Good To Go?

A European Cockpit Association report says that “pilot fatigue contributes to 15-20 per cent of fatal aviation accidents caused by human error. It also established an increased probability of a human factor accident the longer pilots are on duty. ” The March 19 crash of a FlyDubai 737-800 in Russia which killed all 62 aboard has brought the issue of pilot fatigue into stark relief with accusations made to the BBC that the airline’s pilots were fatigued.

Pilots speaking anonymously to the BBC said fatigue was a contributory factor in the accident, with claims that one pilot reported previously falling asleep at the controls from exhaustion.

Responding to the claims the airline said it was “unable to disclose confidential information relating to our employees”.

The pilots who spoke to the BBC said their colleagues are at “significant and obvious risk” from fatigue.

Making optimally safe sleep time vs flight time decisions is no simple matter, but indications are the airline industry is making rapid progress.

In November 2011 the International Civil Aviation Organization (ICAO) amended its Operation of Aircraft annex to introduce a science-based approach to flight and duty time limitations. The idea was to provide a framework for regulators to oversee newly-emergent Fatigue Risk Management Systems (FRMS).

A bit of context. According to the International Air Transport Association (IATA), “The traditional regulatory approach to manage crewmember fatigue has been to prescribe limits on maximum flight duty hours, and required breaks within and between duty periods. ” The problem with that is “It was pretty much a one-size-fits-all approach that didn’t take into account when you were flying, or how long you were flying, or if you were crossing time zones,” says sleep researcher Dr Joseph Chandler (Chandler is the co-author’s son, an assistant professor at Birmingham Southern College in the US and a former research psychologist with the Naval Aerospace Medical Research Lab. ) “All sorts of things…can have a large impact on whether or not you’re good to go after those rest periods. ” IATA says FRMS enable airlines to customise flight and duty time limitations “to better manage fatigue risk. ” Chandler notes, “Prior to these individualised programs, which are present in civil aviation as well as the military, really nothing more than prescriptive flight times and rest times existed. ” The US military’s version of FRMS is a program called the Fatigue Avoidance Scheduling Tool (FAST).

Now, ICAO’s 191 member states (countries) are required to develop fatigue mitigation regulations based on scientific principles and operational knowledge. ICAO doesn’t tell member states precisely how to do that, but – in conjunction with IATA and the International Federation of Air Line Pilots’ Associations (IFALPA) – it has come out with an FRMS implementation guide for operators.

Indications are the airline industry and ICAO member states are responding comparatively rapidly to fashion their own individually-targeted FRMS.

CASA introduced it in 2013 with compliance due in April 2016 but this was eased last year to May 2017.

Operators such as United Airlines are actively working with sleep experts to study the issue with real subjects. The airline has engaged “sleep science experts from Washington State University in conjunction with ALPA to study Boeing 777 and 787 pilots to collect data on long-haul flights to Sydney and Melbourne. ” Aiding efforts to collect sleep data in general, says Chandler, is something called ‘actigraphy. ’ Pegged to “wrist-worn devices that look a lot like a watch, they have an assembly on the inside of them that is extremely sensitive to the movement of the body. ” Before their advent, if you wanted to track someone’s sleep patterns in the field, generally you had to ask them. Not good, asserts the sleep researcher. Actigraphy can ferret out ‘micro-sleeping’, short periods of sleep ranging from 250-milliseconds to a second-and-a-half, “where you have no awareness that you’ve fallen asleep,” he says. “But you have, [and] in such a way that you really lose the ability to interact with the environment. ” In the world of aviation milliseconds matter. “A half-second to a second-and-a-half is a long time in an airplane,” says Chandler.

It didn’t take a long time for some key ICAO member states to ramp up FRMS efforts. Spurred by the February 12 2009 crash of Colgan Air Flight 3407 near Buffalo, New York which killed all 49 aboard, then US National Transportation Safety Board chair Deborah Hersman said pilot fatigue should have been counted as a contributing factor.

Another wake-up call was the February 2008 incident where both Go! pilots fell asleep on the 36 minute flight from Honolulu to Hilo and flew for another 18 minutes past their destination.

In what passes for light speed in regulatory circles, on December 21 2011 the US Federal Aviation Administration issued a final rule on pilot fatigue, mere months after the Colgan crash and hard on the heels of ICAO’s November 2011 amendment to its Operation of Aircraft annex. Among other things, the FAA’s new regs: Incorporated the latest fatigue science to set differing requirements for pilot flight time, duty period and rest time based on the time of day they begin their first flight. Also taken into consideration: the number of scheduled flight segments (or “legs”), and the number of time zones pilots cross; Pegged the allowable length of a flight duty period to when the pilot’s day begins and the number of flight segments they’re expected to fly; Allow airlines to develop an alternate way of mitigating fatigue, one that’s scientifically based and uses data validated by FAA. That means an FRMS. In his May 2015 IATA presentation in Lima, Peru Delta Air Lines pilot fatigue program director Captain Jim Mangie pointed out that to pass muster an FRMS must:

• Be an alternative to a prescriptive rule;
• Establish an equivalent level of safety;
• Minimise acute and chronic sources of fatigue and manage potential risks associated with fatigue associated with a specific operation;
• Be a management system airlines actually use for mitigating fatigue in their operations.

CASA’s CAO 48. 1 has operators and flightcrew with shared responsibility to manage fatigue.

The new CAO adopts a tiered approach to managing fatigue, ranging from prescriptive requirements to a mix of prescription and risk management to a fully-developed fatigue risk management system.

CASA says having a tiered system allows operators to choose an appendix based on operational requirements and with an overlying fatigue risk management strategy appropriate for their organisation.

