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6
Reducing the Risk of Fatigue
from Commuting
Current federal flight duty time regulations (14 CFR 91 and 14 CFR
121) do not address pilot commuting. There is only a general requirement
(in Part 91.13) that “No person may operate an aircraft in a careless or
reckless manner so as to endanger the life or property of another.” This
provision is interpreted by the Federal Aviation Administration (FAA) and
the airline industry as requiring that pilots report fit for duty.
PROPOSED FAA RULE RELEVANT TO FATIGUE
In response to P.L. 111-216 (the Airline Safety and Federal Aviation
Administration Extension Act of 2010), the FAA on September 14, 2010, is-
sued a Notice of Proposed Rulemaking (NPRM) (Federal Register, Vol. 75,
No. 177) related to flight and duty time that attempts to take advantage of
the available research on fatigue, sleep, and circadian rhythms and, among
other things, to consider the effects of commuting, means of commuting,
and the length of the commute on fitness for duty. In referring to the flight
duty period (FDP) the NPRM states that “An FDP begins when a crew-
member is required to report for duty that includes a flight, series of flights,
or positioning flights (including part 91 ferry flights) and ends when the
aircraft is parked after the last flight and there is no plan for further aircraft
movement by the same crewmember” (p. 55,859). Thus, in the proposed
regulations, time spent commuting is not considered duty time. Time spent
commuting is also not considered rest by the FAA. As the NPRM states,
“The FAA does believe that it is unreasonable to assume that an individual
99
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100 THE EFFECTS OF COMMUTING ON PILOT FATIGUE
is resting while commuting. Accordingly, time spent commuting, either lo-
cally or long-distance, is not considered rest” (p. 55,875).
Background
As part of its efforts to update the regulations, the FAA chartered
an Aviation Rulemaking Committee (ARC) in June 2009. The ARC was
comprised of representatives from labor, industry, and the FAA, and it was
tasked with using fatigue science and a review of international approaches
to develop recommendations for revisions of current regulations. The ARC
was unable to reach consensus on all issues, however they did reach con-
sensus on the role of commuting in any proposed regulations. With respect
to commuting they “unanimously recommended that pilots be reminded of
their existing obligations under part 91 to report to work fit for duty, but
that the FAA impose no new requirements” (p. 55,874).
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 mean-
ingful 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. 55,874). The NPRM places considerable emphasis
on education because, as the NPRM states, “The FAA believes a primary
reason that pilots may engage in irresponsible commuting practices is a lack
of education on what activities are fatiguing and how to mitigate develop-
ing fatigue” (p. 55,875). Pilot education is one of the specified objectives of
the draft advisory circular on fitness-for-duty mentioned above. The effect
of commuting on fatigue is also one element of a recommended training
curriculum specified in the NPRM.
In the NPRM (p. 55,875), the FAA further states that “it is inappro-
priate to simply rely on the existing requirements in Part 91 to report to
work fit for duty.” FAA proposes a new Part 117 to address fitness for
duty. The proposed rule states, “Fit for duty means physiologically and
mentally prepared and capable of performing assigned duties in flight with
the highest degree of safety” (p. 55,885). The proposed section 117.5 goes
on to place specific responsibility on both the flight crew member and the
airline: see Box 6-1.
As a complement to issuance of the NPRM, the FAA issued a draft ad-
visory circular (AC 120-FIT) on fitness for duty “to demonstrate acceptable
methods of compliance with Title 14 of the Code of Federal Regulations
(14 CFR) proposed part 117, § 117.5.” The draft circular clearly states
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101
REDUCING THE RISK OF FATIGUE FROM COMMUTING
BOX 6-1
FAA Proposed Regulations on Fatigue (Section 117.5)
a. ach flight crew member must report for any flight duty period rested and
E
prepared to perform his or her assigned duties.
b. o certificate holder may assign and no flight crew member may accept as-
N
signment to a flight duty period if the flight crew member has reported for a
flight duty period too fatigued to safely perform his or her assigned duties or
if the certificate holder believes that the flight crew member is too fatigued to
safely perform his or her assigned duties.
c. o certificate holder may permit a flight crew member to continue a flight duty
N
period if the flight crew member has reported himself too fatigued to continue
the assigned flight duty period.
