Pilot Fatigue Rules...Sound Familiar?

[ATeam]

The Washington Post reports that pilot rest rules are under review by the DOT and FAA (story here). This debate and the truck driver hours of service (HOS) debate are similar.

To me, the most frustrating part of these HOS debates is the assumption that a "science based" rule can be created at all and that science and broad-brush rule making can somehow be used to create well-rested pilots and truck drivers.

If scientists studied my sleep patterns and needs in depth, they could easily come up with a story that scientifically describes my sleep patterns and needs. That does not mean they would be right but they would sound scientific and that seems to be all that matters in sleep debates. It seems that each advocate in these debates has one's own set of scientific facts that, amazingly, proves the advocate's point.

For the purposes of discussion, let's say the scientists are correct when they use science to study and describe my sleep patterns and needs. Unless the rule makers assume that all humans sleep alike, there is no way my sleep patterns and needs can be effectively used as basis for rules that apply to all truck drivers.

That's the problem with current HOS debates. Advocates and rules makers seem to be blind to the obvious fact that human beings do not all sleep alike. They need go no further than Diane's and my co-driver operated truck to discover that is true but they don't seem to care about that fact at all.

Rules that acknowledged that human beings do not all sleep alike would place some judgment and decision making power in the hands of individual pilots and drivers. Sadly, the rule makers show no sign of viewing pilots and drivers as anything other than the problem instead of the solution, and as entities to be regulated instead of professionals to be relied upon in the ongoing quest for safety in the sky and on the road.

 

[nightcreacher]

Taking this to another step.Us old guys like to take a nap now and then,has nothing to do with the amount of sleep we get during our 10 hour rest period.In the act of driving the truck,there is a boredom factor,and being able to stop for a couiple hours and take a break helps that out.But with the HOS as it stands,if you stop for a couple hours it goes against your time to work.

 

[highway star]

As I've always said, there will never be a "one size fits all" solution and the quest to come up something like that is just a typical exercise in government stupidity.

Please, please, o wise governmental sages, save me from myself!!

 

[Turtle]

Rules that acknowledged that human beings do not all sleep alike would place some judgment and decision making power in the hands of individual pilots and drivers. Sadly, the rule makers show no sign of viewing pilots and drivers as anything other than the problem instead of the solution, and as entities to be regulated instead of professionals to be relied upon in the ongoing quest for safety in the sky and on the road.

Unfortunately, they have history on their side, where drivers (and pilots) will use bad judgment and push it, sometimes with things like amphetamines or large doses of caffeine, to keep the wheels rolling.

And now we have this, where you almost hate to see something like this happen:

Traffic deaths at lowest in 60 years
Traffic deaths in the USA are at a 60-year low despite a slight uptick in miles driven, and the chances of dying on the road are the lowest ever, the Department of Transportation says.

The number of people who died on the nation's roads fell 3,615, or 9.7%, from 2008 to 33,808 last year, the latest available data from the department. That was the lowest total since 33,186 people were killed in 1950, when there were one-fifth the number of vehicles on the road than today.

"This is unprecedented, historic progress," says Barbara Harsha, executive director of the Governors Highway Safety Association, which has traffic safety offices in the states.

Harsha attributes the decline in deaths to a number of safety-related factors, including increased seat belt use, stronger enforcement of drunken-driving laws, improved roads, safer vehicles and better coordination in the states.

"Fatalities going down in every category is a strong indication that safety programs are working," Harsha says.

"We could not be happier, but we are not going to sit back on our laurels. We have a long, long way to go," Transportation Secretary Ray LaHood says.

"We think (distracted driving is) an epidemic, because everybody in America owns a cellphone, and everybody who owns one has either used it or texted on it while driving," he says.

You'd almost rather see injuries and deaths rise, at least in line with the increase in drivers and vehicles on the road. But with a decrease, and a rather dramatic one at that, it allows the DOT, NHTSA and others to beat their chest and say, "See! I told you so! We were right, and we're just getting started. We're going to do more and more and more."

Distracted driving is LaHood's pet project, and he's been all up in it for the last 2 years. Seeing traffic deaths drop over the last two years is a ginormous confirmation of his pet project, as well as the HOS rules from the FMCSA which were a part of it, and gives the empowerment justification for further rules and regulations. They will use science, junk science actually, to prove their points. It kind of like the "no cell phone use" when pumping gas laws in nearly every state, because it might cause a spark, even though there has never, ever, been a single documented case where that happened.

 

[greg334]

Sadly, the rule makers show no sign of viewing pilots and drivers as anything other than the problem instead of the solution, and as entities to be regulated instead of professionals to be relied upon in the ongoing quest for safety in the sky and on the road.

Phil,
the regulatory bodies have no choice but to see us as problems, here's why;

Unfortunately, they have history on their side, where drivers (and pilots) will use bad judgment and push it, sometimes with things like amphetamines or large doses of caffeine, to keep the wheels rolling.

Now Turtle has pointed out the real issue, bad judgement and because we, like some pilots, depend on our jobs, we take chances.

If we are going to complain about things and be compared to pilots (which is a joke) then we should worry about health, age and other things that commercial pilots also are limited to. Maybe an Airline pilot shouldn't have to go through the training and met the requirements they do for our safety but rather a simple skills test (touch your nose), a simple written test (what is a flap), a simple 2 year physical (yep you are breathing) and be allowed to fly past their 65 year on earth? Would anyone feel safe?

