The issue of pilot fatigue and its implications for safety has been much in the headlines recently, as pilot unions protest against the introduction of revised flight time limitation regulations. BILL READ looks at the background to the debate and the issues involved. This is a full article published in Aerospace International: April 2013 [caption id="attachment_7970" align="alignnone" width="393"] Modern airline operations are 24/7. But what does this do to the pilots?[/caption] In February 2009, a Colgan Air Q400 regional turboprop flying from Newark to Buffalo in the US, stalled shortly before landing and crashed into a house killing all 49 passengers and crew, as well as a man on the ground.  According to reports, the pilots had failed to respond to cockpit warnings that the plane was close to stalling. A report from the National Transportation Safety Board (NTSB) concluded that fatigue was a contributing factor to the accident, as the pilots had had to travel long distances to get to the airport. Another incident occurred in May 2010, when the pilot of an Air India Express Boeing 737-800 flying from Dubai to Mangalore misjudged his landing and overshot the runway killing 158 people. A Court of Inquiry investigation concluded the pilot had been asleep for much of the three-hour flight and was ‘disorientated’ when the plane started to descend. These two fatal accidents lead a list of recent incidents in which pilot fatigue was identified as a causal factor (see panel below).  In a non-fatal but much publicised incident in January 2011, an Air Canada Boeing 767 was on a night-time flight over the Atlantic from Toronto to Zurich with 95 passengers and eight crew aboard. The first officer co-pilot was awoken from a nap by the sound of the captain's reporting of the aircraft’s flight position. The first officer was told by the pilot that a US military cargo plane was flying towards them but at an altitude of 1,000 feet below. Still confused and disorientated from sleep, the co-pilot then mistook the planet Venus for the other aircraft and, wrongly believing that the 767 was on a collision course, put the aircraft into a dive injuring 14 passengers who did not have their seat belts fastened and two cabin crew. The flight officer in the ‘Venus’ incident had slept badly the night before but was deemed not to have followed proper procedures. [caption id="attachment_7971" align="alignnone" width="305"] Recent pilot fatigue incidents.[/caption] The incidents that reach the headlines are only the tip of the iceberg, as there have been many more minor incidents involving fatigue which have gone unpublicised. The European Cockpit Association (ECA), which represents over 38,000 European pilots, has published ‘2012 Barometer on Pilot Fatigue’ which collated a number of surveys on pilot fatigue. According to the report, pilot fatigue is common, dangerous and under-reported with four out of five pilots having to cope with fatigue while in the cockpit and over 50% experiencing fatigue which impaired their ability to perform. However, because of fears of disciplinary action or stigmatisation by employers or colleagues, 70-80% of fatigued pilots would not file a fatigue report or declare to be unfit to fly. A recent study at UCE Birmingham on the effect of fatigue on 162 short-haul pilots  (Prevalence of fatigue among commercial pilots) reported 75% of the pilots had experienced severe fatigue with 81% considering the fatigue to be worse than two years previously. The US National Sleep Foundation published a poll in March 2012 which asked over 1,087 transportation professionals, including pilots, about their sleep habits and work performance. Of the 220 pilots interviewed, 23% admitted that sleepiness has affected their job performance at least once a week with 20% saying that sleepiness had caused safety problems on the job. Pilots also report the longest commuting times with 37% saying that it took more than an hour to get to work from home. 37% of pilots reported that their current work schedule did not allow adequate time for sleep with 50% saying that they rarely or never got a good night’s sleep on work nights.  

