In June of this year, the NTSB revealed its “2011 Most Wanted List”—what the NTSB calls “the most critical changes needed to reduce transportation accidents and save lives.” As aviators and aviation businesses, this is an important list to keep an eye on because it typically gives us a glimpse of where we can expect to see tougher regulations in the future. One of these areas is human fatigue.
Unlike the other issues on the NTSB’s “top 10” list, human fatigue is a safety factor that crosses modes of transportation and affects the safety of the occupants of any vehicle. According to the NTSB, it has issued “more than 180 separate safety recommendations to address the problem of human fatigue in all modes of transportation.” Although the NTSB acknowledges that duty schedules are one mechanism for increasing the amount of sleep, it has determined that such things as “medical conditions, living environment, and personal choices” can adversely impact the quality of sleep.
To address this issue, the NTSB has concluded that more research must be done on how fatigue manifests itself so that tools can be developed which will reduce and eventually eliminate fatigue. The NTSB believes that these tools “must include science-based, data-driven hours-of-service limits, particularly for professional drivers, pilots, mechanics, and air traffic controllers.” Additionally, the NTSB wants to implement “medical oversight systems” to identify “sleep-related medical impairments and methods for identifying and treating individuals who are adversely affected by fatigue.
Notably, the NTS believes that employers should: “(1) establish science-based fatigue management systems that involve all parties (employees, management, interest groups) in developing environments to help identify the factors that cause fatigue, and (2) monitor operations to detect the presence of fatigue before it becomes a problem” and, (4) “allow individuals to acknowledge fatigue without jeopardizing their employment.”
The NTSB did not identify any specific process for accomplishing the above; however, the issue of human fatigue is clearly on the NTSB radar. It is important to note that human fatigue has been on the NTSB Most Wanted List since 1990. However, beginning in 2008, the NTSB began pressing this issue harder after four accidents and incidents occured, which were attributed to pilot fatigue. Accordingly, the NTSB departed from its previous focus on flight-duty times, and began concentrating on the “fatigue management systems.” According to the NTSB, these systems involve various methods of managing fatigue, some of which include pilot scheduling, attendance policies, education, medical evaluation and treatment, environmental conditions, and commuting policies.
As we have experienced in the past, the FAA is often a reactionary agency and may not kick into high gear in addressing fatigue management issues until a catastrophic fatigue-related event occurs. Nevertheless, we should be cognizant of the fact that further regulations in this area will be coming—it is not a matter of if, but when.