Getting tired of it

Everyone agrees that fatigue is a hazard that needs managing.

Everyone agrees that long-haul operations need a comprehensive FRMS.

Everyone who is actually working in the industry and operating in a prudent and safe manner understands the requirements and application of CAO 48. 0 plus the Standard Industry Exemptions.

Everyone (including the ATSB) who takes an objective view of the status quo agrees there are no unmitigated fatigue issues in regional Australian regular public transport operations.

CASA has yet to supply the RAAA with a substantive supporting safety case in spite of three Freedom Of Information requests. Neither has CASA ever expended any effort to investigate the ‘state of the nation’ and actually sit down with operators and their safety management systems (SMS) and obtain the real data. CASA claims they simply do not have the resources to do that.

The wonderfully feel-good written communications from CASA very recently talks about collaboration, consultation, being a fair regulator, just culture, etc. This is at complete odds with what is actually happening.

As for any ICAO-compliant red herring argument, don’t be distracted. We can easily establish that the status quo of SMS, 48. 0 and the Standard Industry Exemptions are ICAO‑compliant.

The industry would welcome an independent review, but not simply of the efficacy of CAO 48. 1 to manage fatigue. That is not our argument, never has been and never will be.

Any review needs to start right back at the beginning and establish if there is in fact an unmitigated risk that needs addressing.

We need a truly independent risk analysis to determine if there is in fact an unmitigated problem in the first place. We believe it would be best conducted by an overseas expert as we doubt there are any independent reviewers available in Australia. They all have a vested interest in the prosecution of CAO 48. 1 as they stand to make significant windfalls from drafting a myriad of FRM systems. Any review should be well funded as just going to tender may result in the lowest cost option and it will be a case of you get what you pay for, with the outcome not being supported by the industry.

The RAAA wishes CASA would listen to the industry, accept reality and announce a moratorium on the commencement date of CAO 48. 1. That way we can all take a step back from the brink, stop the public stoushes and take a more professional and cool‑headed approach.

CASA got itself into this embarrassing position by assuming there is a problem and concocted CAO 48. 1.

There are no unmitigated fatigue issues in Australian regional RPT operations.