Airline Pilots’ Associations and off days

by Capt. G A Fernando MBA

gafplane@sltnet.lk

Hony Life Member Air Line Pilots Guild Sri Lanka,

Former International Federation of Air Line Pilots Associations (IFALPA) director for ALPGSL

Former Member ALPA (Singapore),

Former Crew Resource Management Facilitator Singapore Airlines Ltd,

Former President of the aircraft Owners and Operators Association, Sri Lanka

Recently the Minister Aviation Minister Nimal Siripala de Siva publicly declared that SriLankan Airlines’ woes are due mainly to pilots not flying on their ‘off days’. These ‘off days’ are mandated by law to enable flight crewmembers to spend at their leisure, unwinding, resting and relaxing.

History

As early as in 1931, The Commerce Department of USA set a monthly flight-time limit of 110 hours for pilots. The air operators and owners wanted a limit of 140 hours while The Air Line Pilots’ Association (ALPA) of USA wanted a limit of 85 hours a month. In 1934 the National Labour Board of USA acceded to the ALPA request and made the limit 85 hours a month.

In February 1953 an Avro York aircraft of Skyways Ltd, a now-extinct British non-scheduled and cargo airline, was en route from the Azores Islands in the Atlantic Ocean to Gander, Canada when it went missing. The subsequent enquiry by an air accident investigation board noted that the flight crew had been on duty continuously for 23 hours, a factor which might have contributed significantly to the accident. The report, released in 1954, also recommended that “The whole subject of air crew fatigue [should] receive study”.

Also, in 1954 a British Overseas Airways Corporation (BOAC) Lockheed 749 Constellation undershot the runway while landing at Kallang, Singapore. The aircraft, operating a multi-stop flight from Sydney, Australia to London, England, crashed into a seawall, broke up and burst into flames. Thirty-three of the airplane’s 40 occupants were killed. However, Capt. T.W. Hoyle, the pilot-in-command who had escaped through a shattered window, was a key witness in recounting the sequence of events that led to the accident. At the public inquiry carried out by the Supreme Court of Singapore it was discovered that the flight crew had been on duty, without a break, for 21.5 hours. The 46-page report concluded that “insidious fatigue” undoubtedly contributed to Capt. Hoyle’s error of judgement, causing an undershoot and consequent collision with the seawall close to the touchdown end of the runway.

Interestingly, The Singapore Free Press newspaper stated on November 16, 1954: “The pilot, not ridge gets blame!”

The accident report made two recommendations. Firstly, the requirement for more scientific research into air crew fatigue. Second, a review of regulations governing air crew work and rest. After World War II the non-binding guidance for the UK’s Civil Aviation Ministry was the Air Navigation Order (ANO) which puts the onus on airline operators to set and maintain a prescribed limit on flight crews’ maximum flying hours per month. In Britain the British Air Line Pilots’ Association’s (BALPA) general secretary commented in a newspaper article that “The public has a right to expect that, whatever else may be the hazards of air travel, at least those which can definitely be eliminated by straightforward ministerial regulation should not be allowed to persist.”

The Air Ministry formed a ‘working party’ headed by Sir Fredrick Bowhill to tackle the balance between safety and profitability, matters over which trade unions and airline managements held opposing views. The working party mainly comprised personnel from the Royal Air Force (RAF), who relied on and cited their wartime flying experience. Medical specialists were also consulted, all of whom confirmed that fatigue (mental and physical) could contribute to accidents. For the record, the Ceylon Air Navigation Regulations (ANR) of 1955 had a limit of eight flying hours over 24 consecutive hours, but nothing was mentioned about mandatory crew rest periods.

Ultimately in 1957, based on the Skyways Avro York and BOAC Constellation accident reports, a regulatory framework for work and rest, which involved crew schedules, was enacted in the UK. Scientific studies of air crew fatigue went on to influence regulations. BALPA representatives had argued that pilots might be influenced ‘by fear of [their] owners’ or by ‘being paid more’ to continue work. However, the new ANO that was promulgated by the working party wasn’t watertight, falling far short of the trade unions’ expectations. BALPA argued that “too much discretion” was being granted to operators and that “excessive flying” was still legally possible with nothing to stop astute operators exploiting loopholes to create intensive and imbalanced schedules.

Fatigue

Over the next 20 years scientists got a better understanding of the nature of Mental and physical fatigue in airline crews. Essentially, three areas were identified: Transient (Acute) Fatigue; Cumulative Fatigue; and Fatigue caused by the disruption of the Circadian Rhythm due to trans-meridian travel (crossing multiple time zones).

Transient Fatigue is acute fatigue or tiredness brought about by extreme sleep deprivation and stress or extended hours of wakefulness over one or two days.

Cumulative Fatigue is brought on by repeated mild sleep restriction or extended hours awake across a series of days.

Circadian Fatigue arises from the disruption of one’s internal body clock resulting from crossing of many time zones at all hours of day or night. It is commonly known as ‘jet lag’.

The worst-case scenario is a combination of cumulative fatigue and circadian fatigue

In the early 1970s, by which time the ‘Bowhill Working Party’ ANO had become outdated, a committee more representative of civil aviation interests was established. It was headed by Douglas Bader, the legendary and legless veteran WW2 fighter pilot. That committee took into consideration rest taken at base, starting time of the flight duty period, and number of sectors to be flown, coming up with maximum flying hours that could be scheduled. The committee also recommended that rest prior to flying should be “uninterrupted” and “‘horizontal” of at least eight hours’ duration. Sleep was not a requirement, but desirable.

The final report evolved into a complex volume called the UK Civil Aviation Authority (CAA), Civil Aviation Publication (CAP) 371 called “Avoidance of Excessive Fatigue in Air Crews” Where cabin crew members were concerned, they were allowed to

work one hour more in accordance with International Civil Aviation Organisation (ICAO) Standards and Recommended Procedures (SARPS). From the mid -seventies even Air Ceylon, Air Lanka and Sri Lankan Airlines adopted these limits through the ICAO and CAASL.  In February 2016 these flight time limitations were harmonised with those of the European Union Air Safety Agency (EASA). All pilot associations the world wide were quick to mention these ‘work and rest’ limitations in their Collective Agreements with the Managements.

Standard Industrial practice now dictates that no airline operator should schedule any air crew to the maximum limit but allow a margin for unexpected delays. Airline captains too could use their desecration under certain extenuating circumstances to extend the duty period.  An operator’s scheme should be filed with the official regulator (CAASL, in Sri Lanka’s case). Importantly, a crew member’s personal limits should be even more stringent than the airline operator’s flight time limitations (FTL) scheme, so that situational awareness will build up by self-regulation. The CAASL can withdraw the crew member’s Air Transport Pilot’s Licence (ATPL) if there is a violation of FTLs. Worst still, if there is an incident or accident it can compromise insurance compensation for all parties involved.

It is a fact that because captains and professional flight crew put ‘safety first’ by being responsible and striving to be well rested to avoid fatigue, SriLankan Airlines Management and the Minister can sleep soundly at night. Flight Crew will be the last to kill the goose that lays the golden egg!