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Sunday, November 14, 2010

Work longer hours, but experience LESS fatigue?

The impact of fatigue on aviation safety concerns everyone. The comment period on an FAA Notice of Proposed Rulemaking (NPRM) on duty and rest rules for pilots covering all commercial operations closes Monday, November 15. I can't count how often passengers poke their head in the cockpit to ask us if we're "feeling ok." Unfortunately, despite the acuity of their concern at that time, the lax regulations which validate it don't change when they arrive safely at the other end. The time to enhance your safety isn't as you're walking onto the airplane.

The time is NOW.

If you or anyone you love flies (or lives beneath the sky), this issue affects you. Clicking on the link below will take you to an easily-filled web form that will allow your concerns to be heard by the FAA and your Congressional representatives and will NOT place your name or personal information on any list unless you request it. This rule absolutely must be amended if we are to prevent a further erosion in the margins that have made America's air transportation safety record the envy of the world. Please take a moment to click the link below!

http://capwiz.com/alliedpilots/issues/alert/?alertid=19247511

Some elements of the proposal represent important improvements over current regulations:

1. The concept of duty limits based upon time of day recognizes the physical toll of late night, all night and early morning flying.

2. Providing prospective rest for reserve pilots flying international routes ensures these pilots will finally be as likely to get adequate rest before a trip as their domestic counterparts.

3. Establishing limits on actual flight time, rather than scheduled flight time, will protect against delay-induced fatigue and compel carriers to schedule realistically and responsibly.

4. The concept that rest cannot begin until a crew arrives at the rest location will no longer be an issue for which our unions must fight.

5. Schedule reliability metrics, including those based upon individual segments, will require carriers to develop realistic schedules and discourage deceptive practices.


However, there are some items in the NPRM that fall short of mitigating—and in some cases even threaten to increase—fatigue:

1. The flight time limit would be increased by 25 percent from eight hours to 10 hours. THIS IS NOT TIME ON DUTY. THIS IS TIME SPENT IN ACTUAL OPERATION OF A MOVING AIRCRAFT. Duty time typically exceeds this amount by as much as 150%!

2. Three-pilot crews will be permitted to fly 15 hours, a 25 percent increase over the current maximum of 12. The current regulation is far more realistic in that it mandates three pilots for flights over eight hours, and four pilots (and bona fide rest bunks) for flights over 12 hours.

3. Rest requirements should provide for the scientifically-mandated eight hours of SLEEP. In normal circumstances, 10 hours free from duty would be the minimum to afford eight hours of sleep. For the physiologically demanding conditions of extended and “back side of the clock” operations, 14 hours would be a more appropriate minimum. These minimums ensure an opportunity to achieve restorative sleep, obtain nutrition, and attend to personal hygiene and a minimum of daily personal business.

4. Relying on in-flight rest is never a substitute for obtaining a fresh crew. Thus, as long as an airplane can land, there is absolutely no safety rationale for augmenting domestic crews with additional crew members to facilitate more grueling schedules.

5. Fatigue Risk Management Systems (FRMS) cannot become a blank check for carriers to circumvent their responsibility for safety. An effective FRMS must be structured as a partnership between carriers, their pilots and the FAA.

As a result of numerous incidents and accidents, the National Transportation Safety Board has placed fatigue on its "Most Wanted List" of transportation safety improvements for 30 years. As a professional pilot, I am responsible for the safety and well-being of my passengers while operating massive, high-speed aircraft through congested airspace and in challenging weather, around the world, around  the clock. Based on my experience, I assure you that reducing fatigue is essential to increasing the safety of the traveling public. The regulations that result from this NPRM would go a long way toward reducing fatigue and increasing safety--but only if the items that fall short are addressed.

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