d. ny person who suspects a flight crew member of being too fatigued to per-
A
form his or her duties during flight must immediately report that information to
the certificate holder.
e. nce notified of possible flight crew member fatigue, the certificate holder
O
must evaluate the flight crew member for fitness for duty. The evaluation must
be conducted by a person trained in accordance with § 117.11 and must be
completed before the flight crew member begins or continues an FDP.
f. s part of the dispatch or flight release, as applicable, each flight crew member
A
must affirmatively state he or she is fit for duty prior to commencing flight.
g. ach certificate holder must develop and implement an internal evaluation and
E
audit program approved by the Administrator that will monitor whether flight
crew members are reporting for FDPs fit for duty and correct any deficiencies.
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 man-
agement plans (FRMPs) and fatigue risk management systems (FRMSs). It
is important not to confuse the two.
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102 THE EFFECTS OF COMMUTING ON PILOT FATIGUE
Fatigue Risk Management Plans
Fatigue risk management plans are an airline’s policies and procedures
to reduce the risk of flight crew member fatigue and to improve flight crew
member alertness (see Federal Aviation Administration, 2010a). P.L. 111-
216 required U.S. airlines to submit drafts of their plans to the FAA. On
August 19, 2010, the FAA issued an InFO (Information for Operators; see
Federal Aviation Administration, 2010a) that provided the necessary in-
formation 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).
The guidance instructs that FRMPs should be updated every 24
calendar-months. In support of the development of FRMPs, the FAA issued
another InFO that provides an FRMP checklist for operators to ensure that
all of the relevant elements of an FRMP were included in their submission
(Federal Aviation Administration, 2010b).
According to the FAA (Federal Aviation Administration, 2010a, p. 1):
A FRMP is an air carrier’s management plan outlining policies and proce-
dures for reducing the risks of flightcrew member fatigue and improving
flightcrew member alertness. The FRMP policies and procedures should
focus on the air carrier’s specific kind of operations (e.g., domestic, flag,
and supplemental) and the type operations (e.g., continuous duty over-
nights, night vs. day operations, cargo vs. passenger operations, short-haul
vs. long-haul, etc.).
1 The checklist can be found at http://www.faa.gov/other_visit/aviation_industry/airline_
operators/airline_safety/info/all_infos/media/2010/InFO10017.pdf [June 2011], and the
supplemental document can be found at http://www.faa.gov/other_visit/aviation_industry/
airline_operators/airline_safety/info/all_infos/media/2010/info10017SUP.pdf [June 2011],
respectively.
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REDUCING THE RISK OF FATIGUE FROM COMMUTING
The FAA issued guidance as to the structure of the plan as well as the
submittal, review, and acceptance processes. Of relevance to commuting,
the FAA checklist identifies “The effects of fatigue as a result of commut-
ing” as one of 15 elements and tasks for the fatigue education and aware-
ness training program to be referenced in the FMRP (see Federal Aviation
Administration, 2010b).
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 commut-
ing? If so, please provide a copy of the plan.”
Out of the 33 airlines that provided input to the committee, 17 re-
sponded with comments relevant to the FRMP. Eleven provided a statement
on the status of their FRMP, if indeed they had one. For the most part, these
responses included statements that the plan was submitted and pending
approval. In one instance, the airline mentioned that commuting was not
referenced as commuting is not allowed. Another airline pointed out that
commuting was not relevant because the airline practiced home basing. In
yet another case, a very small airline wrote that it was not relevant because
of the few fatigue calls they had had in the past 5 years, none was related
to commuting.
Among the six airlines that provided copies of plans, five included the
wording, noted above, from the FAA guidance document regarding com-
muting as a factor to be addressed in a fatigue education and awareness
training program. Two of these five included an additional statement that
commuting information was to be collected when fatigue was reported by
a pilot. One of these five airlines had a statement in its FRMP that fatigue
was a factor under review for event evaluation.
In one other case an airline includes the following statement in its
FRMP (personal communication):
Crewmembers commuting greater than two hours from the company
facility are required to overnight in their domicile, if their bid assignment
includes an early morning departure between the hours of 0000-0600, thus
elevating the potential of fatigue. The STBY crew understands the time
zone they are on STBY for and are expected to be rested and prepared to
report to duty as needed.