The need for sleep

[caption id="attachment_7973" align="alignnone" width="322"] A pilot's day does not just begin in the cockpit. (Wikipedia Commons)[/caption] It is a biological fact that humans need sleep. The human body is genetically controlled by 24-hour circadian rhythms that prompt wakefulness during the day and sleep at night. This does not pose a problem for people who work regular hours but does for those who have to work long, irregular or unsocial hours - such as pilots. A pilot’s working day does not just include the hours spent flying the aircraft but also includes the time needed to prepare and finish before and after flights, as well as commuting long distances to and from the airport. Add to this the extra working time needed if the flight is delayed, layovers at airports, repetitive tasks, the stress of night flights and difficulty getting to sleep due to stress or jet-lag and it is no wonder that pilots often feel fatigued. For many workers, feeling tired is nothing more than an inconvenience but for those in safety-critical professions, it becomes a more serious problem. The International Civil Aviation Organization (ICAO) defines fatigue as (Annex 6, Part I, as amended in 2009) "A physiological state of reduced mental or physical performance capability resulting from sleep loss or extended wakefulness and/or physical activity that can impair a crew member's alertness and ability to safely operate an aircraft or perform safety related duties." Fatigue can result in degraded vigilance, reaction times, memory recall, motor co-ordination skills, information processing capabilities and decision-making skills. If deprived of sleep for long enough, the brain can spontaneously shift from wakefulness to sleep for periods lasting from a few seconds to as long as several minutes. The ECA Barometer survey cited earlier reported that over 50% of pilots in Scandinavian countries had fallen asleep while flying. In the UK, a third of pilots who fell asleep had woken up to find their colleague sleeping as well. A sleep research project on transport and army personnel published in 2000 reported that, after being awake for over 17 hours, subjects exhibited decreases in cognitive performance equivalent to proscribed levels of alcohol intoxication. In short, fatigue is not something a flight crew wants to be suffering from in a job that needs alertness in observation, communication and action to maintain the safety of an aircraft.  

Regulations

[caption id="attachment_7975" align="alignnone" width="376"] Crew rest areas on long-haul flights allow pilots to catch up on much-needed sleep.[/caption] The dangers posed by pilot fatigue have been recognised by air transport regulators since the 1944 Chicago Convention. To ensure that crews are free from fatigue during flight, regulatory authorities have created flight time limitation (FTL) regulations which set maximum legal limits for flying hours. The FTL regulations cover flying hours per day, per month and per year, together with rules for minimum rest periods between duties. The two largest international regulatory authorities, the US?Federal Aviation Administration (FAA) and the European Aviation Safety Agency (EASA) each have their own set of FTLs. Current FTL requirements for European air transport are laid down in Subpart Q of EU-OPS 6. As part of an EU initiative to harmonise the different national rules across Europe, a revised version of ‘Subpart Q’ FTLs is due to be introduced in 2015 which will replace the UK and other current national regulations. However, the new amendments are not being welcomed by pilots who claim that, rather than reducing the problem of fatigue, the new rules will actually exacerbate it. The updated EU fatigue rules were compiled following an EASA-commissioned scientific and medical evaluation study by Moebus Aviation into pilot fatigue published in January 2009 EASA prepared proposals for the new regulations in December 2010, which were then analysed by three independent scientists. The Moebus Aviation report identified a number of provisions in Subpart Q that needed improvement, recommending that the current maximum daily flight duty period of 13-14 hours ‘exceeds reasonable limits’ and is ‘not in keeping with the body of scientific evidence’. The permitted maximum of 11:45 hours for night duty should also be reduced to ten hours because of the fatiguing nature of work at night. The study also recommended that the current rules allowing three consecutive 60-hour weeks (i.e. 180 duty hours in 21 days) needed to be changed to an maximum of 100 duty hours within 14 consecutive days (i.e. an average of 50 hours/week, instead of 60). In addition. stand-by