FAA Pilot Rest Requirements Capstone Project

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As Henry Bowles noted in his essay, "Numerous studies have concluded that significant sleep deprivation is equivalent to operating while under the influence of alcohol. The British Medical Journal concluded that, "after 17 -- 19 hours without sleep, performance on some tests was equivalent or worse than that at a BAC of 0.05%. Response speeds were up to 50% slower for some tests and accuracy measures were significantly poorer than at this level of alcohol. After longer periods without sleep, (up to 28 hours) performance reached levels equivalent to the maximum alcohol dose given to subjects (BAC of 0.10%)" (Bowles, 2010). Studies such as this one help to illuminate the real dangers of piloting (or driving or operating heavy machinery) when one is suffering from sleep deprivation.

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Yet what is unknown, and to circle back to the NTSB Board's finding, is how much of a role sleep deprivation plays in airline crashes. In a paper written by Mark Brandon, an Airline Transport Pilot, he stated, "Seventy percent of the accidents in aviation are due to pilot error, and fatigue is a major cause of those errors" (Brandon, 2000). The problem with a statement like this is there is an assumption that fatigue was a major cause, even though there is no objective proof. Most pilots agree, and they would know better than anyone else, that fatigue is a concern, but it is a very difficult to measure a variable like pilot fatigue. This is in part because every pilot is different as far as his/her predilections for sleep requirements. And, additionally, in the majority of instances there is no way to know how tired and/or awake the pilot is at the time of the crash.

The FAA states, "Although sleep science is evolving, research has indicated that most people need eight hours of sleep in 24 hours to perform effectively, and the average person needs in excess of nine hours of sleep per night to recover from accumulated sleep debt" (Dorr & Duquette, "Pilot Fatigue," 2010). Once can argue that this is a generality, but a good starting point for ensuring that pilot rest policy is finely tuned to the findings sleep science has uncovered.

Capstone Project on FAA Pilot Rest Requirements on Assignment


Regardless of whether or not fatigue is a major cause in airline crashes, and regardless of whether or not new rest requirements will actually help mitigate airline accidents, change is on the horizon. The Colgan crash was enough of a lynchpin to precipitate policy change in the airline industry, assuming the FAA ratifies the new rule changes proposed in Administrator Babbitt's Notice of Proposed Rulemaking (NPRM) -- (issued in Sept. 2010). The FAA will make a final ruling on the issue by August 1, 2011.

To recap a quick history, there was policy proposed in 1995 that would have specifically addressed some of the current concerns regarding pilot fatigue. As mentioned, due to lack of sufficient evidence and the lobbying power of the ATA, those early efforts to pass impactful polices were thwarted.

Prior to the Colgan crash, in June 2008, the FAA sponsored a fatigue symposium called the "Fatigue Symposium: Partnerships for Solutions." This event was designed to incite a proactive response - within the airline industry - to pilot fatigue via new fatigue management and mitigation techniques (Dorr & Duquette, "Pilot Fatigue," 2010). The event was limited to 300 attendees and may have been considered by some to be just another perfunctory event to create the illusion of doing something with regard to pilot fatigue.

One thing that is worth noting is the politics involved with FAA. At the time of the Colgan crash, February 2009, Administrator Babbitt had not yet assumed his position. According to the FAA website, the acting Adminstrator at the time of the crash was Lynne Osmus. One could argue that when Babbitt took office in June, 2009, he felt overly compelled to address safety concerns in the FAA. He wanted to put his stamp on things right away. So, not long after the NTSB published its report on the Colgan crash (Feb 2010), he issued the landmark Notice of Proposed Rulemaking (Sept 2010).


Before one discusses the proposed changes in policy, it might be helpful to remind the reader of the nomenclature used in aviation, particularly with regards to flight time for a pilot vs. duty time for a pilot. Flight time is the actual time the pilot is flying the plane and duty time accounts for the whole time a pilot is on the job, from the moment the start his/her shift, till the moment the finish. With this issue clarified, here are the key changes purported in the new proposal:

The first is proposal addresses the universal nature of fatigue. The proposal would standardize rules for all types of Part 121 flights, (passenger and cargo airlines): domestic, flag international), or supplemental (unscheduled) (Dorr & Duquette, "Pilot Flight Time," 2010). As it stands right now, not all types of Part 121 flights have the same rest policies. This would, in effect, make them congruent. This part of the proposal does not effect on Part 135 operators (commuter and on demand).

The new rules will account for an individual's circadian rhythms and limit flight time and duty time accordingly. The National Institute of General Medical Sciences, "Circadian rhythms are physical, mental and behavioral changes that follow a roughly 24-hour cycle, responding primarily to light and darkness in an organism's environment" (NIH, 2008). The current rules are not sensitive to an individual's circadian rhythms.

The proposal unequivocally states that fatigue mitigation and management is a shared responsibility between the pilot and the airline. Moreover, a pilot shall not accept an assignment if he/she is considered to be "too" fatigued to fly (Dorr & Duquette, "Pilot Flight Time," 2010).

The proposal allows each airline to determine and create its own Fatigue Risk Management system that would clearly set out an airline's policies and procedures for fatigue mitigation and management. However, each system or plan is subject to the review and approval of the FAA. Additionally, ongoing fatigue education and awareness training will be conducted (Dorr & Duquette, "Pilot Flight Time," 2010).

As far as pilot rest is concerned, the FAA suggests a new minimum number of rest hours prior to flying related duty. The current rules are 8 hours of rest. The FAA hopes to up that to 9 hours of rest (Dorr & Duquette, "Pilot Flight Time," 2010).

As for flight time, which functions on a weekly, monthly, and yearly basis the proposal makes the following suggestions, a 25% increase in the number of free hours from duty. Under the current rules a pilot gets 24 consecutive hours free from duty per week. The proposed rules would change this to 30 consecutive hours free from duty per week. For monthly flight time, the proposal opts for a maximum 100-hours of flight time in any 28 days. The current rules say 100-hours of flight time in any 30 days. And lastly, the yearly limit for domestic flights, 1,000 hours in any calendar year, will be extended to all types of operations, not just domestic (Dorr & Duquette, "Pilot Flight Time," 2010).

Finally, the proposal seeks to limit the current 16-hour duty period (between rest). The proposal would decrease duty time to 13-hours, which could slide to nine hours at night, contingent on take-off time and number of segments scheduled ((Dorr & Duquette, "Pilot Flight Time," 2010).


After reviewing the proposed changes in the NPRM, one can see that the FAA is not suggesting a few minor policy adjustments, rather, the FAA is lobbying for a complete overall of the existing scheduling system. Airlines will now have to create and integrate Fatigue Risk Management Systems into their scheduling systems (P. Gilligan, Testimony, September 16, 2010), both flight and duty time hours will be shortened while rest requirements will be protracted, costly fatigue mitigation training will take place and implicit in all of this, is the fact that airlines will have to adjust to these new regulations by hiring new personnel to cover the gaps caused by the restrictions. And expanding the workforce of an airline means higher costs and less revenue. One can assume, due to the relatively recent struggles of many airlines to remain solvent during times where fuel costs are relatively high and public demand for tickets is elastic, that the profit margin for many airlines is already very tight, and so to remain profitable these new costs will have to be shoveled back to the consumer. However, if the consumer is unwilling to purchase the tickets at the higher prices, then the airline will struggle to turn a profit. In short, either the consumer will be paying higher ticket prices so pilots are less likely to fall asleep at the helm or airlines will sacrifice profitability in an attempt to keep pilots awake during flights.


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