Fatigue Risk Management Systems
New developments both in the science of fatigue and performance and
in management and regulatory philosophies have led to the other regula-
tory approach in the transportation domain, usually termed fatigue risk
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104 THE EFFECTS OF COMMUTING ON PILOT FATIGUE
management systems (FRMSs).2 These systems are focused on integrating
scientific knowledge about fatigue and its management with the realities of
airline operations. 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), the International Air Transport Association, the Flight Safety Foun-
dation, and the International Federation of Airline Pilots’ Association—to
obtain information regarding existing regulations, policies, and best prac-
tices regarding commuting outside the United States. It is interesting to note
that little information was received as to relevant aspects to commuting and
fatigue with the exception of FRMSs.
The ICAO established a FRMS task force to review scientific and opera-
tional knowledge and to develop detailed regulatory standards and guidance
for member countries on implementation of such systems (see International
Civil Aviation Organization, 2009). The proposed Standard and Recom-
mended Practice (SARP) was approved for adoption by the ICAO Council
on June 13, 2011. It will become effective for member states on October 15
and applicable on December 15, 2011.
FRMS, according to the new ICAO standard, promotes addressing
flight crew fatigue in a comprehensive and proactive manner by gather-
ing objective data regarding sleep, fatigue, and operational parameters to
manage the risk which fatigue can pose to flight safety (International Civil
Aviation Organization, 2011a, 2011b). This approach is in stark contrast to
managing the risk through prescriptive limits of flight time or duty periods
based on the assumption that a pilot is safe to fly as long as he or she is
operating within prescribed hourly limits. It is important to note that hours
spent commuting are not included in such limits.
When an airline chooses to implement FRMS within an approved
regulatory framework it commits to specifying both predictive and proac-
tive processes that it will use to identify potential fatigue hazards and the
resulting safety risks. The predictive processes are applied when developing
monthly crew rostering schedules and can include the use of scientifically
derived biomathematical computer models as well as operational experi-
ence to take into account factors known to affect sleep and fatigue and
their effects on performance (International Civil Aviation Organization,
2011a, 2011b).
2 An FRMS is a data-driven and scientifically based process to continuously manage and
monitor fatigue-related risks to ensure that personnel are performing at adequate levels of
alertness in flight operations.
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REDUCING THE RISK OF FATIGUE FROM COMMUTING
After the rostering schedules are implemented then the proactive pro-
cesses are used to identify hazards during current operations on an ongoing
basis. These processes can include crew self-reports of fatigue as well as
more objective measures of sleep, using actigraphs (a wristwatch-like device
that is worn continuously), and crew performance, using simple tests devel-
oped in the laboratory, such as the widely accepted Flight Data Monitoring
(also known as Flight Operations Quality Assurance or FOQA) to identify
deviations from planned flight parameters in airplane handling performance
during approach and landing. The operator must also ensure that remedial
actions, necessary to effectively mitigate the risks associated with the haz-
ards, 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).
According to the FAA, “An FRMS can be part of an organization’s SMS
[safety management system] or a stand-alone system” (U.S. Department of
Transportation, 2010a, p. 4). If an airline has a safety management system,
then the data collection and analysis would preferably be carried out in
a manner consistent with that SMS.3 Sample crews are selected with no
regard to whether or not they have commuted long distances by car, bus,
train, or air before starting duty. Given the prevalence of commuting, de-
scribed elsewhere in this report, it can be assumed that a substantial number
of the sampled crews will include commuters who travel long distances by
all forms of transportation.
Thus, FRMSs provide a rigorous method to assure that crews are oper-
ating at a suitable level of alertness without regard to the characteristics of
their commutes. FRMSs can offer both the operator and regulators a valid
“snapshot” of crew alertness during normal operations and thereby provide
at least a partial assessment that the contribution of commuting to fatigue is
or is not within an acceptable level. Such limited assurance offers a signifi-
cant benefit beyond simply requiring the crew and the operator to adhere to
prescriptive limits when no data are routinely gathered to assess the specific
risk that fatigue may pose to a particular set of flights. Furthermore, if an
operator wishes to assess whether some types of commuting produce more
fatigue for a specific trip pairing, an FRMS provides a ready method to do
so. FRMSs are currently under development by several foreign carriers.
Industry and professional groups, as well as U.S. state regulatory agencies,
are also involved in development and implementation efforts.
