The reporter has expressed a concern in relation to marine pilot fatigue. The reporter states that FAID (Quantum fatigue assessment) scores governing a pilot's ability to safely pilot a vessel were removed from the [Operator's manual] on [date] when it was apparent that the operation was not going to succeed unless the FAID system was removed, or a higher FAID score was accepted for operations. During this period, [Operator] made the claim that they were working with the FAID system provider to rectify problems surrounding software and pilot error in using the system. The FAID score system was reintroduced into the [Operator's manual] six months later. The pilot working group assume this was to satisfy [Regulator] who would be aware of the high fatigue issue at [Location] and [Operator's] non-compliance with state and national legislation.
The reporter advises that the [Operator's manual] states; any pilot whose projected FAID fatigue score will exceed threshold levels should be rested. Any pilot who feels fatigued to the extent that they feel they should not be piloting, despite their calculated FAID fatigue score, should advise the pilot manager, as early as possible.
However, the pilot group is experiencing the following situations:
- pilots are allocated duties with an initial FAID score above 80, 90, 100, 100+
- pilots are allocated duties with a projected FAID score above 80, 90, 100, 100+, and
- the FAID system has been consistently and overwhelmingly disregarded by [Operator] who have treated it as optional rather than a crucial consideration when allocating pilots to vessels.
The reporter states that [Operator's] management are sceptical of the science and usage of the FAID system and challenge any pilot who claims fatigue when their score or projected score is 80, 90, 100 or 100+.
The reporter further states that when a pilot's FAID score reaches 80 or above for an upcoming pilotage allocation, management is to take active management of the pilot's fatigue. This means that operations/pilot manager is responsible for instructing the pilot on next actions. This could be where the pilot is to rest, what method of transport a pilot is to use to get home, etc. If a score is over 80 then the Fatigue Management checklist is completed, and the pilot is consulted before the next allocation. In reality, when a pilot's FAID score is above 80 and operations/pilot manager takes active management of the pilot's fatigue this will mean the following:
- the pilot is allocated to another vessel without consultation, or
- occasionally the pilot will be consulted prior to an allocation and asked if they deem it safe to undertake the pilotage regardless of their current or projected FAID score.
In a port such as [Location] where the travel, launch and pilotage time can vary from 8-14 hours from station to station it is impossible for a pilot to try and project the degree of fatigue they will experience. The FAID system has been developed to remove the ambiguity of this task being performed by an individual or management personnel. The FAID system is designed to designate a fixed FAID score with a safety critical cut off to all allocations to ensure a pilot does not experience high fatigue during the operation.
The reporter states that operator is operating outside its FAID fatigue management system on a regular basis and is not actively managing highly fatigued pilots. For example, in a one-week period [dates provided] pilots operated with FAID scores between 80 and 129. 168 movements were completed in the port, 51 of these movements by pilots with a FAID score above 80, meaning over 30% of shipping for this week was conducted by pilots likely experiencing high fatigue.
The majority of the pilot working group experience coercive pressure and emotional manipulation by the management when declining a job due to experiencing high fatigue or the projected fatigue score being in excess of 80+. In addition, pilots who request to adhere to the pilot allocation working rules and wish to decline a job or request additional rest to manage their fatigue find themselves in conflict with management. In many cases this situation leads to pilots subordinating to management and accepting an allocation knowing they will be piloting a vessel in a highly fatigued state.
Dispatch operations
The allocation of pilots to vessels is co-ordinated by the dispatch office in [Location]. At the initial stages of allocation, dispatch personnel were trying to manage pilot fatigue in accordance with the pilot allocation working rules using the FAID system as a reference or guide. The report states dispatch personnel complain regularly about a shortage of pilots and many of them have expressed their concerns about the soaring fatigue levels of the pilots.
The responsibilities of dispatch officers to follow fatigue management systems is left to individual opinions and attitudes, which vary widely. Any genuine effort to ensure safety by following proper fatigue management systems is repeatedly revoked and undermined by management. This puts pilots in the awkward position of having to decide if they are going to challenge an allocation and thereby engage management in an uncomfortable discussion or accept the allocation and pilot unsafely whilst fatigued. The pilot manager is consulted by dispatch when there are not enough pilots to be allocated to vessels or a pilot advises they are highly fatigued and therefore a vessel cannot be allocated a pilot. This is when pressure is applied to a pilot to accept an allocation.
In summary, the report states that pilots are allocated pilotage tasks when highly fatigued on vessels loaded with explosives, toxic substances, crude oil, petroleum products, chemicals and various other cargos. The risk of an accident causing an environmental catastrophe is high. Meanwhile, [Operator] continues to avoid the compliance and safety issue of pilot fatigue management.
The reporter has requested that:
- pilot FAID scores be monitored by an external government department using algorithms that account for travel, launch and pilotage times
- an anonymous survey be conducted amongst the pilot working group and dispatch staff via an external government department, and
- dispatch staff receive in-depth training into fatigue risks and management.
