Fatigue Management - Appendix 4A - Balloon Operations
CASA PART 48.1 - Instrument 2019
Operations Manual - 17.1
Version September-2020
Approver John Allen – Chief Pilot
Review Date September 2021
Table of contents
Table of contents 2
Glossary 3
Revision history 6
1 Flight crew member fatigue management 8
1.1 Fatigue management policy 8
1.2 Flight duty limitations and fatigue management 8
1.2.1 Responsibilities 9
1.2.2 Prior sleep opportunity 11
1.2.3 Duty time, FDP flight time and cumulative limits 12
1.2.4 Increase in FDP limits by split duty 13
1.2.5 Off duty periods 14
1.2.6 Access to sustenance 14
1.2.7 Recording flight and duty times 14
1.2.8 Reporting 15
1.2.9 Home base 15
1.2.10 Accommodation 15
1.2.11 Training 16
1.2.12 Fatigue hazard identification 21
1.2.13 Flight and duty records 26
1.3 Conditions and processes for extensions to limitations 26
1.3.1 Extensions 26
2 Rostering in accordance with Flight and Duty Time Policy 29
Appendix A. Fatigue Occurrence Report (Form OR) 30
Appendix B. Alertness Consideration Table (Form ACTab) 32
Appendix C. Extension Report (Form ER) 36
Appendix D. References 37
Glossary
Acronyms and abbreviations
Acronym / abbreviation
Description
CASR
Civil Aviation Safety Regulations 1998
HABT
Hot Air Balloon Tasmania
Definitions
Where these definitions differ in wording from those in Civil Aviation Order 48.1 Instrument 2019 the wording in this manual is used to simplify complex definitions. The wording in the Instrument takes precedence over the wording in this Manual.
Term
Definition
Access
No restriction on, or impediment to, a flight crew member’s (FCM’s) immediate and actual use of a necessity.
Adequate sustenance
Food and drink (including clean drinking water) in quantities sufficient to reasonably sustain a person in the person’s circumstances.
Bed
For suitable sleeping accommodation, includes at least 1 pillow, clean bed linen, and bed covering appropriate for the temperature of the accommodation
Call out
Being required by an operator to commence a duty period during a standby.
Consecutive
A continuous, unbroken, period of time for the duration of the hours or days mentioned.
Cumulative duty
The progressive sum of duty periods.
Cumulative flight time
The progressive total of flight time accrued by the FCM when acting as a crew member on board any aircraft but excluding flight time accrued during recreational private operations.
Day
The period between local midnight at home base and the subsequent local midnight at home base.
Displacement time
the difference in local time between:
· the place where a pilot commenced an FDP
· the place where the pilot undertakes an off-duty period following the FDP.
Duty
Any task that a person who is employed as an FCM is required to carry out associated with the business of an operator.
Duty period
A period of time that starts when an FCM is required by an operator to report for duty and ends when the FCM is free of all duties. A duty period includes any time spent by the FCM in positioning.
Emergency service operation
An aircraft operation:
· 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.
Fatigue
A physiological state of reduced alertness or capability to perform mental or physical tasks, which:
· may impair the ability of the FCM to safely operate an aircraft
· is caused by one or more of the following:
- the FCM’s lack of sleep
- the FCM’s extended wakefulness
- the FCM’s circadian phase at any relevant time
- the FCM’s workload of mental activities, or physical activities at any relevant time.
Note: An individual's level of fatigue and state of alertness can also be influenced by their health, diet, fitness and overall well-being.
Fit for purpose
For a crew rest facility, or suitable sleeping accommodation, means that it has ergonomic characteristics that make it suitable for an FCM to obtain sleep or rest (as the case requires).
Flight crew member (FCM)
A crew member who is a pilot or flight engineer assigned to carry out duties essential to the operation of an aircraft during flight time.
Flight duty period (FDP)
A period of time that:
· starts when a person is required, by an operator, to report for a duty period in which they undertake one or more flights as part of an operating crew
· ends at the later of:
- the person’s completion of all duties associated with the flight, or the last of the flights; or
- 15 minutes after the end of the person’s flight, or the last of the flights.
Flight time
The time when an FCM is acting in the capacity as a crew member on board an aircraft that includes:
· in the case of a lighter-than-air aircraft — the total time from the moment at which the aircraft first becomes airborne until it comes to rest on the ground, excluding any time during which the aircraft is moored.
Note: Recording flight time from 'push-back' or 'off blocks', rather than from the moment the aircraft first moves under its own power (as per the definition), is acceptable.
Home base
The location, assigned by the operator to the FCM, from where the FCM normally starts and ends a duty period or a series of duty periods.
Late night operation
An operation where an FDP includes more than 30 minutes between the hours of 2300 and 0530 local time at the location where the pilot is acclimatised.
Local night
A period of eight consecutive hours which includes the hours between 2200 and 0500 local time.
Multi-pilot operation
A multi-pilot operation is an operation conducted under multi-pilot procedures. However, this does not include contracted recurrent training or contracted checking unless it is conducted as a multi-crew operation within the meaning of regulation 61.010 of CASR.
Off-duty period (ODP)
A period of time during which a pilot is free of all duties and standby associated with their employment.
Recreational private operation
Flying conducted by an FCM in a personal capacity, and at and for the FCM’s leisure. A flight conducted by an FCM as a private operation is not a recreational private operation if it is conducted for, or on behalf of, an entity (regardless of whether or not the entity is an operator).
Reporting time
The time assigned to a pilot to commence an FDP.
Roster
A list made available to a pilot by the operator, Hot Air Balloon Tasmania setting out the times when the pilot is assigned to undertake duties or standby.
Sector
The following meanings:
· except for a rotorcraft—any flight consisting of a take-off and a landing, when conducted by a person in the capacity of a FCM;
· each hour, or each part of an hour, of an FDP spent in a synthetic training device.
Single pilot operation
Any operation other than a multi-pilot operation.
