Congress is not likely to be satisfied with the results of a National Research Council study, required by the Airline Safety and Federal Aviation Administration Extension Act of 2010, published yesterday on pilot commuting, concluding there is not enough data to dtermine whether commuting may be a safety risk. In a new report – The Effects of Commuting on Pilot Fatigue - stems from the 2009 Colgan Airways accident but is a huge issue for the airline industry.
The issue is tied with regulatory proposals on fatigue that could cost the US industry USD20 billion annually and mean a massive hiring campaign that will only exacerbate the pilots shortage. The issue will also compound the impact of new requirements that require 1500 flight hours and an ATP licence for a pilot to be hired by an airline which is already causing regionals heartburn.
The NRC, a division of the National Academy of Sciences, seemed to be sending a mixed signal saying there is not enough data but recommending development of fatigue management practices. This is more than prudent since Fatigue Management Systems (FMS) are shown to be extremely important in managing safety.
The NRC recommended instead that airlines and FAA take steps to reduce the chance commuting will pose a safety risk. In addition, it called for FAA to study how airline commuting practices relate to risk factors and fatigue.
The committee studied 17,400 mainline pilots and 7500 regional pilots from 15 airlines to determine commuting distances and showed about a half lived within 150 miles of their base. Less than one fourth lived more than 750 miles away while only 2% of mainline pilots commute coast to coast along with only 1% of regional pilots. One of the missing data points NRC wants studied is whether or not pilots actually begin their work day from home or whether the commute was done the day before reporting for duty.
Pilot unions, regulators and airlines are loathe to change commuting practice. Regardless of its popularity, commuting drew massive Congressional and public criticism after the Colgan Airways accident in which both pilots commuted long distances overnight.
Pilots, the FAA and airlines have relied on the fact that regulations already call for pilots to show up ready and able to fly, but that was not good enough for the families of those lost in the Colgan accident. Nor did it satisfy the National Transportation Safety Board which convened a three-day symposium on pilot professionalism issues. Even so, the issue of commuting was little discussed.
The accident spawned a number of recommendations including to study the impact of commuting on a pilot’s ability to perform his or her duties and whether regional pilots are at higher risk giving their multiple, short-hop legs.
The NTSB was unable to determine if fatigue contributed to the accident, although Chair Deborah Hersman wanted to include that as a finding. The NRC report is the first to address commuting but without more data was unable to make a conclusion on the safety impact. The fatigue issue - not how commuting contributes to fatigue - has been on the Board's most-wanted list of transportation safety improvements since the list was established in 1990.
“The board has issued 34 separate recommendations concerning fatigue, spanning all modes of transportation,” said Hersman. “We need to see more, especially in aviation and in marine, where the current rules were written before many of today’s workers were born.”
While there are still no definitive tools to conclusively identify the degree to which a person is fatigued, the main challenge is to ensure that all those in transportation report to work rested and fit for duty - for their own safety and for the safety of those they are transporting.
"We can't always prove fatigue as a cause of an accident, but the frequency with which we now routinely document the presence of fatigue-related factors in transportation operations is alarming," Hersman stated.
Recently, Finnair became the first to add an alertness module to crew scheduling. The science-based system has been verified by experiment and is based on Boeing’s Alertness Model (BAM) assessing alertness and well being and a pilot’s readiness for work. It was developed by Boeing subsidiary Jeppesen and is designed to reduce safety risks and links safety criteria to productivity.
The alertness model also considers back-of-the-clock flying as well as the effect of flying across time zones and the impact on alertness for crew scheduling by flagging fatigue inducing schedules. The airline said that it was developing the system in advance of expected requirement to include fatigue risk management as a requirement in flight operations.
Despite the controversy, the NTSB has been unable to cite fatigue as a causal factor in accidents, according to the NRC report. In only nine of the 863 accidents occurring between 1982 and 2010 was fatigue mentioned as a probable cause or contributing factor. None mentioned commuting as either a probable cause or contributing factor. After the Colgan accident it was found that 70% of pilots commuted to Continental’s Newark hub with 20% commuting more than 1000 miles.
