One of the many hardships that the post-9/11 era brought to airline flying was new work rules which resulted in pilots flying more days per month to reach their contractual hours. This has resulted in safety impacts, fatigue, and more stress. Sixteen-hour domestic duty days – even longer with some long-range international operations – are facts of life for many airline pilots. Irregular shifts, crossing time zones, all-night operations, and significant circadian rhythm challenges all contribute to pilot fatigue. The pay and productivity hits of the last few years mean that our members are working at or near regulatory limits.
Technological advances have exacerbated the problem of pilot fatigue. The current prescriptive regulations regarding maximum flight time and duty periods have not been significantly changed since well before jet transports came into commercial use in the late 1950’s. Some airliners being operated now can fly for more than 20 hours without refueling. With flights of this duration, combating flight crew fatigue is a real and constant concern.
The National Transportation Safety Board (NTSB) lists as one of its “most wanted” aviation safety improvements reducing the potential for accidents and incidents caused by human fatigue. Although the FAA issued a notice of proposed rulemaking in December 1995 to update the flight and duty regulations for airline pilots, in the intervening 14 years, the regulations have not been revised. Last summer, the FAA held a conference on the subject of fatigue, at which hundreds of government and industry personnel convened to discuss the need for creating new flight and duty requirements which will protect against fatigue-related accidents and incidents. The agency has stated that it is developing a fatigue risk management system (FRMS) to provide an alternative to prescriptive limitations, and it has issued new rules for ultra-long range (ULR) operations (i.e., those in excess of 16 hours of flight time). Pointing up the difficulty in making inroads on this problem, however, several affected ULR carriers have sued the FAA over these new operations specifications.
To address the problem of pilot fatigue, ALPA advocates for adequate rest periods, reasonable duty periods and special provisions for flying “backside of the clock” and for crossing multiple time zones. Any regulations developed to deal with fatigue should be: science-based; apply to all sizes of aircraft operators; and, address passenger and all-cargo operators equally. Fatigue risk management systems should complement, and not be used as a substitute for, a flight-/duty-time regulatory framework. ALPA is also urging Congress to direct FAA to arrange for a study by the National Academy of Sciences on pilot fatigue to include an examination of recommendations made by the NTSB and the National Aeronautics and Space Administration (NASA) on this subject.