Call to action for Flight Duty Regs
09-16-2011, 01:09 PM
#81
Back on TDY
Joined APC: Apr 2008
Position: 747-400 Captain
Posts: 12,487
Now, how about the 'fine print'. Does it say "Actual" or "Scheduled"? They can Schedule a 10hr. block time, 13hr. duty time, west coast turn, and when you get to LAX and then there is some type of delay getting out, well...are you legal to continue or do you go to the hotel if you can't be back in ATL by Sign in + 13?? And do we 'extend' up to 2 hours beyond the 13, or do we shut it down and go to the Holiday Inn Express?
Carl
09-16-2011, 03:05 PM
#82
Gets Weekends Off
Joined APC: May 2010
Position: Baja Vermont
Posts: 5,197
The NTSB wants the FAA to look at the effects of commuting on fatigue which is the real lesson on Colgan 3407. Flying all night and sleeping in chair is more fatiguing than any of the duty rules changes. For the record, live in base; if the company wants to move you, for WHATEVER reason, they pay. You want to move up requiring a change in domicile, you pay. Old fashioned, but it worked.
GF
GF
09-17-2011, 01:38 PM
#83
Gets Weekends Off
Joined APC: Oct 2006
Posts: 1,001
Incorrect Sniper. There are many, many studies that state the obvious. Which is: More work = more fatigue. This is one from the nursing field:
http://www.ahrq.gov/qual/nurseshdbk/...sA_EFSNPPS.pdf
http://www.ahrq.gov/qual/nurseshdbk/...sA_EFSNPPS.pdf
The 'study' you cite (it is a nurse handbook, not a study, though it references many studies) focuses primarily on "the effects of fatigue associated with insufficient sleep (see Key Terms and Definitions). The impact of extended work shifts and the relationship of these work schedules to nurse and patient safety will also be explored."[from p. 1]
As the handbook states:
Originally Posted by page 8 of the handbook
There is a very large, strong body of evidence showing that insufficient sleep has adverse effects on cognition, performance, and mood. . . .
The evidence regarding shift duration, however, is less clear-cut. Although some studies suggest that reductions in the work hours of resident physicians and interns is associated with fewer errors,35 other studies suggest that the implementation of work hour limitations has not decreased the number of adverse events.169,170 Although there are numerous literature reviews,171173 descriptive and other comparative studies,14, 25, 26, 69, 174176 there are no meta-analyses and only one systematic review177 focusing on the impact of work hours on medical errors or work performance. The strongest study, involving 20 critical care residents and interns and direct observation of errors, found that traditional schedules were associated with 35 percent more serious errors, and shortened workdays (16 hours) were associated with both fewer order-writing errors and diagnostic errors.35 Unfortunately, this study has not been replicated outside of the critical care setting or at any other institution.
The evidence demonstrating a relationship between working long hours and adverse effects on health is stronger.[p. 8]
The evidence regarding shift duration, however, is less clear-cut. Although some studies suggest that reductions in the work hours of resident physicians and interns is associated with fewer errors,35 other studies suggest that the implementation of work hour limitations has not decreased the number of adverse events.169,170 Although there are numerous literature reviews,171173 descriptive and other comparative studies,14, 25, 26, 69, 174176 there are no meta-analyses and only one systematic review177 focusing on the impact of work hours on medical errors or work performance. The strongest study, involving 20 critical care residents and interns and direct observation of errors, found that traditional schedules were associated with 35 percent more serious errors, and shortened workdays (16 hours) were associated with both fewer order-writing errors and diagnostic errors.35 Unfortunately, this study has not been replicated outside of the critical care setting or at any other institution.
The evidence demonstrating a relationship between working long hours and adverse effects on health is stronger.[p. 8]
A relevant study is one that compares time on duty to time on task, like flight time to duty time. Providing a link to a handbook that focuses on sleep deprivation, primarily, is not sufficient to prove your point. Most employment is unlike pilots, where you are 'working' while on duty, but are concerned about the fatigue of work on a specific task, flying. Medical doctors have been extensively studied, but researchers don't break down the time spent on duty (@ the hospital, doing rounds, for instance) and the time spent on task (directly performing surgery, triage, or ordering treatment, for instance).