Sleep opportunity
A period of time during an ODP when an FCM:
· is not meeting the reasonable requirements of bodily functioning, such as:
- eating
- drinking
- washing
- dressing; and
- has access to suitable sleeping accommodation without, under normal circumstances, being interrupted by any requirement of the operator.
Note: Normal circumstances refer to those situations where the operator wishes to preserve the prior sleep opportunity. Abnormal circumstances refer to the case where the operator needs to contact the FCM and it is understood that this will mean that the prior sleep opportunity has been interrupted.
Split-duty rest period
A predefined period of time during which an FCM:
· has access to suitable resting accommodation or suitable sleeping accommodation; and
· is relieved of all duties associated with their employment by the operator.
Standby
A period of time during which an FCM:
· is required by an operator to hold themselves available for duties
· has access to suitable sleeping accommodation
· is free from all duties associated with their employment.
Standby-like arrangement
A period of time during which a pilot:
· is required by an operator to hold themselves available for duties
· has access to suitable sleeping accommodation
· is free from all duties associated with their employment.
Suitable resting accommodation
A comfortable resting area that:
· has a comfortable temperature and minimal noise levels
· contains at least a comfortable chair
· provides access to adequate sustenance at times appropriate to the duty requirements.
Suitable sleeping accommodation
Accommodation not within an aircraft that is fit for purpose for an FCM to obtain sleep, and that includes all of the following:
· a comfortable room, compartment or facility
· a single occupancy, at the discretion of the FCM
· access to clean, tidy and hygienic amenities, including a toilet and hand washing basin
· a bed that is comfortable, flat and horizontal, allowing the occupant to sleep on their stomach, back, and either side
· minimum noise levels, including low occurrence of random noise
· the means to control light, temperature and ventilation
· access to adequate sustenance
Time zone
A defined region of earth with a uniform local time which differs by one hour, or by part of one hour, from the uniform local time of an adjoining region of the earth.
Unforeseen operational circumstance
An unplanned exceptional event that becomes evident after the commencement of the FDP (i.e. un-forecast weather, equipment malfunction, or air traffic delay).
Reference material
Document type
Title
CASR
Civil Aviation Safety Regulations 1998
Reference documents
See Appendix D of this manual
Revision history
Revisions to this manual are recorded below in order of most recent first.
Version no.
Date
Parts / sections
Details
1 Flight crew member fatigue management
1.1 Fatigue management policy
Hot Air Balloon Tasmania is committed to ensuring accumulated fatigue does not reach a level where it results in unsafe working practices and procedures. In terms of pilot fatigue management, we are committed to:
· ensuring that our pilots are aware of the way fatigue builds up, to identify it, manage it and recover from it
· embracing a just safety culture that enables open and fair reporting which allows us to learn and improve our understanding of the impact of fatigue and the best ways to manage it
· fatigue management rostering practices that avoid disruptive roster patterns and minimise the risks associated with fatigued pilots, with the goal of having no flights on which pilots are impaired by fatigue to the extent that safety is impacted.
HABT will not require a pilot to operate an aircraft if the pilot is suffering from fatigue or considering the circumstances of the flight to be undertaken, is likely to suffer from fatigue, which may so impair the pilot’s performance that the safety of the operation may be affected.
This policy and the fatigue management procedures noted in this manual apply to, and are expected to be followed by, (as applicable):
· all pilots employed or engaged by HABT regardless of their employment status
· all staff (including management), whose work may cause (or impact on) the fatigue of pilots, e.g. with their involvement in pilot rostering, extensions, reporting and continual improvement.
This fatigue management policy and procedures section will be formally reviewed:
· once a year on the anniversary of commencement of operations to this supplement
· upon identification of a fatigue related issue associated with this section including extensions
· upon dissemination of relevant scientific advances improving fatigue management
· if operations change significantly enough to affect rostering, crewing, training or aircraft types
· if there are any amendments to applicable legislation.
The formal review will be conducted by the Chief Pilot and stored as a record associated with flight and duty times. The review is to ensure continual improvement of the system and its ongoing applicability to current operations.
1.2 Flight duty limitations and fatigue management
HABT complies with CAO 48.1 Instrument 2019 Appendix 4A for Balloon Operations.
1.2.1 Responsibilities
1.2.1.1 Chief Pilot Responsibilities
The Chief Pilot has responsibility for implementing and managing the fatigue management system on behalf of HABT. Responsibilities include:
· maintaining a reporting system for fatigue occurrences
· ensuring roster limits are designed and promulgated in accordance with (iaw) the provisions of this manual
· designating and recording a home base for each pilot and ensuring that each pilot is advised of this designation
· ensure the roster is kept as up-to-date as possible and includes the most accurate account of expected operations for at least the following 7 days
· ensuring records of the following are made and stored for a minimum of 5 years:
- the roster – the roster will be backed up daily and considered a reasonable prediction of operations for the following 7 days
- ensuring records are maintained of all actual flight duty periods, standby periods, duty periods, split-duty periods. Off-duty periods and actual flight times of each pilot when acting in the capacity of a crew member
- extensions and exceedances including details of the situation involved and why the extension was required for the purposes of continual improvement.
· authorising extensions in unforeseen operational circumstances (iaw Section 1.3 – Conditions and processes for extensions to limitations)
· maintain a register of suitable accommodation locations (hotels/motels etc.) applicable to the scope of company operations
· ensuring pilots are contacted only in accordance with the communication protocol (refer Section 1.2.1.4 – Communication protocol)
· ensuring all pilots and relevant staff (including rostering staff) are trained in accordance with Section 1.2.11 – Training
· ensuring all pilots are aware of the fatigue management system, its limits and procedures and their responsibilities
· conducting Fatigue hazard identification in accordance with Section 1.2.12 – Fatigue hazard identification
· conduct an annual formal review and other reviews as required by the Fatigue Management Policies and Procedures (iaw Section 1.1 – Fatigue management policy).
