Despite huge advances in medical research and a much greater understanding of circadian rhythms and their relationship to human fatigue, flight- and duty-time regulations for professional airline pilots have not changed significantly since the end of World War II. Recognizing that advancements in fatigue standards have not kept pace with other improvements in airline safety, ALPA has worked for the past 25 years to modernize FTDT regulations at the U.S., Canada, and international levels. Its partners in the effort have included the International Federation of Air Line Pilots’ Associations, the International Civil Aviation Organization, the Federal Aviation Administration, and, more recently, the U.S. Congress.

ALPA’s campaign to base FTDT rules on scientific research took a leap forward this year when FAA Administrator Randy Babbitt appointed members of labor, industry, and government to the FAA Aviation Rulemaking Committee (ARC) and directed the committee to comprehensively review current flight-time and duty-time regulations and recommend changes to reduce pilot fatigue and improve safety. Administrator Babbitt recognized ALPA’s expertise in fatigue and its important role as a key stakeholder in the aviation safety process by appointing seven ALPA pilots to the ARC, representing every constituency at the Association: regional, domestic, international, and cargo airlines.

The ARC completed its review and made its recommendations to the FAA privately on September 1. The FAA has begun reviewing the Aviation Rulemaking Committee’s report with an eye toward releasing a Notice of Proposed Rulemaking (NPRM) by the end of the year.

The work of the ARC members is similar to that of NTSB accident boards: participants in the process are expected to keep the results and recommendations of the committee confidential until the FAA releases its fatigue rule NPRM. While ALPA honored the confidentiality rules, other parties in the ARC did not and leaked information to the news media, which led to stories prematurely revealing some of the committee’s recommendations.

After much deliberation, ALPA leaders decided its members deserved to be told what the Association’s position was on revising flight- and duty-time regulations, so ALPA distributed a communication on September 24 detailing the recommendations that its seven ARC representatives had given to the rulemaking committee.

The basis of ALPA’s recommendations on fatigue comes from the belief that the aviation industry needs a single, scientifically based rule for all types of flying. This was the first point in our six-point recommendation plan, which follows:

1. One rule for all airline pilots, not “carving out” the cargo and supplemental operators.
2. A minimum 10-hour rest period.
3. A reserve rest rule for all pilots.
4. Having multiple segments and circadian rhythm disruptions addressed.
5. Establishing limitations on duty periods, flight duty time, and block time based on the fact that excessive working hours affect flight safety.
6. Requiring the operator to prepare and publish reliable schedules.

Other concepts that ALPA addressed included a non-punitive provision for pilots to be removed from flight duties when they are fatigued, and a fatigue education program.

ALPA’s recommendations are based on millions of hours of operational experience by our members, backed up with years of scientific study. They incorporate ICAO and IFALPA guidelines and represent a comprehensive framework, in concept and in detail, of a flight- and duty-time and rest requirement rule. The ALPA recommendations use proven research on human fatigue and sleep patterns to mitigate the dangers both short-term fatigue and cumulative (long-term) sleep deprivation can pose to safe operations.

Maximum Flight Time (Block) Limits:

Flight Duty Period: Non-augmented Operations