As a 9,000-hour ATP-rated pilot and a former senior manager in Allegheny Airlines’ flight operations and safety department, RAA senior vice president of operations and safety Scott Foose perhaps brings as balanced a perspective as one could expect when it comes to the issue of fatigue in the cockpit. So it should come as little surprise that while he appreciates the need for changes to today’s existing flight and duty time rules, Foose at the same time strongly advocates for “shared responsibility” among all so-called stakeholders. 

Proposed new rules on pilot flight time and duty periods issued by the FAA in September last year included provisions for varying rest requirements based on the time of day, time zones, number of segments, flight types and the likelihood that a pilot can sleep under different circumstances. It also included provisions related to a pilot’s commute, including consideration of commute time when determining rest periods and of flight and duty time in relation to a pilot’s home base.

“I think the limitations that were based on the fifteen-hour duty day and eight hours of flying were somewhat arbitrary, although back in the day were based on what experience we had,” said Foose. “Since then, of course, there’s been quite an evolution in the industry. Flights last a lot longer these days and there’s a lot more science that’s been done, primarily by the academic community on the circadian effects of operating on the back side of the clock.”

But while the RAA agrees with the need for varied rest period requirements, provisions related to commuting, for example, remain controversial. The association has not wavered from its position that pilots choose to commute for various reasons–not only economic–and that if managed properly, the practice should not pose a safety threat, as long as the pilot takes some of the responsibility for his or her own actions while off duty.

“We agree that it makes absolute sense that you really need to adjust how long a pilot can be on duty based on [his or her] sleep opportunity,” said Foose. “We also realize that, looking at past events, it’s important for the flight crews, when they arrive for a flight, to make really sure they arrive rested. If they’re off duty, they need to make sure that prior to reporting for duty they get the proper rest and they show up bright-eyed and bushy-tailed and ready to do the job.”

Association Fatigue Research

The RAA filed 85 pages of comments on the proposed new rule, backed by data collected from Phase 1 of a three-phase fatigue study commissioned by the RAA and conducted by Washington State University’s Sleep and Performance Research Center. Now entering Phase 2, or the validation phase, the study centers on the effects of multi-segment operations common to regionals.

During Phase 1, or the modeling phase, the RAA collected actual crew schedules for long-haul operations and schedules for regional airline operations from January and February 2010. The sleep lab used software originally designed for a study under way on ultra-long-haul trips, updated it for the regional airline environment and compared projections on the level of fatigue a regional pilot might experience during a five-segment trip to what Foose called a “gold-standard” transcontinental trip, universally accepted as non-fatiguing, such as Los Angeles to New York. It also compared regional schedules with the elevated level of fatigue expected to result from overnight flying, for which, said Foose, ample science already exists.

According to Foose, the FAA found the RAA’s comments on the NPRM “one of the more helpful set of comments that they had received” because the association drew its conclusions from scientific research. “That’s really why the FAA was excited to receive our input, because we actually had developed science in regard to pilot workload that was not available until Phase 1 was complete,” he said.

“I’m not the scientist, but what we saw was incredibly promising,” said Foose. “Our predictions I think are pretty close…And secondly, we were impressed that the actual fatiguing effects were tied more closely to circadian rhythms, much like they are in the ultra-long-haul study, than they were the actual number of cycles.”  

That, of course, could spell good news for the regionals, if the Phase 1 findings pass validation trials and the FAA takes into consideration the findings when crafting new rules on varied rest period standards for different types of operation, as the RAA would hope.

Plans call for Phase 2 validation to start with simulator trials in the third and fourth quarters of this year, said Foose. During the second phase, the sleep center will use what Foose called an ActiGraph device to measure pilots’ activity levels under various conditions and circumstances, then researchers will compare the actual alertness of the pilots with the predictions calculated during the modeling phase.

“That, of course, gives us two things,” said Foose. It validates what we saw last year in the modeling but also it indicates that that model can be used by airlines to review all their pilot schedules and determine if there are any schedules there that can actually cause pilots to be fatigued.

“The two ultimate goals of this is to be able to look at the schedules and modify them if there’s anything there that can cause a pilot to be fatigued and, secondly, it’s going to tell us what it is about schedules and a pilot’s day that actually causes fatigue, and we’re going to train both the pilots and the chief pilots and the schedulers to avoid those.”

Foose said the RAA expects to receive the preliminary results from the validation phase some time around the start of next year and report on them by next May.

Finally, Phase 3 involves training pilots and operations management to use the new model. According to Foose, during Phase 3, the RAA will reassess “all the things we need to do to really get what we learned in the hands of the people at the airlines” during the second and third quarter of next year. 

Of course, a Congressional mandate requires that the FAA issue a regulation no later than this August 1. Nevertheless, Foose expressed confidence that “the FAA sees this as an ongoing improvement, and that the new rule is going to accommodate anything we learn in the future.” o