Issue: fatigue

During the sector safety risk profile (SSRP) workshop in June 2023, operators participating discussed complexities and risks around using communication equipment during a fire emergency.

What can aerial firefighting operators do

Operators recognised the large disparity of fatigue rules organisations operate to can be a risk when tasking agencies are assigning work.

An organisation can potentially operate under either a:

  • Fatigue Risk Management System
  • 1 Appendix 4
  • prescriptive limits under Part 137.Q.

Operators must understand each of these at the time a task is assigned to them.

Hazard identification was also a concern. Operators say they need to:

  • identify hazards related to human fatigue and alertness,
  • assess and manage safety risks (for example, putting in place controls and mitigation strategies).

The nature of the flying and environment introduces various additional operations factors outside of the risk of fatigue due to sleep loss, time away time of duty or other factors. These include, but not limited to:

  • night flying
  • time critical operations
  • temperature – extreme heat, dehydration
  • environmental degradation – smoke, reduced visibility, changing conditions, windshear, turbulence
  • lack of automation
  • route variations
  • aerodrome unfamiliarity and
  • high noise or vibration levels.

What we are doing and already delivered

We published resources, procedures and rules for managing fatigue to reduce safety risks across aviation. We have a dedicated Fatigue Management section with resources and requirements. 

For operators who have a requirement to comply with CAO 48.1 CASA there is specific guidance material including:

  • CAAP-48-01 Fatigue Management for Flight Crew Members which supports AOC holders and flight crew members understand their obligations in relation to fatigue risk management.
  • Fatigue Management Plain English Guide: our plain English guide for fatigue management makes it easy to meet your obligations under:
    • Civil Aviation Order 48.1 Instrument 2019
    • Subpart 137.Q of Civil Aviation Safety Regulations 1998.
  • Safety behaviours: human factors for pilots – Booklet 3 – Human performance focusing on fatigue, stress and workload management.

Operators who don’t have an obligation to comply with CAO 48.1 may still be required to manage the risk associated with fatigue in their operations.

These operators can use CAO 48.1 requirements and the associated guidance to develop appropriate fatigue management procedures within their operations.

Published date: 28 November 2023
Online version available at: https://www.casa.gov.au//operations-safety-and-travel/safety-management-systems/sector-safety-risk-profiles/aerial-firefighting-sector-safety-risk-profile/issue-fatigue
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