Confidential Human Factors
Incident Reporting Programme
The Charity
Aviation
Maritime
FC5082
Initial Report
[Airline] recently made multiple pilots redundant. They claimed this was due to an issue of over-crewing. Within 2 weeks of making pilots redundant, they were trying to remove leave from the remaining pilots and compel them to work multiple off-days. I believe this to be a deliberate policy to use less than minimum crewing levels and use pilots’ off/rest days to plug the serious gaps. I believe that this is leading to severe fatigue, multiple minor, significant and one serious incident. [Airline] crewing levels on the [Aircraft type] fleet are woefully inadequate. It is an extremely questionable employment practice and somehow they now have managed to have the correct crewing level but by decimating the remaining employees’ terms and conditions.
CAA Comment
The CAA Oversight Teams conducted targeted audits in FTL/Fatigue Management for this operator both pre and during the pandemic and will continue to do so to ensure appropriate safety standards are being maintained. The management of the prescriptive FTL limits within the approved FTL scheme, and evidence of the management of any FTL exceedances are required whilst also managing the fatigue hazards using the SMS processes in place. Standby coverage and the utilisation of crew on days off (overtime) formed part of these oversight activities as well as the management of roster disruptions (under Subpart FTL), which required the operator to ensure robustness of rosters and have appropriate metrics established to measure these.
The UK Retained Regulations do not define what is the legal minimum number of crew to operate a fleet of aircraft. However, rostering practices and the level of the fatigue reporting rate could be indications of a potential hazard on the rise. The CAA Oversight Team will always conduct a focused oversight in any cases where insufficient crew levels are being raised as safety concerns such as these.
CHIRP Comment
The CAA conducted an extensive investigation of the issues raised but were unable to share any of the detailed findings or headlines due to confidentiality. Although we have no details of the findings, CHIRP welcomed the CAA’s comment that they will continue to conduct ongoing oversight activities focused on ensuring appropriate safety standards are maintained by the operator. The risks associated with airlines attempting to fill schedules from depleted crew numbers are clear; stress on FTL and fatigue management systems can soon become an issue in themselves, and a leading indicator of potential safety problems elsewhere. In this respect, roster stability can be an important indicator of airlines operating with too few crews as they attempt to mitigate normally occurring gaps due to illness etc from an already stretched crew complement. Although roster stability can be adversely affected by many factors, the CAA informs CHIRP that they are keeping an eye on company rosters as a loose indicator of overall safety performance. The issue is topical in that other airlines are no doubt also trying to fill schedules with reduced numbers of crews during the COVID return-to-flying period and are also potentially subject to short-notice roster changes.