Dissenting Report—Mr Paul Fletcher MP
This Dissenting Report sets out my conclusions following the inquiry of
the House of Representatives Standing Committee on Infrastructure and
Communications into Cabin Crew Ratios on Australian Aircraft.
I disagree with the conclusion of the Chair’s Report. In my view the
evidence received by the Committee offers no satisfactory basis for Australia
persisting with a 1:36 cabin crew ratio when a 1:50 ratio is recommended by
major aircraft manufacturers Boeing and Airbus and is the regulatory
requirement in the United States, Europe and other jurisdictions.
The right way to frame the question
The Committee has been asked to consider a serious question of public
policy, raising issues of public safety, security and cost. That question is
whether the legal minimum requirement for the number of cabin crew in certain
passenger aircraft should be a ratio of 1:50 or 1:36.
Several points bear upon this question:
- The relevant specialist Commonwealth government regulatory body,
the Civil Aviation Safety Authority (CASA), proposes a 1:50 ratio.
- Single aisle aircraft in the relevant size range (such as the
Airbus 320 and Boeing 737) are designed on the basis of a 1:50 ratio.
- In the US, Europe and in fact in all International Civil Aviation
Organisation (ICAO) jurisdictions except Australia and Canada, 1:50 is the
- While the existing Australian ratio is based on the number of
passengers, the ratio used internationally (and the one proposed by CASA) uses
the number of seats.
The right way to frame the question facing the Committee is to ask
whether there is any good reason for the cabin crew ratio used in Australia to
diverge from the 1:50 ratio which is used in other developed nations, and
recommended by the aircraft manufacturers (“International Standard Ratio”
If there is persuasive evidence that countries which use the ISR have
inferior aviation safety or security outcomes to those in Australia, or that
Australia’s use to date of the 1:36 ratio (“Legacy Australian Ratio” or
“LAR”) has delivered tangible practical benefits for safety or security,
then we should have no hesitation in continuing to diverge from the ISR. If
there is no such evidence, we should adopt the ISR.
The Chair’s Report seems to assume that adopting the ISR will result in
there being more passengers for each cabin crew member than is the case today.
A similar assumption was made by some witnesses, such as the Flight Attendants’
Association of Australia (FAAA). That assumption is not universally correct.
If we start with the simplifying assumption of a fully loaded aircraft,
then the number of seats equals the number of passengers. Even with this
assumption, when we consider the range from 16 passengers to 216 passengers,
using the ISR will produce no reduction in cabin crew when there are
Between 19 and 36 passengers
Between 50 and 71 passengers
Between 100 and 107 passengers.
A more important point is that the ISR is calculated on a per seat
basis; the LAR is calculated on a per passenger basis. There is limited
discussion in the Chair’s Report of this point, but it makes a significant
difference whenever an aircraft is not fully loaded. If the load factor is
less than 72 per cent (that is, 36 divided by 50), using the ISR will produce a
minimum required number of cabin crew which is equal to, or higher than,
No persuasive evidence that ISR produces inferior safety or security
The committee heard no persuasive evidence that using the ISR produces
inferior safety or security outcomes.
Australia has very high aviation safety standards. Since 1966 we have had no fatal accidents on transport category aircraft where cabin crew were carried.
Of course that reflects many factors including maintenance practices, pilot
training and quality, aircraft age and quality, air traffic control systems and
weather. The number of cabin crew is one factor in a complex mix. It is
relevant in certain circumstances, particularly where there is an accident
requiring a rapid evacuation.
