As witnessed by rulemaking dockets on a variety of proposals replete with massive comments (and by equally exhaustive interpretation requests on the meaning of the underlying rules as well as six JDA Journal posts in the last six months), flight and duty time regulations are the most contentious and scrutinized FAA standards. The academic analyses of circadian rhythms, economic impact assessments, episodic testimony about sleep deprived pilots and related topics are contained in these comments, studies, letters and other documents.
Rarely discussed and as-of-yet unregulated is the question: In what state does the crew present itself for duty?
The attached article in The Telegraph includes an authoritative statement by Dr. Simon Bennett of Leicester University that this dimension of the issue should be included in the debate/analysis:
“The reality is that pilots commute huge distances to get to work and the same to get home. But if I raise this in Westminster or in Europe, the response is that the airlines are abiding by the rules.”
His study found that more than half of the pilots studied admitted to having been awake for more than 23 hours; another fifth of the sample said that they were flying 28 hours since their waking-up. None of this behavior is regulated unless the pilot/copilot is required to be ready to perform the cockpit duties.
It seems redundant to say (but it needs to be said) the regulation should make it clear that reporting for duty means that the pilot must be rested. Flight and duty rules should not, cannot, account for the pilots’ choices of where to live and of how to get to work. It is clear that the “professionals” responsible for such presentation do not adequately regard this duty as a REQUIREMENT, so it should be incorporated in any future regulation.Share this article: