Fatigue hazard identification
FATIGUE RISK REGISTER ACTIVITY
CASA has designed a set of prescriptive limitations that are
designed to broadly manage the risk of fatigue due to sleep loss,
time awake, time on duty and the time of day effects.
Tier 2 offers more flexible limits, but with additional operator
obligations (such as hazard identification and continuous
monitoring).
Different workplace environments can increase or decrease
fatigue, as can differing workload. CASA has only provided
minimal consideration of these influences within the limitations,
for example, the number of sectors flown.
Operators should consider their own circumstances using prior
company experience or discussions with other operators and
groups so that these measures may be included within their
operations manual.
Activity – List 3 fatigue hazards for your operation
Identified fatigue hazard Existing controls
Your next steps
oo Develop fatigue risk register
oo The fatigue risk register is referenced in your operations
manual (The process for updates will need to be further considered if the
fatigue risk register is maintained within the operations manual)
oo Implement a process for fatigue reporting, analysis of fatigue
reporting and feedback loop
oo Consider developing fatigue reporting forms
oo Is fatigue being adequately managed and not affecting safety
of operations?
• Implement a process for review of limits
• Implement a process to review rostering practices
www.casa.gov.au/fatigue
Operators are reminded that it may be possible to reduce the
identified hazard through means other than limiting flight or
duty times.
If an operator has an approved safety management system
(SMS), the processes within the SMS could, and should, be
used for the purposes of complying with those obligations.
In the activity below you should consider:
What policy, procedures and training you have in place
to control the risk? Do fatigue occurrence reports or survey
results suggest changes are needed?
If an operator has an approved SMS, the processes within the SMS should
be considered.
Additional risk management
oo Will you need to operate across multiple appendices?
• Implement processes for transitioning across appendices
so that the FCM does not exceed applicable
limits and safety is not impacted
oo Document informal procedures which management and
FCMs have already identified as ways of avoiding
fatigue and managing fatigue during duty periods
oo Communicate practices, procedures and processes across
the organisation
oo Set up ongoing review.
 Hazard identification
and associated procedures [SAMPLE]
The fatigue risk register below is a sample of fatigue hazards that may exist for some operators. This list is not specific to any particular
operation type, but is intended to inform operators who may not be experienced in SMS-type processes on how hazards may be
mitigated for the purposes of complying with the tier 2 operator obligations.
If you need to adjust a limit in order to manage fatigue risk, the adjusted limit would need to be reflected in the appropriate place in the
fatigue management limits and you will need to notify CASA of the change. You do not need to wait for a response from CASA before
operating to the new limit or procedure. Operators can make changes to their operations manual whenever they feel it is required as
part of their risk management process, as long as compliance is maintained within CAO 48.1 Instrument 2013, and as long as you are
satisfied that fatigue is managed appropriately.

Table FR – Fatigue Risk Register

Identified fatigue hazard
(date recorded)
An FDP commencing after late
morning that is longer than 9 hours
and has more than 5 sectors
consistently leads to unacceptable
levels of fatigue (source: fatigue
reports) xx/xx/2016
An FDP that commences after midday
and is longer than 9 hours with more
than 7 hours flying time consistently
leads to unacceptable levels of fatigue
xx/xx/2016
Layover port accommodation
undergoing renovations causing
sleep disruption to FCMs xx/xx/2016
Operations being conducted in an
aircraft without an autopilot leading
to excessive fatigue after 8 hours
flight time xx/xx/2016
Reports of FCMs being unable to
achieve 8 hours sleep opportunity
on layovers at a particular port where
minimum off-duty period is provided
xx/xx/2016
OAT greater than 36oC has coincided
with increased fatigue reports on
higher sector FDPs xx/xx/2016
Additional FCM workload required to
complete refuelling, baggage/cargo/
passenger loading at away ports is
leading to excessive fatigue on long
multi-sector FDPs xx/xx/2016
Existing controls, Additional risk Responsible person and Chief pilot
including limits management, including policies and practice signature and date
limit adjustment considerations acknowledging
acceptance of risk
NOTE: The references to chief
pilot would be modified to the title
used in your organisation.
†† Maximum FDP 10 All FDPs involving more Chief pilot responsible for
hours, between than 5 sectors, the conducting a 6 month trial of
0700–1359 maximum FDP is 9 hours the new limit. Trial ends on
†† Reporting fatigued unless FDP commences xx/xx/2016
between 0700 and 0900
†† Fatigue training
†† Between 1200–1359: For all FDPs commencing Chief pilot responsible for
Max FDP 11 hours; after midday, the maximum conducting a 6 month trial of
Max flight time 9 flight time is reduced to the new limit. Trial ends on
hours; 7 hours xx/xx/2016
†† Between 1400–0459:
Max FDP 10 hours;
Max flight time
8 hours
†† Reporting fatigued For the period of the To be reviewed by chief pilot
†† Fatigue training renovation XXXX hotel will monthly until renovations
be used in lieu of hotel determined to be complete.
XXXX at XXXX
†† Table FD – Maximum For operations on all aircraft Chief pilot responsible for
FDP and FT duty without a serviceable conducting a 6 month trial of
periods autopilot, maximum flight the new limit. Trial ends on
†† Reporting fatigued time is reduced to 8 hours. xx/xx/2016
†† Fatigue training
†† Minimum sleep Under investigation Investigation underway, report will
opportunity is be completed by xx/xx/2016
8 hours in the
10 hours prior to
FDP commencing
at away ports
†† Reporting fatigued
†† Fatigue training
†† No specific limit For forecast OAT greater Chief pilot responsible for
†† Reporting fatigued than 36oC, the maximum conducting a 12 month trial
number of rostered sectors of the new limit. Trial ends on
†† Fatigue training
will be 4 xx/xx/2016
†† Reporting fatigued Interim Control: FCMs Chief pilot investigating steps
†† Fatigue training and support staff briefed to reduce reliance on FCMs
to avoid additional FCM doing refuelling, baggage/cargo/
workload at away base passenger loading) at away ports
ports on FDPs over 8 hours
unless absolutely necessary

www.casa.gov.au/fatigue
 Template for Fatigue Hazard Identification
OPERATIONS MANUAL REFERENCE IB2.5.17
1B2.5.17—Fatigue Hazard Identification
As [Insert organisation name] is committed to safe working practices and
procedures, we will undertake fatigue hazard identification and management,
to ensure that FCM’s can safely operate an aircraft or perform safety related
duties whilst minimising any fatigue risk.
The fatigue hazard identification follows through three phases and will be an
ongoing process. It will be required to determine prescriptive limits that suit
[Insert organisation name’s] operations and circumstances (which will not
in any case exceed [Insert Appendix/Appendices] limits). Any proposed
operations will be subject to the fatigue hazard identification process before
FCM’s will be permitted to conduct the operation. The process may also define
other controls that can be used to minimise fatigue risks.
[Insert organisation name] acknowledges the FCM’s expertise in the
operations they conduct, and [Insert organisation name] will register
and monitor any fatigue problems that is brought to the attention of the
[Insert delegated person e.g. Chief Pilot/Head of Operations]
[Insert organisation name] will undertake the following hazard identification
and risk management phases:
Initial phase (Hazard Identification)
[Insert organisation name] will identify fatigue hazards that could potentially
cause harm to the health and safety of people or damage to plant and
equipment. [Insert organisation name] will work with FCMs 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 FCMs).
[Insert organisation name] 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:
†† FCM’s input from their experience of particular types of operations
†† Any fatigue problems brought to the attention of the Head of Operations
(or delegated person)
†† Information from Flight and Duty records, including fatigue reports,
extension reports and any reported exceedances
†† Brainstorming/consulting with colleagues/discussion
†† Formal review of standards, procedures and systems (including
observations)
†† Staff surveys or questionnaires
†† External sources (such as industry specific knowledge sources and
industry groups)
†† Details from past external audits/safety assessments.
[Insert organisation name] will take action to minimise fatigue risk as low
as reasonably practicable. Information gathered through this phase and the
following two phases will be used to populate Table FR – Fatigue Risk Register
(or an equivalent).
Column 1 in Table FR – Fatigue Risk Register details the hazards identified by
the above steps. Any existing controls (such as legislation) will be entered into
the table (column 2).
www.casa.gov.au/fatigue
Further risk management controls (especially limit adjustment) to manage
the risk “as low as reasonably practicable” will be found in column 3.
The information in column 3 will then prescribe the limits found in
Section 1B2.5.2 – Duty Time FDP, Flight Time and Cumulative limits.
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 4.
In column 5, [Insert delegated person e.g. Chief Pilot/Head of
Operations] will sign each line acknowledging that risk is as low as
reasonably practicable.
The major outcome of this initial phase is to identify known or likely hazards
and recommend the maximum flight and duty limits prescribed and any
other mitigations required.
This phase 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.
Incident phase
[Insert organisation name] 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 add newly identified fatigue hazards or
amend existing fatigue risk mitigation.
These results must be entered into Table FR – Fatigue Risk Register (and may
have a reference linking them back to the specific report).
(Refer Sections 1B2.5.11.1 – Fatigue Occurrence reporting, Section 1B2.5.11.2
– Extensions reporting, Section 1B2.7.1 – Extensions and Section 1C2 –
Emergency Response and Reporting Procedures).
Annual review phase
Where the fatigue management approach (including hazard identification and
risk mitigation) is reviewed and amended where necessary. Refer to Section
1B2.1 – Fatigue Management Policy.
[Insert organisation name] will meet with all FCM’s 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 1B2.5.2) as set by
[Insert organisation name] – review adequacy
†† Accommodation – Any issues or improvements
†† F & D Reports – review procedures and improvements that could
be made
†† Communication Protocols – Improvements
†† Hazard Identification process – review adequacy.
Records from the Fatigue Hazard Identification Phases and associated reviews
will be kept with the Flight and Duty Records (Section 1B2.5.18 – Flight and
Duty Records).
The table and analysis form part of the Flight and Duty Records.