Alongside the concerns raised in the previous chapter regarding ARFFS equipment and the development of new stations, significant concerns were raised with regard to the level of staffing provided at ARFFS locations, against each aerodrome category.
Concerns over staffing related to insufficient staffing levels or reductions in staffing levels against airport category at certain airports; a lack of proper risk assessment and consultation prior to the implementation of significant ARFF service delivery changes; and the redeployment of firefighting crews to other, non‑regulated activities. This chapter explores these concerns.
Throughout the inquiry, ARFF firefighters and their union representatives voiced serious concerns over apparent reductions in staffing levels by Airservices at ARFFS locations across Australia, and over inadequate staffing numbers against aerodrome categories.
NFPA staffing levels
It was often raised in evidence that the staffing profile developed by the NFPA in relation to ARFFS was to be preferred over the Australian regulations. Mr Andrew Hanson, currently a Fire Commander, provided a comparison of the recommended staffing levels put forward by the NFPA, and those currently in place for the ARFFS in Australia. Mr Hanson suggested that the 'disparity is staggering' between the two organisations, particularly at the lower categories, and that to date, no explanation had been provided by Airservices as to the discrepancy. The comparison is provided at Table 4.1.
Table 4.1: Comparison of staffing levels - NFPA against ARFFS
Source: Mr Andrew Hanson, Submission 16, p. 5.
Mr Hanson suggested that the NFPA standards, when compared with the ARFFS requirements in Australia, were to be preferred. Mr Hanson observed that the NFPA numbers were developed using an expert panel, and considered realistic staffing numbers. The greatest disparities between the ARFFS and the NFPA were at the lower category levels (for example, nine staff recommended by the NFPA for Category 6 airports, compared with actual staffing of five at Australian airports). Mr Hanson expressed particular concern about this, noting that:
In Australia this is compounded by the fact that these stations do not receive the same level of outside support within the same timeframes as the larger city airports.
This view was supported by the UFUAB, which said that many regional ARFF stations did not have ready access to local ambulance services, or appropriate medical facilities, such as hospitals within close proximity to the airport. While noting that the ARFFS was not responsible for providing this type of support, the UFUAB suggested that additional firefighters should be provided in such areas in order to provide adequate emergency responses. The UFUAB was particularly concerned that the ARFFS was 'failing to meet the minimum staffing numbers in remote and regional locations'.
It was also noted by the UFUA that the NFPA standards were preferred, as they exceeded the personnel and firefighting vehicle numbers required by Airservices.
Reduction in staffing levels
It was put to the committee during the inquiry that staffing levels were being reduced or re‑allocated across the ARFF service, placing the safety of both crews and the travelling public at risk.
For example, the UFUAB explained that until recently, the ARFFS had resourced its DRS with staff separate to those who were maintaining category requirements. This was to 'reduce the risk of a domestic response (non‑aviation) degrading the category coverage'. However, under a 'hybrid model', ARFFS crew were now responding to non‑aviation incidents. Mr Hunter confirmed to the committee that there were significantly more domestic responses than responses to aircraft incidents.
In another example, evidence to the committee suggested that in 2013, Brisbane Airport was reclassified as a Category 10 airport following the completion of a Safety Case Assessment and Reporting Determination (SCARD), in light of the fact that the A380 was entering service at that airport. The SCARD determined the staffing level at Brisbane as 17 ARFFS staff, in order to accommodate the newly arrived A380s.
However, it was put forward by the UFUA that in recent years, there had been a reduction in crewing levels at the Brisbane Airport from 17 to 14 crew (as well as at Perth Airport, which faced similar circumstances). The UFUA argued that both airports had been reclassified from Category 10 to Category 9 airports, despite both still receiving Airbus A380 aircraft (although infrequently).
The UFUAB noted that this reduction in crew equated to three staff per crew, a total loss of 12 operational positions (based on a 24‑hour roster), or 24 crew members across the two airports.
