On 6 May 2013, the European Transport Safety Council (ETSC) issued a position paper benchmarking the EASA Opinion against the opinion of 6 scientific experts. In their paper, the ETSC criticises EASA’s insufficient take-up of scientific evidence, pinpoints areas where improvement is required, and urges EU decision-makers to “think carefully before giving final approval” to the FTL proposal.
While welcoming the EASA’s proposal as a comprehensive attempt to address the problem of aircrew fatigue, ETSC states that “the proposals do not fully and properly reflect the scientific evidence that should underpin fatigue management. Nor do they fully incorporate the scientific evidence which EASA itself commissioned.”
In particular, the 6 scientists recommend the following changes to the Opinion:
1. Daily maximum Flight Duty Period (FDP):
- Night duties should be limited to 10 hrs FDP (while up to 14 hrs are possible for start times between 08:00-11:00);
- FDP should be reduced as of the 2nd take-off (‘sector’), not as of the 3rd;
- Possibility to extend FDP by 1 hour twice per week should be abolished.
- As sleep will always be shorter & of poorer quality, rest facilities should be comparable to Class 1 inflight rest facilities;
- Standby duty should count towards FDP if it interferes with normal sleep patterns,
- Long times on standby+FDP should be avoided.
3. Disruptive schedules:
- Schedules that disrupt normal sleep patterns (early starts, late finishes) should be done under a Fatigue Risk Management System (FRMS);
- No more than 3 such schedules in a row should be allowed;
- Early starts should not be followed by duty overlapping the deep-sleep ‘WOCL’ period (02:00-05:59);
4. Inflight-rest on board of an aircraft:
- Base FDP extensions should be based on a %age of the duration of the sleep in an on-board rest facility; not on a simplistic formula based solely on type of rest facility (as EASA proposes).
5. Fatigue Risk Management Systems:
- FRMS to be used to enhance the mitigation of fatigue risks, not simply to increase and exceed the limits set by the rules.
6. Commander’s discretion:
- Extensions of the FDP decided by the Captain (due to unforeseen circumstances, such as bad weather etc.) is to be reported within 14 days, not after 28 days.
This ETSC paper – and the scientific advice it is based upon – re-confirms many of the recommendations made by scientific experts previously. It also makes evident that EASA’s Opinion is insufficiently based on scientific evidence – contrary to what is required by EU law and ICAO standards.
Read the full ETSC Position on Flight Time Limitations
Read: Dead-tired News