Leading Newspaper Blasts Indian DGCA
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Leading Newspaper Blasts Indian DGCA
The following article appeared in The Hindu - arguably India's best and most respectable newspaper.
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A. Ranganathan
Charles Darwin said: “Ignorance more frequently begets confidence than does knowledge”. On May 29, 2008, vide a circular DG/Air Safety 2008, the Director-General of Civil Aviation, who is supposed to be the guardian of flight safety, undid all that a well-thought-out and well-formulated regulation on Flight and Duty Time Limit (FDTL) for pilots issued in August 2007. The Civil Aviation Regulation on FDTL was the culmination of an extensive study carried out by the Joint Director-General of Civil Aviation with his team. The study involved experts from aviation medicine and scientific studies conducted by various aviation safety agencies worldwide.
Indian aviation is suffering from the Dunning-Kruger effect, which is the phenomenon where people with little knowledge (or skill) tend to think they know more than they do. In a series of experiments performed by Justin Kruger and David Dunning of Cornell University, they found that:
— Incompetent individuals tend to overestimate their own level of skill.
— Incompetent individuals fail to recognise genuine skill in others.
— Incompetent individuals fail to recognise the extremity of their inadequacy.
The Committee on Flight Time Limitations in the United Kingdom provides a useful differentiation of tiredness from fatigue; this underpins how fatigue is understood in this report: “Tiredness resulting from physical or mental effort is a normal experience. Whilst tiredness may develop into fatigue, it differs from it in that a tired person can be quickly aroused to a high level of performance. We have come to consider fatigue as a markedly reduced ability to carry out a task. It is a condition of reduced performance from which there is no certainty that a person can be aroused in an emergency, even when considerable stimulus is present.”
Matter of competence
Take the way the Reserve Bank of India functions. Its policies are not dictated by the Finance Ministry, whose decisions veer more towards vote-bank politics. If the RBI were to follow the performance of the DGCA, the economy would collapse. But the DGCA, a mere puppet in the hands of the Ministry officials, carries out misplaced orders without any thought or reasoning. The first paragraph in the circular describes the way the DGCA functions:
“The competent authority in the Ministry of Civil Aviation has decided to keep the Civil Aviation Regulation CAR 7, Section 7, Flight Crew Standards, Series ‘J’, Part III dated July 27, 2007 in abeyance”
Is there anyone competent in the Ministry who can do better than what has been compiled from scientific studies? And, if the DGCA is not competent enough to oversee safety, why has the Ministry given him two extensions of terms? And this was with the falsehood that the ICAO safety audit has rated safety standards in India as among the best in the world!
The real truth came out when the ICAO audit report was covered in an article in The Wall Street Journal, where it was reported that the Indian safety and training standards were well below the average. Do we need a puppet who signs on a dotted line?
SERIOUS IMPLICATIONS
The implications of the latest order of the DGCA are very serious. The lives of all the air travellers and people who live in the vicinity of airports are in danger. When the CAR was issued in 2007, all the earlier circulars and regulations on FDTL were cancelled. The present order does not indicate what the airline operators and pilots need to follow. It is a free-for-all and the consequences are dangerous.
On May 30, thanks to the media, everyone witnessed the effect of fatigue on the Minister of Defence, who collapsed during the passing out parade at NDA, Pune. He was feeling the effect of a hectic schedule during his trip to Germany and had had very little rest! The Minister, luckily, did not have the lives of over 400 people in his hands.
The pilot of an aircraft does not have the luxury of a team of doctors and personnel of the armed forces to rescue him immediately. Fatigue is a silent killer and has been found to be a major contributor to fatal air accidents. The FDTL circular, which has been kept in abeyance by the “competent authority” in the Ministry, had plugged many loop-holes in the earlier circulars. A few individuals, in their capacity of senior management pilots, misused the rules to satisfy their greed.
The two glaring examples were the following: the Deputy Director of Operations in Air India, travelled as a passenger on board the Mumbai-Franfurt flight which was of almost 11 hours duration. He had arrived at the airport more than an hour earlier than the departure, and he would have woken up at least a couple of hours earlier.
After this long duty period as a “staff on duty” he operated the Frankfurt-New York sector on the same aircraft. This super human being was awake for more than 24 hours while at the controls of a jumbo jet with 450 passengers. It was fortunate that nothing untoward happened.
