There are currently seven appendices. Each appendix contains regulations for a particular type of operation. Many operators will need to operate to multiple appendices.
Additional appendices are in development to address the fatigue risks associated with medical transport, helicopter mustering (and daylight-only aerial work operations) and ballooning operations.
Operators can choose what type of approach they want to adopt, within the limits and requirements that apply to their operation type. At times, such as when an operator needs their flight crew members to conduct several activities, for example, a public transport service (charter) as well as an aerial work activity, it may be easier to conduct both of these operations under the more conservative appendix. In this example, if both activities were conducted under Appendix 4 (single-pilot public transport operations), this would avoid needing to have procedures and limitations that apply to Appendix 5 (Aerial work operations).
Table 1 below lists which prescriptive limit appendices are applicable to each operation type. Any operator can elect to apply for an FRMS approval under Appendix 7 (the most customisable approach to fatigue management) for part or all of their operation.
|Operation type||Applicable appendices (select one for each operation type)|
|Multi-crew public transport services that involve complex operations||1, 2 or 7|
|Multi-crew public transport services that do not involve complex operations||1, 3 or 7|
|Single-pilot public transport services||1, 4 or 7|
|Aerial work operations (other than flying training)||1, 5 or 7|
|Flying training (Part 141, Part 142 or aerial work) *||1, 6 or 7|
|*Appendix 6 applies to Part 141 flight training and Part 142 flight training.|
Any operator type can elect to adopt Appendix 1 for all or part of their operation. Appendix 1 offers the simplest and most restrictive set of fatigue rules.
Note: this appendix is currently being amended to increase its scope and make it applicable to more operators.
If an operator conducts a multi-crew public transport operation that involves augmented crew operations and/or finishing a flight duty period at a location that differs by two or more hours in local time from the location where it originated, they must put their multi-crew operation under Appendix 2.
There is no restriction on also conducting multi-crew aerial work under this appendix.
This appendix approaches fatigue management in a similar manner to Appendix 6, but if the operator also wants to conduct flying training during a flight duty period, they will have to take the different flight duty period, flying hours and off-duty period limits of Appendix 6 into account (see Operating under multiple appendices).
If an operator conducts a multi-crew public transport operation and cannot conduct the operation to Appendix 1 limits, they must put their operation under Appendix 3.
There is no restriction on also conducting multi-crew aerial work under this appendix.
This appendix approaches fatigue management in a similar manner to Appendix 6 although there are different flight duty period, flying hours and off-duty period limits that will need to be taken into account if the operator also wants to conduct flying training during a flight duty period (see Operating under multiple appendices).
If an operator does not want to conduct their single-pilot public transport activities under Appendix 1 (or within the limits of Appendix 6) then they must conduct it under Appendix 4.
Any operator may also choose to include any aerial work activities under Appendix 4. This might be appropriate for an organisation that primarily conducts single-pilot public transport services (charter) but wishes to also conduct aerial work and does not need the added flexibility of Appendix 5. This is possible because an aerial work activity conducted under the limits of Appendix 4 will always be compliant with Appendix 5 limits.
By combining single pilot public transport activities and aerial work activities under Appendix 4 the operator does not need to consider the different approach required by Appendix 5 and does not need to consider the management requirements of transitioning the pilots between these appendices.
If the operator also wants to conduct flying training, they need to have specific limitations to ensure the pilots do not exceed the limitations of Appendix 6 while operating to Appendix 4 limits. While Appendix 6 is very similar to Appendix 4, there are some differences. If a pilot conducting flying training does not exceed any limit within Appendix 4 and in addition, does not exceed 7 hours flying time during a flight duty period and has a minimum of 12 hours off duty following a flight duty period that contains flying training, they will be compliant with both Appendix 4 and 6.
Operators conducting single-pilot, or multi-crew aerial work operations that need greater flexibility than Appendix 1 (or Appendix 4 and 6), must put their aerial work activities under Appendix 5.
If the operator wants to transition a pilot into another appendix after operating under Appendix 5 limits they must keep track of the requirements of the other appendix to ensure the pilot is within the limits of the other appendix when they transition into it. Appendix 5 is significantly different in the flexible approach it takes to fatigue management, particularly with regard the management of cumulative fatigue. For example:
- Appendix 5 does not require the operator to keep track of the duty hours of the pilot because there is no direct limit in Appendix 5. Conversely, all other appendices have a limit on duty hours and the pilot must be within these limits in order to commence operations under one of these other appendices.
- Appendix 5 has higher flying-hours limits than other appendices. Once a pilot exceeds the flying hours' limits of other appendices they cannot then transition into one of these other appendices until they are back below the limits of that appendix.
- Appendix 5 does not have the longer-term requirement for day's off-duty, like in the other appendices. If an operator wishes to transition a pilot into another appendix, the operator will need to keep track of off-duty days in order to establish when the pilot can transition into another appendix (see Operating under multiple appendices).
An operator conducting flying training under Part 141 or Part 142 must either conduct their flying training activities under Appendix 1 or Appendix 6.
If an operator conducting single-pilot operations can conduct their entire operation under the limits of Appendix 6 this is acceptable because the limits of Appendix 6 are more restrictive than the limits of Appendix 4 or Appendix 5. The operator is using the limits of Appendix 6 to ensure they are within the limits of the other appendices. This means they cannot take advantage of facilities such as the delayed reporting clause in Appendix 4. Without this facility, if the operator wants to delay the start of a rostered flight duty period they can only do it if the flight crew member is notified prior to 10 hours before the rostered commencement time.
This might be appropriate for an organisation that primarily conducts flying training but also offers charter and aerial work on an ad-hoc basis, and doesn't require greater limits than those offered by Appendix 6.
The Fatigue Risk Management System (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 that aims to ensure relevant personnel are performing at adequate levels of alertness. The FRMS approach represents an opportunity for operators to use advances in scientific knowledge to improve safety and increase operational flexibility. The FRMS is therefore more likely to be for more complex operations where the operator has the safety systems maturity to effectively manage an FRMS. For example, organisations that have the capability to collect valid fatigue-related data and objectively use that data for fatigue risk management and continuous improvement of rostering systems.
In line with the ICAO guidance material, CASA requires an extensive approval process with a 12–24 month trial period prior to final approval of an operator’s FRMS.
An FRMS is a management system focused on fatigue and has added requirements beyond that which would be expected of an operator complying with prescriptive flight and duty-time limitations and managing their fatigue risks through their SMS. In meeting these additional FRMS-specific requirements, an operator with an approved FRMS may move outside the prescribed limits.
The cost and complexity of an FRMS may not be justified for operations that remain inside the flight and duty time limits and where fatigue related risk is low.
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