CASA adds that a tiered system also allows for improvements in the light of current sleep and fatigue research with international evidence suggesting the changes will generate safety benefits and significant operational efficiencies, without imposing undue cost or time burdens on operators.

Current flightcrew fatigue regulations have been in place for more than 50 years without significant review. Advances in technology, and scientific understanding of human performance limitations, and of sleep, mean the old regulations are out of step with contemporary practice and knowledge says the regulator.

CASA notes that “they do not properly address transient and cumulative fatigue, operator and individual responsibilities, the impact of circadian rhythms, and crossing of multiple time zones. ” In its Fatigue Risk Management Systems (FRMS) lmplementation Guide for Operators IATA says that the US National Transportation Safety Board has examined the relationship between time since awakening (TSA) and errors in 37 aircraft accidents (1978-1990) in which flightcrew actions or inactions were causal or contributing factors.

The NTSB found that the median TSA at the time of the accident was 12 hours for captains and 11 hours for first officers. Six crews were classified as low TSA (both the captain and the first officer were below the median) and six crews were classified as high TSA (both the captain and the first officer were above the median).

For low TSA crews, the median time awake was 5. 3 hours for captains and 5. 2 hours for first officers. For high TSA crews the median time awake was 13. 8 hours for captains and 13. 4 hours for first officers.

Overall, high TSA crews made about 40 per cent more errors than low TSA crews, primarily due to making more errors of omission (5. 5 versus 2. 0 errors). In terms of error types, high TSA crews made significantly more procedural errors and tactical decision errors than low TSA crews.

And it is not about just feeling tired says CASA. The regulator says that “sleep deprivation impairs the brain’s effectiveness, with research showing it can produce effects very similar to alcohol consumption. ” On-the-job performance loss for every hour of wakefulness between 10 and 16 hours is equivalent to about a . 004 per cent rise in blood alcohol concentration.

Seventeen to 18 hours of wakefulness is usually considered to be equivalent to a blood alcohol concentration of about 0. 05 per cent.

Both Qantas and Virgin Australia are leading the pack on the issue with both having fatigue management as the cornerstone of their pilot rosters.

According to Qantas Group medical director Dr Ian Hosegood the Group “has robust systems in place to manage the risk of pilot fatigue”.

“We closely monitor fatigue risk on all shifts, particularly longer and late night shifts, through our fatigue management committee, which includes pilots, safety specialists, and crew planners,” said Dr Hosegood.

He says that the airline group is on track to implement FRMS within CASA’s timeframe. “However, it really just formalises what we’ve been doing for many years which is taking an evidence-based, data-driven approach to managing fatigue risk. ” The airline adds that it is confident it will comfortably reach CASA’s requirement to have entered into an FRMS trial by 2017. “We are on track to start our FRMS trial by mid-2016, and we hope to receive CASA approval in 2017,” said Dr Hosegood.

At Jetstar the airline is working with CASA on a proposal to introduce FRMS in the next 12 months under Appendix 7 of CAO 48. 1, and recently set up a specialist fatigue management function within the safety department to help with the rollout.

Dr Hosegood adds that both airlines “have an open safety reporting culture and we always encourage our pilots to report fatigue and to put their hand up and remove themselves from duty if they’re unfit to fly due to fatigue. ” The more critical areas are the international flight patterns that involve long sectors or a longer time away from home base where crew’s circadian rhythm may have shifted and are protected, says the airline, by ensuring adequate rest periods before and after.

It cites a recent example of changes to the rosters for pilots flying the overnight Narita-Brisbane sector. It now rosters them on the following day at a later time and with reduced workload.

They land at 6. 45am after doing a 10 hour night shift so to ensure they get a proper night’s sleep, we roster them on the following day at a later time and with reduced workload (1-2 short domestic sectors).

Dr Hosegood said that Jetstar responds to fatigue reports, and recently adjusted its Singapore-Bali-Perth schedule in response to feedback on the timings of this schedule. “This was a direct result of feedback from the Fatigue Management Working Group. Jetstar had a duty where pilots signed on in Singapore at 1. 15am local time and undertook a 10hr 10min duty that included 2hr 20min waiting between flights in Bali. ” “In response to fatigue concerns, Jetstar rescheduled so that the pilots signed-on in Singapore at 3. 45am and reduced the wait in Bali so that the overall duty was reduced to 8hr 40min. ” A spokesperson for the Virgin Australia Group said that the airline Group has “some of the strictest safety and fatigue management systems in the world”.

“The Group works with the Civil Aviation Safety Authority and other relevant stakeholders to ensure these systems remain world-class,” said the spokesperson.

Virgin Australia first established its Fatigue Risk Management System (FRMS) in 2007. The FRMS operates under an operator-specific exemption of the existing CAO 48. 0 rules.

The airline says that if flightcrew report fatigue to crewing they are removed from their designated flight. It adds that fatigue is reported in a blameless or nil jeopardy environment.

Virgin Australia’s spokesperson said that fatigue is considered when building rosters.

“The rosters are then reviewed and amended where fatigue risks are identified by a bio-mathematical modelling tool and/or a specialist review committee. ” Overlayed on that, additional rules have been introduced in the past to mitigate fatigue risk based on trends and data says the airline.

Of course there are Australian pilots who are not satisfied with the current system and who look forward to adjustments being made to fit the CASA model.

But will it go far enough? Only time will tell but it’s great start. The final word is from CASA which says bluntly: “Fatigue cannot be overcome with coffee and willpower. ”

Current flightcrew fatigue regulations have been in place for more than 50 years.