The head of training of Indian airlines operated an early morning Delhi-Goa-Cochin- Bangalore flight, landing at Bangalore at around 11 a.m. He then went as a “staff on duty” to Hyderabad, one more hour’s travel. He proceeded straight to the simulator and did four hours of training and went to bed past 10 p.m. He carried out another four-hour simulator session from 6 a.m., proceeded to Bangalore as a “staff on duty’, and operated the return flight to Delhi via Cochin and Goa.
This kind of enthusiasm is not due to commitment to work but because such staff are paid for every hour of duty, whether operating a flight, or travelling as a ‘SOD’ or doing a simulator training. Their pay cheque is several times what a normal pilot earned.
This blatant misuse was covered in the 2007 circular and this resulted in a drastic reduction in unscrupulous earnings of a few individuals. Apart from jeopardising safety of passengers, these individuals affected the quality of training imparted, as they just went through the motions of training when they were actually fatigued. The National Transportation Safety Board of the US, in its study on effects of fatigue, concluded that the performance level and reaction times reduced drastically as “time since awake’ went beyond 12 hours.
Narrow escapes
Two recent accidents highlight this fact. The Air France A-340 accident at Toronto resulted in the aircraft being destroyed by fire. Fortunately, all the 300 odd passengers had a miraculous escape.
The investigation report concluded that one of the reason for the overrun was a “seventeen-second” delay in the deployment of thrust reversers. The captain had been up from early in the morning, drove three hours to Paris airport to reach a couple of hours before an 8-hour flight, during which the accident took place.
In the Southwest Airlines accident at Midway, Chicago, US, the overrun was the result of a “Twelve Second” delay in deployment of thrust reversers.
If one is fatigued, it takes less than 20 seconds to make a difference between a safe flight and an accident. The FDTL circular issued in 2007 was an excellent one and one of the best in safety standards. It is unfortunate that we have incompetent people running such an important agency like the DGCA who are manipulated by an equally incompetent team from the Ministry of Civil Aviation. The monsoon has already set in. The last year saw more than nine overrun accidents in India in wet conditions.
The world has seen a major accident in the months of July-August, during the last four years — the AF A340 accident in Toronto in August 2005, Sibir airlines A-310 accident in Irkutz, Russia in July 2006, and the TAM airlines A 320 accident in Sao Paulo, Brazil in 2007.
The Americas and Europe are covered. The year 2008 may be the turn of Asia, and the way civil aviation is heading in India, it may be our turn to witness a major accident.
(The author is an airline captain with 35 years flying experience.)
-----------------------------------------------------------------
A. Ranganathan
Charles Darwin said: “Ignorance more frequently begets confidence than does knowledge”. On May 29, 2008, vide a circular DG/Air Safety 2008, the Director-General of Civil Aviation, who is supposed to be the guardian of flight safety, undid all that a well-thought-out and well-formulated regulation on Flight and Duty Time Limit (FDTL) for pilots issued in August 2007. The Civil Aviation Regulation on FDTL was the culmination of an extensive study carried out by the Joint Director-General of Civil Aviation with his team. The study involved experts from aviation medicine and scientific studies conducted by various aviation safety agencies worldwide.
Indian aviation is suffering from the Dunning-Kruger effect, which is the phenomenon where people with little knowledge (or skill) tend to think they know more than they do. In a series of experiments performed by Justin Kruger and David Dunning of Cornell University, they found that:
— Incompetent individuals tend to overestimate their own level of skill.
— Incompetent individuals fail to recognise genuine skill in others.
— Incompetent individuals fail to recognise the extremity of their inadequacy.
The Committee on Flight Time Limitations in the United Kingdom provides a useful differentiation of tiredness from fatigue; this underpins how fatigue is understood in this report: “Tiredness resulting from physical or mental effort is a normal experience. Whilst tiredness may develop into fatigue, it differs from it in that a tired person can be quickly aroused to a high level of performance. We have come to consider fatigue as a markedly reduced ability to carry out a task. It is a condition of reduced performance from which there is no certainty that a person can be aroused in an emergency, even when considerable stimulus is present.”