An FRMP includes some elements of an FRMS (e.g., management
policy, event reporting and evaluation, and fatigue education and aware-
ness training), but it is still based on flight time and duty period limita-
3 For
explanation of an SMS, see http://www.icao.int/anb/safetymanagement/DOC_9859_
FULL_EN.pdf [June 2011].
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106 THE EFFECTS OF COMMUTING ON PILOT FATIGUE
tions and a focus on reported events. It does not include the key proactive
FRMS element of routinely assessing fatigue risk on specific trip pairings.
Consequently, its ability to address commuting is limited to education and
training and reactive analyses of reported unsafe events.
When FRMS becomes applicable as an ICAO worldwide standard in
December 2011, member states will each have to decide how to implement
the new standard within their aviation regulations. The proposed SARPs
combine all standards for fatigue management under a general heading
of “Fatigue Management” rather than being dispersed as they are now
throughout Annex 6, Part I. This consolidation will enable states to allow
operators the option of utilizing FRMS as the basis for some or all of their
operations in place of prescriptive regulations. In anticipation, ICAO has
worked with industry (International Air Transport Association, IATA) and
labor (International Federation of Airline Pilots’ Association, IFALPA) to
draft complementary FRMS Manuals for Operators and Regulators, which
are scheduled to be released in July 2011.
Although an FRMS is not mandatory for U.S. carriers, the FAA did
issue an Advisory Circular (AC 120-103) on FRMSs on August 3, 2010
(U.S. Department of Transportation, 2010a). The circular identifies the
basic components of an FRMS and how it may be implemented in avia-
tion operations as a means of improving safety and performance. In the
circular, an FRMS is described as “a data-driven and scientifically based
process that allows for continuous monitoring and management of safety
risks associated with fatigue-related error. It is part of a repeating perfor-
mance improvement process. This process leads to continuous safety en-
hancements by identifying and addressing fatigue factors across time and
changing physiological and operational circumstances.” The circular notes
that it may be implemented as part of the organization’s safety management
system or as a stand-alone system.
The components for an FRMS include (a) a fatigue risk management
policy, (b) an education and awareness training program, (c) a fatigue anal-
ysis and reporting system, (d) monitoring fatigue in flight and cabin crew,
(e) an incident reporting process, and (f) performance evaluation. Roles and
responsibilities in the FRMS process include the operator, the employees/
crew, and the regulator. The regulator’s responsibility is to audit the pro-
cess and ensure that the FRMS is responsive to feedback and provides a
level of safety that is equivalent to those established by existing regula-
tions. The data-driven approach of an FRMS is derived from the guidance
developed by the Flight Safety Foundation for regulatory authorities to
use for approving flights greater than 16 hours (Flight Safety Foundation
Editorial Staff, 2005). The process was used first for Singapore Airlines,
and it has since been by several other airlines, including the current effort
by the FAA to assess fatigue on ultra-long-range flights by Delta, American,
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REDUCING THE RISK OF FATIGUE FROM COMMUTING
and Continental Airlines. In the NPRM, related to fatigue, the FAA has
proposed that carriers use a similar FRMS approach for flights not covered
by the new regulations. In order to be consistent with other states, the
FAA will need to adjust the circular to be consistent with the ICAO FRMS
SARPs recently approved by the ICAO Council.
The FAA approach is compatible with ICAO’s initiative on fatigue risk
management systems and the trend over the past two decades of many U.S.
federal regulatory agencies to shift more responsibility to the organizations
they regulate and to encourage cooperative rather than adversarial rela-
tionships. Generally, these initiatives rely on management systems that use
continuous monitoring to identify and mitigate potential risks before they
have safety consequences.4
Pilot Decision Making
Decision making is central to pilots’ efforts to avoid flying their aircraft
while they are fatigued. Once a pilot has made a strategic decision of where
to live in relation to his or her domicile, there are three major circumstances
in which such tactical decision making has special significance: (1) when the
pilot is developing plans for commuting to the domicile; (2) when the pilot
must make adjustments in plans necessitated by arising contingencies (e.g.,
bad weather); and (3) when the pilot has to decide whether and how to can-
cel a duty assignment because of (anticipated) fatigue. The decisions in all
such situations are highly challenging. For instance, they typically involve
multiple, often conflicting considerations, numerous stakeholders with com-
peting interests (e.g., family members, colleagues, and supervisors), and the
need to be informed by nonobvious and sometimes counterintuitive facts
about the biology of fatigue and rest.