[Operator] acknowledge the contents of the REPCON and appreciate the significance of many of the alleged items, however, note that the majority of the REPCON detail is unsubstantiated, and hence neither credible nor reliable. Subsequently, [Operator] offers the following:
- [Operator] has received no previous REPCON’s (or like) from the ATSB in their 12 months of operations to date.
- Pilots are allocated to jobs in accordance with the Transport Operations Marine Safety Regulation 2016 (TOMSR).
- [Operator] operates within and is guided by established pilotage operating safety management systems (POSMS), which contains the fatigue management plan.
- [Operator] management systems, reporting and operations has been audited (surveillance and compliance) by [Regulator] and independent audit agencies.
- [Operator] is compliant with all relevant obligations across all areas of their operations.
- [Operator] has maintained accreditation with several ISO categories.
- [Operator] has worked extensively with experts for the Fatigue Assessment Tool by InterDynamics (FAID) system in order to better understand the system and improve our fatigue management.
- [Operator] has worked extensively with the supplier of their pilot allocation software to rectify defects and improve the system configuration, hence improving safety and efficiency.
- Where working correctly, the FAID system has been used within its limitations, and hence has never been disregarded in any way.
- [Operator] actively consults pilots with respect to emerging fatigue issues and encourages the engagement and consultation as a mechanism in management of fatigue.
- Pilots are not subject to any coercive pressure and emotional manipulation in any regard.
- There are no formal or informal complaints regarding pilot allocations noted within any dispatch logs.
- Dispatch staff continue to undergo training and development.
- [Operator] regularly conduct anonymous surveys of all staff, with the initiatives outlined further in this letter addressing much of the survey feedback.
- There are parties external to [Operator] seeking to cause disruption and issues, with malicious reporting on a topic like fatigue being a quick and easy means to trigger this disruption.
Notwithstanding above, fatigue and the effective management thereof remains an enduring focus for our management team, advisory Board and the Executive Management team. Accordingly, our response herein outlines our capability, operations to date, methods, issues, and improvements, and hence show that [Operator] is meeting all obligations for the safe and adequate delivery of pilotage.
In brief, and as detailed within Appendix 1 (provided to ATSB and Regulator), [Operator] use the guideline which indicates that where a FAID score reaches 80 or above for an upcoming Pilotage Allocation, the following will take place:
- Operations/pilot manager actively manages the pilot’s fatigue. This means Operations/pilot manager is responsible for instructing the pilot on the following actions this could take, including where the pilot is to rest and what method of transport a pilot is to use to get home.
- Operations will print out a pilot fatigue report for the next pilot allocation to assess FAID scores and provide this to the pilot manager.
- Operations/pilot manager is to ask the pilot where their fatigue is represented on the Karolinska Sleepiness Scale (KSS) scale.
- Operations/pilot manager will conduct an internal risk assessment via the fatigue management checklist to establish the pilot’s fatigue levels, bearing in mind that FAID is only an indicator and ensuring that the previous work levels are taken into consideration from the preceding days.
- The completed Fatigue Management Checklist will guide Operations/pilot manager as to whether a pilot will proceed with the following task allocation or advise the pilot to take a break. A pilot will be consulted on any allocation where a FAID score is >80. While the fatigue management checklist identifies a number of steps and decision points, a pilot will not be allocated to a pilotage task if they have worked more than 14 hours before the next pilot allocation, and furthermore, a pilot must have at least 12 hours off before the next allocation.
These actions are compliant with obligations under TOMSR. Finally, [Operator] encourages and accepts an individual pilot opting out of a movement due to fatigue. [Operator] actively consults pilots with respect to emerging fatigue issues and encourages the engagement and consultation as a mechanism in the management of fatigue.
To date, [Operator] has tested and reviewed a variety of roster models against the shipping profile, with various iterations adopted over time. The working group will now review what has been tried to date and our learnings, and from this, recommend a roster to be implemented that meets the aforementioned objectives.
Core to [Operator's] success is the need for the roster to be accepted by the pilot cohort but also adequately address the shipping profile and be manageable within our systems, with the roster tested to ensure it is adequate prior to implementation. Accordingly, [Operator] has engaged [Consultant] to collaborate with the working group to review, test and optimise the roster. [Operator] will work closely with [Consultant] to leverage learnings to date, including various initiatives such as staggered starts and number of jobs and belt positions.
[Operator] is confident that this way ahead will enable the optimal roster to be identified and validated, with [Operator] targeting a go live for the revised roster by 14 March 2023. Whilst the analysis is underway, [Operator] will continue to recruit into 2023, with our focus being to secure more Level 1/experienced pilots whilst continuing to pursue a casual pool of pilots for surge capacity.
[Regulator] as the relevant pilotage regulator for [State], initiated a number of performance outcomes for the immediate attention of [Regulator's] pilotage contractor, with two main focal areas – fatigue management and service delivery.
These items have been addressed and [Regulator] is satisfied with the current state of performance for these key objectives.
[Regulator] is monitoring [Operator's] performance closely.