Matter of competence
Take the way the Reserve Bank of India functions. Its policies are not dictated by the Finance Ministry, whose decisions veer more towards vote-bank politics. If the RBI were to follow the performance of the DGCA, the economy would collapse. But the DGCA, a mere puppet in the hands of the Ministry officials, carries out misplaced orders without any thought or reasoning. The first paragraph in the circular describes the way the DGCA functions:
“The competent authority in the Ministry of Civil Aviation has decided to keep the Civil Aviation Regulation CAR 7, Section 7, Flight Crew Standards, Series ‘J’, Part III dated July 27, 2007 in abeyance”
Is there anyone competent in the Ministry who can do better than what has been compiled from scientific studies? And, if the DGCA is not competent enough to oversee safety, why has the Ministry given him two extensions of terms? And this was with the falsehood that the ICAO safety audit has rated safety standards in India as among the best in the world!
The real truth came out when the ICAO audit report was covered in an article in The Wall Street Journal, where it was reported that the Indian safety and training standards were well below the average. Do we need a puppet who signs on a dotted line?
SERIOUS IMPLICATIONS
The implications of the latest order of the DGCA are very serious. The lives of all the air travellers and people who live in the vicinity of airports are in danger. When the CAR was issued in 2007, all the earlier circulars and regulations on FDTL were cancelled. The present order does not indicate what the airline operators and pilots need to follow. It is a free-for-all and the consequences are dangerous.
On May 30, thanks to the media, everyone witnessed the effect of fatigue on the Minister of Defence, who collapsed during the passing out parade at NDA, Pune. He was feeling the effect of a hectic schedule during his trip to Germany and had had very little rest! The Minister, luckily, did not have the lives of over 400 people in his hands.
The pilot of an aircraft does not have the luxury of a team of doctors and personnel of the armed forces to rescue him immediately. Fatigue is a silent killer and has been found to be a major contributor to fatal air accidents. The FDTL circular, which has been kept in abeyance by the “competent authority” in the Ministry, had plugged many loop-holes in the earlier circulars. A few individuals, in their capacity of senior management pilots, misused the rules to satisfy their greed.
The two glaring examples were the following: the Deputy Director of Operations in Air India, travelled as a passenger on board the Mumbai-Franfurt flight which was of almost 11 hours duration. He had arrived at the airport more than an hour earlier than the departure, and he would have woken up at least a couple of hours earlier.
After this long duty period as a “staff on duty” he operated the Frankfurt-New York sector on the same aircraft. This super human being was awake for more than 24 hours while at the controls of a jumbo jet with 450 passengers. It was fortunate that nothing untoward happened.
The head of training of Indian airlines operated an early morning Delhi-Goa-Cochin- Bangalore flight, landing at Bangalore at around 11 a.m. He then went as a “staff on duty” to Hyderabad, one more hour’s travel. He proceeded straight to the simulator and did four hours of training and went to bed past 10 p.m. He carried out another four-hour simulator session from 6 a.m., proceeded to Bangalore as a “staff on duty’, and operated the return flight to Delhi via Cochin and Goa.
This kind of enthusiasm is not due to commitment to work but because such staff are paid for every hour of duty, whether operating a flight, or travelling as a ‘SOD’ or doing a simulator training. Their pay cheque is several times what a normal pilot earned.
This blatant misuse was covered in the 2007 circular and this resulted in a drastic reduction in unscrupulous earnings of a few individuals. Apart from jeopardising safety of passengers, these individuals affected the quality of training imparted, as they just went through the motions of training when they were actually fatigued. The National Transportation Safety Board of the US, in its study on effects of fatigue, concluded that the performance level and reaction times reduced drastically as “time since awake’ went beyond 12 hours.
Narrow escapes
Two recent accidents highlight this fact. The Air France A-340 accident at Toronto resulted in the aircraft being destroyed by fire. Fortunately, all the 300 odd passengers had a miraculous escape.
The investigation report concluded that one of the reason for the overrun was a “seventeen-second” delay in the deployment of thrust reversers. The captain had been up from early in the morning, drove three hours to Paris airport to reach a couple of hours before an 8-hour flight, during which the accident took place.
In the Southwest Airlines accident at Midway, Chicago, US, the overrun was the result of a “Twelve Second” delay in deployment of thrust reversers.
