submission - Independent Pilots Association

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Another reference is A Scientific Review of Proposed Regulations Regarding
Flight Cre*'member Dun, Period Limitations, Docket #28081, The Flight Duty
Regulation scientific Study Group. This study \\'as sponsored by the Independenr pilots
Association to provide a scientific review of NPRM 95- 18. It is refened to as the
Scientific Srudy Group and is attached as Appendix C.
The pilots met with sleep expert, Dr. William Dement, Director of Sleep Research
and Clinical Programs at Stanford University. The transcript of that meeting appears in
Appendix D.
We have attached an article titled Fatigue, Alcohol, and Performance Impairment
that summarizes a study conducted by The Centre for Sleep Research at the eueen
Elizabeth Hospital in South Australia in Appendix E. This study quantifies the
performance impairment associated with sustained wakefulness in terms of equivalent
percent blood alcohol impairment. A subsequent study, titled, Quantifuing the
-Performance Impairment associated *'ith Sustained Wakefulness, by l-amond and
Dawson replicates this study and extends the initial findings. It is attached as Appendix
F.
The NTSB requested that the FAA conducr an expedited review of the FARs after
pilot fatigue and continuous hours of wakefulness were found to be key findings in the
crash of a DC-8 at Guantanamo Bay, Cuba in 1993. A NASAAITSB report titled Cr¿¡.
futiguefaclors i,t the Guantanatno Bat'aviation accident is attached as Appendix G.
Sereral airlines have switched to reserve pilot schemes very similar to the one we
propose. These carriers include Continental Airlines, UPS. America Wesr. Alaska
Airlines. and British Airways. The reserve pilots at these airlines have protected time
periods of 8 ro l2 hours with reserve availabilitv periods of 1,4 to lg hours.