Air Operator Certification Manual 7 . Other than High Capacity RPT Operations, Initial Issue of an AOC 7.

28 Fatigue Risk Management System

Approved by Group General Managers Air Transport Operations Group and General Aviation Operations Group Version 4.7: December 2004
7 Other than High Capacity RPT Operations, Initial Issue of an AOC 7.28 Fatigue Risk Management System

7.28.1 CAO 48 Exemptions Fatigue Risk Management System

7.28.1.1 Sleep Physiology Sleep is a physiological requirement for all human beings. Considerable research has been conducted on this subject, particular over the last 10 years, to the point that there is now a large body of scientific data from which to draw. Sleep is an active behaviour, which is a reversible, repeating state of unconsciousness that can only be resisted for a limited period of time. Further, laboratory testing and field studies have conclusively determined that insufficient sleep in any given 24 hour period leads to sleep deprivation, that manifests itself in measurable performance degradation. Most significantly for the aviation industry is that such deficits may include reaction time, vigilance, sustained attention, cognitive ability, short-term memory, mental arithmetic, tracking ability, word generation and vocal intonation. 7.28.1.2 What Is CASAs Role? Prior to the Chicago Convention, the only rules governing flight time grounded a pilot who had flown 100 hours or more in the last 30 days, until such time as the pilot had undergone a medical examination clearing him or her for flight. Following the Chicago Convention, the ICAO was established with a view to developing international standards and recommended practices (SARP) to ensure safe, consistent operating practices for civil aviation. ICAO Annex 6 to the Convention on International Civil Aviation recommends that regulatory authorities establish regulations that ensure that fatigue occurring either in a flight or successive flights or accumulated over a period of time due to these and other tasks, does not endanger the safety of a flight.
CAO 48

Australia, as a signatory to the Chicago Convention, adopted this recommendation and imposed prescriptive limits, on flight and duty times, in 1947. These rules were expanded with the introduction of Air Navigation Order 48 in January 1953. CAO 48, which remained largely unchanged from the rules of the 1950s, was introduced in 1988 with the formation of the CAA.

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Air Operator Certification Manual 7 . Other than High Capacity RPT Operations, Initial Issue of an AOC 7.28 Fatigue Risk Management System
Approved by Group General Managers Air Transport Operations Group and General Aviation Operations Group Version 4.7: December 2004

7.28.1.3 Why Change Now?

CAO 48

It was apparent from an early stage that there would be numerous circumstances requiring exemption from strict compliance with CAO 48. This gave rise to the development of a series of Flying Operations Instructions that were, essentially, standard exemptions. CAO 48 makes provision for the issue of exemptions against its requirements and this provision has been widely used to accommodate the increasing demands of what is now a 24 hours a day, seven days a week industry which is extremely diversefrom commercial ballooning to airline operations. This system, which is largely based on exemptions from the rules, has proven difficult to manage and the rules themselves have not kept pace with current science. In fact, it is now widely acknowledged that CAO 48 has more to do with regulating work than managing fatigue. In 2000, the House of Representatives Standing Committee on Tourism, Transport and the Arts released its report into the management of fatigue in the transport industry, entitled Beyond The Midnight Oil. Among other recommendations, the report recommended that The Civil Aviation Safety Authority should implement a Fatigue Risk Management System to regulate flight and duty times for aircrew as soon as it is feasible to do so. That report has also provided the impetus for various State governments to amend their OH&S legislation to actually name fatigue as an occupational health and safety hazard which must be managed this initiative is expected to be adopted nationally in the very new future.

CAO 48

CAO 48

CASA commenced a trial of operator developed safety cases, as the basis of exemptions against CAO 48, in late 2001. This initially involved 21 operators developing Fatigue Management Systems. The overall consensus, of the operators involved, was that the trial provided significant benefits over CAO 48. This was substantiated by the field validation conducted for CASA by the Centre for Sleep Research, at the University of South Australia, which found that: it is appropriate for CASA to develop an ongoing program to ensure that FMSs continue to evolve and improve based on current scientific knowledge, industry feedback and current best-practice from around the world on how to best manage fatigue. The reports recommendations provide the basis for a proposed new outcome based rule set, which will mandate a transition to Fatigue Risk Management Systems as the future method of managing fatigue in the aviation industry in Australia.

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Air Operator Certification Manual 7 . Other than High Capacity RPT Operations, Initial Issue of an AOC 7.28 Fatigue Risk Management System
Approved by Group General Managers Air Transport Operations Group and General Aviation Operations Group Version 4.7: December 2004

7.28.2 References
Legislation: Other References: CAR 5.55 and CAO 48. The Parliament of the Commonwealth of Australia House of Representatives Standing Committee on Communications, Transport and the Arts. BEYOND THE MIDNIGHT OIL: Managing Fatigue in Transport, October 2000. Kirtsy McCulloch, Dr Adam Fletcher & Professor Drew Dawson. MOVING TOWARDS A NON-PRESCRIPTIVE APPROACH TO FATIGUE MANAGEMENT IN AUSTRLIAN AVIATION: A FIELD VALIDATION, August 2003. SLEEP, WAKING AND NEUBEHAVIOURAL PERFORMANCE Naomi L.Rodgers, Jillian Dorrian, David F. Dinges; Frontiers in Bioscience 8, s 1056-1067, September 1, 2003. International Standards and Recommended Practices, Annex 6 to the Convention on International Civil Aviation: Operation of Aircraft Part 1, Chapter 9 Aeroplane Flight Crew, para 9.6 Flight time, flight duty periods and rest periods; Eighth Edition July 2001. Proposed Legislation
(for information only):

CASR Parts 115,119, 133, 136, 137, 141 and 142.

