Pilot Commentary: Safety on Crutches
By Capt. Rich Hughey (FedEx Express), ALPA President’s Committee for Cargo Chairman
Commercial aviation is often characterized as a well-defended, highly technical, complex, and interconnected system of systems. As such, the least-defended segment—cargo—is a vulnerability to the entire system because of continued regulatory imbalances, different operational environments, and increasing complexity.
Safety performance: The disparity in safety between passenger and cargo operations is stark. According to the Department of Transportation, for the last 20 years cargo operations (by departure) have made up 7 percent of the FAR Part 121 industry and passenger operations about 93 percent. Yet cargo accounts for 46 percent of all fatal accidents in FAR Part 121 operations. If passenger operations experienced the same cargo accident rate of 2.72 per million departures (2004–2013), 276 fatal passenger accidents would have occurred during those 10 years. Conversely, if cargo operations experienced the passenger accident rate of 0.14 per million departures, there would be one fatal accident over the same 10 years. Several factors account for this disparity.
Regulatory imbalance: As regulators began using cost-benefit analysis (CBA) to determine the “value” of safety/security improvements to the system, cargo didn’t add up. As a result, cargo was excluded from most safety and security improvements, including science-based flight-time/duty-time rules for pilots and rules for transporting hazardous materials. Regulatory disparities also exist regarding aircraft rescue and firefighting, extended-range twin-engine operations requirements, and security requirements that allow cargo flights to often operate outside the SIDA or security area. To illustrate, cargo aircraft weren’t initially required to have traffic collision avoidance systems (TCAS) until a mid-air collision occurred between a cargo aircraft (no TCAS) and a passenger aircraft (with TCAS), which reversed the safety decision based solely on a CBA.
Operational environment: Cargo pilots, on average, have longer duty periods than passenger pilots. Also, cargo pilots fly 27–35 flight hours per month, while passenger pilots fly 47–55 hours. This means fewer takeoffs, approaches, and landings and less time on task in critical phases of flight while working longer duty periods. Furthermore, more than 60 percent of domestic cargo operations are conducted at night during a pilot’s window of circadian low when fatigue is most prevalent. As such, cargo pilots are exposed to greater fatigue hazards due to different operational environments.
Increasing complexity: As technology changes our flight decks, adds efficiency to our operations, and increases density in the national airspace system, it also adds complexity to our system. Additionally, the cumulative effect of hazards affecting other hazards isn’t accounted for, such as how fatigue may affect a pilot’s ability to recognize, assess, and recover from a possible controlled-flight-into-terrain or loss-of-control situation.
A variable with the most variability: With fatalities being one of the CBA variables with the most variability in aircraft accidents, CBA predisposes safety decision-makers to benefit the passenger side of our system. However, if the UPS Flight 1354 accident had occurred in San Diego, Calif., versus Birmingham, Ala., where population density around the airport is dramatically higher, then the CBA variable for fatalities would likely have had to also include lives lost on the ground.
The cost-benefit crutch: According to the Feb. 12, 1997, White House Commission on Aviation Safety and Security report, a catalyst for the Commercial Aviation Safety Team, “Cost alone should not become dispositive in deciding aviation safety and security rulemaking issues.” Yet that’s exactly what we see in our industry. Furthermore, the report concluded, “Cost considerations and mathematical formulas, however, should never be dispositive in making policy determinations regarding aviation safety; they are one input for decision-making. Further, nonquantifiable safety and security benefits should be included in the analysis of proposals.” ALPA concurs wholeheartedly.
If we’re to advance safety while persistent change and increasing complexity are part of this system, then safety decisions should be tied to actual safety performance to achieve parity between passenger and cargo operations while improving safety and security across the U.S., Canadian, and worldwide commercial aviation system.
