Rule- and/or risk-based approaches to fatigue management: new EU rules on pilot working hours

The European Aviation Safety Agency (EASA) is drafting new rules on pilot and cabin crew working hours, aiming to set a European-wide standard to manage aircrew fatigue.  However the British Airline Pilots Association (Balpa) has noted a number of issues with the new rules including airport stand-by time not counting towards hours worked.  Under one scenario a pilot could be required to land a plane 22 hours after having woken up in the early morning.  However this scenario has been labeled as an ‘extreme’ case by the UK Civil Aviation Authority (UK CAA).

Currently, not all countries have rules regarding the maximum length of hours pilots are allowed to fly, which the EASA rules would define.  In the UK flight duty hours are currently limited to 13.25 hours, which new proposals would extend.  Balpa has released a video (watch it here) explaining its position on the new rules, which it sees as driven by commercial reasons rather than safety.  Yet, whilst the UK CAA acknowledges that in some cases the proposals will see flight hours extended, they will also require airlines to manage fatigue with greater vigilance, suggesting the new rules are part of a growing trend towards the use of fatigue management systems.

Fatigue management systems are processes put in place to monitor and manage fatigue dynamically,  through watching for the warning signs – e.g. monitoring overtime and encouraging staff to report when they are fatigued – and arranging the workload in a way that minimises the risk of human failure due to fatigue.

According to the International Air Transport Association (IATA) website, crew flight duty and flight time limits are being re-examined in light of new, more scientific approaches to managing the risk of crew fatigue.  Whilst crew fatigue has typically been controlled by a simple set of prescriptive rules concerning flight time and duty limitations these rules can sometimes lead to situations in which crew are given rest periods when they are unlikely to be able to sleep, such as when circadian rhythms have been interrupted due to time zone changes.

“It has been demonstrated that the timing of the break is more important than the duration of the break itself. A prescriptive approach, based only on daily time limits, cannot take into account the complex interaction of factors that are linked to hours of work and rest periods.

In other words, prescriptive rules are not the total solution. With a well-managed fatigue risk management system, flight duty time and schedule of operation will be optimised, and this enhances efficiency.”

In 2011 IATA, the International Civil Aviation Organization (ICAO) and the International Federation of Airline Pilots’ Associations (IFALPA) jointly published The Fatigue Risk Management Systems (FRMS) Implementation Guide for Operators.  This guide provides insight in to the methodology and framework for implementing an effective fatigue management programme, the science supporting it, and aims to move the airline industry away from a prescriptive approach to fatigue management towards a risk-based approach.

Energy sector experience

The use of fatigue management systems has become more common in the energy and allied process industries in recent years.  API RP 755, published in 2010 by the American Petroleum Institute, outlines recommended practice for implementing such a system, and the EI is currently updating its publication Improving alertness through effective fatigue management to include good practice on implementing fatigue management systems as well.

Whilst API RP 755 still sets limits for shift length, these limits are fairly relaxed, with maximum unscheduled shift lengths of up to 18 hours, and recommending only a minimum of 8 hours downtime between shifts of 14-16 hours.  These recommendations are somewhat controversial: for example, research presented in the 2006 edition of EI Improving alertness through effective fatigue management shows that the risk of incidents occurring significantly increases after 12 hours on the job (although this publication is currently being updated with the latest research into fatigue management); HSG256, also published in 2006, recommends that shifts longer than 12 hours should be avoided.  As previously reported on HOF Blog, there is also an increasing trend in some industries to account for commuting time when setting shift lengths and patterns, recognising that work and non-work activities both cause fatigue.

However, API RP 755 provides a set of minimum standards which can always be surpassed.  The shift lengths in API RP 755 are in light of having an effective fatigue management system in place which should catch and prevent fatigue from becoming an issue.  Those implementing API RP 755 should also be aware of local regulations – for example, under in EU Working Time Directive 2003/88/EC, companies must provide 11 hours downtime between shifts.

One without the other?

Risk-based approaches to fatigue management are gaining support in both the energy and aviation sectors, and in some cases we are seeing a move away from strict limits on working hours.  These moves are perhaps not without controversy, yet there seems to be evidence to support both methodologies.

It may be worth asking whether they need to be mutually exclusive: is it possible to implement an effective fatigue management system without having cautious prescribed limits on working hours?

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