periods at an airport should not count as rest but as part of flight duty. EASA issued a Notice of Proposed Amendment (NPA) on 20 December 2010 which was open for a three-month period of public consultation. By 20 March 2011, the Agency had received 49,819 comments from 2,715 individuals and organisations, including national aviation authorities (NAAs), professional organisations and private companies. In January 2012, EASA issued a Comment Response Document on revisions to EU-OPS 1 Subpart Q rules on pilot flight and duty time limitations and rest requirements The Agency decided to only make minimal changes to Subpart Q, except where scientific evidence ‘identified a clear need for safety improvement’. These included increasing the maximum daily flight duty period (FDP) for the ‘most unfavourable starting times’ from ten to 11 hours, together with the introduction of a binding limit of 110 hours in any 14 consecutive days. The UK Transport Committee published its own review of the issues in May 2012 which was critical of the both the Civil Aviation Authority (CAA) and EASA.  which can be downloaded from the www.parliament.uk Transport Committee website. However, the ECA is actively campaigning against the new regulations, claiming that they fail to reflect the scientists’ findings, despite being required to by ICAO. “The rules drafted by EASA are a blow in the face of Europe’s air crews and passengers,” ECA president Nico Voorbach is quoted as saying. “The new rules will allow airlines to carry out dangerous flight schedules. Air crews can be on duty for 20-22 hours. And they will be asked to fly over 12 hours throughout the night whilst scientists warn that safety risks increase significantly after ten hours at night.” According to ECA, new standby provisions in the EASA proposals will make it legal for pilots to operate and land an aircraft after having been awake for more than 22 hours. ECA also claims that the new regulations will allow:
  •  - a reduction on the number of pilots required on very long-haul flights
  • - extremely long hours awake at the moment of landing, after long standby and flight duties;
  • - night flights of up to 12 hours while scientists set the limit at ten hours;
  • - evading stringent rules on flight schedules that disrupt sleep patterns (e.g. early starts);
A British Airline Pilots’ Association (BALPA) summary of the changes to the EU regulations, as they will affect British pilots, appears below. [caption id="attachment_7974" align="alignnone" width="403"] From BALPA www.keepflyingsafe.co.uk website.[/caption] The ECA’s concerns are shared by the Irish Airline Pilots' Association (IALPA) whose safety and technical officer Captain Paul Cullen warned that flight schedules disrupting the pilots’ sleep patterns can cause dangerous levels of fatigue. On 22 January this year, the ECA representing pilots and the European Transport Workers Federation (ETF) representing cabin crew staged a series of public demonstrations at major airports in 15 EU member states under the title of ‘Walk out’ for Passenger Safety’. The action included handing over of a Safety Petition with over 100,000 signatures to the EU institutions in Brussels. In the UK, pilots from BALPA delivered a dossier containing scientific reports, correspondence and testimonials to the Prime Minister, the Department for Transport and the Civil Aviation Authority (CAA). BALPA’s general secretary Jim McAuslan said: “Our message to the decision makers is ‘You have been warned.’ We have done everything we can to warn ministers, politicians, civil servants and EU bureaucrats about why these rules are unsafe and could endanger passengers. Now, frankly, it’s over to them.” Concerns over the EASA?regulations have also been expressed by academics. “FTLs take no account of the pilot lifestyle,” commented Dr Simon Bennett at the University of Leicester’s Civil Safety and Security Unit “No account is taken of prior wakefulness, the duration and quality of sleep or commuting. FTLs are dissociated from the realities of life – despite the fact that those realities affect performance. The aviation industry is volatile. In debt due to training fees, novice pilots struggle to make ends meet. Properties in airport catchments are expensive. Hard-up pilots find themselves commuting long distances. The new regulations must take account of the fatigue-inducing aspects of life beyond the airport perimeter.” Dr Bennett published a survey of pilots in January 2013 which reported that over 20% of the respondents said that they had been awake for 28 hours or more before completing their shifts. Nearly 50% of respondents took over 60 minutes to commute to work.  

