BALPA urges a new “sleepiness” test; what’s wrong with Part 117 which ALPA uses

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Union requests use of computer program on future duty schedules

Ignores FAA Part 117, state-of-the-art research

ALPA is teaching the FAA regimen of new scheduling, training and 


Pilots should undergo a ‘tiredness test’ before flights to stop them falling asleep in the cockpit, union says

BALPA, the British pilots union, has announced a “test” for assuring that its members are, indeed. fit for flight. The below article indicates that BALPA proposed assessment tool is a “computer program to estimate pilots’ fatigue levels based on their flight rosters, which are created weeks in advance of their duties”.

This is most curious since their American counterpart, ALPA,  is involved in implementing an FAA program which is designed to determine pilots’ readiness to perform her/his duties on both a systematic and a real time basis.

Pilot Fatigue is and has been a real problem for a long time. The FAA and other aviation safety regulators have devoted substantial resources to creating what was known as “flight and duty time” and now is entitled “flight and duty limitations and rest requirements for all flightcrew members” (14 CFR Part 117).

  • Varying flight and duty requirements based on what time the pilot’s day begins. The new rule incorporates the latest fatigue science to set different requirements for pilot flight time, duty period and rest based on the time of day pilots begin their first flight, the number of scheduled flight segments and the number of time zones they cross.
  • Flight duty period. The allowable length of a flight duty period depends on when the pilot’s day begins and the number of flight segments he or she is expected to fly, and ranges from 9-14 hours for single crew operations. The flight duty period begins when a flightcrew member is required to report for duty, with the intention of conducting a flight and ends when the aircraft is parked after the last flight. It includes the period of time before a flight or between flights that a pilot is working without an intervening rest period. Flight duty includes deadhead transportation, training in an aircraft or flight simulator, and airport standby or reserve duty if these tasks occur before a flight or between flights without an intervening required rest period.
  • Flight time limits of eight or nine hours. The FAA limits flight time – when the plane is moving under its own power before, during or after flight – to eight or nine hours depending on the start time of the pilot’s entire flight duty period.
  • 10-hour minimum rest period. The rule sets a 10-hour minimum rest period prior to the flight duty period, a two-hour increase over the old rules. The new rule also mandates that a pilot must have an opportunity for eight hours of uninterrupted sleep within the 10-hour rest period.
  • New cumulative flight duty and flight time limits. The new rule addresses potential cumulative fatigue by placing weekly and 28-day limits on the amount of time a pilot may be assigned any type of flight duty. The rule also places 28-day and annual limits on actual flight time. It also requires that pilots have at least 30 consecutive hours free from duty on a weekly basis, a 25 percent increase over the old rules.
  • Fitness for duty. The FAA expects pilots and airlines to take joint responsibility when considering if a pilot is fit for duty, including fatigue resulting from pre-duty activities such as commuting. At the beginning of each flight segment, a pilot is required to affirmatively state his or her fitness for duty. If a pilot reports he or she is fatigued and unfit for duty, the airline must remove that pilot from duty immediately.
  • Fatigue Risk Management System. An airline may develop an alternative way of mitigating fatigue based on science and using data that must be validated by the FAA and continuously monitored.”

The Part 117 regimen includes flight rosters DESIGNED to reduce the likelihood of fatigue PLUS creating tools to be used by all involved to identify the individual who appear to be tired. The systematic approach is far more likely to be effective.

What is unclear from the BALPA position is whether its computer’s parameters are nothing more that a set of rules different from the existing EASA regulations. That aviation safety organization established its criteria for permissible scheduling based on its expert judgment as to what hours of assignment are safe or not likely to contributing to fatigue.

It would seem, without further explanation that the BALPA Karolinska Sleepiness Scale (KSS)  may be nothing more than a set of rules which the union considers to be better than EASA’s. There is a way to reach that goal- file a petition with the agency explaining why the KSS is a more accurate predictor of sleepiness  and request an amendment.

Or perhaps, BALPA should ask that EASA adopt the regimen which ALPA seems to acc


“Pilots should be made to undergo ‘tiredness tests’ before they fly to help stop them from falling asleep in the cockpit, MPs have been told.

The British Airline Pilots’ Association (BALPA), which represents over 10,000 UK pilots, warned politicians that lethargy affecting captains and first officers presented the single biggest threat to plane passenger safety.

The union said it wants airlines to use computer programmes to estimate pilots’ fatigue levels based on their flight rosters, which are created weeks in advance of their duties. 

Long working hours and regularly crossing different time zones are said to contribute towards severe tiredness inside plane cockpits.

Under rules set by the European Aviation Standards [stet: SAFETY] Agency, which regulates working hours, pilots who declare they are too tired to safely lead a journey are not compelled to fly. 

However, it is claimed aviators are still operating flight controls over fears they could be penalised or even lose their jobs if they report being too fatigued to work.

BALPA has proposed airlines could use a computer based model based on the Karolinska Sleepiness Scale, a study used to measure an individual’s drowsiness.

The scale ranks a person’s tiredness from 1, classified as extremely alert, to 9, recorded as extremely sleepy. The union suggested no pilot should be allowed to fly if they are determined to be an 8 (sleepy) or above when tested.

[NOTE: this appears to be a real time test rather than the computer model mentioned earlier.]

Dr Rob Hunter, head of flight safety for BALPA told The Telegraph that pilots were at risk of sleeping on the job unless workloads were managed more efficiently.

He said: “Pilots can be rostered duties which we know will leave them fatigued and that is normal and acceptable in this industry. 

“Performance is affected because they are at an increased risk of falling asleep. Other effects are that pilots cannot think as quickly nor when they are tired and this is a problem depending on the situation.

The regulations are written so as to give airlines a great deal of flexibility but that gives the possibility of them rostering a pilot with severe fatigue. The regulator thinks that the airlines can be trusted to manage this situation but we do not.

“There is a discrepancy in the number of official fatigue reports received by the Civil Aviation Authority and what pilots tell us they are experiencing.”

Dr Hunter called for politicians to help change legislation surrounding pilot working hours at a health seminar held at Portcullis House in October.

The Air Safety Group, a campaign group comprised of aviation professionals to improve passenger safety, said it supported BALPA’s proposal and called for a scientific study to examine the risks caused by fatigue.

Some MPs have declared support for pilots to be assessed for tiredness before flights, but others said more research was needed.

Former Liberal Democrat leader Tim Farron said: “Our aviation industry prides itself on incredibly high standards and a strong reputation for safety and BALPA are absolutely right to for better rules to improve the safety both of pilots and of passengers. I fully support their proposals.”

Airlines including British Airways, easyJet and Virgin Atlantic said it met all safety requirements and EASA standards when rostering their pilots.

The EASA said managing fatigue is a shared responsibility between airline management and individual crew members

A spokesperson said: “Responsibility for preventing fatigue cannot rest on the airline alone or the crew member alone; all involved must contribute to achieving the goal.

“Only training and education can change individual behaviours. Therefore, an airline should provide adequate fatigue training, as well as tools for staff to use when assessing their own alertness.”

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1 Comment on "BALPA urges a new “sleepiness” test; what’s wrong with Part 117 which ALPA uses"

  1. An important ingredient of pilot performance is nourishment. When pilots lack adequate nourishment, they exhibit extreme effects of fatigue. As an ASAP counselor/instructor, most of the incidents I have dealt with involved hungry pilots (even when they did not realize it). Pilots need to take this seriously, and management needs to address the matter directly, and not just permit a delay for eating. I suggest that the dangers of pilots flying hungry is second only to upset as a threat to safe operations.

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