Sir - The letter from R P Holubowicz "Pilots to influence flight-time limits?" (Flight International, 25-31 January, P52) clearly illustrates the difficulties of trying to legislate in the area of flight-time limits (FTL).
FTL should fall into two separate areas. The first is the national, or now-planned, European Joint Aviation Authorities (JAA) regulations, which should be the outside safety-orientated rules to prevent excessive fatigue. The second is in the separate industrial agreements between carriers and their aircrews, which may take into account the particular nature of individual operations. The latter should, of course, fall inside the outer envelope of the national or supra-national regulations.
No-one should underestimate the difficulties faced by the JAA in attempting to produce a single set of regulations for its 18 member states. Each national operator wishes to continue to operate as they had previously. The starting premise was the lowest common denominator of all the existing regulations.
Considerable progress has been made, although the lack of adequate aero-medical input is somewhat surprising. Most unbiased expert commentators would agree, however, that the latest JAA proposals represent a relaxing of regulation to the detriment of flight safety.
One of the conclusions of the November 1994 report of the European Transport Safety Council is that "...it is the case, however, that existing and proposed flight-duty-time regulations do not recognise sufficiently the scientific consensus and may be based more on economic and political considerations".
Should the current proposals be introduced, then they must be policed effectively throughout Europe and an in-depth review must be undertaken at the end of the first peak season, to enable required changes and improvements to be implemented before the subsequent season.
C L HODGKINSON
Source: Flight International