1.2.1.2 Pilot responsibilities
HABT recognises that many factors are outside the control of the individual and unforeseen circumstances will arise from time to time that will affect the individual’s ability to manage their sleep opportunities and level of fatigue. However, pilots have a legal responsibility to appropriately manage fatigue factors (and fitness for duty generally) that it is reasonable to consider are within their control and thereby prepare adequately for each flight duty period. Pilots also have a responsibility to notify the Chief Pilot if they believe they are not or unlikely to be fit for a flight.
HABT expects the following from its pilots in respect of fatigue management. All pilots must:
· participate in the Company provided training and work towards a detailed understanding of the underlying causes, effects, mitigation strategies applicable to both fatigue and alertness management
· take advantage of sleep and rest opportunities provided to achieve required restorative sleep or rest, in order to be sufficiently alert for subsequent flight duties
· monitor their fatigue state and advise the Chief Pilot (or delegated person) via the communications protocol (refer Section 1.2.1.4 – Communication protocol) as soon as possible once they believe that they might not be available or could have an unacceptable fatigue risk level
· complete a fatigue occurrence report (Form OR) when they believe that fatigue has led to an unacceptable reduction in safety margins or would have led to an unacceptable reduction in safety margins had some additional mitigating action not been taken
· accurately record actual flight and duty times (refer Section 1.2.7 – Recording flight & duty times)
· notify the Chief Pilot (or delegated person) via the communications protocol as soon as it becomes apparent that flight and duty time limits might be exceeded (e.g. due to unforeseen operational circumstances)
· if working on a contract basis, provide details of previous FDPs, ODPs and cumulated flight and duty time so that rosters can be built that do not exceed any limits
· if they become aware of any errors in rosters, or the possibility of exceeding cumulative limits bring these to the attention of the Chief Pilot (or delegated person)
· be aware of obligations relating to extensions and reassignments, including when to refuse, consideration of alertness and authorisation requirements
· notify the Chief Pilot (or delegated person), of their personal situation or any changes to their situation, if they believe that, because of its nature, duration, effects or for any other reason, it might impact on their ability to meet the operator’s fatigue risk management policies or their obligations. This could include factors such as: a new baby, being a caregiver, secondary employment, travelling a long distance to report for duty. Once notified this will be noted as a continuing state of affairs for the pilot and does not require repetition reporting (unless circumstances change)
· report for duty. Once notified this will be noted as a continuing state of affairs for the pilot and does not require repetition reporting (unless circumstances change).
1.2.1.3 Alertness consideration table (Form ACTab)
It is recommended that the alertness consideration table Form ACTab be used to assist a pilot in assessing their alertness before an FDP or extension. This table is for assistance to increase the awareness of the Pilot and operator to the individual’s current fatigue status. If the pilot feels they are too fatigued to commence or continue in an FDP or to undertake an extension, then they should report fatigued and discontinue the FDP. Similarly, while 5:03 PMHABT may use the Form ACTab to assist in discussing the pilot’s level of fatigue, the form, similar to any predictive fatigue tool, should not be used as a means to apply any pressure pilots to continue an FDP or undertake an extension.
Alternatives to Form ACTab (Appendix B) may be found on the iOS App Store or the Google Play Store. For example: Fatigue SAFE, Fatigue App. These applications could be used as a starting point in the assessment of an individual's fatigue level.
1.2.1.4 Communication protocol
All communications between HABT and a pilot during an ODP or that could impact on the pilot’s sleep prior to an FDP must be in accordance with the following communication protocol.
During an Off-Duty Period
A pilot will only be contacted during the 10 hours prior to an FDP if there is to be a delay in FDP commencement time and then preferably by SMS. A voice message may be left if the message is deemed too complex for SMS:
· the pilot should ensure that their registered mobile is on ‘silent’ during sleep periods to, as best as possible, ensure uninterrupted restorative sleep
· the pilot must check their SMS messages and reply to any SMS or voice message notifying the pilot of a delay, before leaving the location of the prior sleep opportunity
· an SMS sent and shown as delivered or leaving a voice message is deemed to be notification however the pilot shall still reply to the SMS before leaving the location of the prior sleep opportunity to confirm they understand the message
· the timing and content of SMS messages (and phone calls) regarding delays will be logged in the rostering system.
All required or urgent communications between a pilot and HABT during an ODP or FDP will be in accordance with the following communication protocol:
· in the first instance the pilot will contact the Chief Pilot as soon as practicable on the duty phone number
· if no answer is received, the pilot will leave a detailed voice message including their name and aircraft registration (if appropriate) and send an SMS message notifying that a voice message has been left
· if the message relates to an extension request, the pilot must ensure they receive a response approving the extension prior to extending.
All required or urgent communications between the Chief Pilot and a pilot during an FDP will be in accordance with the following communication protocol:
· in the first instance the Chief Pilot will contact the pilot on their registered mobile phone number supplied by the pilot
· if no answer is received, the Chief Pilot will leave a detailed voice message and send an SMS message notifying that a voice message has been left
· if the message relates to an extension request, the Chief Pilot will gather sufficient information about the nature of the extension and the level of fatigue of the pilot to ensure they can adequately assess whether safety will be impacted before approving the extension.
1.2.2 Prior sleep opportunity
When rostered for an FDP or period of standby the pilot will have at least 8 consecutive hours sleep opportunity in the preceding 10 hours before the planned commencement of their duty or 10 hours sleep opportunity of which 6 must be consecutive within the 24 hours immediately before the commencement of the FDP.
1.2.3 Duty time, FDP flight time and cumulative limits
For HABT an FDP is a period of time which starts when a pilot is required by HABT to report for a duty period in which one or more flights as a pilot are undertaken and ends not less than 15 minutes after the end of the pilot’s final flight.
Table 1: Maximum FDP
Does the FDP contain a split-duty rest period?
Maximum FDP (hours)
No
6
Yes
10
An FCM cannot continue an FDP for longer than 6 hours unless they have completed or commenced a split-duty rest period of at least 4 consecutive hours.