Regulatory Considerations: General Issues
A major concern in establishing any regulation is designing it so that
it achieves its intended effect. Negative unintended consequences often
emerge when a seemingly simple regulation is implemented in a complex
system. 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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108 THE EFFECTS OF COMMUTING ON PILOT FATIGUE
the intended consequence of an action is desired so strongly that potential
unintended effects are purposely ignored (Merton, 1936).
The committee is concerned that a rush to establish regulation regard-
ing pilot commuting and fatigue without an adequate understanding of
how pilot commuting and fatigue interact with the aviation system might
trigger unanticipated and unintended consequences that have not yet been
carefully anticipated.
Such unanticipated and unintended consequences can reduce the effec-
tiveness of the regulation in achieving its goal, and in some cases may even
result in a regulation having the opposite effect of what had been intended.
A noteworthy example occurred with the 55 mph speed limit, established
in March 1974 in response to the 1973 oil embargo (see National Research
Council, 1984). Following this adoption, highway fatalities dropped. Al-
though 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. However, in
response to other pressures and interests, in 1987, 40 states raised the speed
limit to 65: many anticipated that highway fatalities would again increase
due to the higher speeds. Although highway fatalities did increase, so did
vehicle miles traveled. A study that examined statewide fatality rates, con-
sidering not only the roads on which the speed limits were changed but also
the non-interstate roads on which they were not, found that the higher 65
mph speed limit reduced the statewide fatality rates by 3.4-5.1 percent in
comparison with other states (Lave and Elias, 1994). It appears that this un-
expected and initially counterintuitive result was because enforcement and
highways are integrated systems. The federal government had threatened
to impose financial penalties if the 55 mph speed limit was not enforced, so
states devoted considerable patrol resources to rural interstates and reduced
both enforcement on other highways and other safety activities. In addition,
it appears that the higher level of enforcement on rural interstates may have
caused some drivers to switch to parallel noninterstate highways, which are
more dangerous in terms of fatalities but which had the same speed limit
and less speed enforcement. Where the 55 mph speed limit was raised and
the threat of federal financial sanctions removed, highway patrols reallo-
cated their activities to a better balance from a safety perspective and with
the higher interstate speed limits, some drivers switched from parallel rural
roads to the safer interstate highways.
This experience offers two cautionary lessons for safety regulation. One
is that complex systems may react to regulation in ways that were unan-
ticipated and, in this case, counter to the goal of improved highway safety.
The second is that patterns of enforcement can have important and often
unanticipated effects on how a system reacts to regulation.
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REDUCING THE RISK OF FATIGUE FROM COMMUTING
In aviation safety regulation, another possible unintended consequence
of regulation can come from modal shift effects. A regulation that increases
costs to the airline industry will likely result in some portion of those costs
being passed on to travelers in the form of higher airline ticket prices.
Higher airline ticket prices would cause some travelers to switch their mode
of travel from airplanes to automobiles. Since travel by private automobile
is more dangerous than travel by commercial airline, the result of such a
shift would be an increase in highway fatalities. Thus, however many airline
passenger and crew lives are saved by the airline safety regulation, the net
savings of life from the regulation would be less because of the increase in
highway fatalities. In some cases, the net effect may actually be a net loss
of lives from a regulation intended to save lives.
This potential for an outcome other than that intended was forecast
for a proposed regulation to mandate the use of child safety seats on
commercial airlines. One study of the proposed regulation (Windle and
Dresner, 1991) concluded that more lives would be lost from the switch
to highway travel from the higher travel costs for families with children
than would be saved from the added safety benefit of child safety seats.
Regulatory Considerations: Pilot Commuting
Developing a regulation to address pilot commuting would face several
challenges. The first would be to determine how many lives the elimination
of commuting-related fatigue would be expected to save. Although there is
no doubt that, in principle, commuting can contribute to pilot fatigue, that
pilot fatigue can contribute to reduced pilot performance and that reduced
pilot performance can contribute to aviation accidents that can result in
fatalities, the magnitudes of any of these effects are not well understood.
