Just came across this on flightglobal.com. Apparently EASA has done a research in FTL and fatique in order to revise the current FTLs. If implemented as recommended the airlines estimate they must hire 15-20% more pilots. Below you can find the conclusion. The whole report can be found on
Flight time limitation: pilots cheer, airlines howl
Conclusions
This review has addressed a number of questions on different topics that all involvedaspects of flight time limitation associated with potential effects on fatigue and safety. Ourresponses are based on the available scientific knowledge which, briefly, finds that fatigueis increased by extended time awake, reduced prior sleep, the window of circadian low, andtask load, and that these effects are modified by changes of time zones and rest provisions.
Some of the present rules or proposed modifications of rules are in violation
with one or more of these factors. We have tried to indicate this and the consequences thereof. In particular, we see problems with:
· a large number of duty hours in a short time;
· long duty hours (which are not only directly fatigue inducing but which also
may interfere with rest periods);
· split duty (which creates similar problems to those of long duty periods);
· night duty (which combines duty at circadian low with extended waking and
suboptimal temporal position of rest periods);
· early start of duty (which negates the value of the prior rest period);
· rest periods given outside the window of circadian low (which reduces the
recuperative value);
· recovery time after time zone flights (that have induced shifts in the circadian
system);
· standby duty (which often is as fatigue inducing as actual duty);
· the recuperative value of rest facilities (bunk-seat-environment-standby).
A central idea in our responses has been to counteract the effects of a violation
immediately, and to ensure that combinations of violations are avoided. Several of thequestions presented cannot be answered in detail because of a lack of scientific evidence.
In these cases, we have only presented a general view and indicated the need foradditional research. Though the questions posed often require detailed and complicated
explanation we have, nevertheless, attempted to summarize our responses as follows:
· The permissible maximum of 180 duty hours in 3 consecutive weeks allows
for a high density of work hours in a short period of time and should be
limited through an additional provision for a maximum of 100 duty hours in
14 consecutive days (Q1);
· The maximum daily flight duty period (13/14 hours) exceeds reasonable limits
especially under exacerbating circumstances (e.g. high workload, night flying,
acclimatization) and should be reduced. Also, extensions to the maximum
FDP should not be permitted (Q2 & 3). Night duties need special provisions
and must not be combined with other sources of fatigue (Q4);
· In general, the same duty/rest rules should apply to cabin crew as to cockpit
crew – the fatigue of the former is often very high (Q5 & 13);
· Split duty often combines several sources of fatigue (early starts, long periods
of wakefulness, late bedtimes) and should be used only outside the WOCL and for a
maximum of 14 hours (start of first sub-duty to end of last sub-duty)
(Q6);
· Home base recovery days after time zone crossings should be provided
according to the number of time zones crossed and the duration of the layover
(see Table 1) (Q7);
· Reduced rest periods (<12 hours) should be avoided and, if used, be applied
Commercial in Confidence Page 40 of 47 FTL Study Final Report
within a FRMS, and then only if the entire WOCL is included in the rest
period (Q8);
· Permitting (as an exception) a FDP to start at 04:00h after a rest period would
negate the effect of the rest period and should be omitted from EU OPS (Q9);
· The format of rest periods should include a provision for “local night”, defined
as 10 hours between 22:00h and 10:00h to ensure proper rest. The length of
the rest period needed after a number of consecutive days on duty is not
possible to answer in a detailed way because of a lack of scientific data, but
the present provision of a weekly rest period after 168 hours of duty falls short
of reasonable requirements (Q10);
· To maintain alertness during extended FDP operations, augmented crews
should be allowed to take in-flight rest. The quality of on-board rest conditions
(e.g. bunk-economy seat) will determine the recuperative value of the rest
period and will be modified by acclimatization level (Table 2) (Q11 & 12);
· Airport standby time carries approximately the same fatigue load as work and
should count as FDP unless a FRMS is applied with proper rest facilities (14).
Standby time with proper rest facilities is still likely to involve reduced
recuperative value because of anticipatory stress influences (of imminent
duty), but the quantitative effects cannot be determined because of a lack of
scientific data (Q15 & 16);
· With respect to breaks there is a large body of research and regulation – a 20
minute meal break for each 6 hours of work may be a lower limit but for cabin
crew the physical load should raise this to 30 minutes for every 6 hours of
duty. To avoid dehydration problems, an additional 10 minute break should be
provided in each 3 hour period that does not contain a meal break (Q17);
· Permanent or a large number of successive night duties should not be exempt
from the present rules, since adaptation to night work probably does not occur.
However, data relating to aircrew are limited