Safety Matters, an India based non governmental organisation carried out a Safety Culture Survey from 7th Oct-7th Nov 2020. The conclusions of the survey report indicate a general agreement amongst the respondents that a positive safety culture prevails in the organisation. However, to take benefit of the response received from various functional areas, an in-depth analysis was carried out.
The 3 areas of concern are:
1. Safety concerns once raised are not dealt with in a timely and comprehensive manner by the the state (C18)
2. Acceptable behavior and unacceptable behavior is not clearly defined and understood (F29)
3. Fatigue management is not implemented by my employer (H36).
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EASA documentation in the public domain acknowledges that their 900 hours annual FDTL limit is not backed through scientific studies, and a non- WOCL early morning departure has limited utility if pilot is waking up in WOCL to report for duty.
DGCA FDTL CAR is a collation of applicable rules from FAA and EASA without any domestic scientific studies to check for applicability.
A sustained data driven process has to be initiated to fix the gaps.
This study is a good starting point.