The US Regional Airline Association is in the middle of what promises to be a landmark study on how the frequent daily take-offs and landings that represent regional airline service affects pilot fatigue. It is thought regional schedules are more fatiguing than long-haul flights. However, its conclusions, expected out next year, could impact pilots who do daily multi-leg trips at low cost and mainline carriers. Indeed, aasyJet is in a NASA study to gauge commuting and fatigue.
A 2010 study, done in 2009, by Flight Safety Foundation found 96% of regional pilots flew fatigued. About 28% of pilots have a second job to make ends meet and 41% commute to their duty base. Nearly three fourths indicated their duty day exceeded eight to 12 hours. Forty percent said they flew more than 400 hours in the past six months and 73% reported most flights were less than two hours. Co-pilots constituted 58% of respondents while 76% of respondents flew jet aircraft. Contrary to popular belief, a third have 3000-plus or fewer hours of experience. Some 15% were required to be available for duty even when they are off.
Flight Safety also found that a major stress centred on the fact schedules are not predictable. Ten hours or more of rest between duty times were provided, according to 73% of respondents meaning about a quarter have less. The study also found that rest began 30 minutes after landing rather than at hotel check-in, which pilots thought more reasonable.
Pilots also reported trouble falling asleep with more than half taking more than an an hour and 14.2% taking sleep aids with another 14% including alcohol as a sleep aid. The quality of sleep was also brought into question with most waking at least once and 25% more than once. Early-morning flights caused the most stress with pilots afraid they’ll miss the wake-up call, according to 76.7%. Another 18.3% reported being the subject of sanctions for reporting late after missing the call. The study also confirmed that pilots believed that calling in fatigued would result in disciplinary action, according to 60% of those surveyed with 96.8% feeling fatigued as they approached their final destination.
In addition, a recent USA Today study revealed 10% of US airline schedules in May – 2600 flights – make it harder for pilots to get enough rest, especially with early-morning departures, post-midnight arrivals and back-of-the-clock flying. It cited NTSB statistics saying fatigue was an issue in 15 accidents and incidents which killed 24 since 1993.
The NRC report indicated there is insufficient evidence to tag commuting as a safety risk simply because so little is known about specific commuting practices. It suggests that existing safety checks, balances, and redundancies in the aviation system may mitigate the consequences of pilot fatigue. It cited the fact that commuting is rarely done on a daily basis because of how dispatchers schedule pilots. Some pilots, said the report, commute only a few times a month and others arrive early enough to get sleep, as suggested by FAA Administrator Randy Babbitt when he discussed practices he adopted when he was a commercial airline pilot.
“Defining what constitutes a fatiguing commute based on time or distance is difficult,” the committee added, “because the length of commute does not necessarily determine whether a pilot reports well-rested and fit for duty. A pilot may commute a long distance, for example, but arrive in time to get adequate sleep at a local accommodation before flying. Conversely, a pilot could live close to the airport where he or she is based, sleep poorly for any number of reasons, and report to duty fatigued.”
Further study should include the relationships between commuting distances and primary risk factors for fatigue, such as sleep quantity in the 48 hours before the end of duty on each day of the trip. The study should include a large random sample of pilots from multiple companies representing major parts of the industry, and it should collect objective data on sleep and waking time using reliable technology as well as sleep-wake diaries.
The report also offered guidance for how pilots should manage their sleep and awake time in order to avoid fatigue. This is coupled with fatigue management programmes suggested at several airlines, especially regionals, in advance of an FAA mandate. NRC said pilots should plan their commutes and other pre-duty activities so that they will have been awake no more than approximately 16 hours when their duty is scheduled to be completed, and they should endeavor to sleep for at least six hours prior to reporting for duty. Often this is easier said than done given the impact of weather and delays on the duty day.
