submission - Independent Pilots Association

' (c) A certiftcau holder may assign aflight crewmember and aflight
crewmemba may accept an assignmenlfortlight time in scheduled air
transportotion or other commetcialtlying if such assignment k
permitted fo this subpan;
(l) If úc øssignnent is scheduled to be compl¿ted within 16 houn
afta the end of the preceding Protected Time Period;
Scientific support:
(c) l6 hour Reserve Availability Period Limitation
Continuous Hor¡¡s of Wakefulness/Iluty Ca¡ Afiect AleÉness rnd
Perforurance - Encnded wakefulness and prolonged perbds of continuous
performance or vigilance will engender sleepiness and fatigue.
Extended flight dutv period -
An extended flight duty perircd should be limited
to l2 hours within a 24-hour period to be accompanied by additional restrictions
and compensatory off-dur¡* periods. This limit is based on scientific findings
from a variety of sources, including data from aviation, that dermnstrate a
significant incre¡ccd vr¡lnerability to performance-impairing fatigue af¡er 12
hours. It is readill'æknowþdged that in current practice, flight duty periods
extend to l4 hours m regular operations. However, the available scientific data
support a guidelim different from current operational practice. The data indicate
that performance-impairing fatigue does increase beyond the l2-hour limit and
could reduce the sr-ety margin.
NASA TM,ll 1.4,2.3.1. ¡p 4. 6
NASA does not provide a saeciflc recorrrmendation for the duration of a Reserve
Availability Period. Houerer, it follows that NASA'S recomrnended maximum duty limit
of l2 hours plus 2 hours t'oroperarional delays (total - l4 hours)obviouslyrequires a
pilot to be awake æ least rhet much time. By adding report tinp to NASA's
recofiunended maximum 'ùrty limit, it is apparent that NASA's duty lim¡t is
cornrnensurate with our proposed l6-hour reserve availability period lim¡t for unaugrnented
flying.
The results of an \TSB analysis of dornestic air ca¡rier accidents occurring from
1978 to 1990 suggst that time since awake (TSA) was the dominant fatiguerelated
factor rn tlrse accidents (NTSB, 1994). Perforrnance decrements of high
time-since-awake crews tended to result from ineffective decision-making rather
than deterioration oi ai¡craft handling skills. . . . There did appear to be two peaks
in accidents: in ¡he morning when time since awake is low and the crew has been
on duty for about tbree to four hours, and when time-since-awake was high, above
l3 hours. Simila¡ æcident peaks in other modes of transportuion and industry
have also been reported (Folkar4 1997). Akerstedt & Kecklund (1989) studied
prior time awake tfour to l2 hours) and found a strong conelation of accidents
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