The operator’s viewpoint

European airlines do not agree with the pilots. From the point of view of an airline operator, FTLs are quite restrictive in they do not allow any flexibility if flights get delayed which could lead to cancellations, passengers being stranded and extra costs for the carriers. On the day of the pilot and cabin crew demonstrations on 22 January 2013, The Association of European Airlines , the European Regions Airline Association and the International Air Carrier Association, which collectively represent 115 European carriers, issued a joint statement saying that the new regulations are safe. ‘Based on the EASA proposal, Europe will continue to have one of the strictest flight time limitation rules in the world.’  

Cargo concerns

[caption id="attachment_7976" align="alignnone" width="341"] Frieghter pilots too are also concerned about FTL changes.[/caption] The debate over FTLs is not restricted to Europe. In the US, the FAA issued a revision to its safety rules on pilot fatigue in late 2010 requiring passenger carriers to raise the minimum time between pilot shifts from eight to ten hours with a minimum opportunity of eight hours of undisturbed sleep. The new rules also limit workday hours for pilots performing multiple take-offs and landings during late-night or early-morning shifts. However, the rules do not cover cargo aircraft pilots, whose airlines argued that they would be too expensive and difficult to implement because their pilots often flew overnight to a range of destinations. In December 2011, the Independent Pilots Association representing 2,700 pilots working for cargo airline United Parcel Service (UPS)  filed a petition asking the federal appeals court in Washington to review FAA rules which excluding cargo carriers from new requirements. The Air Line Pilots Association (ALPA) also opposes the exclusion of cargo pilots, saying the FAA has ‘seriously overestimated the cost, and undervalued the benefits’ and has pledged to fight the regulations. Other commentators have also criticised the revised rules as they apply to passenger aircraft pilots, saying that they do not take account of the long and potentially tiring commutes that many regional airline pilots make before reporting for work - a contributing factor in the 2009 Colgan Air crash. The FAA issued a final rule on the revised FTLs in January 2012 for implementation in 2015. A bill was proposed to Congress in 2012 to amend the regulations to include cargo pilots but failed to get approval. A second bill is under consideration this year.  

Other initiatives

[caption id="attachment_7981" align="alignnone" width="376"] Flight and cabin crew ‘Walk out’ protests in Austria against the new EASA FTL rules. (Austrian Cockpit Association (ACA))[/caption] The FAA and EASA are not the only regulators to be in the process of changing their FTL regulations. In January, the General Civil Aviation Authority (GCAA) in UAE announced that it would be forming new rules aligned with ICAO Annex 6 Fatigue Management SARPs which include fatigue risk management systems (FRMS). Pressure is also growing for FTL changes in other countries. Following the Mangalore crash in India, the Indian Commercial Pilots Association (ICPA) requested the Indian government to revise flight and duty time limitations (FDTLs). The association claimed that, although the FDTL in India had been changed in 2005, the Directorate General of Civil Aviation later withdrew the revised rules under ‘pressure from private operators’. While regulators debate over new rules, a number of individual organisations have launched their own fatigue-reducing initiatives. In October 2012, Singapore Airlines announced that it was consulting its 2,000 pilots to collect data on crew fatigue, including how they ensure they get adequate rest before reporting for duty, and the periods during the flight when they feel tired or sleepy. Cathay Pacific also conducted a three month fatigue survey of its pilots starting in January 2011 covering over 21,000 flights and the time leading up to them. In September 2012 the Alaska Pacific Office of the National Institute for Occupational Safety and Health (NIOSH)  invited operators of small aircraft to share experiences and methods of preventing fatigue .  

Not just pilots

[caption id="attachment_7977" align="alignnone" width="374"] It is not only pilots who can suffer from fatigue in aviation. (NATS)[/caption] While this article has concentrated on pilot fatigue, it must not be forgotten that there are many other air transport personnel who also have to work unsocial hours - including cabin crews, maintenance workers and air traffic controllers. The issue of fatigue in cabin staff was included in the EASA Moebus report, which noted that cabin crew: ‘require a sufficiently high level of alertness and cognitive performance to ensure safety and adequate response especially in non-routine situations. From the viewpoint of general health and physiological needs, the same requirements for cockpit and cabin crew should be applied’, adding that: ‘it has been shown that the fatigue levels of cabin crew towards the end of flight duty period tend to be much higher than those of cockpit crew.’ Cabin staff in Europe are also concerned over the new EASA FTL proposals and joined in the ‘Walk out’ for Passenger Safety demonstrations in January. “EASA’s proposals are hugely worrying for cabin crew,” commented Oliver Richardson from the Unite union. “We are working closely with our pilot colleagues to ensure decision makers are aware of our shared concerns. Alert and well-rested cabin crew are vital to ensuring the safety of passengers on board aircraft, and these proposals will simply make the situation much worse for both cabin and flight crew.’ Fatigue also affects air traffic controllers (ATCs). In April 2011, the FAA introduced new work rules for ATCs which allow an extra hour between shifts and more staff on overnight duty. The move came after a spate of reports of ATCs falling asleep on duty and failing to respond to calls for airliners. In one incident, two passenger aircraft had to land with assistance from a regional ATC centre after the lone controller at Ronald Reagan Washington Airport fell asleep after working his fourth consecutive 10pm- 6am overnight shift. An earlier study by the FAA’s Civil Aerospace Medical Institute found ‘widespread evidence of fatigue’ among controllers. Between 60-80% of responding controllers admitted to nearly dozing off during early morning or midnight shifts, while over two-thirds reported attention lapses while driving to work for late shifts with another third saying they had fallen asleep on similar journeys. In 2007 a lone controller on duty at Lexington, Kentucky, where an aircraft used the wrong runway and crashed, killing 49 on board, had only slept for two out of the 24 hours before the accident. The new FAA ATC?work rules also include a ‘fatigue education programme’ in which controllers can learn how to avoid fatigue on-the-job and the risks it poses. Other staff subject to fatigue include airport security staff responsible for screening passengers and checking X-ray images for dangerous items in luggage. Because the work is repetitive, many airports like to rotate screeners to different tasks every 20 minutes in order to avoid reduced performance. In an effort to reduce the risk of accidents, Zurich Airport recently introduced a Safety Management System (STS) for managing safety risks - including the problem of fatigue. Consisting of a series of standardised operational and safety processes, the STS allows employees to refuse tasks that put their own safety or that of the airport at risk.  

