The Effects of Commuting on Pilot Fatigue (2011) / Chapter Skim
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6 Reducing the Risk of Fatigue from Commuting
6 Reducing the Risk of Fatigue from Commuting
Pages 99-114
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111-216 (the Airline Safety and Federal Aviation Administration Extension Act of 2010) , the FAA on September 14, 2010, issued a Notice of Proposed Rulemaking (NPRM)
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. Issues Related to the Proposed Rule The proposed regulations present commuting as fundamentally an issue of fitness for duty, defining a responsible commuter as a pilot who "plans his or her commute to minimize its impact on his or her ability to get meaningful rest shortly before flying, thus fulfilling the proposed requirement that he or she reports for an FDP rested and prepared to perform his or her assigned duty" (p.
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that fitness for duty is considered a joint responsibility of the air carrier and the crew member and goes on to say, "Part 117 recognizes the need to hold both air carriers and pilots responsible for making sure crewmembers are working a reasonable number of hours, getting sufficient sleep, and not reporting for flight duty in an unsafe condition. Many of the ways that air carriers and crewmembers negotiate this joint responsibility are handled in the context of labor management relations and agreements." FATIGUE RISK MANAGEMENT PLANS AND SYSTEMS There are currently two different regulatory initiatives that are relevant to the discussion of commuting and its effect on fatigue: fatigue risk management plans (FRMPs)
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that provided the necessary information for air carriers regarding the structure and elements involved in the development of a fatigue risk management plan.1 The FRMP structure should consist of: • s enior-level management commitment to reducing fatigue and im proving flight crew member alertness; • F RMP scope and fatigue management policies and procedures; • c urrent flight time and duty period limitations; • r est scheme consistent with limitations; • f atigue reporting policy; • e ducation and awareness training program; • f atigue incident reporting process; • s ystem for monitoring flight crew fatigue; and • a n FRMP evaluation program (Federal Aviation Administration, 2010a)
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. The following question regarding FRMPs was posed to airlines from whom the committee requested input for this study, "Does your Fatigue Risk Management Plan include any reference or consideration of commuting?
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In essence, these systems recognize that responsibility for managing fatigue-related safety risks is a shared responsibility of regulatory authorities, operators, and individual pilots. In an effort to collect additional data, the committee approached many international regulatory and safety oversight organizations, operators, and pilot associations -- including the International Civil Aviation Organization (ICAO)
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The operator must also ensure that remedial actions, necessary to effectively mitigate the risks associated with the hazards, are implemented promptly, and it must specify the methods it will use to actively monitor the effectiveness of those actions taken to mitigate fatigue risks (International Civil Aviation Organization, 2011a, 2011b)
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a fatigue risk management policy, (b) an education and awareness training program, (c)
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Regulators may not have enough knowledge about the detailed operation of the systems and so may adopt seemingly simple regulations that fail to anticipate how the system will respond to those regulations. An early analysis of the general problem of unintended consequences found that one of its sources is "imperious immediacy of interest," which is where 4 Such voluntary FAA programs include the Aviation Safety Action Program and the Flight Operational Quality Assurance Program.
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Although multiple factors contributed to the decline in fatalities, the general consensus was that the reduced speed limits had resulted in fewer highway fatalities. As the fuel shortage eased, the speed limit was retained largely on the grounds of the increased safety it apparently provided.
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In particular, there is very little knowledge about the extent to which pilot commuting contributes to pilot fatigue in practice, in part because there are almost no systematic data on current pilot commuting patterns. Determining the extent to which fatigue may have contributed to an accident is difficult in an accident investigation, the committee's examination of 863 accidents found only 9 in which fatigue was judged to be a probable cause or contributing factor (see Chapter 3)
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Those higher wages, should they be necessary, would result in higher costs to the airlines and eventually higher ticket prices. With these considerations in mind, it is important to note that assessing the impact of cost on airline ticket prices and, in turn, on increased highway fatalities is beyond the scope of the current requirements for cost-benefit analysis of proposed regulations.
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FRMSs can offer both the airline and the Federal Aviation Administration an improved assessment of crew alertness
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RECOMMENDATION 3: The committee supports fatigue education and awareness training as part of an airline's fatigue risk manage ment plan. Training relative to commuting should include guidelines regarding the effects of inadequate or disturbed sleep or prolonged wakefulness on fatigue and performance.
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This information, combined with information that is recommended for inclusion in the required FRMPs or in FRMSs, when such systems are required, will provide input needed to inform further research and industry policies. RECOMMENDATION 6: To inform the development of industry best practices and policies relative to commuting, the Federal Aviation Administration should fund a study to determine the relationships be tween distance from domicile and five primary fatigue risk factors: (1)
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114 THE EFFECTS OF COMMUTING ON PILOT FATIGUE validated technology that provides reliable information on sleep and wake periods, such as wrist actigraphy, as well as sleep-wake diaries. Collecting data on a 48- to 72-hour period is needed to fully understand pilots' commuting experiences within the context of multiple factors.
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