Are exhausted pilots flying our planes? Pilots union says “yes”

The president of the Airline Pilots Association, John Prater, had some sobering words about pilot fatigue before the Senate Subcommittee on Aviation, Committee on Commerce, Science and Transportation, yesterday. His testimony about the realities of a pilot’s life and duty time are eye-opening, to say the least.

Here are his comments in his own words from Senate Subcommittee testimony. Most interesting to me is the section on rest time between duty days.

“Fatigue may adversely affect every flight crewmember every time they fly. Due to airline economic conditions which require pilots to work longer days and more of them than ever before, fatigue has reached alarming levels within the industry. The FAA’s flight and duty time regulations are woefully inadequate to address today’s situation and have not significantly changed in over 60 years, since well before jet transports came into use in the late 1950s. The current U.S. flight and duty time rules are a patchwork of regulations that are intended to address disparate domestic, international flag, and supplemental operations. There have been a number of attempts to revise the regulations over the past 25 years, but those attempts have met with generally abysmal results because of the contentious disagreement by the stakeholders as to which changes were appropriate or needed.

One fact about pilot fatigue that is not widely known is that airline pilots frequently spend much more time at work each day than the number of hours recorded actually flying an airplane. This is especially true in the regional industry although the work schedules at the so-called “legacy carriers” are by no means free of these same concerns. Currently, airline pilots are routinely assigned duty days of up to 15 hours. During a typical 14- to 15-hour duty day, a pilot can expect to be assigned fewer than 8 hours of flying but up to 8 individual take offs and landings, in various types of weather and across multiple time zones. The time not flying may be spent performing duties such as checking weather, dealing with routing, dispatch and flight paperwork, overseeing aircraft loading and unloading, dealing with mechanical issues, waiting on the ground between flights, and similar activities. Thus, although a pilot may have only flown 7 or fewer flight hours by the end of a duty day, he or she could easily have been on duty 14 or 15 hours. This work pattern may be repeated over a period of several days. The weight of the scientific evidence accumulated over the last 20 or so years has firmly established that the vast majority of humans simply cannot be expected to reliably and safely perform operational tasks beyond 12 to 14 hours on duty. It cannot be overstated that pilots are making their most critical decisions on landings at the very end of their duty day which, due to unplanned circumstances, can easily be 20 hours or more since their last rest period. It is worth noting in this context that most fatal accidents occur during the landing phase of flight.

The airlines are required to give pilots only an 8-hour break after any duty day, regardless of its length. Unfortunately, this 8-hour minimum break does not provide an adequate opportunity for recuperative sleep because the break is not an opportunity for 8 hours of sleep, but rather a period of time away from the aircraft. During the 8-hour break, it is not unusual for a pilot to be left with a maximum 4 or 5 hours of sleep opportunity. This occurs because the FAA has defined all time away from the airplane (“release to report”) on a trip as “rest.” Incredible as it may seem, the time a pilot spends waiting for a hotel shuttle and going through airport security screening is defined as “rest” under the current FAA regulatory scheme. A pilot must also attend to all of his or her other non-work- related daily physical and nutritional needs and requirements during this 8-hour break away from the aircraft. It is not at all unusual for a pilot to elect to forego a meal so as not to further reduce their sleep opportunity. This situation is highly objectionable– sleep experts agree that most adults require 7 to 8 hours of sleep each night to meet their physiological needs and restore their alertness. Pilots need a longer, and genuine, daily rest period than is allowed under current regulations.

Another serious deficiency in current regulations is the failure to acknowledge circadian rhythms. Every human has an internal circadian cycle that determines sleep and wakefulness. Typical “circadian low” cycles (i.e., a period of reduced wakefulness and energy) will occur from approximately 3:00 to 5:00 a.m. and again from 3:00 to 5:00 p.m. Performance and alertness may be decreased during the nocturnal window, which is from approximately 2 a.m. until 6 a.m., depending on individual variability. Flight and duty regulations need to acknowledge this cycle.

Because the FAA’s present fatigue regulations are antiquated and outmoded, they have frequently been augmented by contractual work rules negotiated between pilots and their employers in the decades from 1960 to the mid 80’s. Through the restructuring of pilot contracts in corporate bankruptcies (note: over 160 U.S. airlines have gone through bankruptcy since 1980) and the complete absence of negotiated work rule improvements at many carriers, there has been non-uniform treatment of flight duty and rest limitations at the various airlines, leaving only the antiquated Federal Aviation Regulations to govern maximum duty days and minimum rest periods for thousands of airline pilots. Further exacerbating the problem is the fact that pilot wage rates and pensions were slashed by more than 30% in corporate bankruptcies forcing pilots to accept even more flights or face their own financial crisis. Fatigue provisions are rarely found within any pilot contract, especially within a regional airline agreement. Of the regional contracts that do have such provisions, only one of which we are aware allows a pilot to recoup his or her lost pay. All contracts of which we are aware contain real threats of disciplinary action if the company determines that a pilot’s claim of fatigue was fraudulent.

In recent times, there has been severe pressure on individual airlines to slash pilot staffing and reduce rest periods to minimum levels due to a belief that such actions would result in “productivity” increases necessary for economic survival. The demands for more monthly and yearly flight hours flown by fewer pilots has lead to endemic fatigue levels, and with fewer pilots staffed on reserve or standby duty for weather disruptions, pilots are forced to fly more flights to the upper limits of the FARs or watch as scheduled flights are cancelled for lack of available rested crews. The fatigue cushion once provided by negotiated work rules has been virtually eliminated largely due to a single-minded focus by airline managements on minimizing the labor costs associated with flight operations. This elimination of the fatigue protections once provided by negotiated work rules that were developed over decades of experience at most established air carriers means that today, for more and more pilots, the bare minimum protections afforded by the FAA flight and rest regulations have become a daily way of life.

The current cumulative effects of reduced rest resulting from working to minimum FAA limits, combined with the effect of personal financial stress and uncertainty brought about by nearly eight years of severe economic downtimes in the industry, have taken a severe toll upon pilots. Many pilots feel that they are just hanging on to a barely tolerable job instead of pursuing a once-promising career. Today’s airline pilot is typically working substantially more hours for less money and spending more hours away from home than his or her predecessors. In addition, regularly required training events are crammed on top of the monthly flight schedule often paying less than 3 hours of pay for 8 hours of training with none of that time counting towards the FAR flight time limits. The repeated attempts by airline managements in recent years to return U.S. airlines to an era of profitability by cutting labor costs continues to be paid for by the daily sacrifices and toil of airline pilots and other workers.”

Tagged as: airline pilots association, FAA, fatigue, pilots