Table 2: Cumulative limits on flight and duty times and off duty period limits
The following limits on cumulative flight time will apply
Period
Flight time limit (must not exceed)
Any 28 Consecutive Days
50 hours
Period
Duty time limit (must not exceed)
Any 168 consecutive hours (7 Days)
45 hours
Any 336 consecutive hours (14 Days)
84 hours
ODP limits - projected to end of assigned FDP or standby
Before an FDP
At least 2 full days off duty (do not have to be consecutive) in the 14 days before the projected end time of the FDP (a full day is the period between two midnights)
Following an FDP
At least 10 consecutive hours
Split ODP in to 2 ODP of not less than 4 consecutive hours
May split ODP of 2 periods of not less than 4 hours, intervening FDP not more than 2 hours. Total ODP is to be no less than 13 hours.
1.2.4 Increase in FDP limits by split duty
Split-duty rest periods may be assigned as part of the rostered FDP or they may be assigned on the day of operations. Rostering staff will notify the pilot of the need for a split duty rest period as soon as they become aware. The split-duty rest period must have a designated rest location that meets the standard for suitable sleeping or resting accommodation (refer Section 1.2.10 – Accommodation).
The split duty times and limits are as follows:
Table 3: Split duty times and limits
Location/time
Minimum split duty rest period
FDP limits
Access to suitable sleeping accommodation.
4 hours
· Increased by duration of the split duty rest period.
· Total FDP including the split-duty rest period must not exceed 15 hours.
· Remaining portion of FDP after split-duty rest to be no more than five hours
Split rest includes the period 2100 to 0329 local time with access to suitable sleeping accommodation
7 hours
· Increased by the duration of the split rest duty.
· Total FDP including the split-duty rest period must not exceed 15 hours.
· Remaining portion of the FDP following the split rest period must be no longer than 5 hours.
1.2.5 Off duty periods
Refer Table 2 Cumulative Limits on Flight and Duty times and Off Duty Periods Limits.
1.2.6 Access to sustenance
Where an FDP is to exceed 5 hours HABT will provide the pilot the opportunity for a meal break during that FDP. Not more than 5 hours will elapse between opportunities to access adequate sustenance. At home base a fridge has been provided specifically for food/beverage storage to facilitate access to adequate sustenance.
1.2.7 Recording flight and duty times
Flight and duty records (refer Section 1.2.13) are stored in the Pilots file (Flight Ops Documents) on the computer at Head Office. Each pilot is responsible for recording accurate flight and duty times and other relevant information in the system as soon as practicable after each duty period and not more than 24 hours after the duty has been completed. If the pilot cannot record the relevant information within 24 hours, they should contact the Chief Pilot with the details to maintain the accuracy of the rostering system.
Pilots will be trained in the rostering and recording system as part of the specific fatigue management processes and procedures training (refer Section 1.2.11 - Training).
If a pilot becomes aware of any errors in rostering (or the possibility of exceeding cumulative limits) these must be brought to the attention of the Chief Pilot as soon as possible.
The rostering and recording system will be backed up at least monthly and records (including electronic files) kept for 5 years.
1.2.8 Reporting
1.2.8.1 Fatigue occurrence reporting
HABT hazard reporting system includes fatigue occurrence reporting. If any of the following occur, a fatigue occurrence report (Form OR – Appendix A) must be submitted to the Chief Pilot.
· a pilot has not commenced an FDP (or an FDP has not been completed) due entirely, or in part, to fatigue. This includes when the FDP is completed but only after some additional mitigating action such as adding an extra crew member, reducing the workload of the duty, delaying the reporting time and creating the opportunity for an unscheduled inflight rest, increasing supervision/monitoring
· following an FDP if the FCM believes (upon reflection) that the level of fatigue they, or other crew members, were experiencing meant sufficient safety margins had not been maintained throughout the flight(s)
· when the FCM notices something in their operating environment that is likely to impact on their, or other crew members’, alertness to such an extent that safety margins could be reduced to unsatisfactory levels
· when an incident or event has occurred where fatigue may, or may not, have been a contributing safety factor. Additionally, an ATSB and ABF incident report form will be submitted with the fatigue details completed including the pilot’s sleep history for the previous 72 hours. The incident report form (with fatigue related issues) and/or the fatigue occurrence report will be stored as part of the Flight and Duty Records or if confidential, stored appropriately by the Chief Pilot.
· Refer to Appendix 7 & 8, HABT Ops Manual Aviation Accident or Incident Notification.
1.2.8.2 Extensions reporting
All extensions or exceedances to FDPs or flight time limits require an extension report to be filled out (Form ER) and provided to the Chief Pilot. There should be sufficient detail to establish what happened and what the circumstances were that led to the extension or exceedance.
1.2.9 Home base
Any change to a pilot’s home base will trigger the requirement for 3 consecutive off-duty days commencing from the day the change becomes effective.
1.2.10 Accommodation
The Chief Pilot is responsible for ensuring that pilots have access to suitable accommodation when away from home base and assigned to be on standby, or on split duty.
A pilot’s home or residence is taken to be suitable accommodation (resting or sleeping).
The Chief Pilot will retain a list of assessed and suitable accommodation for the purposes of rostering and this will form part of the flight and duty records.
When assessing sleeping accommodation that is not a three star (or equivalent) commercial motel or hotel for suitability the standard for suitable sleeping accommodation (see definitions) will be required.
If the accommodation is within a commercial motel or hotel that has previously been used by flight crew without any adverse reports, or if a pilot can attest to the suitability of the facility, it is deemed suitable. If a pilot finds any aspect of away accommodation unsuitable, they must advise the Chief Pilot and submit a fatigue occurrence report (Form OR) as a ‘general concern regarding fatigue’.
If the anticipated accommodation is a commercial hotel of 3 stars or more standard the assessment by the Chief Pilot can be done remotely.
