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CASA releases final report of review of new fatigue rules

written by Gerard Frawley | March 22, 2018

Australia’s Civil Aviation Safety Authority (CASA) is seeking feedback in response to an independent review of its new fatigue risk management rules.
The review was announced in August 2017, when CASA deferred the introduction of Civil Aviation Order (CAO) 48.1 in response to feedback from the aviation community.
The final report, released on Thursday, said the independent review team “supports the need for CAO 48.1”.
“Scientific knowledge about fatigue and its effects on human reliability are strong enough to assert the existence of a significant risk exposure that needs to be properly managed,” the report said.
“The absence of a precise and reliable quantitative model to describe the exact link between duty time and fatigue on the one hand, and fatigue and airborne risk on the other, should not be used as an excuse to underestimate the need to adapt fatigue risk management approaches.
“On the contrary, these uncertainties must trigger a precautionary attitude and encourage routine regulatory attention to ongoing fatigue research, including aviation industry fatigue-related accident/incident analysis.”
To that end, the report outlined 24 recommendations to improve and implement the fatigue rules contained in CAO 48.1.
These included freezing “transition dates for all elements of the aviation industry until recommended changes resulting from the current review can be made to stabilise a final version of CAO 48.1 and all associated supporting documentation for implementation”.
Another recommendation called for CASA to adopt a “staggered approach to the implementation of and transition to CAO 48.1, with initial transition proceeding first for elements of the industry with the highest risk exposure”.
There was also a recommendation to revise flight duty period (FDP) limitations to make them more closely aligned with international averages, as well as increasing the flexibility of the fatigue risk management system (FRMS) option to enhance scalability through additional risk-based tiers.
The report also recommended CASA consider removing Civil Aviation Safety Regulations (CASR) Part 137 aerial application operations from CAO 48.1 “due to the sector’s lower relative risk exposures”.
“The current version of CAO 48.1 attempts to cater for the diverse nature of Australian aviation operations by proposing different rules for different groups of operations,” the report said.
“Within each of these groups however, there is still substantial diversity in the operations being conducted. Hence this approach may disadvantage some operators by imposing a rule set that is overly prescriptive and/or not suited to the varied characteristics of their operation.
“It is proposed that limited dispensations be allowed, where it can be shown that CASA considers specified fatigue mitigation to be appropriate relative to the risk exposure profile of an operation.”

The review was conducted by professional consultancy services company Dedale Asia Pacific. Members of the review team comprised two experts from Dedale, two from Integrated Safety Support (ISS) and one from the University of Queensland. There was also a three-person expert advisory panel that supported the review.
CASA chairman Jeff Boyd welcomed the report.
“The review team has confirmed the need to change from the old Civil Aviation Order 48 fatigue rules and standard industry exemptions and CASA’s Board supports this view,” Boyd said in a statement.
“The report provides a method to find an appropriate balance between fatigue risk and operational impact and the board is seeking input from industry on potential implementation issues prior to finalising changes to the rules.”
CASA said the deadline for public submissions in response to the report was April 17.
The final report and details on how to offer feedback can be found on the CASA website.

VIDEO: An October 2016 video published on CASA’s YouTube channel on CAO 48.1
The new CAO 48.1 rules had been welcomed by some aviation groups and condemned by others.
When their introduction was previously delayed in 2016, the Australian Airline Pilots Association (AusALPA), said its members were “very concerned” and described fatigue as a “clear safety issue” given how often it had been cited as a contributing factor in recent aviation accidents and incidents.
Meanwhile, The Australian Aviation Associations’ Forum (TAAAF), which comprises peak representative bodies in the local industry, has previously called on CASA to abolish CAO 48.1, arguing that “industry rejects the limited science it is based on, the ignoring of decades of safe operations, the massive costs it will impose and the complexity that will inevitably lead to non-compliance”.
The Regional Aviation Association of Australia (RAAA) chief executive Mike Higgins has said previously the association’s airline members had a different set of operational environmental factors to the larger operators.
“We are all for rules for managing fatigue, don’t get us wrong, but they have got to be fit for purpose,” Higgins said in the October 2017 edition of Australian Aviation.
“We are arguing on behalf of our members, who don’t fly multiple timezones, who don’t get up at 3 o’clock in the morning, who don’t land after 11 o’clock at night.
“Therefore any fatigue management rule should look at each individual sector of the regional airline industry and because we operate primarily in one time zone and so forth we should have a particular set of rules for managing fatigue.”

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