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The latest fatigue rules for operators and pilots (CAO 48.1 Instrument 2013) currently contain 10 appendices, with some tailored to specific sectors of the aviation industry. The appendices available to operators are shown in the diagram above.
Following changes to improve the fatigue rules (finalised in July 2016) we introduced new appendices for ballooning, medical transport or emergency service operations and daylight aerial work operations such as helicopter mustering.
Some operators will operate to multiple appendices.
Operators can choose which appendix they want to adopt. At times, such as when an operator needs their flight crew members to conduct several activities (e.g. charter as well as an aerial work operation) it may be easier to conduct all operations under one appendix. In this example, if both activities were conducted under Appendix 4 (single-pilot operations) it would avoid the need to develop the additional procedures and limitations that apply to Appendix 5 (aerial work operations).
Table 1 below lists which prescriptive limit appendices are available to each type of operation. Any operator can elect to comply with Appendix 1 (the most basic limits) or apply for an FRMS approval under Appendix 7 (the most customisable approach to fatigue management) for part or all of their operation.
Table 1: Available appendices for each type of operation
|Type of operation||Available appendices|
|Any operation||1 or 7|
|Multi-crew operations (excluding flight training)||2|
|Multi-crew operations (excluding flight training and complex operations)||3|
|Medical transport and emergency service operations||4B|
|Aerial work operations (including flight training associated with aerial work)||5|
|Aerial work operations in daylight only (including flight training associated with aerial work)||5A|
Appendix 1 - Basic limits
Appendix 1 is available to all operators conducting any type of operation. However, the window within which a flight duty period may be undertaken does not permit operations in the early hours of the morning (between 1am and morning civil twilight/7am—whichever is earlier).
Appendix 2 - Multi-pilot operations (except flight training)
Appendix 2 is available to operators that conduct operations under multi-pilot procedures and operations with two pilots or more in single-pilot certified aircraft.
Operations that involve contracted checking or contracted recurrent training conducted as a multi-pilot operation are permitted under Appendix 2.
Flight training for the grant of a licence, rating or endorsement is not considered to be a multi-pilot operation and must not be conducted under Appendix 2 (Appendix 4 or 6 should be applied instead).
Appendix 3 - Multi-pilot operations (except complex operations and flight training)
Appendix 3 is available to multi-pilot operations as per Appendix 2, but excludes complex operations. A complex operation is one that involves:
- augmented crew operations (carrying more than the minimum number of pilots for the purpose of relieving one or more pilots of duty during flight time),
- operations that involve a displacement time of two hours or more (where a time zone change from the beginning to the end of the duty period is two hours or more), or
- operations where a pilot is not acclimatised to the location where they commence a flight duty period.
Simple multi-pilot operations that do not cross time zones may find Appendix 3 more suitable than Appendix 2 because it has the same limitations but is less complex.
Appendix 4 - Single-pilot operations
Appendix 4 is available to single-pilot operations (i.e. operations not conducted under multi-pilot procedures).
A training flight consisting of a student and an instructor is considered a single-pilot operation unless it is in an aircraft requiring more than one pilot to operate.
Appendix 4 would be suitable for most operators that conduct both charter and flight training with the conditions that:
- any flight training is completed within 7 hours flight time, and
- any flight duty period that includes flight training must be followed by an off-duty period of at least 12 hours.
Appendix 4A - Balloon operations
Appendix 4A has been tailored specifically to meet the unique requirements of balloon operators. However, balloon operators also have the flexibility to choose Appendix 1 or 4, or to implement a fatigue risk management system (Appendix 7) if preferred.
Appendix 4B - Medical transport and emergency service operations
Appendix 4B is tailored around the characteristics of medical transport and emergency service operations.
To implement Appendix 4B, the operation must be a medical transport operation or emergency service operation. These terms have specific meanings in CAO 48.1 Instrument 2013 as follows:
A medical transport operation means an aircraft operation consisting of 1 or more flights for any of the following purposes:
- delivery of urgent medical assistance to a person, when determined to be necessary by a medical transport tasker;
- transportation of any of the following, when determined to be necessary by a medical transport tasker:
- an ill or injured person;
- another person directly involved with the person mentioned in sub-subparagraph (i), for example, a close relative or the police.
- medical personnel intended to be, or who are, directly involved with the person mentioned in sub-subparagraph (i);
- blood, tissue or an organ for transfusion, grafting or transplantation (an item), including a person who has authorised custody of the item;
- the return of the aircraft to its base because an operation mentioned in subparagraph (a) or (b) is completed.
