Fatigue Regulation Air

Fit to fly

New requirements aim to make pilots more prepared, less fatigued


After Colgan Air Flight 3407 crashed near Buffalo, NY, in February 2009, killing 50 people, Congress passed an act to update Federal Aviation Administration regulations on pilot qualification, training and fatigue – all of which were factors alleged to have contributed to the crash.

Among FAA’s responses to the Airline Safety and Federal Aviation Administration Extension Act of 2010 are new rules regarding qualification requirements for first officers – the entry-level pilots of commercial passenger and cargo flights – as well as an increase in the amount of flight and simulation training carriers must provide commercial pilots.

More controversial are new scheduling requirements aimed at reducing pilot fatigue. The rule, which went into effect Jan. 4, exempts cargo pilots – a provision supported by leading cargo carriers but strongly opposed by some pilot associations, safety advocates and lawmakers.

Schedules and pilot fatigue

A National Transportation Safety Board investigation determined that the captain and first officer of Colgan Air Flight 3407 were fatigued when they failed to anticipate and correct a stall during snowy weather. Scheduling issues and long commutes had resulted in “interrupted and poor-quality” sleep for both pilots in the 24 hours before the crash occurred, NTSB concluded.

Pilot fatigue is not a rare occurrence in the aviation industry, according to a poll released in March 2012 by the Arlington, VA-based National Sleep Foundation. Poll results showed that 1 out of 5 commercial pilots of passenger and cargo-carrying aircraft admitted to making a “serious error” due to sleepiness that nearly caused a crash or other incident. More than one-third of the respondents said their current schedule does not allow enough time for sleep.

Fatigue affects a person’s motor skills and can degrade cognitive performance and cause complacency, said Bruce Landsberg, president of the Frederick, MD-based Aircraft Owners and Pilots Association Foundation, which also houses the Air Safety Institute. Pilots who are complacent may choose to perform unsafe maneuvers or make inappropriate flight path decisions, said Landsberg.

FAA’s new scheduling requirements increase the amount of time pilots of passenger-carrying aircraft must be allowed to rest each day to 10 hours from eight hours, with the opportunity for at least eight hours of uninterrupted sleep. To combat cumulative fatigue – the degradation in performance over time caused by inadequate restful sleep – the rule increases the number of weekly consecutive off-duty hours pilots must receive to 30 from 24, and limits the amount they can work monthly and annually.

Cargo aircraft pilot exclusion

FAA exempted cargo pilots from the anti-fatigue scheduling rule, stating in a regulatory impact analysis that the rule’s safety benefits would not offset the high costs to cargo carriers.

The Air Line Pilots Association, International, argued that FAA did not analyze a sufficient number of cargo aircraft crashes and ignored the health and safety benefits of extending the rule. Immediately after the rule was issued, the Independent Pilots Association, which represents United Parcel Service pilots, echoed the Air Line Pilots Association’s stance and called for “one level of safety” in a petition filed with the U.S. Court of Appeals for the District of Columbia Circuit. At press time, the Independent Pilots Association’s challenge of the exclusion was ongoing.

FAA is encouraging cargo carriers to voluntarily comply with the new requirements, although some carriers support the exclusion. Other carriers have stated that extending the new rule to cargo pilots may decrease those pilots’ safety because they have different flight responsibilities than passenger pilots.

Calling the exclusion an “economics decision,” Landsberg said he believes FAA received pressure from the cargo industry because carriers would need to pay for additional pilots to rotate out those who reach the new daily flight duty time limit.

On April 16, 2012, Rep. Chip Cravaack (R-MN), a former cargo pilot, co-introduced an act that would require FAA to extend the updated anti-fatigue scheduling requirements to cargo flights. The Safe Skies Act was reintroduced in the House and Senate in 2013 and, at press time, had been referred to each chamber’s aviation subcommittee.

The Air Line Pilots Association supports the legislation, stating in November that “science shows that airline pilots don’t suffer from fatigue differently based on whether they fly passengers or cargo on their aircraft.”

Training and qualification rules

NTSB’s investigation of Colgan Air Flight 3407 concluded that both the captain and first officer, although certified to fly, were not sufficiently qualified to operate the recently manufactured aircraft they were flying. NTSB also noted inadequacies in the captain’s flight and simulator training for aerodynamic stalls.

It was not the first time FAA’s pilot qualification and training requirements had been questioned by an independent government body. In a 2012 report, the Government Accountability Office found that FAA’s entry-level pilot training requirements were too focused on the motor skills needed to perform maneuvers and the mechanics of flying, and were missing behavioral aptitudes such as situational risk assessment and decision-making desired by the aviation industry.

To address NTSB’s and GAO’s concerns about pilot training, FAA issued a final rule, which went into effect Nov. 5, 2013, mandating that carriers increase commercial pilot training on the most dangerous types of flight situations, including stalls. Commercial air carriers have up to five years to implement some of the changes to allow time to update simulator hardware or software.

Additionally, a final rule on first officer qualification requirements takes steps to address new pilots’ behavioral aptitudes, according to William Brogan, chair of the Aviation Department and associate professor of aviation and transportation at Lewis University in Romeoville, IL. The rule, which went into effect in August 2013, requires first officers to spend 1,500 hours in a cockpit before earning a certificate – a sixfold increase from previous requirements – with a reduced time requirement for pilots with two- or four-year aviation degrees or with military experience. First officers also must receive specific training and complete testing on the primary type and class of aircraft they will be operating.

“It’s experience that is above and beyond what used to be required,” Brogan said. “Experience builds usually better skills and a better decision-making process.”

Many four-year aviation graduates – who typically complete 500-600 hours by the end of their programs – will now need to log 400 or more hours as flight instructors, crop dusters or other cockpit roles to meet the increased 1,000-hour requirement, Brogan said. Although this may discourage some aspiring pilots, the new qualification standards are a good thing from a safety perspective, he said.

“Any time anything bad happens in the aviation industry, there is an amazing amount of time and effort that goes into why something went bad,” Brogan said. “All changes moving forward, such as this change, [are] just trying to make it safer and better for the flying public.”

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