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, issued 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



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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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103 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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105 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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107 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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109 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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111 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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112 THE EFFECTS OF COMMUTING ON PILOT FATIGUE 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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113 REDUCING THE RISK OF FATIGUE FROM COMMUTING 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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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 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.