It would not surprise any flight operations staff or pilots to hear that flight time limitation (FTL) regulations are not perfect. There are almost as many variations in FTL rules as the number of countries in which such limitations exist. In some they do not exist at all.
FTLs are partly subjective. In the USA the maximum number of hours airline pilots may fly in a year is 1,000 – which is a suspiciously round number – but Europe’s limit is not far away at 900 flying hours a year, so there is a degree of consensus on what appears to work. In the USA over the last few years, however, there have been increasing numbers of accidents in which the National Transportation Safety Board (NTSB) has deemed pilot fatigue to have been a factor (see Headlines P6). This may be an increasing real problem, the result of growing NTSB awareness of fatigue’s effects, or both.
Flight hour limits alone are not good enough today, however. When they were drawn up, the FTL maxima were just that – the limits. Not many pilots were expected to reach them. But things have changed, and the airlines – especially the low-cost carriers (LCC) – admit openly that the limits have become performance targets. There are certain aspects of the way LCCs operate that make it more feasible to aim safely for a flight time limit, one of which is the fact that the pilots are back at their home base every night, and able to sleep in their own beds, making their lives more “normal” than those enjoyed by flightcrew in other sectors like long-haul or charter. But is that assumption correct? What is a “normal” pilot’s life?
EasyJet got permission from the UK Civil Aviation Authority to check out whether its pilot roster, compliant with the authority’s FTL “bible”, CAP371, was actually the best option from the safety point of view, as well as in terms of getting the optimum number of flying hours out of its crew. The crew performance study funded by the airline, and overseen by the CAA, proved there was a better roster that achieved lower risks of crew error and at least equal efficiency – but it did not comply with the letter of the law according to CAP371. The CAA has allowed EasyJet to adopt the new roster, however. The study is continuing, and is expanding into areas not normally considered to be issues for FTL – like the effects of the environment a pilot lives in, the airport he is based at, and what “life stage” he has reached. This sounds highly ambitious and might lead, potentially, to more complex FTL rules or guidelines. But who is to say the CAA should not go there? Just as a departure from the official rules led to lower human factors risks at EasyJet without lessening crew productivity, perhaps there are benefits to be had from admitting that unavoidable “hassle factors” crews face in their everyday lives will affect their performance in the cockpit. Pleased with the results of the EasyJet study, the CAA is now going to see if it can work with overnight package carrier DHL to find out if the magic combination of lower risk and higher productivity is available at its UK operation.
EasyJet’s safety and security director Capt Peter Griffiths describes the nature of the exercise with clarity: “If you are pushing your assets to the limit of what you can get them to do, what you want to know is: where is the boundary?” Ryanair is just as aware as EasyJet that “pushing your assets to the limit” is the name of the LCC game, but the management there is not as analytical in establishing what Griffiths calls “the boundary”. Neither is the Irish Aviation Authority (IAA). The airline uses off-the-peg European FTLs; it arranged for three independent specialists to review them in the light of Ryanair’s roster and work pattern – which produced favourable reactions – and has assumed that Ryanair’s “boundary” has thus been established. The IAA says it is satisfied with that, and who is to question it? It is certainly good practice, but is it best practice?
These two carriers – Europe’s largest LCCs – have much in common. They both have first-class pilot selection and training systems and first-class maintenance. They are both ruthlessly efficient people-moving machines that are constantly pushing the boundaries in every way. But in a safety-sensitive industry, if you push the limits you have to be very sure of exactly what they are, not just put all the ticks in all the boxes.
In the end the safety issues boil down to human factors, and that is influenced by more than good training, regular written directives to crews, and discipline.
Source: Flight International
