Post-implementation review of the pilot fatigue framework – pilot survey - (DP 2614OS)

Overview

We are conducting a post-implementation review (PIR) of the fatigue framework in Civil Aviation Order 48.1 Instrument 2019 (CAO 48.1).

CAO 48.1 provides a framework for managing the risks of flight crew member (pilot) fatigue in Australian aircraft operations.

In particular, appendices 1 to 7 of CAO 48.1 establish fatigue management settings for commercial operations (commercial operations being operations that are not private operations).

This consultation is part of the PIR to assess whether the current fatigue framework for commercial operations is operating efficiently and effectively and meeting the needs of Australia’s diverse aviation industry.

This consultation is one part of the PIR. It includes 2 sections:

• a survey for pilots to tell us about their experiences with fatigue
• the ability for pilots to provide feedback on the Discussion Paper that is informing our review.

This survey is specifically seeking feedback from pilots covered by the appendices to CAO 48.1 and will generally be less relevant to pilots engaged only in private operations.

Pilots experience the fatigue framework directly through their day-to-day flying duties and can provide unique insights into how the rules, fatigue management practices, and rostering arrangements work in practice.

To ensure we capture both individual and organisational perspectives, we are conducting a separate survey for aircraft operators covered by CAO 48.1. CASA is contacting operators directly for this purpose.

Your feedback will help us understand how the fatigue framework is working in practice and identify opportunities for improvement.

Review of the fatigue management framework

Pilot fatigue is a recognised aviation safety hazard that can affect alertness, decision-making, and operational performance. Factors such as disrupted sleep, night flying, early starts, long duty periods, and changing schedules can all contribute to fatigue.

CAO 48.1 was introduced in 2019 and fully implemented in 2021. Since then, operators have had time to embed fatigue management processes into their operations.

We are now reviewing the framework to:

• assess whether the rules are effective in managing fatigue-related aviation safety risks
• evaluate how efficiently the framework operates for industry
• understand practical implementation challenges
• identify opportunities to improve safety outcomes
• inform future policy and regulatory development.

Survey scope

All survey questions are optional and you can choose whether to complete both parts or just one part.

The first part of this consultation asks you for your experience and feedback as a pilot. It seeks feedback on:

• the effectiveness of the CAO 48.1 scheme
• the efficiency and industry accessibility of the CAO 48.1 arrangements
• rostering practices in relation to certain flying operations that may be a predictor of high(er) fatigue risk.

You do not need to have read the Discussion Paper to tell us about your experiences as a pilot. Many questions can be answered based on your flying experience alone.

However, reading the Discussion Paper before completing the survey may help you provide more informed feedback.

The second part of the survey gives you the opportunity to provide feedback on the Discussion Paper that is informing our review and supporting this consultaion.

• Operations under Appendices 1-6: with a focus on the performance-based elements of operations under these Appendices.
• Fatigue Risk Management Systems (FRMS): the operation, accessibility, scalability and oversight of FRMS approvals and implementation.
• Fatigue reporting and just culture in commercial operations: fatigue reporting practices, organisational safety culture and opportunities to strengthen just culture across the industry.
• Data and evidence: how best to collect and use data to assess the effectiveness of the fatigue framework and support continuous improvement.
• International developments.
• Future improvements: 2 specific policy issues and other suggestions that could improve the operation, effectiveness or efficiency of the framework.

Why your views matter

Your feedback will help us assess whether the CAO 48.1 framework is achieving its intended safety outcomes and identify opportunities to improve its effectiveness and efficiency, with a particular focus on fatigue management in commercial operations.

How to submit feedback

Please submit your comments using the survey link provided below.

If you are unable to provide feedback via the link below, please email us at regulatoryconsultation@casa.gov.au.

What happens next

At the end of the response period, we will:

• review all comments received
• make responses publicly available on the consultation hub (unless you request your submission remain confidential)
• publish a post-implementation review report that takes account of all feedback.

All feedback received will be considered. Relevant feedback will be used to inform further policy analysis and potential improvement to the CAO 48.1 framework.

Related documents

All documents relevant to this consultation are attached in the ‘Related’ section at the bottom of the this page. They are:

• Discussion Paper 2614OS – supports this PIR consultation
• MS Word copy of online consultation.