NTSB Chairman Stresses the Need for Pilot Sleep and Rest Requirements  

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National Transportation Safety Board Chairman Mark V. Rosenker recently reminded operators of vehicles in all modes of transportation about the inherent dangers of fatigue.

"The Safety Board is very concerned about reducing accidents and incidents caused by human fatigue," Rosenker said. "We have seen numerous accidents where human fatigue was the probable cause or a contributing factor."

Fatigue has been on the Board's Most Wanted List of safety improvements since the list's inception in 1990.

Throughout its 41-year history, the NTSB has seen the issue of fatigue reoccur in many of its accident investigations with fatal results. As a result, NTSB has studied operator fatigue and issued recommendations calling for improved scheduling regulations and practices, education for operators and employers concerning fatigue and sleep disorders, and research to better understand the risks associated with fatigue in transportation.

"Inadequate sleep puts the public at risk," Rosenker said. "Improving the quantity and quality of our sleep can increase safety and save lives. "

The Safety Board wants the Federal Aviation Administration (FAA) to: set working hour limits for flight crews, aviation mechanics, and air traffic controllers based on fatigue research, circadian rhythms, and sleep and rest requirements; and, develop a fatigue awareness and countermeasures training program for controllers.

The Safety Board has long been concerned about the effects of fatigue on persons performing critical functions in all transportation industries including flight crews, aviation mechanics, and air traffic controllers.

In 1989, the Board issued three recommendations to the Secretary of Transportation calling for research, education, and revisions to existing regulations. These recommendations were added to the Board's 1990 Most Wanted List.

Safety Board recommendations on the issue of human fatigue and hours-of-work policies have had a substantial effect on encouraging the modal agencies to conduct research and take actions towards understanding the complex problem of operator fatigue in transportation and how it can affect performance.

However, the FAA has taken little if any action directly related to revising existing regulations and work scheduling practices. The FAA issued a notice of proposed rule making (NPRM) in December 1995 to update the flight and duty regulations for airline pilots; however, in the intervening 12 years, the regulations have not been revised.

The FAA has indicated to Congress that it is looking at alternatives without specifying an anticipated schedule. An ARAC reviewing Part 135 regulations has made some recommendations to simplify and improve the duty time regulations for flight crews covered by Part 135. The FAA has for some time indicated that it is developing an NPRM that incorporates the ARAC's recommendations; the NPRM will include a fatigue risk management system that provides an alternative to the prescriptive limitations.

In 1999, the FAA issued a report, Study of Fatigue Factors Affecting Human Performance in Aviation Maintenance. The FAA expanded this study, completing the first phase of the expanded study and issuing a report in April 2000, titled Evaluation of Aviation Maintenance Working Environments, Fatigue, and Maintenance Errors/Accidents.

The expanded study looked at multiple and combined environmental factors of temperature, noise, light, vibration, and sleep, which are known to accelerate fatigue onset, as well as the effects of lifestyle habits on fatigue and human performance. The study was designed to collect data in the aviation maintenance work environment on known factors that affect human fatigue and performance.

The FAA's findings suggest that fatigue is an issue in this work force. Data from "mini-logger monitors" that recorded data from the selected parameters of light, noise levels, and temperature; activity monitors that monitored physical activity, sleep, and sleep quality; and answers to background questions that employees were asked clearly indicate that sleep durations are inadequate to prevent fatigue. For most aviation maintenance technician specialties, 30-40 percent of respondents reported sleep durations of less than 6 hours, and 25 percent of respondents reported feeling fatigued or exhausted.

The data were intended for use in predicting situations that are conducive to fatigue, accidents, incidents, and errors. Data collection began in August 2000, and the expanded study was planned for completion in December 2003. However, an FAA Aviation Maintenance Human Factors Project Report from January 2004 stated that the research had not progressed, nor is any broad research effort or regulatory activity currently being conducted in this area.

The FAA has reported to Congress that, based on several studies completed on the maintenance fatigue issue, it believes that the extreme complexity of the issue of maintenance crew fatigue and duty time do not present appropriate material for regulatory activity, and that education and training in fatigue management are the most appropriate actions for the FAA to sponsor and foster. The FAA has consequently conducted education and training activities on fatigue management for aircraft maintenance personnel.

On April 18, 2006, the Safety Board informed the FAA that the Board disagrees with the FAA's positions that regulatory action is not appropriate and that the FAA's current education and training activities related to this issue can achieve the intent of this safety recommendation.

On February 22, 2007, the Safety Board informed the FAA that it had reviewed Advisory Circular (AC) 120-72, "Maintenance Resource Management (MRM) Training," which seemed to be the primary focus of the FAA's education and training initiatives related to fatigue among aviation maintenance crews as reported to Congress.

The Board found little in AC 120-72 that provides guidance on human fatigue in maintenance crews other than generalized warnings that attention to fatigue is important and should be considered in MRM Training. The AC contains little guidance as to how an employer should design a program to ensure that maintenance crews are not fatigued.

The Board asked the FAA whether it has any additional guidance related to fatigue in aviation maintenance crews besides AC 120-72 and whether the FAA will consider establishing duty time limitations for personnel who perform maintenance on air carrier aircraft, as recommended. The FAA has not yet responded.

The FAA plans to convene a working group to develop shift rotation and scheduling guidelines, and the FAA will invite the National Air Traffic Controllers Association (NATCA) to participate in the group. The FAA plans to develop and implement a fatigue awareness and countermeasures training program to be used by all FAA Air Traffic Organization operational service units. NATCA has informed the FAA of its eagerness to participate in this group, and indicated its commitment to developing workable scheduling practices that minimize controller impairment due to fatigue.