ARTICULATION OF MAINTENANCE FATIGUE – BEGINNING OF A DEBATE?

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ARTICLE:  An Awakening to MX Personnel Fatigue

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The issue of pilot fatigue and the effect of circadian rhythm is an often debated subject and one to which considerable scientific research as well as regulatory resources have been devoted. This article in Aviation Maintenance Magazine does a masterful job of applying the same science to the Aviation Maintenance Technician (AMT). The author provides evidence that maintenance personnel incur the same debilitating long hours and also contends that their jobs involve high levels of stress. These conditions impact the worker’s physical, mental and emotional performance.

The research includes NTSB findings of accidents involving AMT fatigue (primarily ValuJet) as well as an Australian Transport Safety Bureau report summarizing similar problems in maintenance attributed to tired personnel. Also cited are studies by Dr. Terry von Thaden, president of Illumia Corp. and by Marco Giovannoli of Airbus (which was submitted to City University London as a Masters thesis.)

The article includes many of the arguments on both sides and initiates an important debate. Review of all of the points raised is recommended. Some salient observations include: the existing regulation 14 CFR §121.377 is very general, obviously requires further consideration and applies only to Part 121 maintenance (Part 145, particularly FRS’s?); while there are a number of fatigue assessment/prevention tools, none are controlling in terms of scientific or regulatory authority and Mr. Jensen includes many more thoughtful questions and a few initial answers.

MRO is an arena of considerable debate already with outsourcing and foreign repair stations becoming points of controversy due to the airlines search for low cost alternatives. The unions argue that they are cheaper because they are less safe. New rules, which limit the hours an AMT can work and define rest periods between duty times, may exacerbate the cost differential. At the same time, the initial review of the date presented by Mr. Jensen suggests that the costs of not addressing fatigue may be measured in human lives.

Resolution of this regulatory debate will test the FAA’s ability to define a well designed, balanced, safe rule which meets the OMB cost/benefit test. JDA has experienced professionals who understand how to construct FAA rules, are familiar with the science involved in fatigue assessment and have dealt with the internal and external negotiations inherent in such a battle.

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