If a large number of airlines were to adopt fatigue risk management (FRM) systems as an alternative to flight-time limitation, national aviation authorities would not have the resources to carry out the necessary oversight, delegates at an International Civil Aviation Organization (ICAO) seminar heard.
Flight-time limitation (FTL) is a contentious subject, and the UK Civil Aviation Authority hosted an ICAO seminar at London Gatwick airport earlier this month to discuss the issues.
Speaking at the seminar, Nico Voorbach of the European Cockpit Association told the seminar that both FTL and FRM can be abused - and it is important that FTLs are based on science. Because FTL will be a benchmark against which to judge FRM, he said, it must err on the side of caution rather than stretch the limits. If FTLs err toward caution, he said, it will encourage airlines to adopt FRM.
But he suggested a slack FTL system will provide airlines with no incentive to move up to an FRM. "An FRM could backfire without a strong framework based on ICAO standards and recommended practices," Voorbach said. "It is still a young, untested concept - while pilot fatigue is a reality."
The US Federal Aviation Administration is revising FTL - a decision linked to the Colgan Air crash in Buffalo, New York state, in February 2009 - but Voorbach observed that it would look extraordinary if - as expected - the FAA reduces maximum duty periods for pilots, while Europe chooses higher flight times in its own revision.
European Aviation Safety Agency (EASA) licensing specialist Daniel Coutelier said Europe is moving to revise FTL because the present regulations - EU Ops Sub-part Q - "were negotiated rather than based on science", and only intended as a stop-gap measure.
He told the seminar that ICAO wants to ease the industry away from FTL and towards FRM, because FTLs are crude, one-size-fits-all regulations that cannot apply equally to intercontinental carriers and commuter operators. "Rules should allow operators to modify FTL appropriately for their operation," he said.
EASA concedes, however, that FTLs must continue to exist for those that want to use them and to provide a benchmark for FRM, even if a crude one.
ICAO FRM specialist Michelle Millar told airline delegates that if they want to move to FRM they must design an evidence-based rostering system that produces measurable beneficial results, before national authorities are permitted to approve it. However, both Millar and others on a seminar panel also held the view that there would be a resource problem if too many carriers tried to shift to FRM at once.
One fundamental change in FTL legislation is that all airlines are responsible for managing crew fatigue through their safety management systems - even without embracing FRM.
UK CAA FRM specialist Kathryn Jones explained that, even within FTLs, airlines "are ultimately responsible for ensuring safety and avoiding rostering patterns that would generate fatigue" - so compliance with FTLs may be no defence if fatigue is a causal factor in accidents.
FRM will deal with individual airline variables that FTL cannot take into account, she added.
Delta Air Lines' Capt Jim Mangie, who has been managing the US carrier's FRM system, said the scheme will not work unless airlines persuade pilots of the scientific validity behind FRM.
Speaking at the seminar, Capt Paul Naylor of the British Airline Pilots Association quoted Boeing safety guru Curt Graeber: "If your crews are intimidated by reporting fatigue, you do not have an FRM."