submission - Independent Pilots Association

4. Sufficient advance notice of a flight assignment can provide a reserve pilor
u'ith a sleep opportuniry.
We believe that it is incumbent upon the Federal Aviation Administrarion (F.\A)
to include time-of-day as a factor in designin,e duty and rest limitations. A substantial
body of resea¡ch and pilot reports shows that a decrease in performance frequently occurs
during "back-side-of-the-clock" operations due to circadian factors. To address this
issue, our proposal provides for a reduction in the reserve availability period when
scheduled duty touches the 0200 -
"window of circadian low."
0ó00 time period, or what the scientists refer to as the
Our submission refers to several documents that have provided us with a
foundation of scientific support. Prominent among them is NASA Technical
Memorandum I 10404 , Principles and Guidelines for Dun' and Rest Scheduling in
Comntercial Aviation, (May 1996). This document, herein referred to as NASA Tlvf.
offers NASål:-spec_rlc recommendations on duty and rest Iimitations based on more rhan
20 years of extensive research into the cause and prevention of pilot fatigue. It is
attached hereto as Appendix A.
Another reference is An Overt'iew of the Scientific Literature Concernin7
Farigue, Sleep, and the Circadian Ct'cle, Battelle Memorial Institute Study (January
1998). This study, herein referred to as the Battelle Study, commissioned by the FAA's
Office of the Chief Scientific and Technical Advisor for Human Factors, provides an in-
depth revier"'of scientific research concernin-s sleep and fatigue. Drawing upon l6_5
scientific references. the Battelle Report identifies major trends in the scientific literature.
and has provided valuable information and conclusions. This study ìs attached as
Appendix B.