submission - Independent Pilots Association

ARAC Reserve Duty' Worbng Group Indusrry/lvlanagemenr Repon ( l/15/99)
uled operations. At least scveral
despiæ the lack of an overall
It was also generally agreed by the industry/management group that the Part l2l, scheduled
reseryc relt ProPosat should not apply !o Fhrt 135 operations for many of the same
Feaso¡Ls..Tw-o proposals werc submitted for Pa¡t 135 operations, one by the Helicopter
Association Inærnati_onal (Attachment 3) and onc fq Part 1.35, non-schéduled opera-tions
by tbc National Air Tranportation Association and tbe National Business Aircrafì
Assæiation (Anachment 4).
Natiooal Business Aviation Association, and
the members of these organizations.
IndustrJr/-lVlsnagerrent Resgonses to SDeciñc Tssks
Task 1: Review of current scientific dat¡ on the eflects of fatigue in
reserve duty. Coneider conflicting opinions.
The l¡¡s public meeting included an extensive disc¡rssion of the relevant scientific literai,rrc,
and whether any new data pertaining to this issue h¡d emerged since the issuance of NIRM
9418. It was generally agreed that there wer€ no signifrcant new scientific studies relevant
to the rcsewe duty question published since that time.
It was frequently pointed out by the indrstry/management group that there bave been no
known accidents where the probable cause was deemed to be pilot fatigue associated with
reserve duty assiguments. In the minds of many RDWG members, this was relevant to the
question of whether changes to the existing rules should be a regulatory priority.
Extensive discr¡ssions ensued th¡t illusuated the fact that the scientifrc literature pertaining
to this issue can be inærpreted in a variety of ways. As a result, many different and
sometimes inconsistent conch¡sions can be d¡awn, and thus, there a¡e no clear ansìyers
from the body of scientific liæran¡re ^s to appropriaæ rcgulatory policy
The RDtl/G did agree that there are two very broad scientific principles specifically rclevant
to res€rye duty. Frnt, it was agred that humans generally need the oppo(uniry to acquire
approximately 8 hours of sleep per V+ hour period Second, it was agreed that fatigueis
more probable during the period of time encompassing approximately 02OO to 060, whicb
rougbly corresponds to the low point in an "averaç" (across the population) human
circadian cycle.
However, it was also noted that the scientific literarure demonstrates that humans, in
general and piloa in particular, arc highly variable in their slecp habits, lifestyles, and
circadian cycles. This phenomenon poses significant a¡d diffic¡¡lt complications for FAA
rcgulatory policy on flight and duty time. An appropriate rest opportunity (no matter how
long) cannot guarantec that a particular res€rve pila will obtain appropriate sleep. In
addition, because of the high degree of variability in individual sleep habits and lifestyles, it
is difficult to know the natu¡e and timing of a paìticula¡ individual's circadian cycle. For
example, since a large percentage of pilos commute across multiple time-zones to both
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