Cross-crewing and the Brisbane and Perth airports
In light of the above staff reductions, the UFUA took the view that a Category 10‑level ARFFS response at these airports could therefore only be achieved through Airservices 'cross‑crewing' its ARFF and DRV vehicles. Cross-crewing means that 'the same crew can respond either to a DRV or ARFF incident, but not both simultaneously' (emphasis in original). For example, at a Category 10 airport an ARFF domestic response with the DRV, with three crew, would leave 11 crew at an ARFFS station, below the 14 personnel required for a Category 10 response.
Mr John Hancox, an ARFFS firefighter, provided the committee with an example of this occurring, when in February 2019 three staff from the Brisbane ARFFS responded to a cardiac event on a plane at the international terminal. During this time, an A380 taxied and took off. However, as there were only 14 staff available at the station, the domestic response meant that the ARFFS station was left with 11 crew during the A380's movements. Previously, when the Brisbane ARFFS had 17 staff, three staff could attend a first‑aid emergency while 14 staff remained at the station, thus maintaining category.
The UFUA suggested that this cross‑crewing approach was occurring regularly, and concluded that such an approach was a risk to both firefighter and public safety. The UFUA summarised the cross‑crewing process, stating that:
…when firefighters are required to turn out in the DRV, the level of staffing remaining at the station is insufficient to maintain a Category 10 response (the level required when an A380 Airbus utilises the airport) and to respond to any major incident. Maintaining crewing and vehicle numbers appropriate to the Airport Category is crucial to the safety of airport passengers, staff and visitors.
Mr Peter Marshall, National Secretary of the UFUA, suggested that cross‑crewing was a 'cost‑cutting exercise' which put ARFF firefighters in an 'untenable position'. Conversely, before its implementation, Mr Marshall said there were adequate staffing levels to contend with multiple scenarios (for example, a Category 10 aircraft and a medical emergency). Mr Marshall continued that:
Emergency response is not predictable; it is time critical. Aircraft intervention is time critical…it's seconds, not minutes, to be able to intervene. The point I'm making is that you can't be in two places at the one time.
Mr Tim Limmer, a firefighter at the Brisbane ARFFS, also argued that the cross‑crewing occurring at Brisbane Airport was compromising safety and causing 'great stress' among firefighters.
There was some confusion as to when cross‑crewing was implemented at Brisbane. In light of this, Airservices provided to the legislation committee a timeline of events leading to the change of category at Brisbane Airport. The timeline is as follows:
January 2018 – local ARFFS management was advised that A380 operations at Brisbane would reduce to one arrival and one departure per day, as of 25 March 2018, and would potentially cease entirely between 2 June and 1 September that year;
Following this advice, staff consultation was commenced by Airservices regarding amendments to the staffing roster, and due to the further consultation and safety work required, no changes to staffing were made at the time;
February 2018 – staff were advised that there was no intent to implement staffing changes in March 2018, and at that stage, there was no intention to implement cross‑crewing at Brisbane Airport;
March 2018 – Airservices received confirmation that, as of 2 September 2018, Brisbane Airport would only receive one arrival and one departure daily of A380s, with services to cease between 2 June and 1 September 2018;
2 June 2018 – Brisbane Airport reverted to a Category 9 airport, 24 hours a day (with 13 crew at all times), and consultation commenced with staff about 'upcoming reversion to periodic Category 10 operations';
August 2018 – Airservices determined that from 2 September 2018, 14 staff would be on duty at all times at the Brisbane ARFFS, and that the DRV could be utilised safely using these 14 staff.
Airservices advised that this staffing model has been in place 'effectively and safely' at Perth Airport since 2016. Further, with these category amendments and cross‑crewing there were no changes at all to the provision of ARFF services in response to any fire on an aerodrome, or the provision of first aid responses, with no intention to change this in the future.
