We are undertaking a post-implementation review (PIR) of the fatigue framework in Civil Aviation Order 48.1 Instrument 2019 (CAO 48.1).
CAO 48.1 provides a framework for managing the risks of flight crew member (pilot) fatigue in Australian aircraft operations.
In particular, Appendices 1 to 7 of CAO 48.1 establish fatigue management settings for commercial operations (operations that are not private operations).
As part of the PIR, we are seeking feedback from commercial pilots and aircraft operators to assess whether the current fatigue framework in Appendices 1 to 7 of CAO 48.1 is operating effectively and efficiently and meeting the needs of Australia's diverse aviation industry.
The PIR focuses on how the fatigue management system is working, examining:
- whether pilots feel comfortable to report fatigue
- how operators respond to fatigue-related reports and concerns
- the education and training programs operators provide to help pilots manage fatigue effectively.
Recognising that fatigue affects individuals differently, it highlights the importance of adaptable, system-based approaches to managing fatigue risk rather than relying solely on prescriptive hour limits.
Why are we reviewing the fatigue management framework?
Pilot fatigue is a recognised aviation safety hazard that can affect alertness, decision-making and operational performance. Factors such as disrupted sleep, night flying, early starts, long duty periods and changing schedules can all contribute to fatigue.
CAO 48.1 was introduced in 2019 and fully implemented in 2021. Since then, operators have had time to embed fatigue management processes into their operations. The PIR provides an opportunity to understand how the framework is performing in practice.
How pilots and operators covered by CAO 48.1 can provide feedback
As part of the PIR, we are inviting feedback from commercial pilots and aircraft operators on the fatigue risk management arrangements in CAO 48.1 Appendices 1–6, minor variations, and Fatigue Risk Management Systems (FRMS).
Commercial pilots
Pilots operating under the appendices to CAO 48.1 can:
- complete the pilot survey to share their experiences with the fatigue management arrangements
- provide feedback on the discussion paper that is informing the review.
Aircraft operators
Aircraft operators can:
- complete the operator survey and provide feedback on the discussion paper, which will be distributed directly to operators by CASA.
The surveys are specifically seeking input from pilots and aircraft operators operating under the Appendices to CAO 48.1.
Why feedback matters
Pilots and operators experience the fatigue framework first-hand through their day-to-day flying duties and can provide unique insights into how the rules, fatigue management practices and rostering arrangements work in real-world operations.
Feedback collected through the pilot and operator surveys will help us better understand how the fatigue rules are working in practice and identify opportunities for improvement.
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