There is no more contentious set of rules in all the Federal Aviation Regulations than those written to prescribe the hours a pilot’s hours of work and rest. Whether the criteria are known by the old phrase “flight and duty” time or their new nomenclature, 14 CFR Part 117 , the debate on the meaning of words and phrases derive from these safety rules also define the hours of employment. The hours of scientists, lawyers and staff that were devoted to writing these regulations are only exceeded by the same set of experts parsing their meaning post promulgation.
The Flight Safety Foundation, which has as its motto “independent, impartial, international”, worked with NBAA to create Duty/Rest Guidelines for Business Aviation. The work had as a foundation the extensive study and analysis which supports Part 117. Unfortunately the document does not mention specifically who participated in the development of this document other than the author; it did describe in general terms that the panel was composed of GA operators with a very wide range of experience and of “highly regarded and widely published” scientists:
“Their experience ranges from laboratory research, medicine and operational research to regulatory development and operational design. Each member of the scientific panel brought extensive knowledge of fatigue management in many operational environments, including understanding of the impact and limitations of duty guidelines and rest requirements in aviation.”
That’s an impressive array of talent and knowledge.
The preamble clearly incorporates the industry’s learning under the prior 1997 guidelines and articulates the goal of the study:
Among the other goals for this document was providing a useful tool that is practical, and easy to understand and to implement. These guidelines hopefully will set the cornerstone of every fatigue management effort in this sector of aviation, with both their design and recommendations easily incorporated into any operator’s Flight Operations Manual.
The “book” describes 1.0 Fatigue Factors (Sleep, Recovery Periods, Time-of-Day and Circadian Physiology, Continuous Waking Hours and Individual Differences) and then establishes Guidelines and Recommendations in four succinct pages (including tables). Thoughts about Fatigue Management occupies another two pages.
It is a well written and hopefully well received book to guide management and cockpit crew through the complexities of providing alert, aware safety professionals. The guidance is not a series of compound, complex sentences which tend to be the cadence of CFRs, but rather provides insights and practices which should insure that all involved are focused on the goal–pilot performing in a global, multiple time zone and on demand operating environment.
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