'Carl' - I support your position that raising the limit to 9-10 hours is not in the best interests of pilots. The world we live in is one where the FAA will not refuse to make concessions to industry in the absence of contradictory science. Does this science even exist?
09-17-2011, 01:44 PM
#84
Gets Weekends Off
Joined APC: Aug 2008
Posts: 799
The big problem with flying 10 hours due to starting the duty day after a "normal" circadian rhythm is that it's not accounting for the previous duty day. In other words, day 1 of the trip signs it at 1500 and doesn't land until 0030, maybe gets to bed at 0130. Day 2 is a short duty day with say a 0530 wakeup on day 3 to make a 0700 sign in. If the pilot got 8 hours of sleep after going to bed at 0130, then they probably had a real hard time getting to sleep on night 2 to get the 8 hours prior to the 0530 wakeup on day 3.
It could be worse on a 4 day trip. Imagine having the first 2 days flying evenings or into the next morning, short day on day 3 with an early get up on day 4 (normal circadian rhythm) to fly 10 hours. Way worse than what we currently have.
It could be worse on a 4 day trip. Imagine having the first 2 days flying evenings or into the next morning, short day on day 3 with an early get up on day 4 (normal circadian rhythm) to fly 10 hours. Way worse than what we currently have.
09-17-2011, 02:07 PM
#85
Gets Weekends Off
Joined APC: Oct 2006
Posts: 1,001
Now, how about the 'fine print'. Does it say "Actual" or "Scheduled"? They can Schedule a 10hr. block time, 13hr. duty time, west coast turn, and when you get to LAX and then there is some type of delay getting out, well...are you legal to continue or do you go to the hotel if you can't be back in ATL by Sign in + 13?? And do we 'extend' up to 2 hours beyond the 13, or do we shut it down and go to the Holiday Inn Express?
§ 117.3 states:
Unforeseen operational circumstance means an unplanned event beyond the control of a certificate holder of insufficient duration to allow for adjustments to schedules, including unforecast weather, equipment malfunction, or air traffic delay.
§ 117.15 Flight duty period: Un-augmented operations.
(a) Except as provided for in § 117.17 [FYI, split duty periods], no certificate holder may assign and
no flightcrew member may accept an assignment for an unaugmented flight operation if
the scheduled flight duty period will exceed the limits in Table B [this is the table that allows a max of 13 hours of duty, and only for 0700-1259 show times] of this part.
(b) If the flightcrew member is not acclimated:
(1) The maximum flight duty period in Table B of this part is reduced by 30
minutes.
(2) The applicable flight duty period is based on the local time at the
flightcrew member’s home base.
(c) In the event unforeseen circumstances arise:
(1) The pilot in command and certificate holder may extend a flight duty
period up to 2 hours.
(2) An extension in the flight duty period exceeding 30 minutes may occur
only once in any 168 consecutive hour period, and never on consecutive days.
(a) Except as provided for in § 117.17 [FYI, split duty periods], no certificate holder may assign and
no flightcrew member may accept an assignment for an unaugmented flight operation if
the scheduled flight duty period will exceed the limits in Table B [this is the table that allows a max of 13 hours of duty, and only for 0700-1259 show times] of this part.
(b) If the flightcrew member is not acclimated:
(1) The maximum flight duty period in Table B of this part is reduced by 30
minutes.
(2) The applicable flight duty period is based on the local time at the
flightcrew member’s home base.
(c) In the event unforeseen circumstances arise:
(1) The pilot in command and certificate holder may extend a flight duty
period up to 2 hours.
(2) An extension in the flight duty period exceeding 30 minutes may occur
only once in any 168 consecutive hour period, and never on consecutive days.
Be aware, the only time you could do a 10 hour flight time, 13 hour duty day is if you had a show time between 0700-1259, and a maximum of 4 legs. The majority of the time, your duty day and flight time limits are lower.
The above is for non-augmented operations only. Augmented is a whole different ball of wax.
