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FEATURE
of passenger and crew safety for airlines to
use an FAA-approved fatigue mitigation
program to reduce the risk of pilot fatigue.
2001 ATA/RAA Request
The FAA denied requests made on
June 12, 2001 on behalf of the Air Trans-
port Association (ATA) and Regional
Airline Association (RAA) to stay all
agency action regarding the November
20, 2000 Whitlow letter of interpretation
and the May 17, 2001 Federal Register
notice of the FAA’s enforcement policy
regarding pilot flight time and rest. The
FAA’s letter and Federal Register notice
were consistent with the agency’s long-
standing interpretation of the current
rules. The documents were consistent
with the statutory mandate to issue rules
governing the maximum hours or periods
of service, the use of plain language in
regulations and the regulatory history of
Fatigue ARC
the rules. ATA subsequently petitioned
natives; perspectives from aviation indus- for review of the Whitlow letter and the
On June 24, Administrator Babbitt an- try experts and scientists on fatigue man- enforcement policy.
nounced that the FAA would undertake agement; and information on the latest On Sept. 5, 2001 the U.S. Court of Ap-
an expedited review of flight and rest fatigue mitigation initiatives and best peals for the District of Columbia granted
rules. This followed Administrator Bab- practices. a motion by the ATA to stay the May 17,
bitt and U.S. Secretary of Transportation 2001 Federal Register notice. On May 31,
Ray LaHood’s June 15 meeting with air-
Ultra Long-Range Flights
2002, the court denied ATA’s petition for
line safety executives and pilot unions to In 2006, the FAA worked with Delta review, ruling in favor of the FAA.
strategize on how to best reduce risk at re- Air Lines to develop and approve fatigue
gional airlines. The FAA chartered an mitigation for flights between John F.
2001 Federal Register Notice
Aviation Rulemaking Committee (ARC), Kennedy International Airport and Mum- An FAA in the May 17, 2001 Federal
which began work in July. The ARC, bai, India. The flights were operated for Register reiterated the agency’s long-
which consisted of representatives from more than 16 hours with four pilots pro- standing interpretation of pilot flight time
FAA, industry, and labor organizations, vided that the airline followed an FAA- and rest rules. The notice informed air-
was charged with producing recommen- approved plan to manage rest and mitigate lines and flight crews of the FAA’s intent
dations for a science-based approach to the risk posed by fatigue. The mitigation, to enforce its rules in accordance with the
fatigue management by September 1. The approved as an Operations Specification Whitlow letter. Each flight crewmember
ARC met their deadline and provided the issued to Delta Air Lines, was specific for must have a minimum of eight hours of
FAA with a broad framework for drafting that city pair. Although that specific route rest in any 24-hour period that includes
the basis for a Notice of Proposed Rule- is no longer flown by Delta, the FAA flight time. That calculation must be based
making (NPRM). viewed Delta’s fatigue mitigation strategy on the actual conditions on the day of de-
as a model program. parture regardless of whether the length
2008 FAA Fatigue Symposium
As a result of Delta’s efforts, the FAA of the flight is longer or shorter than the
In June 2008, the FAA sponsored the proposed in November 2008 to amend originally scheduled flight time. The FAA
Fatigue Symposium: Partnerships for So- Delta’s, American’s, and Continental’s Op- did not anticipate that the notice would re-
lutions to encourage the aviation commu- erations Specifications to incorporate fa- sult in major disruptions to airline sched-
nity to proactively address aviation fatigue tigue mitigation plans for their ultra ules. Beginning November 2001, the FAA
management issues. Participants included long-range flights. Based on comments re- would review airline flight scheduling
the National Transportation Safety Board, ceived from the three air carriers, the FAA practices and deal stringently violations.
the Institutes for Behavior Resources, Inc., withdrew the proposed amendments on The U.S. Court of Appeals for the District
and many of the world’s leading authori- March 12, 2009. The FAA is currently of Columbia granted a stay of the notice.
ties on sleep and human performance. The working with airlines to gather data that
symposium provided attendees with the will help the agency enhance the safety re-
2000 FAA Letter
most current information on fatigue phys- quirements for ultra long-range flights. The On November 20, 2000, the FAA re-
iology, management, and mitigation alter- agency believes that it is in the best interest sponded to a letter from the Allied Pilots
22 ROTORCRAFT PROFESSIONAL • Heli-Expo 2010 Preview Issue
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