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RCP_0709_p08-15:Hangar Talk 8/13/09 4:22 PM Page 12
HANGAR TALK
The FAA is currently working with airlines to gather
data that will help the agency enhance the safety
requirements for ultra long-range flights. The agency
believes that it is in the best interest of passenger and
crew safety for airlines to use an FAA-approved fatigue
mitigation program to reduce the risk of pilot fatigue.
the FAA Administrator notified the avia- jor disruptions to airline schedules. It stated
tion community on June 15, 1999 that it that, beginning in November 2001, the
had six months to ensure that it was in full FAA would review airline flight schedul-
compliance with the agency’s current ing practices and deal stringently viola-
flight time and rest requirements. Reviews tions. The U.S. Court of Appeals for the
of airline scheduling practices conducted District of Columbia granted a stay of the
in December 1999 and discussions with notice on this focused enforcement effort.
pilot unions and airlines confirmed that the tion on fatigue physiology, management,
vast majority of pilots are receiving the
2001 ATA/RAA Request
and mitigation alternatives; perspectives
amount of rest required by the FAA’s rule. The FAA denied requests made on June from aviation industry experts and scien-
12, 2001 on behalf of the Air Transport As- tists on fatigue management; and infor-
2000 FAA letter
sociation (ATA) and Regional Airline As- mation on the latest fatigue mitigation
On November 20, 2000, the FAA re- sociation (RAA) to stay all agency action initiatives and best practices.
sponded to a letter from the Allied Pilots regarding the November 20, 2000 Whitlow
Association that set forth specific scenar- letter of interpretation and the May 17,
Ultra Long-Range Flights
ios that could affect a very small number 2001 Federal Register notice of the FAA’s In 2006, the FAA worked with Delta
of all commercial pilots. The FAA’s re- enforcement policy regarding pilot flight Air Lines to develop and approve fatigue
sponse, known as the “Whitlow Letter,” time and rest. The FAA’s letter and Fed- mitigation for flights between John F.
was consistent with the agency’s long- eral Register notice were consistent with Kennedy International Airport and Mum-
standing interpretation of the current rules. the agency’s long-standing interpretation bai, India. The flights were operated for
In summary, the FAA reiterated that each of the current rules. The documents were more than 16 hours with four pilots pro-
flight crewmember must have a minimum consistent with the statutory mandate to is- vided that the airline followed an FAA-
of eight hours of rest in any 24-hour pe- sue rules governing the maximum hours or approved plan to manage rest and mitigate
riod that includes flight time. The sched- periods of service, the use of plain lan- the risk posed by fatigue. The mitigation,
uled flight time must be calculated using guage in regulations and the regulatory his- approved as an Operations Specification
the actual conditions on the day of depar- tory of the rules. ATA subsequently issued to Delta Air Lines, was specific for
ture regardless of whether the length of petitioned for review of the Whitlow letter that city pair. Although that specific route
the flight is longer or shorter than the orig- and the enforcement policy. is no longer flown by Delta, the FAA
inally scheduled flight time. On Sept. 5, 2001 the U.S. Court of Ap- viewed Delta’s fatigue mitigation strategy
peals for the District of Columbia granted as a model program.
2001 Federal Register Notice
a motion by the ATA to stay the May 17, As a result of Delta’s efforts, the FAA
The FAA published a notice in the Fed- 2001 Federal Register notice. On May 31, proposed in November 2008 to amend
eral Register on May 17, 2001 to reiterate 2002, the court denied ATA’s petition for Delta, American, and Continental’s Op-
its long-standing interpretation of its pilot review, ruling in favor of the FAA. erations Specifications to incorporate fa-
flight time and rest rules. The notice in- tigue mitigation plans for their ultra
formed airlines and flight crewmembers of
2008 FAA Fatigue Symposium
long-range flights. Based on comments re-
the FAA’s intent to enforce its rules in ac- In June 2008, the FAA sponsored ceived from the three air carriers, the FAA
cordance with the Whitlow letter interpre- the Fatigue Symposium: Partnerships for withdrew the proposed amendments on
tation. Each flight crewmember must have Solutions to encourage the aviation com- March 12, 2009. The FAA is currently
a minimum of eight hours of rest in any munity to proactively address aviation fa- working with airlines to gather data that
24-hour period that includes flight time. tigue management issues. Participants will help the agency enhance the safety
That calculation must be based on the ac- included the National Transportation requirements for ultra long-range flights.
tual conditions on the day of departure re- Safety Board, the Institutes for Behavior The agency believes that it is in the best
gardless of whether the length of the flight Resources, Inc., and many of the world’s interest of passenger and crew safety for
is longer or shorter than the originally leading authorities on sleep and human airlines to use an FAA-approved fatigue
scheduled flight time. The FAA did not an- performance. The symposium provided mitigation program to reduce the risk of
ticipate that the notice would result in ma- attendees with the most current informa- pilot fatigue.

12 ROTORCRAFT PROFESSIONAL • July 2009
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