 

[Moot]

To me, the most frustrating part of these HOS debates is the assumption that a "science based" rule can be created at all and that science and broad-brush rule making can somehow be used to create well-rested pilots and truck drivers.

It was science that gave truckers the gear shift lever and pilots the incline plane. It stands to reason that science would give us the HOS rules.

Theology based HOS rules would be difficult, what with all the different religions and atheists to deal with. For Christians, an 11th commandment; THOU SHALT DRIVE FATIGUED, should pretty much cover it.

For those turban wearing drivers at Punjabi Trucking a simple rule like: SIKH REST WHEN TIRED.


A philosophy based set HOS rules could be best summed up by that famous french philosopher Moot Descartes, "I think, therefore I van".

 

[Freightdawg]

Here are the aviation regs:

§ 135.267 Flight time limitations and rest requirements: Unscheduled one- and two-pilot crews.
(a) No certificate holder may assign any flight crewmember, and no flight crewmember may accept an assignment, for flight time as a member of a one- or two-pilot crew if that crewmember's total flight time in all commercial flying will exceed—

(1) 500 hours in any calendar quarter.

(2) 800 hours in any two consecutive calendar quarters.

(3) 1,400 hours in any calendar year.

(b) Except as provided in paragraph (c) of this section, during any 24 consecutive hours the total flight time of the assigned flight when added to any other commercial flying by that flight crewmember may not exceed—

(1) 8 hours for a flight crew consisting of one pilot; or

(2) 10 hours for a flight crew consisting of two pilots qualified under this part for the operation being conducted.

(c) A flight crewmember's flight time may exceed the flight time limits of paragraph (b) of this section if the assigned flight time occurs during a regularly assigned duty period of no more than 14 hours and—

(1) If this duty period is immediately preceded by and followed by a required rest period of at least 10 consecutive hours of rest;

(2) If flight time is assigned during this period, that total flight time when added to any other commercial flying by the flight crewmember may not exceed—

(i) 8 hours for a flight crew consisting of one pilot; or

(ii) 10 hours for a flight crew consisting of two pilots; and

(3) If the combined duty and rest periods equal 24 hours.

(d) Each assignment under paragraph (b) of this section must provide for at least 10 consecutive hours of rest during the 24-hour period that precedes the planned completion time of the assignment.

(e) When a flight crewmember has exceeded the daily flight time limitations in this section, because of circumstances beyond the control of the certificate holder or flight crewmember (such as adverse weather conditions), that flight crewmember must have a rest period before being assigned or accepting an assignment for flight time of at least—

(1) 11 consecutive hours of rest if the flight time limitation is exceeded by not more than 30 minutes;

(2) 12 consecutive hours of rest if the flight time limitation is exceeded by more than 30 minutes, but not more than 60 minutes; and

(3) 16 consecutive hours of rest if the flight time limitation is exceeded by more than 60 minutes.

(f) The certificate holder must provide each flight crewmember at least 13 rest periods of at least 24 consecutive hours each in each calendar quarter.

I'm sure this is all clear as mud! This is for the smaller cargo airplanes, under 7500 lbs of freight. Larger aircraft operate under part 121 regs which are similar. This is also for unscheduled, on demand aircraft.Scheduled have slighty different regs. We have to keep flight manifest, like your logs, and we are easily tracked on various websites. Like you, we do an allnighter, crawl in to bed, wake up refreshed, and are not yet legal. By the time we are legal, you're tired again. In a good year, I'll fly slightly over 1000 hours.

 

[Freightdawg]

I should have added that part 91 aircraft like corporate and private aircraft, do not have duty/ flight time limitations. They also do not have to adhere to weather minimums
like "commercial" aircraft do. Many corporate flight departments choose to operate under the tougher standards even though not required.

 

[Freightdawg]

Phil,
the regulatory bodies have no choice but to see us as problems, here's why;



Now Turtle has pointed out the real issue, bad judgement and because we, like some pilots, depend on our jobs, we take chances.

If we are going to complain about things and be compared to pilots (which is a joke) then we should worry about health, age and other things that commercial pilots also are limited to. Maybe an Airline pilot shouldn't have to go through the training and met the requirements they do for our safety but rather a simple skills test (touch your nose), a simple written test (what is a flap), a simple 2 year physical (yep you are breathing) and be allowed to fly past their 65 year on earth? Would anyone feel safe?

I have to take a flight physical every year. Those operating larger {FAR part 121} aircraft, take 2 flight physical each year. We take a minimum of 2 flight check rides each year with either the FAA, or an FAA designated examiner. I've been doing 3 a year because I've been flying 3 different types of aircraft. A few years back, it was 4 a year. Heart problems, blood pressure issues, and diabetes, and there goes your livelyhood!

 

[stamp11127]

Ok, here is a stupid comment from the peanut gallery...

After reading the post on the flight regs, all I can think about is when are they going to put the weigh in motion scales on the runways?

 

[Freightdawg]

Ok, here is a stupid comment from the peanut gallery...

After reading the post on the flight regs, all I can think about is when are they going to put the weigh in motion scales on the runways?

We have to complete a weight and balance form, before flight, that must be kept in records for a specified amount of time. Some operators leave a copy at the departure airport...just in case. As I'm sure happens to all of you, the weight on the bill of lading is not necessarily the correct weight. We try to get accurate weights, but sometimes.... We have gross weights on our airplanes which we are not legally able to exceed. Aircraft performance is dependent on weight, temp, altitude, and other factors. Probably the most important reason to manage weight is due to extremely reduced performance with an engine failure especially right after take-off.