With monikers like the “do nothing” option, the “changing the numbers” option and “follow another country’s rules” option to describe alternatives, Australian officials are calling for a new approach to managing and minimizing flight crew fatigue.
It attempts to go beyond set limits for hours of duty by encouraging operators to use a fatigue risk management system (FRMS) tailored to their particular needs (e.g., short haul, multiple daily flights; long haul flights crossing multiple time zones, etc.).
Details are contained in an August 10 discussion paper published by Australia’s Civil Aviation Safety Authority (CASA). The initiative is an outcome of recommendations issued by an Australian Parliament inquiry. The report of the House of Representatives Standing Committee on Tourism, Transport and the Arts, titled “Beyond the Midnight Oil,” declared flatly, “We are alarmed at the state of the current system of regulating flight and duty times for air crew.” The committee report called on CASA to take action.
The CASA paper states that the traditional regulatory approach to minimizing operator fatigue is based on the premise that “fatigue is a function only of the amount of time spent working.” However, other factors are now recognized to have a significant impact on alertness, to include the type and intensity of the work, the time of day (e.g., flights scheduled for “the back side of the clock” between midnight and 6 a.m.), the body’s circadian rhythm and the need for sleep.
Prescriptive limits to flight and duty time – and variations thereof – don’t account fully for these factors, or of the latest scientific evidence relating sleep disruption and deficits to performance degradation (see ASW, March 24). Worse, the widespread granting of exemptions to the rules may well be “legally indefensible,” CASA suggests, because they cannot be substantiated “by a safety case.” Despite the recognized absence of a scientific basis for entrenched rules – often decried as complex, inflexible and inappropriate – the CASA paper notes, “there has been no agreement on prescribed flight and duty time limits between nations for the last 50 years.”
CASA proposes the FRMS approach as a way to break the deadlock. Under this approach, operators would develop a “fatigue benchmark,” which would be used to develop schedules to ensure that flight crews “do not operate aircraft while performance impaired to the point where safety is compromised.” CASA references a 2003 report of field trials, in which a number of small operators employed FRMS, to include some “low capacity public transport operators across Australia.”
The study found that 85 percent of aircrews participating the FRMS trial believe that the system had a “positive impact” on operations.
CASA is now seeking industry comment on the applicability of FRMS to “high capacity regular public transport operators.” Costs are unclear, but development of an FRMS is estimated in the range of $10,000-$50,000 per operator, depending upon the price of the software. Improved rostering efficiencies and decreases in fatigue-related incidents are deemed offsetting savings.
Initial reactions of some pilots reflect skepticism that FRMS represents a breakthrough in fatigue management. Airline managements will not accept any fatigue rules that hurt the bottom line, said one.
There is a perception that airlines are not likely to restructure their worldwide timetables and keep track and score “everything that could possibly cause fatigue.”
There also is a perception that by adopting FRMS hard regulatory choices are being skirted, such as limiting sector times and the number of sectors per month. For example, a maximum sector length of 10 hours and a maximum of eight per month, or 10 sectors per month if eight-hour sectors, and so forth.
The CASA paper outlines seven options:
Option 1: Retain and enforce current regulations, with no exemptions. Advantage: relative simplicity. Disadvantage: unworkably stringent and could drive some operators out of business.
Option 2: Maintain the status quo, with exemptions. Advantage: easiest of all the options. Disadvantage: not a “level playing field” with all persons subject to the same standards.
The CASA paper said:
“While the ‘do nothing’ option gives Australia the chance to take a back seat and let other countries become the driving force giving us the opportunity to learn from their mistakes, this would be, at best, a delaying tactic.”
Option 3: Adopt new “absolute” flight and duty time limits. Advantage: could be more scientifically based. Disadvantages: could be more conservative than existing regulations, and could stifle some “best practice” approaches to fatigue management.
Option 4: Replace Australian regulations with another country’s regulatory requirements. CASA believes this option is simply “changing the numbers” relating to flight and duty time limitations rather than managing fatigue. This option involves a Catch-22. According to the CASA paper, the U.S. Federal Aviation Administration (FAA) has deferred modernizing its prescriptive limits pending an anticipated initiative out of Australia.
Option 5: Replace current regulations with operator-developed FRMS. Researchers at the Center for Sleep Research at the University of South Australia have developed some “prior sleep and wake rules” that could be used to guide the development of FRMS, particularly for smaller operators. In this option, operators would be required to set and justify their own “fatigue benchmark. Advantage: pursues “best practice.” Disadvantage: potential for increased “risk exposure” to fatigue if FRMS not fully integrated.
Option 6: Retain current regulations with FRMS as an exemption from compliance. This course represents a combination of Options 2 and 5, allowing operators to “sit back and wait” or to pursue “best practice. Advantage: maximizes near-term flexibility for operators. Disadvantage: some operators may continue to inadequately manage their fatigue risk in the face of current knowledge.
Option 7: Replace current prescriptive regulations with new limits, or an operator-developed FRMS. CASA states baldly that this is its “preferred option,” representing a combination of alternatives 3 and 5. Advantage: companies seeking to operate outside of updated flight and duty limitations can implement FRMS. Disadvantage: increased startup workload involved in FRMS implementation.
Comments to the CASA discussion paper are due October 8. (The CASA Discussion Paper may be viewed at http://rrp.casa.gov.au/download/04_dp.asp#d0404os; comments to the discussion paper may be submitted online, see rrp.casa.gov.au/respond, or by e-mail using the format in the discussion paper to [email protected])
A Template for Constructing Rosters in the Aviation Industry
Developed by the Center for Sleep Research at the University of South Australia
When all points are adhered to, a fatigue-inducing work schedule is unlikely:
- In any 7-day period, a flight crewmember does not exceed 48 hours of duty of any nature.
- In any 24-hour period, a flight crewmember is not rostered for duties that exceed 12 hours (ASW note: could be a major problem for ultra long range operations, which by definition involve flights of 16 or more hours covering 8,000 NM or more, see ASW Dec. 22, 2003)
- Duty periods are separated by a minimum rest period of 12 hours.
- In any 7-day period, a flight crewmember does not work more than a total of 12 hours between 2100 and 0900.
- In any 7-day period, a flight crewmember has at least one continuous period of 36 hours free from all work-related duties.
Source: CASA Discussion Paper, p. 18
Prior Sleep and Wake Rules
‘Rules of thumb’ suggested by researchers at the Center for Sleep Research at the University of South Australia
- The Start Rule: The crewmember must obtain at least X hours of sleep in the last 24 hours and Y hours of sleep in the 48 hours prior to commencing work.
- The Finish Rule: The period from wake-up to the end of a particular work period should not exceed the amount of sleep obtained prior to commencing that shift, and
- The Action Rule: If either rule is broken, fatigue is a potential problem and the operator should engage in an auditable risk reduction (e.g., late start, early finish).
Source: CASA Discussion Paper, p. 20