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How to transition to the new fatigue rules
Fatigue management is a shared responsibility between pilots, operators and CASA.
Having fatigue management policies and procedures ensures that an organisation has mechanisms in place to identify and manage fatigue risks.
Within CAO 48.1 Instrument 2019 there are a number of obligations that individuals (flight crew license holders) and operators (air operator certificate (AOC) holders and Part 141 certificate holders) must meet.
Options available for transition to the new fatigue rules are:
- Prescriptive: Transitioning to the prescriptive rules in Appendices 1 to 6 of CAO 48.1 Instrument 2019 without modification – this does not require separate CASA approval.
- Prescriptive with modification: Transitioning to the prescriptive rules in Appendices 2 to 6 of CAO 48.1 Instrument 2019 with some minor variation.
- The minor variation process recognises that prescriptive rules cannot adequately accommodate all operational differences and differences among crew members for all operational situations, but that an FRMS is only appropriate in the more complex cases.
- Guidance on the variation process is provided on the fatigue management resources page.
- FRMS: Operating under a Fatigue Risk Management System (FRMS) – an FRMS under Appendix 7 of CAO 48.1 Instrument 2019 requires CASA assessment and approval.
CAO 48.1 Instrument 2019 provides a number of appendices that an operator can choose from:
Appendix 1 sets prescriptive flight and duty time limitations without the need for risk management processes or fatigue training. These limitations are relatively restrictive.
Appendices 2 to 6 allows greater flexibility with less restrictive flight and duty time limitations, but requires operators to have in place risk management processes, continuous monitoring processes and an initial and recurrent fatigue training program for pilots, managers and anyone involved in rostering decisions.
Appendix 7 the most comprehensive fatigue risk management, known as a Fatigue Risk Management System (FRMS). An FRMS is a data-driven means of continuously monitoring and managing fatigue-related safety risks, based upon scientific principles and knowledge, as well as operational experience. It aims to ensure relevant personnel are performing at adequate levels of alertness.
Compliance with the chosen fatigue management approach is checked and monitored as a part of the ongoing relationship between the operator and CASA.
Existing exemptions and directions
A number of operators are operating subject to an exemption or instrument of direction in relation to the old rules. Operators should have copies of the latest exemption applicable to their operation.
CASA EX48/18 - Extension of CAO 48.0 Instruments Exemption 2018 (PDF 139.75 KB) (Fatigue Omnibus) extends most current industry exemptions from the flight and duty time requirements of CAO Part 48. The extension of the instrument is until 30 November 2020 however for operators who are transitioning to Appendices 1 to 6 the Fatigue Omnibus instrument ceases to have effect on 30 June 2020. For operators who submit an application for an FRMS trial the Fatigue Omnibus instrument will be valid until 30 September 2020.
Helicopter mustering operators have the option to comply with CASA 28/18 – Flight Time Limitations for Helicopter Mustering Operations – Direction 2018.
Operators conducting aerial application operations in aeroplanes may comply with CASR Subpart 137.Q and are exempt from complying with CAO 48.1 Instrument 2013 under Exemption - Civil Aviation Order 48.1 Instrument 2013 - aerial application operations (in aeroplanes).