[Peetwo]

REPCON: AR201700062 - In SMS I believe! 

Not exactly sure if this is because of Carmody's influence but the regulator's response to AR201700062 is one of the most refreshing and proactive responses that I have ever witnessed...

Regulator's response (Regulator 1)

CASA has reviewed the REPCON and notes that the reporter is not challenging the legality of the fight duty being offered to the off duty crew member. CASA notes the operator’s assertion that the flight duty was offered in accordance with established crewing policies and procedures and that remuneration was in accordance with the applicable employment agreement.

Implicit in the operator’s response to the REPCON is an acknowledgement that the management of fatigue is a responsibility shared by the flight crew and the company. CASA notes that substantive detail regarding how each party should meet its respective responsibility is not expected to be raised by CASA’s Certificate Management Team (CMT) for [operator] until a proposed amendment to CAO 48.1 comes into force.

Taking into account the potential for extended periods of wakefulness during a ‘back-of-the-clock’ flight duty period offered to a flight crew member on their rostered day off, CASA’s Human Factors (HF) and Safety Management Systems (SMS) subject-matter experts have developed a number of suggested measures that could address the risk of fatigue arising from this practice. These have been forwarded to the CMT oversighting [operator] for their consideration and are presented in Appendix 1.

Appendix 1
When making the offer to a flight crew member for a ‘back-of-the-clock’ duty on a day off, [operator] should consider taking the following steps to ensure the risk of fatigue is managed proactively.

a) The responsibility of the organisation and the individual to adhere to sound sleep/fatigue management practices is a cornerstone of an effective SMS/FRMS. Individual fatigue education/ongoing training should specifically cover the potential hazard associated with accepting additional duties (whether work or personal) when on a rostered day off. Equally, an organisation’s fatigue management policy and procedures documents should specifically address offering ‘back-of-the- clock’ duties to a flight crew member who is on a day off. Lastly, crewing officers must follow the organisation’s fatigue management policies and their training should assure their awareness of this obligation.

b) Any agent acting on behalf of the operator is responsible for assuring crew members being offered ‘back-of-the-clock’ duties are fit for the duty as reasonably practicable. Knowledge of the length of the sleep opportunity of a flight crew member, consideration of the notification time of such a contact should be standard practice and demonstrate a reasonable effort to ensure the fitness to fly of the individuals contacted.

c) Some form of ‘standardised’ pre-emptive safeguard incorporated into existing policies and procedures requiring the crewing officer to enquire about the recent sleep history of the flight crew member using a short checklist would be a relatively simple enhancement to the existing SMS. A structured decision process could be built into the checklist to allow for a set of ‘standards’ to be followed to ensure that critical areas are addressed. Any ‘score’ that exceeds a set limit would prevent a flight crew member from accepting a duty. The checklist might request information such as:

• how long the flight crew member has been awake at the time the offer is made
  
• how much sleep has been achieved in the past 24 hours
  
• have they engaged in strenuous physical activity
  
• have they engaged in mentally taxing activities (e.g., study)
  
• a rating of how fit for the duty they feel.
  

d) When crewing involves a member(s) who was scheduled to be off, encouragement to engage the application of the organisation’s approved fatigue countermeasures such as controlled in-flight rest, to maximize alertness and minimize drowsiness should be part of the crew’s briefing. A further strategy might require the flight crew member called-in on their day off to be pilot-flying on the first sector and pilot-not-flying on the second sector.
e) The operator should maintain records of instances where a flight crew member accepts a ‘back-of-the-clock’ duty on a day off as a means of demonstrating the effectiveness of the SMS applied to the scheduling practices. Additional information that may be useful include recording factors such as:

• a pre-duty assessment of how alert they feel, e.g. Samn-Perelli score
  
• a post-duty assessment of how alert they feel
  
• whether controlled in-flight rest was used during the flights – if so
  - how much was achieved
  - was it perceived to be effective.
  

Such questions could be used within the SMS/FRMS as metrics for the use of the procedure and provide information concerning the efficacy of its continuation.
 

Never thought I'd say it but well done that particular CASA crew...
MTF...P2