Research into fatigue has been going on for many decades (see list of research), and has underpinned many national regulations in Europe. The International Civil Aviation Organisation (ICAO) concluded recently that sufficient scientific and medical evidence is available, and it therefore mandates that national fatigue rules must be based on such evidence.
However, the EU’s current rules (‘Subpart Q’) are not based on science, and were mandated to be replaced by scientifically derived rules based on a “scientific and medical evaluation” to be carried out by EASA.
The results of this scientific study – carried out by 10 renowned scientists – were officially published in Jan. 2009. It identifies a number of provisions in Subpart Q that need improvement to ensure adequate levels of flight safety (details see below), concluding among others that:
- The allowed maximum daily flight duty period of 13-14 hours "exceeds reasonable limits" and is "not in keeping with the body of scientific evidence"; it should therefore be reduced;
- The allowed maximum of 11:45 hours night duty should be reduced to 10 hours, because of the particularly fatiguing nature of work at night;
- The allowed practice of 3 consecutive 60-hour weeks (i.e. 180 duty hours in 21 days) needs to be changed by setting an additional limit of 100 duty hours within 14 consecutive days (i.e. an average of 50 hours/week, instead of 60);
- Stand-by at the airport is as fatiguing as flight duty, and should not be considered as "rest" but "count 100% as flight duty when calculating the maximum flight duty period”.
In addition to this comprehensive study, in early 2011 EASA commissioned 3 independent scientific assessments of its Dec. 2010 proposal for EU fatigue rules. In their reports, all three scientists come to very similar conclusions as EASA’s initial study, and make clear recommendations how to revise EASA’s proposed rules.
Despite these 3 reports and the previous study, EASA failed to reflect the scientists’ findings in its legislative proposals – largey due to the stern opposition from the airlines.