December 21, 2011 Celeste Monforton, DrPH, MPH 5Comment

Ms. Madeline Loftus, 24, was just one of the 50 individuals who lost their lives on February 12, 2009 when Continental Flight 3407 crashed in a neighborhood near Buffalo, NY. The NTSB investigation and a frightening PBS Frontline investigation called “Flying Cheap” identified airline industry practices that compromise pilots’ fitness for duty, including severe fatigue, as contributors to the disaster.

The Feb 2009 Pinnacle/Colgan/Continental airline disaster was not the first one in which fatigue was identified as a contributing factor in pilots’ errors and poor performance. Following an October 19, 2004 crash at the Kirksville, Missouri Regional Airport that killed 15, the NTSB noted that the pilots had inadequate overnight rest periods, early report for duty times, and too many consecutive flight legs. In response, the NTSB recommended in 2006 that FAA amend its regulations related to crew hours-of-service, and require the airlines to develop fatigue management programs. FAA responded in September 2010 to the NTSB recommendation by proposing comprehensive improvements and responding to thousands of comments on them. The final result is what was announced today by the FAA.

“The rule recognizes the universality of factors that lead to fatigue in most individuals and regulates these factors to ensure that flightcrew members in passenger
operations do not accumulate dangerous amounts of fatigue. Fatigue threatens aviation safety because it increases the risk of pilot error that could lead to an accident. …FAA has adopted a system approach, whereby both the carrier and the pilot accept responsibility for mitigating fatigue. The carrier provides an environment that permits sufficient sleep and recovery periods, and the crewmembers take advantage of that environment.”

The Air Line Pilots Association (ALPA) is applauding the new FAA rule with ALPA’s president Captain Lee Moak saying

“Today’s pilot fatigue rule release marks historic progress in what must be an unrelenting commitment to ensuring the highest safety standards throughout the airline industry. ALPA is gratified that the DOT and the FAA have delivered on their pledge, and a congressional mandate, to issue new flight- and duty-time regulations and minimum rest requirements for airline pilots.”

The agency had proposed applying these rules as well to cargo operators, like UPS and FedEx, but the final rule only covers passenger aircraft.

The FAA rule characterizes fatigue as

“…a general lack of alertness and degradation in mental and physical performance” and classifies it as: transient, cumulative, or circadian. “Transient fatigue is acute fatigue brought on by extreme sleep restriction or extended hours awake within 1 or 2 days. Cumulative fatigue is fatigue brought on by repeated mild sleep restriction or extended hours awake across a series of days. Circadian fatigue refers to the reduced performance during nighttime hours, particularly during an individual’s window of circadian low (typically between 2:00 a.m. and 6:00 a.m.).”

As I read the litany of symptoms of fatigue, I certainly understand the rule’s benefits for airline crews and the general public.

**Measurable reduction in speed and accuracy of performance
**Lapses of attention and vigilance
**Delayed reactions
**Impaired logical reasoning and decision-making, including a reduced ability
to assess risk or appreciate consequences of actions
**Reduced situational awareness, and
**Low motivation to perform optional activities.

Catastrophic airline crashes can result. It strikes me that workers in other industries—-critical care nurses, fire fighters, overnight road construction crews, etc.—may also be at risk of severe fatigue. Some of it may be self-induced, but other may be directly related to how their organization schedules these individuals’ work and the demands of it.

About the time that the FAA was proposing these improvements for pilots, OSHA received a petition on behalf of medical residents urging the agency to issue a rule limiting the physicians-in-trainings’ work hours. The petitioners’ argued that excessive work hours create an unreasonable risk of injury to these individuals, including motor vehicle crashes, depression and mood disorders, needlestick injuries and other health problems. One study cited by the petitioners suggested that sleep-deprived medical residents had impaired peformance comparable to a 0.05% blood alcohol level.

OSHA’s assistant secretary David Michaels responded to the petition by saying:

“We will review and consider the petition on this subject. …In its investigation of the root causes of the BP Texas City oil refinery explosion in 2005, in which 15 workers were killed and approximately 170 injured, the U.S. Chemical Safety Board identified worker fatigue and long work hours as a likely contributing factor to the explosion.”

He added

“It is clear that long work hours can lead to tragic mistakes, endangering workers, patients and the public. All employers must recognize and prevent workplace hazards. That is the law.”

A good place to start would be for employers to assess the risk of work-related fatigue in their workforce and take steps to mitigate it. FAA’s rule describes a Fatigue Risk Management System, which includes an education and awareness training program, and fatigue-related incident reporting. We’re fooling ourselves if we think that passenger pilots are the only occupations at high-risk of organizationally-induced fatigue.

5 thoughts on “FAA’s pilot fatigue prevention rule could translate to other occupations

  1. Why should the rules be the same for everyone?

    My personal problem is that my biological clock seems to define a day as about 26 hours. I’m sleepy in the morning, and have difficulties at falling asleep in the evening. There must be people with a 22 hour clock, too. Their patterns of developing fatigue must be different from mine.

  2. My personal problem is that my biological clock seems to define a day as about 26 hours.

    That’s pretty standard. (Where’s Bora when we need him?) Most people free-run at longer than 24 hours and stay in sync with intense light. Getting plenty of sunlight, especially early in the day, helps.

    There must be people with a 22 hour clock, too. Their patterns of developing fatigue must be different from mine.

    (/me raises hand) Somewhat different, but since in my case I don’t need as much sleep as most (7 hours is about all I can stand unless I’m sick or otherwise really run down) it’s not really an issue.

  3. This is a very ordinary problem in many occupations.
    In many cases, it is a blatant disregard of the law on the behalf of the employees as well the employers.
    Only stronger enforcement by the responsible agencies can put a stop to it.
    I am sure that almost all, employees as well as employers,
    would welcome better enforcement of the law/rules.

  4. Although there’s plenty of variation in the tau (free-running, endogenous circadian day length) between individuals, I’m pretty sure the average tends to be about 24-and-a-quarter hours in total darkness from most studies. The general problem for most people that would make it seem longer is continuous light exposure into the night.

    Regarding the fatigue problem, it’s been an ongoing issue for the FAA. There was recently the Article 55 workgroup (composed of FAA and NATCA members) who issued recommendations for controllers in June of this year. Of course, the first item on their list was enough time for ‘recuperative breaks’ for controllers working night shifts, in addition to some other recommendations regarding scheduling (one hour more break on the last leg of the 2-2-1 shift) and staffing. That number one item, though, was outright rejected by Secretary of Transportation Ray LaHood (the stubborn ass) who refuses to “pay people to sleep on the job”, even if those naps are for the benefit of safety.

  5. If you’re trying to get people to work weird hours, you’ve got to be creative and not resort to silly soundbites.

    Me? I *want* to pay ATC workers to sleep on the job. I *want* to be confident that they have slept enough.

    (Reminds me of an article I read a few months back about how horribly expensive it would be to have California prison guards be searched to ensure they weren’t smuggling in contraband. The article talked about the union rules adding prohibitive costs. Apparently, the union agreement specified that the workers would have to be paid for the time spent going through screening. I think that’s fair and reasonable. It’s part of the job. IMHO)

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