7.28.3 Policy
CASAs policy is to continue the transition to operator developed fatigue risk management systems (FRMS). During the transition period, assessments of prospective FRMS manuals will continue to be undertaken centrally, with increasing input and assistance by Field Office FOIs, as their skills in this area develop.

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Air Operator Certification Manual 7 . Other than High Capacity RPT Operations, Initial Issue of an AOC 7.28 Fatigue Risk Management System
Approved by Group General Managers Air Transport Operations Group and General Aviation Operations Group Version 4.7: December 2004

7.28.4 Process
When an application for an FRMS is received, the appointed inspector should arrange to meet with the operators representatives. As this system requires commitment by management and technical key personnel, both the CEO and CP should attend. It is also advantageous if the appointed author of the FRMS manual can attend, if this is to be another person. The initial discussions should include, but not be limited to, the following topics: The design of such a system must be a shared approach relying on a high level of commitment by both the employer and employees. The first step for implementation of such a system is the need to create a policy by the management to demonstrate this. The design of various aspects of this system such as risk identification, analysis and subsequent mitigation and prescriptive rostering (if applicable) must be designed in consultation with the relevant employees. CASA has defined some of the parameters of these systems such as some definitions, the maximum FAID (if applicable) peak fatigue score and minimum sleep propensity to be a part of the manual. These may be varied from time to time, an inspector should verify accuracy of information passed on. The inspector should impress on the company representatives the requirement of the manual and its purpose. It is to give clear and unambiguous direction to the employees it relates to. The manual must contain all the relevant sections as stated in the Australian New Zealand 4360 Standard and evolve procedures that will demonstrate how the organisation proposes to meet its obligations here. The manual must contain systems and sub-systems that are auditable.

Direction, by the inspector in these areas will enable an operator to design a system that will gain approval quickly and have the maximum effect in reducing the fatigue related risks.

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Air Operator Certification Manual 7 . Other than High Capacity RPT Operations, Initial Issue of an AOC 7.28 Fatigue Risk Management System
Approved by Group General Managers Air Transport Operations Group and General Aviation Operations Group Version 4.7: December 2004

7.28.4.1 Document Evaluation Manuals may be forwarded to CASA in many formats. Operators who already have an existing Safety Management System may elect to incorporate some aspects of the FRMS for simplicity and to avoid duplication. Caution should be exercised here, as the FRMS may not have an amendment implemented without prior CASA approval. In assessing the manual the following are some attributes that an inspector must be satisfied about before approval. The manual must be auditable. It should be assessed using the reasonable persons assessment criteria and must not contain language that will not provide clear instruction in areas where a fixed value is required. For example, if in consultation with employees it has been determined that a maximum of 5 flying hours per day for an activity will provide fatigue risk mitigation, then an instruction to this effect must not contain words such as should or generally. The document must satisfy all the key areas as stated within the AUS NZ 4360 standard. The document must contain risk identification, qualitative or quantitative analysis and subsequent mitigation. This must be done for all activities prescribed on the Air Operators Certificate. If possible statements of pilots, minutes of meetings etc should support this. The document must contain any directions CASA sees fit for inclusion, such as definitions, minimum sleep requirements etc. These requirements may change from time to time in light of current science.

7.28.4.2 Inspection Pre-implementation: Prior to system approval, where the manual states that as part of risk reduction measures the operator will provide facilities for fatigue management, an inspection should be made to assess suitability or conformity with definitions. This can be quite valuable as if timed appropriately an inspector may be able to witness the training phase of the transition to the new system. The inspector could use this opportunity to answer questions that may arise, but should be careful not to take over the training role of the company instructor. Post implementation: An inspection conducted post implementation should be done in accordance with the principles espoused within the Surveillance Procedures Manual.

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Air Operator Certification Manual 7 . Other than High Capacity RPT Operations, Initial Issue of an AOC 7.28 Fatigue Risk Management System
Approved by Group General Managers Air Transport Operations Group and General Aviation Operations Group Version 4.7: December 2004

7.28.5 Exemptions
CAO 48

Form 868 provides a sample of an instrument of approval granting exemption from flight and duty time limitations set out in CAO 48.

7.28.6 Checklists
Please refer to Form 104 Fatigue Management System Assessment Checklist.

7.28.7 Certificates
There are no certificates of approvals related to this subject.

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