When a pilot is away from home base, they should ensure the quality of their restorative sleep, including by ensuring as much as possible that they will not be disturbed. If at a hotel this can be facilitated by advising reception staff not to disturb (i.e. no phone messages unless very urgent), by putting the ‘do not disturb’ sign on the door and by ensuring mobile phones are on silent (and charged).
When rostering a split duty rest period at suitable resting accommodation (other than at the pilot’s home) the standard for suitable resting accommodation (see definitions) will be required.
1.2.11 Training
1.2.11.1 Training management
· training includes a general fatigue knowledge component and a component that addresses HABT’s specific fatigue management processes and procedures. A syllabus of topics for each is found below in Table 4 – Fatigue training syllabus
· the Chief Pilot, and any delegates assigned fatigue management responsibilities such as rostering, and each pilot, will complete HABT’s specific fatigue management processes and procedures training before commencing authorisation, flying or rostering activities with HABT.
· the Chief Pilot and any delegates assigned fatigue management responsibilities such as rostering, and each pilot, will complete fatigue knowledge training as soon as possible after they commences with HABT and may be delayed if necessary but in any case no longer than 6 months from when they commenced with HABT.
· if the pilot can show that they have conducted training in the fatigue knowledge component with another operator that conducts similar operations then while the date of that training remains within three years (the currency period), they do not need to complete the fatigue knowledge component of this training syllabus
· before commencing in the position, the Chief Pilot will be familiar with the relevant sections of the operations manual, in particular Sections 1.1, 1.2, 1.3, & 2.
· the elements of training that relate to the management of specific fatigue risk, that is, when that training forms a part of the risk management plan in the hazard and risk register, will be completed before the pilot is permitted to conduct the specific operations concerned
· at the completion of each training course each pilot or staff member must successfully complete an assessment and thereby satisfy the Chief Pilot or delegated person that he or she has sufficient fatigue knowledge, and understanding of HABT’s specific fatigue management processes and procedures to meet their obligations under HABTs fatigue risk management policies, limits and procedures. A pass mark is 80%, with any errors discussed with the student and corrected by the facilitator. Any mark below 80% will require re-training and assessment.
1.2.11.2 Training facilitation
Training will be facilitated by a staff member who has completed a minimum of the following:
· participated as a trainee in the HABT fatigue training course and received an assessment of 90% or higher (with correction to 100% knowledge)
· facilitated an entire fatigue training course under the direct supervision of a HABT staff member who meets the standard required to facilitate the fatigue training course (supervisor will be present during course delivery and provide feedback), or who developed the training course.
1.2.11.3 Records
The training and assessment records as well as records of facilitator qualification will form part of the fatigue management records and be kept for the period that the pilot is with HABT plus 1 year. Records of training and assessment should be copied and placed in each pilot’s file.
1.2.11.4 Fatigue knowledge training
There are three main subject areas which form the substance of the fatigue knowledge training program (fatigue, sleep and countermeasures) listed in sections 1 to 3 of the fatigue training syllabus.
1.2.11.5 Company specific procedures training
The training for company specific procedures includes all topics as listed in section 4 of the fatigue training syllabus.
1.2.11.6 Recurrent fatigue training
Chief Pilot, each pilot and each rostering staff member will have recurrent training, both knowledge and company specific procedures, at intervals no longer than 3 years.
The recurrent training syllabus will revise previous fatigue topics (fatigue, sleep and countermeasures) as well as revision of company specific fatigue topics, especially any operations manual changes that have been promulgated solely by internal communication channels. This revision will be covered with a simple question and answer format.
The recurrent training syllabus should consider including knowledge and understanding captured in the fatigue hazard section and include de-identified scenarios from the reporting systems to both expand on the pilot’s knowledge and to raise awareness of company specific hazards and mitigations.
At the completion of each training course each pilot or staff member must successfully complete an assessment and thereby satisfy the Chief Pilot that he or she has sufficient fatigue knowledge, and understanding of HABT’s specific fatigue management processes and procedures to meet their obligations under HABT’s fatigue risk management policies, limits and procedures. A pass mark is 80% will be corrected to 100% with the student. Any mark below 80% will require re-training and assessment.
Table 4: Fatigue training syllabus
Fatigue training syllabus
Delivery Method:
· Lecture and Facilitated Discussion
Assessment Methodology:
· Facilitator assessment of appropriate level of engagement during sessions
· Multiple choice knowledge test.
(Any incorrect answers to be reviewed via facilitated discussion during post-test debrief)
Training Materials:
· Electronic Presentation Media
· Fatigue / Ops Manual
· CAO 48.1
· CAAP 48-1
Fatigue knowledge
Notes
1. Sleep
Duration: 1hr (1x 50 min session with 10 min break)
1.1 sleep physiology
· Achieve an understanding of the physiological need for sleep:
- Describe the process of the build-up of ‘sleep pressure’ while awake
- Develop an awareness of average and individual minimum sleep needs
· Describe the normal sleep process:
- Achieve a basic understanding of sleep cycles and structure
· Develop an understanding of the need for quality sleep:
- Describe the impact of fragmented sleep on sleep quality.
Session 1
1.2 circadian body clock
· Describe circadian rhythms:
- Develop an understanding of the biological rhythms that affect alertness and sleepiness
- Achieve an understanding of terms such as ‘Sleep gate’ and ‘Window of Circadian Low’
- Achieve an understanding of the impact of daylight on setting or resetting of circadian rhythms.
Session 1
1.3 sleep disorders
· Develop an awareness of common disorders that may impact sleep quality or quantity including:
- Sleep apnoea
- Insomnia.
Session 1
1.4 sleep debt and recovery
· Develop an understanding of how a sleep debt can occur:
- Describe link between repeated minor sleep loss and substantial sleep debt
· Describe how sleep debt must be repaid:
- Develop an awareness of the potential need for multiple nights of recovery sleep to regain optimum performance.
Session 2
1.5 shift work
· Achieve an understanding of the impact of shift-work on sleep and performance:
- Describe how shift work can impact sleep quantity and quality
- Develop an understand of how shift work can result in working at times of circadian lows.
