Transport safety experts criticise EASA flight time proposal


The European Transport Safety Council (ETSC) urges EU decision-makers to “think carefully before giving final approval” to the Flight & Duty Time Limitations Rules proposed by EASA. In a position paper published on 6 May, ETSC questions the full take-up of scientific evidence in the proposed rules and pinpoints areas where improvement is required.

ETSC’s position paper welcomes EASA’s proposal as a comprehensive attempt to address the problem of aircrew fatigue. Yet, it also spares no criticism for its overly-complicated and scientifically unsound approach to managing flight duty times in terms of maximum hours per day/night and insufficient recognition of multiple take-offs. Among others, the paper reconfirms that night flights have to be limited to 10hrs, rather than to 11hrs as proposed by EASA. The position paper is equally reproachful about the proposed provisions on flight time extensions due to inflight rest, standby and disruptive schedules.

The position paper is based on advice from scientific experts with considerable knowledge about fatigue in aviation. Among the consulted scientists are also the authors of the three expert reports commissioned by EASA in 2011. Among the criticisms pointed out is that EASA incorporated the scientists’ research at a fairly late stage in the drafting process and “several of their recommendations may not have been fully understood by the Agency”. Similar concerns have been repeatedly voiced by ECA.

ETSC also expresses concerns with “the misinterpretation of the benefits of active Fatigue Risk Management Systems” (FRMS). Instead of mitigating the effects of fatigue, warns the organization, EASA’s proposal uses FRMS to justify or support going beyond the FTL requirements.

Read the full ETSC Position on Flight Time Limitations (pdf).