Keep Flying Safe Keep Flying Safe


What is this all about?

In the UK we have a strict set of flight safety rules which govern how long and how often a pilot can fly before their performance is impaired. The EU is proposing more permissive flight safety rules which would allow pilots to be flying aircraft whilst dangerously fatigued. These rules were not developed using scientific data and could have a grave impact on the safety of UK aviation. The Government needs to keep our UK rules, the Government needs to keep flying safe.

What is pilot fatigue?

Pilot fatigue is a state of serious tiredness and exhaustion that reduces a pilots ability to operate safely. Formally it is defined* as A physiological state of reduced mental or physical performance capability resulting from sleep loss or extended wakefulness and/or physical activity that can impair a crew member's alertness and ability to safely operate an aircraft or perform safety related duties.

* Defined by International Civil Aviation Organisation ICAO (Annex 6, Part I, as amended in 2009)

Does pilot fatigue cause accidents?

Yes it does. 15-20% of fatal accidents related to human errors have pilot fatigue as a contributing factor* and some notable accidents include:

  • 2010 Air India– Mangalore – 152 killed
  • 2009 Colgan Air – Buffalo NY – 52 killed
  • 2006 Comair – Lexington KY – 49 killed
  • 2004 Med Air - San Bernadino CA – 5 killed
  • 2004 MK Airlines Halifax Canada – 8 killed
  • 2002 AgcoCorp Birmingham UK – 5 killed
  • 2001 Crossair, BAe146 at Zurich, Switzerland
  • 1999 American Airlines Texas USA – 11 killed
  • 1997 Korean Air Guam - 228 killed
  • 1994 Air Algerie, Coventry, UK – 5 killed
  • 1993 Kalitta International, Guantanamo Bay – 11 killed

Furthermore, there is extensive scientific evidence that shows accident rates increase markedly after 13 hours on duty** as the graph below shows


*The role of EU FTL legislation in reducing cumulative fatigue in civil aviation” 2003T. Akerstedt, R. Mollard, A. Samel, M. Simons, M. Spencer
**Study by Goode JH, 2003

What are Flight Time Limitations? (FTLs)

Flight Time Limitations are the rules which govern how long and how often a pilot can fly before he (or she) becomes too tired to operate safely. Since the 1944 Chicago Convention*, it has been recognised that pilot fatigue can pose a risk to the safety of air operations. This risk needs to be controlled by the means of Flight Time Limitations (FTLs).

*1944 Chicago Convention (Annex 6, 9.6.) "The State of the Operator shall establish regulations specifying the limitations applicable to the flight time and flight duty periods for flight crew members.

Why are the current UK rules being changed?

To fall into line with Europe. The UK has had its own set of Flight Time Limitations (known as CAP371) which are heralded as one of the safest schemes in the world. However, as of 2013 these UK rules will no longer exist and, unless the Government decide to opt out, we will be using the new EU rules. There is a unique legislative opportunity here to provide safe, scientifically based rules for the whole of Europe but, as they stand, they are simply not safe.

What is wrong with the EU rules?

Quite a lot. They have been developed without any scientific basis and under significant pressure from the airlines who are of course keen to increase staff productivity. The rules are flawed in many areas but here are 3 examples of just how wrong they are:

  • Pilots will be legally allowed to land an aircraft having been awake for 22 hours.
  • Pilots will be operating longer haul flights (such as west coast USA) with only 2 crew rather than the current 3.
  • Pilots could be forced to work up to 7 early starts in a row. Something that is proven to cause dangerous cumulative fatigue.

Fatigue is a growing problem in Europe.

Increasingly, due to commercial pressures, we are seeing FTL rules being set as a ‘target’ rather than the limits for safe operation. Recent surveys in the UK show that … Indeed in a recent poll if UK pilots 43% said they had fallen asleep while working in 2 crew operations. More worryingly, of them 31% have woken up to find the other pilot asleep.*

This reality is not captured by official statistics. This is because the statistical tools often are not precise enough to properly identify pilot fatigue. Furthermore fatigue is significantly under-reported by the pilots themselves. This is because pilots do not file reports on an aspect that has become a ‘normal’ part of their daily work. Many are afraid their fatigue reports could have negative consequences for their professional future (i.e. reprisals by management) – a phenomenon that is growing – particularly when pilots refuse to fly because they are too fatigued. Indeed UK polling results show that 33% of pilots would not feel comfortable refusing to fly if fatigued, and of those who would, three quarters would have reservations. Once a pilot has decided they have no option but to fly, a fatigue report would be tantamount to writing the evidence for their own prosecution.

Click here to view some of the recent research on the occurrence of pilot fatigue

*Telephone Polling conducted by Comres between 20th and 30th September 2011.
Representative sample of 500 pilots.

A tired pilot performs like a drunk pilot

Fatigue significiantly influences reaction time, the ability to concentrate, recall and ability to make good decisions. When landing an aircraft, making the right decision in a stressful situation could make the difference between life and death. Unfortunately a human being is not capable of reliably assessing their own exhaustion. The effects of sleep deprivation are very much like those of excessive alcohol consumption and this has been demonstrated in scientific studies

The graph below (insert your blood alcohol graph) was developed using the CAA’s own computer program which has ‘blood alcohol equivalence’ as an output. It shows that on a long-duty day, that will be legal under the EU proposals, pilots will be landing aircraft with the equivalent of 4 times the legal blood alcohol limit for flying.

What does the science say?

Research into fatigue has been going on for many decades and has underpinned many national regulations in Europe. Click here to see just some of the studies that have been published. A scientific evaluation , commissioned by the EU body developing these rules (EASA) and carried out by 10 renowned scientists was officially published in Jan. 2009. Amongst the conclusions were:

  • The allowed maximum daily flight duty period of 13-14 hours "exceeds reasonable limits" and is "not in keeping with the body of scientific evidence"; it should therefore be reduced;
  • The allowed maximum of 11:45 hours night duty should be reduced to 10 hours, because of the particularly fatiguing nature of work at night;
  • The allowed practice of 3 consecutive 60-hour weeks (i.e. 180 duty hours in 21 days) needs to be changed by setting an additional limit of 100 duty hours within 14 consecutive days (i.e. an average of 50 hours/week, instead of 60);
  • Stand-by at the airport is as fatiguing as flight duty, and should not be considered as "rest" but "count 100% as flight duty when calculating the maximum flight duty period”.

Since being published the study was subsequently de facto put aside EASA and so the process to develop new FTLs began without any scientific basis, nor any involvement of scientists.

In 2011, and following intense pressure from the European Cockpit Association (ECA) and national pilot Associations, EASA commissioned three independent and separate scientific assessments of its Dec. 2010 proposal for EU fatigue rules. All three scientists come to very similar conclusions as the original scientific evaluation, showing a clear need to revise the EU proposals.

What About Other Countries

In contrast, the United States rules are being tightened. Why? Because in 2009 they had a fatal accident in which 50 people died and in which pilot fatigue was proven to be a cause.

On 21 Dec. 2011, the USA’s Federal Aviation Authority (FAA) released its long-awaited new pilot fatigue regulation which is largely based on scientific evidence and much stricter than the proposed EU rules. Surely we can’t wait for a fatal accident in Europe to secure safe FTL’s.

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