Mr Harfield noted that the staffing levels at Brisbane were in accordance with the category of the airport, particularly in light of the fact that Brisbane Airport's service of A380s had been reduced to once or twice a day—thus making it appropriate to change the airport's category to Category 9 (with the ability to service Category 10 aircraft movements when required). Mr Harfield explained this situation as follows:
Brisbane Airport is a category 9 station that is staffed to category 10 levels when there are A380 movements from time to time. The required category 10 staffing is 14, which is three officers and 11 firefighters. Sydney and Melbourne are category 10 stations 24 hours a day. They also have a domestic response vehicle which does the extra first aid, which is staffed separately. It's also provided at Brisbane, but it's staffed within the existing crew.
Mr Harfield conceded that it was possible, at the Brisbane and Perth airports, that only 11 crew could be available during a Category 10 movement, if other crew were responding to, for example, a first aid call. However, Mr Harfield asserted that 'there was the ability to handle that scenario prior to this change, as there is now', and that the ARFFS was adhering to CASA requirements. Mr Harfield concluded that at Brisbane Airport:
They still have a full complement of crew for the required and appropriate level of staffing and service.
Airservices later asserted that the staffing currently in place at Brisbane Airport was developed 'through a risk assessment process based on task resourcing'.
Airservices stated that the safety of the travelling public remains the primary concern of Airservices, and argued that:
Staffing models for the provision of ARFFS across Australia, including at Brisbane Airport, are designed with paramount regard to stringent safety and risk analysis, and are approved by the Civil Aviation Safety Authority as meeting the required regulatory standards.
The recent changes to the Brisbane staffing model did not impact Airservices' ability to both provide fire response services in accordance with regulatory requirements, and respond to first aid incidents in and around the terminal.
The MOS provides, in Chapter 25, that if there is a need to temporarily reduce the category of the ARFFS provision due to an unforeseen circumstance affecting impending aircraft movements, all affected parties shall be notified immediately via the Notice to Airmen (NOTAM) system. The officer in charge at the time makes a determination as to the ability of ARFFS to respond to an aircraft emergency, and advises accordingly through NOTAM and through the control tower.
The UFUAB observed that this requirement then allows the air crew of a plane to determine whether the level of ground service is suitable to their needs. However, this would also be dependent on whether they were notified in a timely manner of the change to category.
Mr Wood explained that in the event of reduced ARFF services, airlines could determine whether to land a plane at that airport. By way of example, Mr Wood said that if there was a major fire in an airport terminal:
…regardless of the number of staff, they are all going to respond to that fire. And in that instance, they will advise through the tower the aircraft that are operating a reduction in service level or category, and then the pilot will make a decision whether or not they still want to land or take off.
DIRDC further advised that the category of an aerodrome can be reduced (dropped) during periods of reduced activity—for example during night operations—to no less than that needed for the highest category of aircraft planning to use the aerodrome during that time.
In documents provided to the committee, it was stated that sustained variations to category could trigger a requirement for a category change, to ensure there were adequate staff and resources to respond to the worst possible scenario. Variations could also be triggered 'due to a regular aircraft movement which is of a greater category than that currently provided', and where Airservices ARFFS:
…seeks to supply that level of category without utilising the ability to provide services one level below the largest regularly operating aircraft.
Case study: Adelaide Airport
For some time, concerns have been raised by firefighters and local stakeholders about Adelaide Airport being reduced in category during its curfew period. During curfew, the airport is classed as Category 5, whereas during daytime operations, the airport is classed as Category 9.
The curfew at Adelaide Airport does not prevent all aircraft movements, but rather limits aircraft movements between 11.00pm and 6.00am by restricting the types of aircraft operating, and the number of flights permitted. Mr Terry Buss, the CEO of the City of West Torrens (where the Adelaide Airport is located) observed that despite the curfew, there are a significant number of flights overnight:
On average, over the past three years, the number of permitted aircraft movements during the curfew period has been 4,160 movements annually—those numbers have been taken from Airservices figures—and that equates to approximately 11.4 aircraft movements per night-morning, or per curfew period, every day. This is not an insignificant number of aircraft movements, considering the curfew that exists.
