australian air transport operator’s documentation, or exposition, are found in: Civil Aviation Safety Regulation (CASR) 119.205 Content of exposition.
CASR 119.205(h)
(h) details of each plan, process, procedure, program, and system implemented by the operator to safely conduct and manage their Australian air transport operations in compliance with the civil aviation legislation.
Legislative provisions require an Australian air transport operator to have a safety management system, appropriate for its size, nature, and complexity of the operator’s Australian transport operations – refer extract: Civil Aviation
Safety Regulation (CASR) 119.190 Safety management system requirements.
CASR 119.190(2)(b)
(2)(b) a safety risk management process, including:
(i) hazard identification processes; and
(ii) safety risk assessment and mitigation processes
CASR 119.190(2)
(2)(d) a safety assurance system, including details of processes for:
(i) safety performance monitoring and measurement; and
(ii) management of change; and
(iii) continuous improvement of the safety management system
The implementation of flight crew fatigue rules under CAO 48.1 has recently completed, subject to a post-implementation review. CASA is planning a project to review the methodology of controlling cabin crew fatigue based on global standards and recommended practices, specifically for cabin crew in the Australian context.
As the current CASA requirements pertaining to cabin crew fatigue are not as extensive as those for flight crew, the measures detailed by the operator in response to the complainant appear positive in that they are:
- applying the existing [Flight crew fatigue system] (approved by CASA) to cabin crew across the network (assuming this application is in keeping with the provisions contained in Part 121 Manual of Standards (MOS) refer: 12.07 Flight crew fatigue and fitness for duty; 13.04 Senior cabin crew training; AMC/GM – GM 121.710 Meeting initial training requirements; GM121.570 Recurrent training and checking requirements)
- conducting a review of the recent changes introduced to the business class meal service introduced [date], and the extension to the meal service delivery timings
- using a predictive fatigue modelling program
- utilising fatigue risk controls for cabin crew, for example, pattern planning, on board rest, hotel rest upon arrival/home transportation
- holding monthly meetings with [Country 1] based [panel] and managerial staff to review trends discuss fatigue trends and identify emerging risks, and
- communicating provisions contained within the FRMP to remind of risk controls available to cabin crew/non punitive nature of SMS and emphasis on the importance of reporting.
- giving consideration regarding the introduction of home transport provisions for [Country 1] based crew following arrivals such as [Flight B], similar to those offered to operating cabin crew following [Flight C] arrivals [Location 3] to [Location 2].