Session 2
2. Fatigue
Duration: 1hr (1x 50 min sessions with 10 min break)
2.1 Understanding fatigue
· Define fatigue
· Achieve an understanding of the types of fatigue:
- Describe transient and cumulative fatigue.
Session 3
2.2 The causes and contributors to fatigue
· Identify major factors affecting fatigue including:
- Time of day (circadian rhythm effects)
- Recent sleep quantity and quality
- Time awake
- Time on Task
- Nature of tasks
- Environmental conditions
- Hydration
- Fitness
- Food
Session 3
2.3 Signs and symptoms of fatigue
· Identify the range of signs and symptoms associated with fatigue including:
- Physical
- Mental
- Emotional.
Session 3
2.4 The consequences of fatigue on safety
· Understanding the impact of fatigue on the effective performance of tasks.
Session 4
2.5 High fatigue risk situations
· Be aware of the areas of human performance most affected by fatigue:
- Develop knowledge of the type of tasks more sensitive to onset of fatigue related performance decrease.
· Develop an understanding of environments and times of the day where fatigue is more likely to occur or to develop more quickly.
Session 4
2.6 The contribution of fatigue in accidents
· Appreciate the contribution of fatigue to incidents and accidents in the aviation environment:
- Review international and Australian case studies of fatigue related aviation incidents and accidents.
Session 4
2.7 Recovery from Fatigue
Understand sleep is the only way to recover from fatigue:
· Develop an understanding of the average time needed to recover from:
- Transient
- Cumulative fatigue.
Session 4
3. Countermeasures
Duration: 1hr (1x 50 min sessions with 10 min break)
3.1 tailoring the sleep environment
· Describe setting up a bedroom or sleeping facility to aid in achieving quality sleep.
Session 5
3.2 managing sleep habits
· Understand how to develop habits beneficial to quality sleep.
Session 5
3.3 napping
· Describe the benefits of napping
· Develop an understanding of how napping can reduce the impact of fatigue during duties
· Describe effective napping techniques:
- Achieve an understanding of controlling napping duration to reduce sleep inertia
Session 5
3.4 exercise
· Describe how exercise can assist in mitigating the impact of fatigue.
· Describe how increased fitness can improve individual resistance to the onset of fatigue.
Session 5
3.5 nutrition and hydration
· Describe how appropriate nutrition and hydration can aid in mitigating fatigue.
· Develop an understanding of food types and nutrition strategies that maintain energy without causing undue drowsiness.
Session 5
3.6 caffeine
· Describe the effect of caffeine on alertness.
· Develop an understanding of the benefits and limitations of the strategic use of caffeine to mitigate fatigue.
Session 6
3.7 avoidance of alcohol before bed
· Be aware of the impact of alcohol on the quality of sleep:
- Develop an understanding of appropriate consumption of alcohol to limit the impact on sleep quality.
Session 6
3.8 use of sleep aids
· Describe common prescription and over the counter sleeping pills and sedatives.
· Understand the use, limitations and risks associated with the use of sleep aids:
- Develop an understanding of the health and performance effects of sleeping pills and sedatives.
- Describe the concept of clearance times associated with the use of sleep aids.
Session 6
3.9 avoidance of nicotine
· Develop awareness that nicotine is a stimulant that may impact ability to sleep.
Session 6
3.10 keeping a sleep log
· Discuss the limitations of informally tracking sleep quantity and quality:
- Develop an awareness of the potential for overestimating sleep.
· Discuss the use of a structured sleep log to accurately record sleep quantity and quality:
- Identify the structure and content of an appropriate log to aide recording of sleep information.
- Develop an appreciation of the benefits of a sleep log in identifying negative habits or repeated minor sleep deficits and in forming beneficial sleep habits.
Session 6
4. Company fatigue management procedures
Duration: 1hr (1x 50 min sessions with 10 min break)
4.1 Fatigue Risk Management Policies
· Develop an understanding of organisational fatigue risk management policies appropriate for the individuals’ position and duties.
Session 7
4.2 Application of Flight and Duty Limits
· Ensure an understanding of the application of organisational flight and duty time limits.
Session 7
4.3 Fatigue Management processes and Procedures
· Develop a working understanding of organisational fatigue management procedures and processes (including proper use of forms).
Session 7
4.4 Extension policy and procedures
· Understand the application of organisational policy and procedure for extensions (and exceedances).
Session 8
4.5 Flight Crew Members’ obligations
· Develop an awareness of the pilot’s obligations regarding individual fatigue management.
Session 8
4.6 Rostering and recording system
· Understand the use of the organisation’s rostering and recording system.
Session 8
1.2.12 Fatigue hazard identification
HABT will undertake fatigue hazard identification and management, to ensure that pilots can safely operate an aircraft or perform safety related duties and minimise any fatigue risk.
The fatigue hazard identification follows through three phases and will be an ongoing process. It will also be used to determine adjustments to prescriptive limits to suit HABT’s operations and circumstances (which will not in any case exceed Appendix 2 limits). Any proposed operations will be subject to the fatigue hazard identification process before pilots will be permitted to conduct the operation. The process may also determine other controls that can be used to minimise fatigue risks.
HABT will undertake the following hazard identification and risk management phases:
1.2.12.1 Initial hazard identification
HABT will identify fatigue hazards that could potentially cause harm to the health and safety of people or damage to plant and equipment. HABT will work with pilots and other staff to identify fatigue hazards that may occur within the following situations:
· work tasks & how performed (e.g.: rostering practices, flying without an autopilot)
· physical work environment (e.g.: hot weather conditions)
· use of equipment, material (e.g.: NVG operations)
· work design and management (e.g.: low level flying or limits for newly qualified pilots).