Last edited by Sniper; 09-17-2011 at 02:43 PM. Reason: added 10 flight hour, 13 duty hour info
09-17-2011, 04:11 PM
#86
Gets Weekends Off
Joined APC: Jul 2010
Posts: 168
Interesting observations about this subject so far. However, blaringly absent in the discussion is how much further the regs goes, especially with the provision that EVERY operator would be required to have a FRMP. This really is the centerpiece of the new set of FDT regulations, and if you don't understand the concept then study it to see the course being charted.
I'm guessing that most have no faith in such system hence the reluctance to removing themselves from the schedule as a result of fatigue. A Fatigue Risk Management Program is no different than the current crop of FSAP and FOQA programs employed today, where the data is used to further refine the system. The more data goes in the more likely to see improvements along the way.
Remember, the company will not remove you until you step up and declared yourself fatigued but unlike current regulations, they will be required by the FEDS to use the data to improve scheduling. The more the program is utilized to report fatigue the better the chances of improvement on the issues that are at the center of the discussion so far.
Fatigue=removing yourself from the schedule period. Not a forward discussion that 9 hours is too much, or the JB clause or whatever. Instead show leadership and professionalism. Get the rest that you need!! The rest will take care of itself...
I'm guessing that most have no faith in such system hence the reluctance to removing themselves from the schedule as a result of fatigue. A Fatigue Risk Management Program is no different than the current crop of FSAP and FOQA programs employed today, where the data is used to further refine the system. The more data goes in the more likely to see improvements along the way.
Remember, the company will not remove you until you step up and declared yourself fatigued but unlike current regulations, they will be required by the FEDS to use the data to improve scheduling. The more the program is utilized to report fatigue the better the chances of improvement on the issues that are at the center of the discussion so far.
Fatigue=removing yourself from the schedule period. Not a forward discussion that 9 hours is too much, or the JB clause or whatever. Instead show leadership and professionalism. Get the rest that you need!! The rest will take care of itself...
09-20-2011, 11:06 AM
#87
New Hire
Joined APC: Sep 2011
Posts: 1
ATA: Airlines would cut 26,700 jobs if FAA implements new pilot rest regulations | ATWOnline
"The US Air Transport Assn. (ATA) said an analysis by consultancy Oliver Wyman demonstrates that the pilot fatigue and duty time rules FAA is proposing to implement would "have severe negative effects on US airline employment while reducing service, especially to small communities."
What bunch of crock...
"The US Air Transport Assn. (ATA) said an analysis by consultancy Oliver Wyman demonstrates that the pilot fatigue and duty time rules FAA is proposing to implement would "have severe negative effects on US airline employment while reducing service, especially to small communities."
What bunch of crock...
09-21-2011, 05:44 AM
#88
Gets Weekends Off
Joined APC: Feb 2009
Position: right for a long, long time
Posts: 2,642
ATA: Airlines would cut 26,700 jobs if FAA implements new pilot rest regulations | ATWOnline
"The US Air Transport Assn. (ATA) said an analysis by consultancy Oliver Wyman demonstrates that the pilot fatigue and duty time rules FAA is proposing to implement would "have severe negative effects on US airline employment while reducing service, especially to small communities."
What bunch of crock...
"The US Air Transport Assn. (ATA) said an analysis by consultancy Oliver Wyman demonstrates that the pilot fatigue and duty time rules FAA is proposing to implement would "have severe negative effects on US airline employment while reducing service, especially to small communities."
What bunch of crock...
10-28-2011, 10:54 AM
#90
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Joined APC: Nov 2008
Position: I'm here, i'm there, i'm everywhere...
Posts: 1,508
Here's my question...
In which scenario are you more fatigued?
Example A:
ATL-PHX (4:10 block)
4:30 sit time
PHX-ATL (3:35 block)
Block time = 7:45
Duty time = 14
Example B
ATL-LAX = 5 hours
1 hour turn time
LAX-ATL = 4:20
Block time = 9:20
Duty day = 11:35
Thanx!
In which scenario are you more fatigued?
Example A:
ATL-PHX (4:10 block)
4:30 sit time
PHX-ATL (3:35 block)
Block time = 7:45
Duty time = 14
Example B
ATL-LAX = 5 hours
1 hour turn time
LAX-ATL = 4:20
Block time = 9:20
Duty day = 11:35
Thanx!
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