The FRMS alternative

[caption id="attachment_7979" align="alignnone" width="403"] Are there lessons from other transport sectors? (Parliament.uk)[/caption] Fatigue does not just affect air travel but other transportation sectors as well, such as railways, long-distance road haulage and sea transport. All of these sectors have limits on hours but still continue to suffer from fatigue-related problems. In an effort to tackle the problem, a number of organisations in the transportation sector are looking at alternative solutions in the form of fatigue management programmes (FMPs) which look at ways to minimise the results of fatigue rather than concentrating solely on hours of service. FRMS looks at the problem of fatigue from a different angle. With FRMS, the operator takes responsibility for managing the risk of fatigue, as the body best qualified to understand their own business with an understanding of where the fatigue risks lie and how to manage those risks. The UK Rail (Office of Rail Regulation) is promoting FRMS as an alternative to prescriptive rules. Typical measures in a ground-transport FMP include informed scheduling, driver and management training, and health screening. Researchers have also developed fatigue risk management systems (FRMS) composed of structure and guidance components to tackle the problem of fatigue effectively and ensure that the system is regulated in a reliable and verifiable manner. Many airlines have adopted FRMS schemes with great success. In the case of air transport, an FRMS includes a commitment to the scheme from the operator, education and awareness training programs for management and flight crews and processes for monitoring fatigue in flight crews. This includes collecting and analysing self-generated reports from flight crews as well as setting up processes for reporting, investigating, and recording incidents that may be attributable to fatigue. The results would be collated on dedicated software packages the output used to develop duty schedules that minimise fatigue-induced safety events. Together with other regulatory bodies, ICAO is promoting FRMS as an alternative to prescriptive regulations. In July 2011, ICAO, the International Air Transport Association (IATA)  and the International Federation of Airline Pilots’ Associations (IFALPA) published a Fatigue Risk Management Systems (FRMS) Implementation Guide for commercial aircraft operators.  

Conclusion

[caption id="attachment_7980" align="alignnone" width="373"] Dead tired? A demonstration outside EASA HQ in May 2012(ECA)[/caption] In conclusion, it appears that the problem of pilot fatigue is far from solved, with pilots, airlines and regulatory authorities seemingly further away from agreement than ever. Whether the solution is in reduced FTLs or FRMS is not clear but what does needs to be done is for everyone involved to start talking to each other to work out a solution which will improve safety and prevent the risk of more serious fatigue-related incidents from happening in the future. A more radical alternative would be to take the pilot out of the loop altogether with pilotless aircraft but this idea might well prove to be even more controversial than the issue of fatigue.  

Aerospace International Contents - April 2013

News Roundup - p 4 Preparing for take-off- p 12 Bombadier rolls out first CSeries Remote control p 14 Preparing to integrate remotely-piloted aircraft into civil airspace Typhoon - the best is yet to come' - p 18 Is the Eurofighter about to unlock its true potential? ATC revolution moves ahead  - p 23 NATS's game-changing iFACTS ATM tool Unmanned air power revitalises old debates - p 26 Analysis of global UAS operations Wake up call - p 30 Debate over new pilot fatigue regulations takes to the streets The last word - p 34 Keith Hayward on waht the European Union has done for air transport  
This is a full article published in Aerospace International: April 2013. As a member, you receive two new Royal Aeronautical Society publications each month - find out more about membership.

Bill Read
5 April 2013