CASA informed the Committee that there is no evidence, to its knowledge,
of systematic differences between aviation safety in Australia and other
countries due to the different cabin crew ratios. In its submission CASA noted
the absence, to its knowledge, of any:
accident or incident investigation in a country that operates at
a 1:50 ratio that has recommended an increase in cabin crew;
studies into cabin safety that have recommended an increase in
cabin crew numbers;
evidence supporting a link between the Australian requirement for
1 cabin attendant to 36 passengers and Australia’s aviation safety record;
any situation where the effective management of an event was
enhanced as a consequence of a cabin crew ratio on that flight of being (up to)
Since 2006, CASA has given exemptions to a number of operators allowing
them to operate using the 1:50 ratio. The committee received no persuasive
evidence of any materially adverse safety consequences having flowed from these
The evidence received by the Committee from the Office of Transport
Security indicated that adopting the ISR will make no difference to aviation
Mr FLETCHER: I would like to ask one further question based
on that. In other words, as we deliberate on the view we should form on this proposed change, the aviation security considerations, in practical
terms, do not assist us and do not point in either direction?
Mr Robertson: On the evidence that is available that would
be a fair assessment, yes.
A number of other arguments were put. I did not find they offered
persuasive support for Australia continuing to diverge from the ISR.
Because Australia has historically had a higher ratio
As the Chair’s Report notes at paragraph 1.43, the main reason that
Australia has used the 1:36 ratio is historical:
From the evidence received by the Committee, it is clear that the
only real basis behind the current cabin crew ratio of 1:36 is that it was used
in the early days of civil aviation in Australia, and has since been
extrapolated as passenger aircraft have increased in size.
Self-evidently, this is not a sufficient reason to continue to diverge
from the ISR.
Arguments from the TWU and the FAAA
The Chair’s Report extensively quotes the views of the Transport Workers
Union (TWU) about the role of cabin crew in maintaining in flight security. I
do not understand why. Neither cabin crew ratios, nor in-flight safety and
security, are issues about which the TWU has particular expertise. Its National
Secretary told the Committee that the TWU does not represent cabin crew or any
workers who have a role when an aircraft is in flight.
Mr FLETCHER: Mr Sheldon, what roles do your members perform
Mr Sheldon: They are baggage handlers, so they come into
contact with the aircraft by putting bags in. They are freight loaders. A large
proportion of passenger flights carry freight. They are catering staff that
will truck the catering to the plane and load the plane with the catering
Mr FLETCHER: Are any of your members in the aircraft in
Mr Sheldon: I am sorry; we also have aircraft cleaners—they
go in and out.
Mr FLETCHER: What about when the aircraft is in flight?
Mr Sheldon: No, we do not have people who are engaged in the
work while in flight.
In my view the opinions of the TWU should be given no particular weight
in considering this question.
The FAAA were strongly in support of Australia continuing to diverge
from the ISR. The FAAA exists to advance the interests of its members, who are
flight attendants on Australian airlines. It is unsurprising that the FAAA
opposes a change which it perceives as reducing the mandated minimum number of
flight attendants on aircraft. However, the criteria for this decision are
safety and security; they are not maximising employment prospects in the
I acknowledge that the FAAA presented arguments based on safety and
security considerations. I found those arguments less persuasive than the
evidence provided by CASA and the Office of Transport Security.
Because the ISR would bring cost savings and these are a bad thing
The Chair’s Report at paragraph 1.71 speaks of the ‘challenges in
assessing operators’ motivations in seeking exemptions to the 1:36 ratio’ and
notes that operators agreed that it had been primarily for cost reasons.
This paragraph implies that it is prima facie a matter for concern that
operators have been motivated by cost savings. I disagree. Of course safety
must be the primary objective and operators must not do anything which
compromises safety. However, if cost savings can be obtained without
compromising safety, I see no objection at all to operators pursuing them. It
is a question to be assessed on the evidence: does diverging from the ISR
delivers safety and security benefits?
The evidence provided to the Committee has not demonstrated material
safety and security benefits. That being so, it makes good sense to pursue cost
savings. After all, if adopting the ISR delivers cost savings, the benefits may
Lower airfares making it more affordable for Australians to fly
Improving the breakeven economics of routes to particular
destinations (especially in rural areas), allowing them to receive services
which would not otherwise be possible
Using the savings to fund other initiatives which have a greater
safety and security benefit than is gained from diverging from the ISR.
Paul Fletcher MP
Member for Bradfield
October 21, 2011