To achieve the best outcomes from fatigue management systems, operators rely on flight crew to participate in providing fatigue related information, data, and reports. It is also important for improving rosters under a fatigue risk management system (FRMS).
This participation often benefits flight crew as this data can help reduce overall fatigue levels in flying rosters produced by operators.
If an operator’s rosters, patterns, or pairings are generating high levels of fatigue for flight crew it is imperative the operator receives this information. The FRMS rules state operators must act based on information provided by flight crew.
It is equally important the information and data provided by flight crew indicate to the operator when fatigue levels experienced are moderate or low. Operators can then verify this information to see if fatigue risk mitigations or controls are operating and effective.
Information can include:
- fatigue safety reports
- flight duty period extension reports
- alertness data often using the Samn-Perelli (SP) or KSS scales. For more information, see Appendix G of CAAP 48-01 - Fatigue management for flight crew members
- fatigue experience surveys
- sleep surveys.
Our just culture directive
We have published a Just Culture Directive for the purpose of explaining the nature and basis of the approach taken in applying the principles of just culture. It also describes our commitment to those principles as reflected in our regulatory philosophy.
The directive is applicable to all our staff. The directive applies to safety information gathered by operators from flight crew whether operating under either:
- a prescriptive appendix
- FRMS.
Under fatigue regulations, operators must use the information gathered to make improvements, on a continuous basis, to their fatigue management system (FMS) or FRMS.
We focus our oversight on operators' administration of their fatigue management systems rather than on individual flight crew members.
Requesting fatigue information from operators
There are times where we require access to fatigue data and information from operators. This can be for the purposes of monitoring or auditing an operator's fatigue management arrangements. In our request we ask operators provide that information in a de-identified form.
We also ask operators to present the information in a batch format – often a spreadsheet, or similar, containing numerical data points only. This supports our oversight of the fatigue management rules. It also encourages pilots to provide fatigue-related information to operators that are best placed to use that information for operational purposes.
Under these arrangements, operators will not report the identity of individual reporters to us.
Sleep survey information
Sleep surveys are an effective tool for operators to assess sleep quality and quantity of flight crew in scenarios such as:
- away from home accommodation
- daytime sleep
- using in-flight crew rest.
The information is highly useful to inform the sleep assumptions that underpin roster generation and predicted fatigue risk.
We may ask the operator to present sleep survey information to us as evidence of effective fatigue risk management. This is only provided in a de-identified batch format.
Poorer sleep quality when not in a familiar environment or sleeping during the day is common. In these cases, and doesn't indicate that a person has a sleep disorder.
Using de-identified fatigue data
Our purpose in obtaining de-identified fatigue data is to monitor operator fatigue risk management consistent with the scheme established by the fatigue rules. It is not to identify and take action on instances of regulatory non-compliance by conducting regulatory action in relation to pilots.
However, if we receive safety information that triggers a response from us, the response will be consistent with our Just Culture Directive and regulatory philosophy.
We only use this information to assess the effectiveness of the policies and practices of the operator's FMS or FRMS.