submission - Independent Pilots Association

(c) A certificate holder may assign a flight crewmember and a flight
crewmember ma! accept an assignment for flight time in scheduled air
transportation or other commercial tlying if such assignment is
permitted by this subpart;
If the assignment ß scheduled to be completed within 16 hours
afrer the end of the preceding Protected Time Period;
Availability Period Limitation
Continuous Hours of Wakefulness/'Duty Can Affect Alertness and
Performance - Extended wakefulness and prolonged periods of continuous.
performance or vigilance will engender sleepiness and fatigue.
Extended flight duty period - An extended flight duty period should be limited
to l2 hours within a 24-hour period to be accompanied by additional restrictions
and compensatory off-duty periods. This limit is based on scientific findings
from a variety of sources, including data from aviation, that demonstrate a
significant increased vulnerability to performance-impairing fatigue after 12
hours. It is readily acknowledged that in current practice, flight duty periods
extend to l4 hours in regular operations. However, the available scientific data
support a guideline different from current operational practice. The data indicate
that performance-impairing fatigue does increase beyond the l2-hour limit and
could reduce the safety margin.
NASA TM, qq 1.4,2.3.4, pp.4,6.
NASA does not provide a specific recommendation for the duration of a Reserve
Availability Period. However, it follows that NASA's recommended maximum duty limit
of l2 hours plus 2 hours for operational delays (total - 14 hours) obviously requires a
pilot to be awake at least that much time. By adding report time to NASA's
recommended maximum duty limit. it is apparent that NASA's duty limir is
commensurate with our proposed I Ghour reserve availability period limit for unaugmented
flying.
The results of an NTSB analysis of domestic air carrier accidents occurring from
1978 to 1990 suggest that time since awake (TSA) was rhe dominanr fatiguerelated
factor in these accidents (NTSB, 1994). Performance decrements of hi-eh
time-since-awake crews tended to result from ineffective decision-making rather
than deterioration of aircraft handlin-s skills. . . . There did appear to be two peaks
in accidents: in the morning when time since aw'ake is low and the crew has been
on duty for about three to four hours, and rvhen time-since-awake s as high, above
l3 hours. Similar accident peaks in other modes of transportation and industry
have also been reported (Folkard.l99l). Akerstedt & Kecklund (1989) studied
pnor time awake (four to l2 hours) and found a strong conelation of accidents
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