HABT may use a number of methods to assist in the process of identifying fatigue hazards and these may include one or more of the following:
· pilot’s input from their experience of particular types of operations
· any fatigue problems brought to the attention of the Chief Pilot
· information from Flight and Duty records, including fatigue reports, extension reports and any reported exceedances
· consulting with colleagues/discussion
· review of standards, procedures and systems (including observations)
· staff surveys or questionnaires (if conducted)
· external sources (such as industry specific knowledge sources and industry groups)
· details from external audits/safety assessments
HABT will take action to minimise or eliminate fatigue risk "as low as reasonably practicable". Information gathered through this phase and the following two phases will be used to populate Table 10.
Column 1 in Table 10 details the hazards identified by the above steps. Any existing controls (such as legislation) will be entered into the table (column 2). This column will also include any other controls that could reasonably be considered as acting to manage the fatigue risk such as workload on the ground, the temperature, noise and vibration, hunger and hydration. Column 3 designates whether the hazard is still present and / or reduced.
Further risk management controls (especially limit adjustment) to manage the risk “as low as reasonably practicable” will be found in column 4. It is important to consider any informal controls that are being used and consider whether they need to be made more formal (documented) as an additional control to ensure they are reliably applied. The information in column 4 should then be considered for adequacy and a decision made as to whether any limits such as those in in Section Error! Reference source not found.- Duty Time FDP, Flight Time and Cumulative limits need to be adjusted. Column 5 designates whether the hazard remains and / or is further reduced with the mitigation(s).
To ensure monitoring and evaluation of the risk management procedures, a responsible person will be assigned for each entry and any further policy or practice considerations will be entered into column 6.
The major outcome of this initial phase is to identify hazards and recommend any mitigations required.
Incidents: HABT will analyse reports received through the incident and/or fatigue occurrence or extension reporting systems for root causes (the ‘why’ of a situation).
The results of this analysis may identify new fatigue hazards or lead to amending existing fatigue risk mitigation.
These results must be entered into Table 10 (and may have a reference linking them back to the specific report).
(Refer Section 1.2.8- Reporting, Section 1.3.1- Extensions).
Annual Review and Significant Change: At this time the fatigue management approach (including hazard identification and risk mitigation) is reviewed and amended where necessary. Refer to Section 1.1 - Fatigue management policy.
HABT will meet with all pilots and staff (or provide a way for their input into the process) every 12 months (at a minimum) and will discuss:
· a summary of fatigue reports including specific mention of more significant reports and all hazards identified and mitigation actions since the last review
· fatigue Risk Management controls – general review of adequacy
· review all limits (as defined in Section 1.2.3) as set by HABT- review adequacy
· accommodation – Any issues or required improvements
· extension Reports – review procedures and improvement recommendations that could be made
· communication Protocols – Improvement recommendations
· hazard Identification process – review adequacy.
This review will also occur when there are significant operational changes including those affecting rostering, the introduction of new aircraft types, new operational areas or routes, new training methods or the introduction of new technology.
Records from the Fatigue Hazard Identification Phases and associated reviews will be kept with the flight and duty records (Section 1.2.13- Recording flight and duty times).
The table and analysis form part of the Flight and Duty Records
Table 10: Fatigue Hazard Identification Register
Identified Fatigued Hazard (date recorded)
Existing Controls
Hazard still present Yes/No/Diminished?
Additional mitigations
Hazard still present Yes/No/Diminished?
Responsible Person and Policies and Practice Considerations
Insufficient or disrupted sleep prior to duty period
Report fatigued
Fatigue Training
Yes
Controlled rest
Caffeine
Diminished
Chief Pilot to monitor fatigue reports.
High Noise levels – Burners / Inflation fan
Fatigue training
No
Ear plugs
No
Chief Pilot
Extreme
temperatures effecting
Sleep
Heat
Fatigue Training
Diminished
Rest intervals conducted in climate controlled facilities, when required
Encourage regular hydration
Diminished to acceptable levels
Hot condition possible between Jan - Feb
Chief Pilot to monitor fatigue reports.
Cold
Consecutive WOCL duties causing fatigue
Fatigue Training
Limit of 3 Consecutive WOCL duties per 7 days
Fatigue Training
Diminished
Yes
Heat pump (air con) gas fire and additional bedding available
Max Limit of two consecutive WOCL duties per 7 days
Increased ODP
Controlled rest
Caffeine
Sleep monitoring
Cold temperatures exist for operations between June – Oct.
Diminished to acceptable levels
Chief Pilot to monitor fatigue reports.
Chief Pilot
1.2.13 Flight and duty records
Flight and Duty Records include all details relevant to the rostering and fatigue management system and specifically include:
· rosters planned and achieved, and staff home base designation
· fatigue occurrence reports
· incident Reports that involve fatigue
· analysis or reports, actions and conclusion stemming from fatigue related investigations
· extension/exceedance reports
· notifications from pilots of unavailability due to fatigue (if not resulting in a fatigue occurrence report)
· the results of annual review of the fatigue management system
· the results of fatigue hazard identification and mitigation reviews
· training and assessment records relating to the fatigue management system
· the list of suitable sleeping accommodation
· completed alertness consideration tables
· any other unique arrangements (e.g. prior sleep opportunity arrangement).
All flight and duty records (including the rostering and recording system) will be backed up at least monthly and records (including electronic records) shall be kept for 5 years. Backups and archived records will be stored on USB stick at Head Office to mitigate loss risk. The Chief Pilot is responsible for managing and backing up records.
1.3 Conditions and processes for extensions to limitations
1.3.1 Extensions
An FDP or flight time extension in unforeseen operational circumstances will occur at the discretion of the pilot in command.
An FDP can only be extended if:
· the FDP has commenced
· the pilot considers themselves fit for the extended FDP
· the FDP is extended no more than 1 hour
· the FCM will not exceed the cumulative flight time limits in Table 2.
If unforeseen operational circumstances arise after take-off on the final flight of an FDP; and those circumstances would cause a pilot to exceed any flight and duty time limit then, the pilot can continue to the planned destination discretion as dictated by the safety of passengers and crew. In these circumstances, if limits are exceeded, it is called an exceedance and must be reported and recorded in the same manner as an extension.
