Fatigue management for grown-ups

For example, current requirements that prohibit pilots from flying more than a certain number of hours per year have no role in day-to-day fatigue management. As long as pilots and other staff are well rested, these prescriptive requirements – especially monthly limits – serve no real purpose in terms of encouraging pilots to self-manage fatigue levels based on, for example, the amount and quality of sleep over the last 48 hours.

Unfortunately, another CASA project – one of more than 50 that CASA is pursuing in addition to the alleged regulatory ‘reform’ program – appears to maintain the previous prescriptive regime despite advances in our understanding of fatigue and its management.

For aerial application operators the proposed changes to CAO 48 and CASR Part 137 are a disaster.

Far from promoting an improved and mature approach to fatigue management, the proposed changes throw out the current regime that has been 90

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tested over decades as effective and safe and would restrict application pilots to 120 hours per month rather than the current 170 hours per month. This has not been driven by a keen knowledge and analysis of aerial application accident trends or any identification of problems with the current system other than a vague reference to the current regime not being ‘science-based’.

For those who either do not have or have forgotten their corporate history, AAAA worked with CASA in 2002 to develop the current regime that was based on sound risk assessment, a safety case and a history of safe practice through a range of exemptions from CASA over previous decades which were then formalised through the orders and the new Part 137.

The potential cost to industry – for no identified improvement in safety – is enormous.

In a sector that is still trying to rebuild pilot numbers after a long-term drought that affected almost every part of the country, the industry will struggle to meet the significantly increased prescriptive demands of the CASA proposals – and again – for what safety benefit? Add to this the ongoing em-

barrassment of the hopelessly out of date CASA exam for ag pilots, the difficulty with getting new ag trainers approved through a byzantine CASA ATO system, and the fact that AAAA has been working on updating the application competencies – started by CASA some nine years ago – and the simple question is where does CASA think these extras pilots, required by their new regime, will come from? The need for aerial applicators to have flexibility within the bounds of safety is critical in a seasonal industry.

Aerial application is simply not like many other forms of aviation – it is dependent on the cropping and related conditions – including markets and commodity prices. This is then overlaid against a competitive environment with ground applicators, so that when it rains and ground rigs are bogged, the aircraft is in very high demand.

Having a fatigue risk management system that recognises this intrinsic need for flexibility and which is based on the current fatigue status of pilots rather than some prescriptive monthly or annual limit is a strong indicator of the maturity of the regulator and its ability to focus on the

big picture, rather than insisting on prescriptive regulation for its own sake rather than safety outcomes.

Reading the current regulations almost requires a lawyer at your shoulder to ensure you are not in breach of the regulations.

Rather than seeking to perpetuate such a scheme, CASA should be using this opportunity to simplify the requirements and bolster a mature industry approach to managing fatigue.

CASA has many regulatory tools available to it to monitor the progress and performance of any new fatigue system – including education and training as well as audits. This would ensure that industry is actually complying with the hopefully more flexibly requirements.

AAAA has been providing human factors training, including fatigue management, to its members for over 14 years.

The significant improvement noted in safety statistics since that time is clear evidence that the industry itself has a very mature approach to the importance of safety. More recent work with CASA on the third edition of the Aerial Application Pilots Manual that incorporates comprehensive coverage of human factors, fatigue management and aviation safety tools and systems is further evidence that the sector takes its role in improving aviation safety seriously.

AAAA is firmly of the view that CASA should, at worst, maintain the current aerial application fatigue management regulations and, at best, work with the industry to develop a mature fatigue risk management strategy system based on sleep/wake concepts that are comparatively simple and easy to understand and use.