If one is fatigued, it takes less than 20 seconds to make a difference between a safe flight and an accident. The FDTL circular issued in 2007 was an excellent one and one of the best in safety standards. It is unfortunate that we have incompetent people running such an important agency like the DGCA who are manipulated by an equally incompetent team from the Ministry of Civil Aviation. The monsoon has already set in. The last year saw more than nine overrun accidents in India in wet conditions.
The world has seen a major accident in the months of July-August, during the last four years — the AF A340 accident in Toronto in August 2005, Sibir airlines A-310 accident in Irkutz, Russia in July 2006, and the TAM airlines A 320 accident in Sao Paulo, Brazil in 2007.
The Americas and Europe are covered. The year 2008 may be the turn of Asia, and the way civil aviation is heading in India, it may be our turn to witness a major accident.
(The author is an airline captain with 35 years flying experience.)
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The author may be a pilot with over 35 years of experience and he is undeniably a skillful writer, but the fact is that the recently scrapped FDTL was one of the most useless pieces of regulation to ever be promulgated.
Just as an example, one of its many features made it possible to continue in whichever direction you started out (E or W) with 20 hours rest between sectors for just about as long as you wanted to. Turning around and returning from whence you came, however, required a ground stop of up to 3-4 days. It took a rare brand of idiocy to create a regulation that actually promoted greater time zone dislocations, but the DGCA managed to do it.
Calling it a "a well-thought-out and well-formulated regulation" is an absolute joke. What it was was one of the most incredible attempts at feather-bedding to ever see the light of day.
India does desperately need a well structured FDTL for all sorts of reasons including the prevention of egregious abuses such as those cited. What it doesn't need, though, is a manipulative recitation of accidents by an author who surely knows better.
The Transportation Safety Board of Canada in investigating the Air France over-run found:
The NTSB investigating the Southwest over-run found:
Hopefully the DGCA will get it right the next time around and provide a regulation that is both safe and rational.
ELAC
Just as an example, one of its many features made it possible to continue in whichever direction you started out (E or W) with 20 hours rest between sectors for just about as long as you wanted to. Turning around and returning from whence you came, however, required a ground stop of up to 3-4 days. It took a rare brand of idiocy to create a regulation that actually promoted greater time zone dislocations, but the DGCA managed to do it.
Calling it a "a well-thought-out and well-formulated regulation" is an absolute joke. What it was was one of the most incredible attempts at feather-bedding to ever see the light of day.
India does desperately need a well structured FDTL for all sorts of reasons including the prevention of egregious abuses such as those cited. What it doesn't need, though, is a manipulative recitation of accidents by an author who surely knows better.
The Transportation Safety Board of Canada in investigating the Air France over-run found:
3.3 Other Findings
There is no indication that the captain's medical condition or fatigue played a role in this occurrence.
There is no indication that the captain's medical condition or fatigue played a role in this occurrence.
2. Analysis
2.1 General
The pilots were properly certificated and qualified under Federal regulations.
No evidence indicated any medical or behavioral conditions that might have adversely affected their performance during the accident flight. There was no evidence of flight crew fatigue.
2.1 General
The pilots were properly certificated and qualified under Federal regulations.
No evidence indicated any medical or behavioral conditions that might have adversely affected their performance during the accident flight. There was no evidence of flight crew fatigue.
ELAC
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Indian FDTLs
Whatever the motivation for DGCAs recent decisions regarding FDTLs, in the final analysis the problem ends up, as always, in the front left hand seat. Individual commanders must decide for themselves how best to handle the matter. My decision has been to bale out.
I would like to think that this decision was due to high minded principle, but it was actually just plain selfishness. The current situation will provoke an incident sooner or later, but my command will not be involved, because I will be elsewhere.
I have always believed that over-regulation is a BAD THING – still do, in fact. However, it has been clearly demonstrated to me that a situation where rules can easily be manipulated, where safety can be set aside in the interest of expediency, is far worse. Over-regulation beats being asked, on a daily basis, to operate in an unsafe manner.
I would like to think that this decision was due to high minded principle, but it was actually just plain selfishness. The current situation will provoke an incident sooner or later, but my command will not be involved, because I will be elsewhere.
I have always believed that over-regulation is a BAD THING – still do, in fact. However, it has been clearly demonstrated to me that a situation where rules can easily be manipulated, where safety can be set aside in the interest of expediency, is far worse. Over-regulation beats being asked, on a daily basis, to operate in an unsafe manner.