Mayor Michael Coxon, of the City of West Torrens, advised that the majority of these flights were for commercial or freight purposes.
It was argued that despite being classified as Category 5 during curfew, Adelaide Airport was receiving Category 6 aircraft during this time. While the airport had five staff during curfew—two more than required by the category—it was suggested that Airservices was looking to reduce these numbers back to three, as per the regulated Category 5 requirements.
Mr Buss noted the concerns of the City of West Torrens over any reduction to ARFF crews at Adelaide Airport, arguing that less firefighters could 'jeopardise the ability of rescue and firefighting personnel to deal with emergencies and security threats' at the airport. Mr Buss suggested a reduction in ARFFS staffing, at a time when the Airport and its surrounding precincts were continuing to rapidly grow, was 'illogical' and 'counterintuitive'.
Mr Barker likewise suggested that this approach presented a direct risk to safety, was a breach of the MOS, and placed an 'increased and unrealistic reliance on external agencies', such as the South Australian Metropolitan Fire Service (SAMFS), to attend in a timely manner to on‑airport emergencies. Mr Barker concluded that:
In the event of an incident requiring ARFF intervention the resources for Category 5 are nothing short of dangerous and compromise the safety of the crew and people who need to be rescued.
Mayor Coxon suggested it would take approximately five minutes from notification of an emergency event at the airport to when SAMFS could potentially arrive at that event. Mayor Coxon raised concerns about this, noting that 'every second counts' when dealing with highly flammable material.
Mr Barker continued by saying that in the event ARFF crew were dispatched to an emergency—either at the airport or within the response area off airport—the Adelaide Airport would be left with no ARFF at all, and therefore no capacity to respond to an aircraft incident. Mr Barker suggested that such an approach represented a 'gross misinterpretation and understanding' of the CASR and the MOS, and demonstrated a failure to recognise the services required to respond to the 'hazards of a major international capital city airport'.
Mayor Coxon voiced his concern about the lack of ARRFS coverage when passenger aircraft were not in operation. Mayor Coxon reasoned that such an approach led to a perception that that no aircraft were operating during such a time, however he noted that:
We have aircraft that come in and out of this airport during the curfew period courtesy of the Royal Flying Doctor Service. I would be really concerned that, should an event occur, we would be unable to proactively respond to an event that involved the Royal Flying Doctor Service, just as an example.
Mr Buss also noted that a number of dispensations to either land or take off were granted to commercial passenger aircraft during the curfew period (for example, due to flight diversions or departure delays). By way of example, Mr Buss stated that:
…in the period of July to September 2018 there were a number of approved dispensations. There was a Tiger Australia dispensation with 164 passengers on board, a Qantas dispensation with 109 passengers on board, a Virgin Australia with 153 passengers on board, a Jetstar with 138 passengers, a Virgin Australia with 176 passengers, an Emirates with 331, and so on.
Mayor Coxon was of the understanding that when these dispensations during curfew occurred, the ARFF service did not have 'enough lead time for them to increase their complement' of staff, in order to maintain or achieve the appropriate category. Mr Buss made a similar point, stating that:
If there were an incident involving one of those aircraft movements, I doubt whether even the current crew could deal with it, let alone a reduced crew.
To remain compliant with the MOS, Mr Barker recommended that the category during curfew at the Airport be raised from Category 5 to Category 7, and be resourced accordingly. Doing so would provide an extra fire vehicle, and three extra ARFF staff during curfew.
In correspondence to Mr Buss dated 15 February 2019, the Minister for Infrastructure, Transport and Regional Development, the Hon Michael McCormack MP advised that Airservices was 'conducting a review of its ARFFS staffing levels' during the curfew period, when no regular passenger transport aircraft were in operation. Minister McCormack further noted that there was no obligation to provide any ARFFS coverage outside the operating hours of passenger aircraft at Adelaide. However:
…reflecting its commitment to aviation safety, Airservices has elected to provide a Category 5 level of service overnight for many years and current staffing levels are above the minimum required for a Category 5 service. Its decision to review staffing levels does not diminish Airservices' commitment to continue to provide a Category 5 service during the curfew period.