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 ac-
cident is difficult in an accident investigation, the committee’s examination
of 863 accidents found only 9 in which fatigue was judged to be a prob-
able cause or contributing factor (see Chapter 3). In none of the accidents
was commuting-related fatigue judged by the National Transportation
Safety Board to be a probable cause or contributing factor, and, of the nine
fatigue-related accidents, there was only one in which a commute may have
been one of the contributors to that fatigue. Although the limitations of the
accident investigation process means that the role of fatigue may be difficult
to detect so that these figures may well understate the role of fatigue, it is
still difficult to conclude that commuting-related fatigue is a major source
of aviation accidents.
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110 THE EFFECTS OF COMMUTING ON PILOT FATIGUE
The second challenge would be to determine what proportion of
commuting-related fatigue accidents a proposed regulation would prevent.
Commuting occurs during a pilot’s off-duty time and, collectively, from a
diverse array of home locations to a large number of domiciles using a wide
variety of transportation options. Enforcement of a regulation designed to
alter pilots’ behavior during their off-duty hours would be difficult. In such
situations, as suggested by the enforcement of the 55 mph speed limit, dif-
ferent patterns of enforcement could have different impacts on the actual
effect of the regulation. Enforcement might well prevent some fatigue-
inducing commutes, depending on how a regulation was implemented,
but the form of enforcement could also induce some counterproductive
behavior.
The third challenge would be to determine what the regulation would
cost to both pilots and airlines and the subsequent effects of those added
costs would be on airline ticket prices. Higher ticket prices would cause
some travelers to switch from airline travel to auto travel, with the result
of some increase in highway deaths. At first glance, it might appear that
only the direct costs to the airlines would influence ticket prices, but costs
the regulation might impose on pilots might also have an effect. If the
regulation imposed costs on pilots, it could make being an airline pilot a
less attractive career than it had been prior to the regulation. If that caused
some pilots to choose a different profession, then the airlines might have
to pay higher wages to attract a sufficient number of pilots to the industry.
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 regu-
lations. There are other possible adverse consequences from regulations: see
Viscusi (1994) and Viscusi and Zeckhauser (1994).
Given that there is some potential for commuting to contribute to fa-
tigue and clear evidence that fatigue can decrease performance, the commit-
tee believes it is important to reduce the likelihood that commuting could
contribute to pilot fatigue during duty. At the same time, the safety risk
posed by commuting-induced fatigue is unknown. There is a need to un-
derstand the extent to which the risk posed by fatigue resulting from some
commutes may be mitigated by individual, airplane (e.g., flight deck sys-
tems), or aviation system (e.g., crew resource management) characteristics.
There is also tremendous variability across individual pilot commuting
practices and day-to-day experiences. Attempting to determine a one-size-
fits-all delineation on what constitutes a fatiguing commute on the basis
of either time or distance is difficult because the length of the commute,
measured either by distance or time spent commuting, does not necessarily
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REDUCING THE RISK OF FATIGUE FROM COMMUTING
determine whether or not the pilot reports fit for duty and well rested. And
as discussed above, regulations specific to commuting could inadvertently
lead to increased safety problems and additional loss of lives due to unin-
tended and unanticipated consequences. Consequently, although action is
warranted to reduce the likelihood that commuting will present a safety
risk, there is a lack of evidence to support the basis for issuance of regula-
tions pertaining to commuting.
CONCLUSIONS AND RECOMMENDATIONS
CONCLUSION: With regard to the proposed provisions in Section
117.5, there are no valid and reliable tools and techniques feasible to
achieve the goals of detecting fatigue and fitness for duty in pilots in an
operational setting. To achieve these goals, further research would be
needed to scientifically validate the tools and techniques, demonstrate
that they are technically feasible in an operational environment, and
evaluate their relationship to operational safety and the extent to which
they can be integrated into an operational context.
CONCLUSION: There are inadequate data to specify or determine
the effectiveness of regulations regarding pilot commuting. Additional
information is needed to determine if a regulatory approach would be
appropriate.
Potential fatigue is an inherent component of a system that functions 24
hours a day, 7 days a week. Recognizing this, the aviation industry has been
developing an approach through FRMSs to better understand when fatigue
is a concern and how to best mitigate that risk. Airlines develop FRMSs
specific to their operational environment. To date, commuting has not been
a major consideration in these systems. Incorporating data on commuting
in relation to pilots’ duty hours and sleep prior to duty would help inform
these systems and allow airlines to consider mitigation strategies specific to
their operations.
