submission - Independent Pilots Association

. . . It is importanr to realize that an individual working nights is at risk for
signifrcanr sleepiness for two distinct reasons: . . . an individual working
successive nighrs is forced to obtain sleep during the daylight hours at a time
when rhe circadian pre-disposition to sleep is minimal. . . . As mentioned, sleep
under these circumstances is r¡rpically fragrnented, sleep state architecture is
distorted, and the restorative nature of sleep - . . is reduced.
A Scientific Revie*'of Proposed Regulations Regarding Flight Crewmember Dunn period
Limitarions. The Flight Duty Regulation Scientific Study Group,12.6,p.5-6.
Minimum rest periods should be adþsted upward for sleep periods that include
tbe tin¡e of peak circadian alertness (4 - 6 PM.)-
efFrcienc-v of sleep during that time. (Errphasis added.)
Scientif,rc Study Group, tI 5.1 .2, 5.1-4, P- I l.
Remarks of Dr. Dement:
e: . - . One of the rmst basic tasks is for us to agree on a recolnrnendation for a sleep
opportunity . . . to afford every reserve pilot the opportunity of a protected tirne
period so that he or she is absolutely insulated from contact from the operuor.
How many hours do you recomrnend for a minimum fixed sleep opportunity?
A: I will start our by assuming that we would take 8 hours of sleep as the rnost
corffnon requiremenr. Then you need to add to that in order to be able to get the
proper arnounr of sleep. In y.our situation, I would think it w'ould be a little lar-ger
rhan ir might be for sorneone who really wasn't doing anything. So. I'd add a
couple of hours to -qet the proper alîount of sleep.
Appendix D.p.4.
Q: Dr. Derr¡ent, . . . we're really at the point now where we're going beyond the
philosophy and we're trying to put our finger on nurneric values. Our position at
least from the pilots' standpoint, is that we see the need for a lGhour sleep
opportunity knowing that ttle opportunity may not always be at the best time of
the day. We're facing an industry position that is Iooking for 8 hours as the
minimurn Our position is predicated on ttre fact that 8 hours may be adequate if it
overlaps the WOCL. But since we don't know for sure when we're going to have
that opportunity. we believe that, or we think that having that extra 2 hours is
going to give us a little more of a buffer, especially when it cornes during the
daytime. Would you consider that to be a conservative and a justified position?
A: Absolutely. I don't think you could possibly assulne solneone is going to fall
asleep instantly and then sleep continuously for 8 hours, not even under the most
ideal circumstances. Maybe it should be longer.
Appendix D, pp. 5-6.
t7