In response to concerns raised about staffing at Adelaide, Airservices advised the legislation committee that no changes had been made to staffing at Adelaide, and that Airservices was undertaking a review of the Adelaide staffing roster in order to:
…understand why rostered staffing numbers at Adelaide are considerably above the staffing levels approved by CASA [and the review] will be informed by the TRA methodology. No changes to current staffing numbers will be made until they are assessed against the TRA framework after it is introduced in early 2019.
Moving forward, Mr Wood advised that Airservices would examine the number of emergencies at Adelaide Airport in recent years, together with the proximity of the local fire services, to feed into an upcoming staffing level review using the TRA framework.
Mr Harfield stressed the fact that there were no cuts to staffing levels at any location, and said it was not correct that staffing would be reduced at Adelaide. He further noted that Airservices had maintained services at locations where, under the current regulations, the ARFFS could in fact be disestablished. Airservices had instead taken the decision to maintain the services.
Mr Harfield contended that a Category 5 ARFFS at Adelaide was adequate 'for the type of aircraft operating at the airport during those curfew hours and according to what's required under the regulations'. Mr Harfield continued that:
We're certified by CASA for the standard of service, and we have to operate to the level that is provided under the certificate. If the certificate allows us to go to category 5, it's been assessed as appropriate.
Mr Harfield further informed the legislation committee that if a dispensation was given for passenger aircraft, ARFFS would have to provide services corresponding to category, regardless of what aircraft arrived during curfew. Despite this, Mr Harfield conceded that at that time, no assessment had been done as to how many people worked at the airport during curfew hours.
In October 2018, Mr Harfield refuted the suggestion that a downgrade of category at certain airports was a cost‑cutting exercise. Mr Harfield explained that Airservices would save no money from changes to category; rather, Airservices was examining its 'resourcing profile around the country', noting that some airports were changing with different aircraft mixes, requiring either an increase or decrease to category.
Views on staffing reductions
The UFUAB took the view that in reducing staff numbers, Airservices had 'completely ignored' the views of a committee of ARFFS operational experts, and had excluded the input of these experts in considering the reduced staffing model. Further, the UFUAB argued that it and many ARFFS firefighters saw reduced staffing, including via ICAO's remission factor, to be 'completely unsafe'.
The UFUAB indicated that ARFFS staff at Brisbane Airport did not believe that they could properly respond to a Category 10 emergency, 'within the current resourcing models'. Staff at the Brisbane ARFFS argued that an incident with a Category 10 aircraft under reduced staffing would 'result in unacceptable increased loss of life', while also endangering ARFFS staff.
The UFUA contended that there was little to no oversight of staffing reductions, therefore placing 'airports, staff, passengers and ARFF personnel at risk on a regular basis'. The UFUA concluded that there was a need to:
…review ARFF regulations and standards to better align them with ICAO SARPs, with consideration given to the standards established in NFPA 403 as examples of best practice.
Legislating staffing levels
The UFUA contended that ARFFS staffing levels should be legislated, rather than placed in regulations or operational procedure documents. The UFUA argued that changes to regulations and operational procedures did not require or involve public scrutiny, and did not properly consider the unintended consequences of reduced staffing levels; if enshrined in legislation, any amendments to staffing levels would be subject to a 'rigorous process of examination and investigation'.
Mr Hunter of the UFUAB supported this position, arguing that 'staffing numbers must be regulated or legislated to prevent the watering down' of safe crew numbers, with the NFPA standards used as the baseline for any legislated staffing levels. Mr Hunter continued that 'legislation and regulations must be brought into line with ICAO', which would include identifying staffing needs above the NFPA.
The UFUA also called for an independent review of current ARFFS staffing levels, to establish an 'appropriate minimum staffing level' by airport category, taking into consideration the NFPA 403 standard.