RECOMMENDATION 2: The potential of commuting on pilot fa-
tigue should be addressed as part of an airline’s strategies to man-
age fatigue risk. If airlines develop fatigue risk management systems
(FRMSs), they should gather information about preduty sleep and
wake time relative to commuting practices and duty cycle. FRMSs
should provide a mechanism for identifying problematic patterns and
addressing them. FRMSs can offer both the airline and the Federal
Aviation Administration an improved assessment of crew alertness
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during normal operations and thereby provide some information on
the contribution of commuting to fatigue and whether fatigue is or is
not within an acceptable level of risk.
FRMPs are the airline carriers’ management plans outlining policies
and procedures reducing the risk of flight crew member fatigue and improv-
ing flight crew member alertness. P.L. 111-216 requires each U.S. carrier
operating under Part 121 to submit to the FAA their draft FRMP for review
and acceptance. Provided in the FAA’s guidance on the development of an
FRMP is a requirement for a fatigue education and awareness training
program element, one of the subtasks of this element is the effects of com-
muting on fatigue.
This requirement reflects the perspective that managing the effects of
commuting on fatigue is a joint responsibility of airlines and pilots, a posi-
tion with which the committee agrees. Although the FRMP approach is not
as rigorous as the FRMS process, it is required of all Part 121 airlines and
therefore presents an opportunity to reach a wider audience than FRMS.
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. Fatigue education and aware-
ness training should be annually updated with particular attention to
incorporating relevant new developments in sleep science.
As part of its data collection, the committee requested that airlines
submit information on their policies on pilot commuting, sick leave, and
fatigue, if available. Although only a relatively small proportion of airlines
responded (39 percent), it is clear from the information submitted and from
comments provided in public comments that there is considerable diversity
in these policies. In addition, not all airlines have commuting or fatigue
policies, with pilots relying instead on sick leave availability to address
potential fatigue. Airlines should consider policies that would help pilots
plan predictable commutes that do not promote fatigue on duty and policies
that minimize negative consequences when unanticipated events alter their
commuting plans and lead to fatigue. The effects of these policies on pilot
behavior are currently not well understood.
RECOMMENDATION 4: The Federal Aviation Administration should
convene a joint industry, labor, and government working group, un-
der the auspices of an independent organization (such as the Flight
Safety Foundation), to assess industry policies on pilot commuting, sick
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leave, attendance/reliability, and fatigue and to develop industry best
practices. The output of this joint working group should inform the
development and updating of airlines’ fatigue risk management plans
and should be validated periodically.
Pilots make decisions about commuting in the context of other factors
in their lives, the specifics of their flights, the policies in place at their air-
lines, including sick leave and commuting policies, and other environmental
factors. It is unclear to what extent pilots are aware of the findings from
current decision science or consider this information in their decision mak-
ing. Decision-making strategies informed by this science could be incorpo-
rated into FRMP training and considered in the development of industry
best practices.
RECOMMENDATION 5: The Federal Aviation Administration should
commission efforts to develop protocols and materials for training pi-
lots to make decisions regarding commuting easily and effectively and
to ensure that they are informed by current decision science.
As described above, little is known about pilots’ commuting patterns
and the extent to which their commuting patterns may affect the amount
or quality of sleep or the amount of time awake prior to duty. A better
understanding of the relationship of commuting to primary risk factors
for fatigue would represent a first step in increasing understanding of the
relationship between commuting and fatigue. 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)
sleep quantity 48 hours prior to the end of duty on each day of the trip;
(2) sleep quality 48 hours prior to the end of duty on each day of the
trip; (3) time awake in the 48 hours prior to the end of duty on each
day of the trip; (4) cumulative sleep time in the 72 hours prior to the
end of a duty period; and (5) circadian phase at which sleep is obtained
and at which duty is undertaken. In order to be maximally useful, the
study should include a large random sample of pilots from multiple
companies representing the major industry segments. The study should
provide objective data on fatigue risk antecedents by using a well-
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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 under-
stand pilots’ commuting experiences within the context of multiple factors.
The results of the study can help identify situations that may warrant spe-
cific attention or additional research.
