Pilot Fatigue
The FAA has proposed new rules to govern rest for pilots and I’m sure it will set off considerable debate. I haven’t read the proposed rules in detail but the highlights didn’t really encourage me. In fact, I don’t think fatigue is being addressed in those rules very well at all. Instead, I think the perception of the problem is being addressed.
Pilots aren’t just fatigued because the number of hours they work in a day. They aren’t fatigued because we only require 8 hours of rest period between duty time on successive days. Both of those conditions do contribute, yes. But one of the hidden problems has more to do with how a pilot has to manage his or her life with respect to their career.
Mind you, we aren’t requiring 8 hours (9 hours in the new rule) of sleep between duty periods. Just rest. Rest being largely defined as “do what you gotta do to get your stuff done and get some sort of sleep.” A pilot entering a “rest period” still has to eat, bathe, tend to family obligations, etc, as well as sleep.
In addition, many pilots have to commute to their duty stations. A pilot assigned to New York City for duty may be commuting in from Topeka, Kansas. That means to make a duty start time of 8am on a Monday, they probably left mid-day the previous day, flew to NYC, went to a “crash pad” or hotel room, had some kind of meal and some kind of sleep but then got up as early as 5am to make an 8am duty time. That doesn’t allow for much rest much less *quality* rest.
If we’re going to have new rules, it would seem to be better to craft rules that allow for quality rest on a regular basis. That doesn’t mean every night necessarily but it does mean more frequently than every 7 days too. We need rules that, perhaps, govern how much time you can spend commuting in the 24 hours prior to your duty time. Do we really want pilots spending 8 hours in a day to get to their duty station and then put them on the job for as much as 8 hours of flying and 12+ hours of duty time?
Maybe pilots shouldn’t be allowed to spend more than 4 hours commuting to their job on their duty day and no more than 6 hours commuting the day before their duty day. I’m certain there is a number to be found that would help reduce real fatigue.
How many hours someone can work in a particular day is important, yes. But how many hours they can work in a week and how many hours they spend commuting back and forth to their job is even more important.
These new rules were spurred by the Colgan Air crash in New York State. Fatigue was cited as a contributing problem. Let me point out that those pilots had commuted coast to coast and their “rest” was garned by sleeping on the aircraft they were commuting on and in pilot “quiet rooms” at airports. That’s not rest, that’s a holding action at best.
The DOT mandates specific work hours for over-the-road truckers, involving hours actually driving the rig, hours spent on-duty but *not* driving – loading, unloading, fuel stops, &c. – and hours actually off-duty (whether you spend it in the bunk or in the truck stop sucking coffee doesn’t concern the friendly DOT Trooper). You are allowed up to 11 hours driving, and/or up to a combination of 14 hours of driving and on-duty-but-not-driving time, at which point you are required by law to go off-duty for at least ten hours. You are allowed up to a total of 70 hours driving and on-duty time in an 8-day week, at which point you must be off-duty for at least 34 hours. Drivers of CMVs[1] carring passengers, e.g. bus drivers, have similar rules, except the limits are 10 hours driving and 15 hours combined on-duty, with an 8-hour rest period.
How do you think something similar to this would work with commercial pilots?
-R
(still Class A after all these years….)
Well, that’s not entirely unlike what pilots are subjected to now.
I think a system that accounts for segment length and the number of landings per day as well as duty hours would be appropriate. It’s a lot more fatiguing to fly 6 trip segments in a day than it is to fly just one. I do think a mandated amount of rest time at our about 9 to 10 hours upon arrival at a hotel or home before leaving home to go back on duty is also appropriate. I think there could be exceptions to that as well. For instance, reduced rest of 6 to 8 hours with the understanding that one trip of no more than 3 hours duration occur the next day.
It’s a complicated in the airline world so I see no reason for it be a bit complicated on rest, too. That said, what you described would, in my mind, almost certainly ensure rest as long as that time prior to trip isn’t spent entirely on commuting across the country. And that brings up the other problem: commuting. It’s a necessary evil but qualifying rest time should be about rest, not sitting in a jump seat flying halfway across the country to get to your duty station so you can fly 5 trip segments the rest of the day.
Damned footnote monkey…
[1] “Commercial Motor Vehicles”
And that brings up the other problem: commuting. It’s a necessary evil but qualifying rest time should be about rest, not sitting in a jump seat flying halfway across the country to get to your duty station so you can fly 5 trip segments the rest of the day.
Yup… In the trucking world, riding the passenger seat in a truck on the way to the terminal to pick up your truck would *not* count as “off-duty” or “rest” periods; even riding in the sleeper berth is not really considered part of your 34-hour clock – you need to be *OUT* of the tractor for at least that thirty-four. Flying jumpseat is no different, in my mind, and does *not* constitute “rest.”
(in fact, not one single part of commercial aviation strikes me as being restful, these days….)
-R