Recently there has been a spate of articles revealing a “secret report” from 2011 which recommended that the FAA implement a NASA solution for ATCer fatigue. The press excoriated the FAA for hiding this scientific analysis and essentially blamed the agency for forcing the controllers to be “dangerously overworked.” The press knew about the NASA report back then and the FAA did not force the controllers to the “rattler” schedule. That said, it might be a good idea for NATCA and the FAA to fully embrace the safest solution at the expense of some three day weekends.
In 2011 there were numerous national news stories about the controllers sleeping on the job. More of the quasi somnambulant behavior in towers and centers was the lead story in the media in 2012. Secretary LaHood and Administrator Babbitt held press conferences on these embarrassments; President Obama also commented about his disappointment about the safety risks caused by this rest at work. As a result of this turmoil, the FAA Air Traffic Control Organization (ATO) COO Hank Krakowski resigned.
NATCA President Paul Rinaldi, Secretary LaHood and the FAA Administrator announced joint action in response to the 2011 incidents. The press release listed the steps implemented to assure an attentive ATC work force:
- “Controllers will now have a minimum of nine hours off between shifts. Currently they may have as few as eight.
- Controllers will no longer be able to swap shifts unless they have a minimum of 9 hours off between the last shift they worked and the one they want to begin.
- Controllers will no longer be able to switch to an unscheduled midnight shift following a day off.
- FAA managers will schedule their own shifts in a way to ensure greater coverage in the early morning and late night hours.”
One national aviation correspondent reported in response to the sleep incidents about a 2011 NASA study on sleep, which may be the culprit “secret study”:
“An FAA and National Air Traffic Controllers Association working group, relying on sleep research by NASA, the Air Force, the Mitre Corp. and others, recommended in January letting controllers take naps for as long as 2 1/2 hours on midnight shifts. They also recommended that controllers be allowed to sleep during the 20- to 30-minute breaks they receive every few hours during day shifts.
Instead, the FAA’s new rules will give controllers at least nine hours off between shifts, compared with eight now. That also was recommended by the working group, but a summary of their report notes the extra hour will likely result in only a “slight improvement” on midnight shift.”
The press seems to have known about the study four years ago and also saw that the FAA did not comply with the “hidden” recommendations.
Further, the FAA and the union agreed that controllers must notify their supervisor if the reporting employee was too tired to do his/her job. The new procedure allowed a controller to ask for time off if too fatigued to work air traffic. In lieu of work on the position she/he would be permitted to read on the job and to take rest breaks.
None of these remedial actions eliminated the source of the problem which NASA identified. Why? One reporter explained somewhat delicately:
“Scheduling needs to be flexible to meet the air traffic system’s demands, and over the years one of the most popular schedules became what was known as the 2-2-1. It was favored by many controllers because it compacted their workweek and created a weekend of at least three days.
Under it, a controller began the work week with two evening shifts, did a quick turnaround to a pair of day shifts and then did another quick turnaround before an overnight shift.
Those quick turnarounds — usually just eight hours — were blamed for controller fatigue, particularly when the final quick turnaround came at the end of the work week and just before an overnight shift.”
Reading between the lines, the controllers preferred the 2-2-1 schedules because it maximized the time off available. Not surprisingly, the union supported their members’ preference and the employer did not fight that demand. Past conflicts between unions and the FAA may have influenced this decision not to mandate the NASA solution.
About a year ago, Joseph Teixeiras, the ATO Vice President for Safety and Technical Training (he recently resigned), wrote a memorandum to his boss, Teri Bristol, the ATO COO which reviewed actions since the 2011 time frame. He listed six actions which had been implemented and then addressed the primary findings of the NASA study: shift scheduling and policy, midnight shift, education & promotion and individual fatigue management.
The outcry about the secret NASA report and the ATCers being compelled to work “rattler” shifts resulted in a press release, NASA Controller Fatigue Assessment Report Q&A, which recited the Teixeiras email’s list of actions. Among the institutional changes noted was the establishment of the Fatigue Risk Management office within the Air Traffic Organization.
One of the work products of that team is FAA Order 1030.7A Fatigue Risk Management document. Quoted from its preamble is the following definition of FRM; it “is a vital component of the Federal Aviation Administration’s (FAA) Safety Management System (SMS) and establishes the policy to define, assess, and manage fatigue-related safety risk…” While Order 1030.7A creates a Fatigue Safety Steering Committee, there is no evidence that the FSSC includes the typical 360° approach to SMS, that is, inclusion of all types (ARTCC, ATCT, TRACON, regional) of personnel drawn from around the country.
Though the bureaucracy and its responsibilities have been established, the 2014 IG Management Challenges – Actions Taken Report lists more bureaucratic activities (training, safety assurance, Fully Charged, a cultural change campaign). There is no mention, in either of these documents, of inclusion of all relevant of the FAA employees in a study of Fatigue Issues identified in the 2011 NASA report. Additionally there are more recent treatises on fatigue; the FAA Flight Standards organization compiled a state-of-the-art library on the science of fatigue in developing the new Part 117.
One can sympathize with Administrator Huerta and the unwarranted press attack of the FAA based on old news and due to the journalists’ failure to understand the true source of the 2-2-1 scheduling preference. However, it would appear appropriate NOW to use this opportunity to create a real 360° SMS team to analyze the literature, review the FAA’s own data and assess alternatives. The recommendations should prioritize SAFETY, minimize FATIGUE and optimize convenient schedules. The results of such a consultative, collaborative process should provide a win/win solution based on science.