Pilots, regulators and airlines do not want to risk forcing a change into the popular commuting practices so it will likely be up to the FAA to mandate the NRC recommendation that airlines should collect more data on their pilots’ commuting practices and educate pilots about potentially fatiguing effects of commuting. NRC went further, saying companies should also consider policies to help pilots plan predictable, non-fatiguing commutes and minimise negative commuting practices that are related to risk factors for fatigue.
“Some commutes have the potential to contribute to fatigue in pilots, and fatigue can pose a safety risk, but at this point we simply don’t know very much about actual pilots’ commuting practices,” said Committee Chair Clint Oster, a professor in the School of Public and Environmental Affairs at Indiana University, Bloomington. “Airlines and FAA should gather more information on pilots’ commutes, and also work with pilots to lower the likelihood that fatigue from commuting will be a safety risk.”
Lowering the risks
The report did note fatigue can lower performance if a person is awake continuously for more than about 16 hours or sleeps less than six hours on the day prior to work. It pointed to the development of Fatigue Risk Management Systems developed by the International Civil Aviation Organisation that focus on integrating scientific knowledge about fatigue and its management with the realities of airline operations. The committee would add a component on the effects of commuting practices on fatigue.
“The adoption of this approach by US airlines would help spot and mitigate potential problems, and it would give both the airlines and the FAA more information on whether commuting is contributing to fatigue and whether fatigue levels are within or beyond an acceptable level of risk,” said the committee, which wants FAA to contract with an independent organisation to assess current policies and develop best practices on pilot commuting, sick leave, attendance and fatigue.
This is significant since controversies arose between pilots and management during the Colgan hearings about the practicality of a pilot calling in fatigued. Pilots said such calls were not welcome by management. Criticism also surrounded the incentives for pilots to report for duty even when fatigued such as the fact they do not get paid if they do not fly, nor does the regional airline get paid by its major partner is the flight has to be canceled.
The committee suggested the well-respected Flight Safety Foundation be part of the FAA effort which would also include the development of a joint industry, labour and government working group that would also help FAA develop protocols and materials that train pilots to make decisions about commuting easily and effectively.
FAA has proposed a rule that would allow others to assess whether a pilot is fatigued. However, there are currently no valid and reliable tools and techniques to detect fatigue in pilots in an operational setting, the committee said. Further research would be needed to scientifically validate these tools and techniques and their use in a real-world context.
The study was sponsored by the Federal Aviation Administration. The National Academy of Sciences, National Academy of Engineering, Institute of Medicine and National Research Council make up the National Academies.
Fatigue rules are a long time in coming
Fitness to fly is a world-wide concern and European pilots and regulators are in a controversial battle just as they are in the US. Last month, pilots picketed an EU Transport Council meeting saying proposed regulations do not go far enough in mitigating fatigue from flight-and-duty-time regulations because they are not science based. Proposals allow 14-hour days, longer than previous rules and the proposed rules in the US which are expected to become final this year. EASA is currently culling through comments to its proposed rule making. The proposal prohibits individual states imposing tougher regulations than those adopted by the EU. Pilots want states to be able to impose their own regulations.
While the US limits flying time to eight hours, European rules allow international pilots to remain on duty in the cockpit for more than eight hours. Pilots there also complain no rest space is provided when the flight requires a third, relief pilot.
One of the major issues in both the US and Europe is the one-size-fits-all approach to aviation safety. Critics say regulations need to account for the vast differences in aviation operations. However, the trend since the mid-1990s has been to a single level of safety and the NTSB would like that single level applied to anything that takes to the sky whether it is a helicopter, an air taxi or a tourist flight.
A Boeing study of fatigue risk management in China, Europe and the US was telling despite its confirmation of the value fatigue risk management. US regulations were found to be the best when it came to productivity in terms of block hours but failed against the Chinese and European limitations when it came to maintaining alertness. FAA regulations have with higher maximum duty time and lower minimum rest requirements.
European regulations were shown to be the best for alertness but the worst on productivity. Combining the two factors under Boeing’s Alertness Model shows that the adoption of fatigue risk management (FRM) is key to mitigating the impact of flight and duty time. It also identified the US system as the one with the potential to gain the most from fatigue risk management although the other two systems would gain great benefits from FRM. However, FRM cannot replace flight-and-duty time regulations as yet, the study concluded.
The FAA is already under fire because of its proposed flight-and-duty-time regulations - 30 years in the making - is long overdue from the promise made that it would be out by the end of 2009. However, it has also been caught in a dispute with the Office of Management and Budget because of projected costs would outweigh safety benefits.
The FAA rule making completely dodged the commuting issue. In addition, the rules ostensibly were developed by an Aviation Rule making Committee (ARC) that was the first attempt to apply science to determining how long a pilot should be on duty. However, once the rule making was actually published critics immediately said the rule was watered down and instead of being based on science was based on political considerations.
Even so, the airline industry has opposed the new regs with American saying it would require it to hire another 2400 pilots at an additional cost of USD514 million annually, in an SEC filing required when changes will have a material impact on a company’s fortunes. Likewise, Southwest opposed the rule saying it undermines the legendary productivity of its pilots, something it sites as a major cost advantage.
Meanwhile, FAA said compliance would cost the industry an additional USD1.25 billion over 10 years but industry has rarely agreed with FAA estimates. Indeed, the Air Transport Association pegged the cost at USD19.6 billion over the same period, noting that was 15 times FAA estimates.
The rule would be particularly devastating for regional airlines which are already facing stiff headwinds as major airlines pressure them to lower the cost of providing capacity. They are already facing increased training and pilot hiring requirements that will make it more difficult to find pilots. Observers predict a major change to regional economics that potentially could further disrupt service to the communities traditionally served by regionals. The impact on regionals illustrates that, while the arguments are cast as either pro- or anti-safety, the issue is fare more complex than that and could mean the abandonment of many more regional communities repeating what happened when the single level of safety which became effective in 1997.
In an effort to streamline regulations so they are less burdensome, efforts in Washington have centered on not only doing an economic analysis of a regulation from the industry standpoint but also going further to determine on what the regulation will mean to the economy.
Critics suggest that would further dilute safety regulations. While acknowledging the necessity for more pilot hiring, FAA Administrator Babbitt, a former Air Line Pilots Association president, said the additional costs could be mitigated by better scheduling practice.
But perhaps the bigger question is where these new hires will come from given the growing pilot shortage which is now coupled with tougher regulations - a requirement of 1500 hours flight time - on who can become a pilot. That is then compounded by new training requirements.
The proposed rule calls for 30 consecutive hours away from work per week and requires nine hours rest between flights. It also limits flight time to between eight and 10 hours, depending on when the duty day starts. The duty day would be limited to 13 hours daily, significantly down from the current 16-hour duty limit. Airlines say that is unmanageable given delays and congestion which are often outside the airline’s control. Indeed, it is for that reason that airlines will be required to allow for delays with 30 to 90-minute buffers between flights.
Southwest, specifically objected to this saying it would not enhance safety, nor would it reduce fatigue. “We feel that many of the rule changes will impact our operation as dramatically, if not more so, than the impact on any other carrier,” said the airline in its comments objecting to the changes. “The proposed rules, layered with multiple restrictions aimed to reduce fatigue, will no doubt serve to lower the productivity of the Southwest Airlines flight crew member.”
As for pilots, the Air Line Pilots Association called the proposed rule a “watershed moment” for safety. It cited the scientific basis on which the proposals were developed and unifies requirements regardless of whether the flight carries passengers or cargo. In a commentary, ALPA defended commuting saying it is a long-time practice even as the industry has improved safety over the decades. It called commuting a “function of economic circumstances or quality of life decisions” that spares families upheaval.
ALPA also said the new flight-and-duty rules address commuting issues with fatigue management techniques and provide consequences for allowing pilots to report to work fatigued. Airlines will be required to audit for pilot fatigue under the new rules in addition to determining the cause and implementing fatigue management programmes.