Extensions and exceedances require an Extension Report (Form ER – Appendix- C) to be completed in accordance with the reporting provisions in Section 151.2.8– Reporting and must also be recorded in the hazard identification and mitigation system (refer also Section 1.2.12– Fatigue hazard identification).
The report will also form part of the flight and duty records.
Extensions will be reviewed by the Chief Pilot as part of HABT’s continuous improvement system (refer also Section 1.2.12– Fatigue hazard identification) and the analysis will be stored as part of the flight and duty records:
- impacts from increased sectors and/or workloads
- environmental factors including weather and temperature
- aircraft serviceability including MEL items.
2 Rostering in accordance with Flight and Duty Time Policy
The Chief Pilot is responsible for preparing and publishing the roster. The roster will be planned on a 28-day basis and published 7 days before the beginning of the roster period. The roster will be amended and republished as quickly as possible if any changes are made. Any pilot affected by the changes will be notified in accordance with the communication protocol.
Appendix A. Fatigue Occurrence Report (Form OR)
Figure 1: Fatigue Occurrence Report (Form OF)
Appendix B. Alertness Consideration Table (Form ACTab)
Figure 2: Alertness Consideration Table (Form ACTab)
B1 Instructions for using the ACTab prior to duty
Q1. How alert are you feeling?
Question 1 involves the FCM rating their current alertness (ideally close to their report time) using one of the seven options on the alertness scale. The result falls into one of three bands of risk – Low, Moderate, or High.
If High Risk, the FCM must consider discussing this with other employees or the Chief Pilot and may need to address the risk through applying previously defined risk control measures, such as extended rest periods or task rotation. If a decision is made to continue with the duty, proceed to Question 2.
Q2. Have you had adequate sleep?
Question 2 involves the FCM accruing points based on their sleep in the prior 24 hours, 48 hours, and hours wake at the end of the duty. The points sum to produce a final score, which is categorised in terms of risk as Low, Moderate, or High.
Note: 48 hours is used in this table, because the table focuses almost entirely on acute or transient fatigue and the assumption is that the pilot was well rested prior to this point. If the pilot has a longer period of disrupted or restricted sleep then they should consider that the cumulative fatigue associated with this, will increase the fatigue risk. An increased cumulative fatigue will increase the risk associated with subsequent, shorter than required, sleep periods identified in the table and FCMs should put more weight on any symptoms (response to question 1) and take a more conservative approach to any heightened risk identified by using this table.
If the result is High Risk, the pilot must consider discussing this with other employees or the Chief Pilot and may need to address the risk through applying previously defined risk control measures, such as extended rest periods or task rotation. If a decision is made to continue with the duty, proceed to Question 3.
Q3. What time does the duty occur?
Question 3 involves the pilot classifying their duty based on the time of day that the duty occurs. The result falls into one of three bands of risk – Low, Moderate, or High.
They then continue to Question 4.
Q4. What level of operational risk is associated with the duty?
Question 4 involves the pilot classifying the level of operational risk associated with the duty.
It is understood that the accumulation of fatigue will eventually diminish performance and increase error rate, to the point where the pilot becomes ‘fatigue impaired’, or simply too tired for the job intended. Aviation systems should be able to tolerate some human error and diminished performance capability, but very often task demands can increase, due to unforeseen circumstances. Consequently, what was previously acceptable in terms of an acceptable performance/error level, now becomes unacceptable.
Fatigue risk interacts with other areas of human performance, such as workload and task complexity and all of these risks need to be considered and if necessary, addressed.
For fatigue risk, pilots should consider what factors are associated with the tasks allocated to them prior to presenting as fit for duty. This is because it has been well researched that reduced alertness (or the accumulation of fatigue) impacts on ‘real world skills’. Pilots, other employees and the Chief Pilot should consider fatigue risks that may be present in conjunction with other risks, such as the type of task being undertaken, the nature of the airspace, weather considerations, airport demands and aircraft serviceability.
Furthermore, all should recognise that tasks that involve cognitive performance (e.g., decision making, memory capacity) and threat and error management can potentially be poorly measured or mismanaged by a FCM who is fatigued.
Using ACT, the pilot continues to the final step, in order to assist their determination of whether they may have adequate alertness to undertake the duty.
Determine the fatigue risk level and what may need to be considered when determining whether to undertake this duty
Based on the results for Questions 1-4, the pilot can use the table provided to determine whether a fatigue risk may be present during this duty. Together with measured levels of alertness, FCMs can begin discussing how to manage possible risks with the Chief Pilot and subsequently develop an effective risk management plan.
Appendix C. Extension Report (Form ER)
Figure 3: Extension Report (Form ER)
Appendix D. References
Fatigue Related Information (CASA)
Fatigue - updating your operations manual to comply with the new fatigue rules (PDF 331.56 KB) provides a simple, step-by-step approach and useful things to consider when updating your operations manual to comply with the new rules.
Fatigue management strategies for aviation industry - Fatigue management strategies for aviation workers: a training and development workbook (PDF 1.69 MB) should be used in conjunction with Fatigue management for the Australian aviation industry - employee training assessment (below).
Fatigue management for the Australian aviation Industry - Fatigue management: employee training assessment (PDF 805.78 KB) guides assessment of individual competence in each of the topics covered in our fatigue management workbook.
Fatigue management for the Australian aviation industry - Fatigue management: trainer's handbook (PDF 880.67 KB) provides trainers with the tools and strategies to prepare and deliver the face-to-face component of the employee training.
Fatigue management for the Australian aviation industry - Fatigue management for employees (ppt 2.7 MB) is a PowerPoint training presentation to be used in conjunction with our trainer's handbook (above).
CAAP 48-1 Fatigue Management for Flight Crew Members
The guidance version of the legislation is a useful compilation of all amendments to CAO 48.1 Instrument 2019 and contains the fatigue rules that all operators must transition to.