Fatigue risk management
I work on the safety side and crew fatigue risk management has been sponsored largely by NTSB in the USA based on the its findings from various accident investigations over the years. Whilst in Australia last year, we had NTSB come over with a freighter pilot who had survived a nasty crunch at Guantanemo. Certainly, this accident event was due to fatigue and there is no doubt about that. However, the hours the flight crew had worked were extraordinary - but legal!! Problem is this: even if 40 or so hours rest periods are mandated between passenger revenue flights, this doesn't imply that the flight deck crew are 'rested.' There are many variable factors. Some pilots find it difficult to sleep given time-zones, hotels (noise and changes of environment), diet and so on. So an arbitrary 40 hour rest period may not be the panacea the FAA hopes it to be. Equally, it is interesting that the FAA perceives that long haul involves higher potential fatigue issues than short haul sector flights where the number of take-offs and landings are much higher in a tour of duty. The obvious stressor that contributes to fatigue is life on the domestic front!!