EASA proposal for air crew fatigue

02/10/2012

“A tired pilot is a dangerous pilot. EASA’s rules fail to address this.”

  • When drafting new EU-wide rules to prevent air crew fatigue, the EU Institutions must make passenger safety their Number 1 Priority.
  • This means: the EU must base its rules on scientific evidence, on a precautionary approach (‘if in doubt chose the safer option’), and on safety considerations only.
  • Decades of scientific research, including 3 scientific reports commissioned by EASA in 2011, shows where the EU should set the crews’ working limits to prevent fatigue.
  • But EASA’s proposal disregards scientific evidence, runs counter to the precautionary principle, and allows flight schedules that are outright dangerous.
  • EASA’s text [1] will not ensure safe operations for Europe’s travelling public, e.g.:

  - ‘Short-call’ Standby: EASA’s rules expect a pilot to land plane full of passengers after having been at work and awake for over 22 hrs. – This is not safe!

  - Night flying: scientists are unanimous that such flights should be limited to 10hrs to prevent high fatigue levels. But EASA proposes 11-12 hrs. – EASA takes risks!

- Open-ended Standby: Crews can be put on open-ended “Reserve” standby for up to 23 days, to be called at any moment day or night for a later full flight duty. Sleep disruption and deprivation will result. – Flexibility before safety!

- Opting out: EASA allows evading stringent rules on flight schedules that disrupt sleep patterns (e.g. early starts). – EASA undermines its own rules!

- Long work days with high workload: the rules must protect against the fatiguing effect of long days with multiple take-offs and landings. The scientists are unanimous on this. But EASA dismissed their advice. – Science disregarded, yet again!

- Safety regression: These rules will be applied across Europe. They replace existing national safety standards which are higher in several EU countries. But they are not allowed to keep higher standards. – This promotes lower safety standards!

  • EASA defends its proposal by focusing on a number of improvements compared to the current EU rules. But these rules are a strikingly low baseline to compare with, and the improvements are by far outweighed by new provisions allowing highly risky schedules. – Improvements should not deflect from the proposal’s severe deficiencies.
  • ECA calls upon the EU Commission, Transport Ministers and the EU Parliamentarians to reject this proposal in its current form and to amend it into a safe package that puts passenger safety before the commercial interests of the airlines.

Background:  Why crew fatigue is a problem

  • Since the 1944 Chicago Convention, it is recognised that pilot fatigue (due to long duty hours, insufficient rest/sleep opportunities etc.) can pose a risk to the safety of air operations. This risk needs to be controlled by the means of Flight Time Limitations.
  • Fatigue reduces the physical and mental ability to operate safely. A fatigued person may lose 80% of his/her attention capabilities and 70% of responsiveness. The effects of severe fatigue are comparable to those provoked by alcohol. However, whilst alcohol is forbidden in transport, fatigue in the cockpit is tolerated.
  • Pilot fatigue contributes to 15-20% of all fatal air accidents related to human error, as show the recent fatal accidents in the USA (Colgan Air, 2009, 50 killed) and India (Air India, 2010, 158 killed).
  • In May 2012, an Air Berlin plane requested an emergency landing in Munich, due to the pilots being severely fatigued. In 2007, an aircraft with 288 passengers on board comes off the runway in Iceland when landing. The investigation shows: fatigue was to blame.
  • Fatigue is already a reality in Europe’s cockpits today. Surveys among pilots show that 71-90% of pilots said they made errors due to fatigue, with 50-54% saying they dozed off in the cockpit without notifying their colleague.
  • This is why Europe needs strict, scientifically based rules to prevent fatigue from posing a risk to the safety of passengers, crew and people living under the flight-paths.



[1] For EASA’s full proposal (EASA Opinion-2010-14) see: http://www.dead-tired.eu/downloads/downloads-home