An emergency service operation means an operation involving an aircraft:
- for the purpose of law enforcement, or saving or protecting life or property; and
- conducted by, or at the request of, an organisation recognised by an Australian governmental agency as having responsibility to conduct or request the operation as part of the organisation’s functions.
For an operation to be classified as medical transport, there must be procedures in place for a medical transport tasker (medical personnel or organisation responsible for medical transport tasking) to determine that a flight is medically necessary; for example, procedures that include a risk assessment considering the nature of the flight(s).
If an operator does not have appropriate procedures in place to be classified as a medical transport or emergency service operation, then Appendix 4B is not available—a different appendix must be chosen.
If a medical transport or emergency service operator also conducts charter operations, another appendix (such as Appendix 4) would need to be complied with when conducting such operations. Special provisions apply for transitioning from Appendix 4B to another appendix—see operating under multiple appendices.
Appendix 5 - Aerial work operations (including flight training associated with aerial work)
Appendix 5 is available to all operations that are classified as aerial work. Flight training associated with aerial work (i.e. training for the grant of certain ratings and endorsements that permit typical aerial work-type operations) may also be permitted under Appendix 5.
Operators who conduct non-aerial work operations—such as charter operations—in addition will need to consider a different appendix (such as Appendix 4) when conducting such operations. Special provisions apply for transitioning from Appendix 5 to another appendix—see operating under multiple appendices.
Appendix 5A - Aerial work operations (daylight only) including helicopter mustering
Like Appendix 5, Appendix 5A is available to all operations that are classified as aerial work, but it is restricted to operations that are conducted during daylight hours, such as helicopter mustering. Flight training associated with aerial work (i.e. training for the grant of certain ratings and endorsements that permit typical aerial work-type operations) may also be permitted under Appendix 5A.
Operators who conduct non-aerial work operations—such as charter operations—will need to consider a different appendix (such as Appendix 4) when conducting such operations.
Special provisions apply for transitioning from Appendix 5A to another appendix—see operating under multiple appendices.
Appendix 6 - Flight training
Appendix 6 is available and suitable to operators who solely conduct flight training (training for the grant of a licence, rating or endorsement under Part 61 of CASR 1998), or conduct multi-pilot flight training.
If an operator conducts single-pilot flight training and other single-pilot operations, Appendix 4 could be chosen instead of Appendix 6. This has the benefit of keeping all operations under the one appendix.
Appendix 7 - Fatigue risk management system (FRMS)
Any operator can choose to implement an FRMS. Of all transition options, an FRMS gives the most operational flexibility for successfully managing fatigue—and for many it is likely to be an investment that will pay dividends in safety and efficiency.
The key to an FRMS is that fatigue risk is being managed systematically. An FRMS is not just another set of limits, another set of rules, rather it is a systematic process for actively managing the risk of fatigue.
Having an FRMS can have benefits even for small operators. Using advances in scientific knowledge of human performance and the effects of fatigue, even smaller organisations can improve safety and increase their operational flexibility.
Smaller operators who engage in reasonably intensive aerial work (e.g. firebombing) and then wish to transition their pilots to charter work, may find that with an effective FRMS they can move outside the prescribed limits and achieve greater flexibility. This flexibility is unlikely with the other more prescriptive flight and duty-time limitations in appendices 1-6 of the new CAO 48.1 Instrument 2013.
This flexibility means you can tailor your approach to managing fatigue risk to suit your operation, and for example, improve your chances of success in particular contracts you may wish to bid for.
A tailored approach to managing fatigue can also mean a happier workforce-an approach which works best for your pilots. Pilots taking off-duty periods at home, rather than when they’re away on a tour of duty, is one example of flexibility which cannot necessarily be achieved under the prescriptive limits.
Actively managing an FRMS, collecting valid fatigue related data and using it effectively, are important to enable monitoring and continuous improvement of your rostering systems. This access to more and better information, in turn, helps you to know your operation better and makes your decision-making better informed.
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.
Transitioning operators seeking FRMS approval to continue existing operations on a ‘like for like’ basis will not be charged application and approval fees. However, any variation of scope requested during transition would incur fees as per the Civil Aviation (Fees) Regulation 1995.
Development of an FRMS is inherently more involved than a prescriptive limits approach and must commence well before the transition date. Anyone considering FRMS should contact their CASA regional office now.
Some operators currently operate under an exemption from the old CAO 48 via a safety case based on a fatigue management system (FMS). FMS is also commonly referred to as FRMS under the old fatigue rules (CAO 48). There are key differences between the old FMS and the new FRMS—for example, the old FMS and the new FRMS are assessed to different standards.
Find out more about how to develop a fatigue risk management system, learn about the differences between an FMS and FRMS, and access tools and resources to assist you implement an FRMS.