After the devastating
crash of Colgan Air Flight 3407 in 2009 the Federal Aviation Administration (FAA)
made immediate changes to the amount of rest pilots are required to have before
their flight duty period in an attempt to combat the effects of pilot fatigue.
Sarina Houston (2016) reported on the new rule stating that the new regulations
call for a “rest period of 10 hours, with the opportunity for at least 8
uninterrupted sleep hours” (para. 11). Houston (2016) further reported that
this was the most noticeable improvement from the old rule which only required a
“rest period of at least nine hours, which can be reduced to eight hours”
(para. 11).
Other new mandates require
that pilots report whether or not they are fit for duty, offer new flight duty
periods in the ranges of nine to 14 hours depending on when a pilot’s day
starts and how many flight segments he or she is expected to fly, and adds new
flight time limits of eight to nine hours depending on the start time of the
pilot’s flight duty period.
With the idea of safe air
transportation in mind, the FAA has required all commercial airline pilots to
adhere to these new regulations under Parts 117, 119, and 121. However, the
cargo airline operators are exempt from following the new flight and duty time
limits set for commercial airline pilots. According to the Cargo Airline
Association (CAA) (2016):
Cargo
pilots are allowed to fly up to 8 hours (as opposed to 9 hours for passenger carriers
under their rules) then legally must have a rest period. In a
situation where there are three crew members or more, cargo pilots may fly up
to 12 hours. While, cargo pilots may be on duty for 16 hours, under no
circumstance do they ever fly 16 hours without rest. (para. 2)
Depending on who you ask,
you may get a variety of reasons for why the FAA excluded the cargo industry from
the new crew rest requirements. Some may say that because there are less souls
on board the aircraft, there is no need to further restrict flight crew rest.
Others may claim that an increased limit on flight crew rest times may not be financially
beneficial to the cargo air carriers. I personally like to quote the FAA’s
reasoning behind the decision to exclude cargo airlines from the new crew rest
requirement rules. The FAA (2011) reported in a press release several years ago
that “the estimated cost of this rule to the aviation industry is $297 million but the benefits are estimated between
$247- $470 million” (para. 14). The FAA (2011) went on to claim that “covering
cargo operators under the new rule would be too costly compared to the benefits
generated in this portion of the industry” (para. 14).
I do not
fully agree with the possibility of compromising safety by not mitigating the
effects of pilot fatigue as a means to save cost for cargo companies. I do
believe that cargo pilots should be considered under the new crew rest
requirements regardless of the financial repercussions to the cargo industry.
Nancy Trejos (2014) collected several statements from an Air Line Pilots Association
(ALPA) representative who happened to touch on several issues, of which I fully
agree with, within the new regulations:
“It is
clear from the science that all airline pilots experience fatigue in the same
ways, regardless of whether they are transporting passengers or cargo,"
the union said. "Cargo airline pilots fly the same aircraft types over the
same routes, into and out of the same airports, as passenger airline pilots.”
(para. 16)
I
do not believe that the number of people on board a transport category aircraft,
or the financials that fund the aircraft being flown, should determine whether
or not an airline crew should be required to follow crew rest requirement rules
that would better help pilots overcome pilot fatigue. It is hard to say if I
think that a change to cargo carriers’ crew rest requirements would impact my
carrier in the future. As of now I had planned, and will continue to plan, on a
career in the commercial passenger airline industry.
References
Trejos,
N. (2014, Jan. 3). New Pilot Fatigue Rules Go Into Effect This Weekend. USA Today. Retrieved from http://www.usatoday.com/story/todayinthesky/2014/01/03/pilot-fatigue-mandatory-rest-new-faa-rules/4304417/
Federal
Aviation Administration. (2011, Dec. 21). Press
Release – FAA Issues Final Rule on Pilot Fatigue. Retrieved from https://www.faa.gov/news/press_releases/news_story.cfm?newsId=13272
Cargo
Airline Association. (2016, Apr. 13). Setting
the Record Straight on Cargo Pilot Duty and Rest Rules. Retrieved from http://www.cargoair.org/2016/04/setting-the-record-straight-on-all-cargo-duty-and-rest-amendment/
Houston,
S. (2016, Mar. 01). FAA Final Rule: Pilot
Duty and Rest Requirements. Retrieved from https://www.thebalance.com/faa-final-rule-pilot-duty-and-rest-requirements-282927
While I agree with the assessment that all pilots, regardless of what or who they are transporting experience fatigue the same way, I don't think that the same rest requirements should be imposed on the cargo industry. While it is important to put safety over monetary gain, it is also important to take a look at whether or not the possible loss is worth what you gain. Part 121 cargo operators are still held to a maximum of 8 hours of flying, unless they "heavy crew" which is a fairly common practice. The allowance for a longer duty day makes sense, as often a cargo aircraft, especially in an on demand operation, will head out to pick up cargo and end up waiting on the ground for several hours because the cargo is late. Is it feasible to delay the trip to get another crew to the destination, or to fly a new plane out? Especially in the on demand industry, moving things like auto parts, the possible trickle down costs of freight arriving late runs easily into the millions of dollars on a single trip. Like I said, money alone isn't a good reason to not adopt the same rest requirements, but I believe that the current flight time limitation is sufficient and the longer duty day allows for an industry where the mission is different than passenger operations. To add a caveat to this whole thing, pilots are allowed to "call fatigue" if they feel unsafe, regardless of how long they've flown that day, at a good company, they are allowed to cancel the flight on safety grounds. Maybe it would be better if the FAA cracked down on cargo operations whose culture does not allow for a pilot to "call fatigue" without fear of repercussion.
ReplyDeleteI also do not fully agree with the decision to exclude the cargo industry form these regulations; however, I do also acknowledge the possible financial problems implementing this regulations could cause. Cargo carriers are a business, and if they start to lose money due to these regulations, they will start cutting cost in other areas (pilot pay, other safety issues?). Something should still be done however, and I would think (from my limited research)that it is possible to reach a “middle ground” in which the regulations are not as strict/costly as passenger flights, yet still combats pilots operating in a fatigued or overworked state.
ReplyDeleteI agree with Erik on this issue. The current regulations on this matter for cargo operators are plenty sufficient. It was also stated in the same article that you referenced by the CAA that there have only been 2 accidents in the past 20 years by cargo operations that were fatigue related. This is not to say that there aren't some operations out there that are not fully "above board" in how they treat their pilots and their rest time. That being said, any reputable company that follows the regulations allows for plenty of rest for their crews. Most of the "duty time" by cargo pilots is spent on the ground sleeping at an FBO waiting for cargo anyway. No matter where you do it rest is rest, and most cargo pilots get more of it than passenger pilots.
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