Fatigue review final report: implementation considerations

Closed 22 Apr 2018

Opened 21 Mar 2018

Results Updated 22 May 2018

Thank you for your feedback to this consultation.

CASA received 26 responses from a wide range of stakeholders including unions and industry representative organisations, aerial mustering, aerial application, rotary, charter, small and large air operators, as well as feedback from a number individuals.

Individual and organisational responses are published here, where permission to publish has been received.

Now that the consultation has closed, all responses will be analysed and considered.

The Aviation Safety Advisory Panel (ASAP) is the primary advisory body through which CASA directs its engagement with industry. CASA anticipates the ASAP will establish a technical working group to help review industry input on implementing the review recommendations.

Feedback received via the CASA Consultation Hub will be provided to the technical working group for consideration prior to CASA releasing a detailed response to the independent review, including an implementation timetable.

CASA expects to have key changes in place during 2018.

Published Responses

View submitted responses where consent has been given to publish the response.


A team of leading international specialists has confirmed the need to modernise Australia’s fatigue rules for air operators and pilots.

The CASA Board has released the final report of the independent review of aviation fatigue rules for operators and pilots. It includes 24 recommendations to improve the fatigue rules contained in CAO 48.1 Instrument 2013 and their implementation.

The independent review considered the safety need for updating the rules, processes underpinning their development and communication to industry, their scientific basis and validity, international alignment, and the impact on the Australian aviation industry.

Key recommendations to improve the fatigue rules include:

  • Revising flight duty period (FDP) limitations by adopting limits more closely aligned with international averages.
  • Increasing the flexibility of the Fatigue Risk Management System (FRMS) option to enhance scalability through additional risk-based tiers.
  • Introducing a standardised approval process (other than an FRMS) to offer limited flexibility for operators to operate beyond the prescriptive limits with specific fatigue risk mitigation measures in place.
  • Removing Part 137 aerial application operations from CAO 48.1 or adopting limits from CASR Sub part 137.Q.
  • A freeze on transition dates until changes flowing from the review are finalised in CAO 48.1 and material to support industry is ready.
  • Allocating appropriate resources to plan a detailed, coordinated implementation for finalising the reform of CAO 48.1.
  • A staggered approach to the next phase of change—addressing the highest risk areas first.

Why We Are Consulting

This consultation invited the aviation community to comment on the recommendations in the review's final report. It was an opportunity for industry stakeholders to raise any implementation issues and provide feedback to CASA on the highest priorities for action.

Download the Fatigue Review Final Report 



  • CASA Staff
  • Aerodrome operators
  • Air operators
  • Instructors and flight examiners
  • Flight training organisations
  • Pilots
  • Sports aviation operators
  • Hot air balloon operators
  • Air traffic controller
  • Drone operator
  • Foreign operator
  • Traveling public / passengers


  • Fatigue management