Fatigue is a real threat to aviation safety. A tired pilot is a dangerous pilot. As pilots we operate in a 24 hour business. We operate around the clock working our regular schedules involving night-time work, early starts and regular time zone changes. The duty days we work are long and mentally demanding, and flight time limitations about which we are here to discuss, dictate the way a pilot's roster is structured. They determine the daily, weekly and monthly total duty times and the minimum rest required between such duties.
The International Civil Aviation Organization, ICAO, which is an umbrella group of the United Nations, has stated that the sole purpose of flight-time limitations, FTLs, is to limit the working hours of pilots in order to minimise the threat of pilot fatigue but what is fatigue? Scientific study into fatigue began in the 1940s and continues today. We know that fatigue is a physiological state of reduced mental or physical performance capability. It impairs a crew member's alertness and ability to safely operate an aircraft or perform safety related duties. It is caused by sleep loss, extended time spent awake and disruptions to the circadian rhythm, which is the body clock, and workload, be it mental or physical.
Much is known about the relationship between pilot fatigue and accidents. Between 1991 and 2005, almost half of all aircraft accidents worldwide had human error by pilots as a contributory factor. The scientific consensus is that a large proportion of these are related to pilot fatigue. The National Transportation Safety Board in America, the United States Government's primary investigation agency for all modes of transport, has stated that 20% to 30% of all transport accidents have fatigue as a contributory factor. It also estimates that 15% to 20% of all aviation accidents have fatigue as a contributory factor. The Federal Aviation Authority has also stated that operator fatigue is one of the most persistent hazards in all travel modes, including commercial aviation.
The airlines have lobbied and argued that fatigue has not caused any accidents. Fatigue may be significantly under-estimated in many accident reports. It cannot be established by a simple test in the way that can be done with alcohol intoxication, and it will not show up in a post mortem examination. Accidents are rarely caused by a single failure or error. A fatigued crew may deal with a problem in a far less successful manner than a fully rested one, and many accidents in recent years have been attributed to pilot fatigue.
Members can see a list on the screen from a crude Google search of aircraft accidents involving fatigue. Since the early 1990s, over 500 people have lost their lives as a result of accidents which had fatigue as a contributory factor. It is worth bearing in mind also that for all fatal accidents there are many non-fatal accidents or incidents, or near misses for want of a better word. If we think of an iceberg, the visible part of the iceberg is the smallest part. If we think of that as the accident, below the level of water is the large number of incidents, occurrences and near misses that go unreported.
Recent studies of Scandinavian pilots have revealed that 80% of Scandinavian pilots have made fatigue related errors. A total of 40% have been involved in incidents and 50% have fallen asleep without warning their colleague.
Pilots like Dr. Hunter to my left undergo regular medical examinations once or twice per year depending on their age and their health. These examinations are carried out by aeromedical examiners who are specialists with a specialist knowledge of aviation medicine. A total of 70% of those doctors surveyed believe that fatigue is increasing. Some 75% of doctors believe that a quarter of pilots are too tired to fly safely, and 60% of pilots think that pilots are falling asleep in flight.
A recent study of a UK airline revealed that 45% of pilots were severely fatigued. That is particularly frightening when one considers that UK pilots operate under different rules to most of Europe - rules that are far more restrictive. Under the general requirement enshrined in international law by ICAO Annexe 6 and European legislation, EASA is required to draw up new flight-time limitations and for these flight-time limitations to be based on scientific and medical evidence.
In 2007, EASA contracted Moebus Aviation to evaluate the current rules. It gathered ten leading European experts and concluded that the current flight-time limitations were deficient and came up with 33 recommendations. EASA's current proposal complies with two of these 33 recommendations. Not surprisingly, there was huge objection to EASA's proposals. As a result EASA commissioned three further independent scientists to review the proposal. The three scientists worked independently of each other, using separate methodology, but their findings were all similar and all supported the original Moebus finding. They also contradict EASA's current proposal.
We argued that the EASA proposal is not based on science, as is required under international and European law. We think it is a deeply misguided attempt to boost airline profits. Although safety can never be absolute, and must always be weighed against productivity, in this case we believe the balance is horribly wrong. We believe the safety risk is unacceptably high and the economic benefit is dubious. It is worth bearing in mind that in 2011 ten European airlines made a profit. Of those ten, one was an Irish airline that made a profit of almost €50 million, and the second was another Irish airline that made a profit of over €500 million.
Under this proposal, European pilots will be asked to fly duties up to 16 hours a day. Science tells us that an accident is 5.5 times more likely if we go over 13 hours. Under European rules, pilots will be expected to work 16 hours, while truck drivers are restricted to ten. Scientific research has told us that pilots will be landing aircraft in a state of fatigue that is four times over the legal blood alcohol limit for flying. Scientists have established a direct link in the deterioration in performance comparable between fatigue and alcohol intoxication.
Science also tells us that night-time duties of 11 hours or more carry an increased risk of fatigue. The original dubious report, commissioned by EASA, and the three independent scientists who were also commissioned by EASA, have all agreed that the maximum night duty of ten hours should be adhered to. However, EASA has gone on to propose a limit of 11 hours.
If the proposal is passed a situation could arise whereby if I were to go to bed at 9 p.m. and wake up at 5 a.m., report for airport stand-by at 7 a.m., I could hang around the airport on duty and at 11 a.m. be asked to operate a flight. That duty could have me back at the airport 14 hours later, at 1 a.m. If I were to be delayed en route, I could be asked and be expected to extend my duty, using my own discretion, by a further two hours. That would have me arriving back in the airport at 3 a.m. having awoken at 5.a.m., some 22 hours later. Bear in mind that, statistically, landing is the most dangerous part of flying, and this would occur some 22 hours after I had awoken.
On 12 February 2009, a commuter flight from Newark to Buffalo, was operated by Colgan Air. As a result of what happened on this flight the US is in the process of implementing new flight-time limitations. It is following an opposite course to EASA. After years of pressure by the National Transport Safety Board, and a high-profile fatigue-related accident, which resulted in 50 people dead, America is now tightening its rules in line with science.
On screen, members of the committee can see the final resting point of the flight that departed on 12 February 2009. After that crash, the NTSB investigation concluded that the probable cause of the accident was pilot mishandling of the aircraft. This caused the aircraft to stall and crash. One of the findings in the report was that the performance of both pilots was likely impaired by fatigue. The aircraft crashed into a house in a suburb of Buffalo, New York. All 49 passengers and crew on the aircraft died, along with the resident of the house.
In its concurring statement to the accident investigation report, the NTSB chairman, Deborah Hersman was critical of the airline industry, including pilot unions, airline management and the regulatory authority in their inadequate response to the issue of pilot fatigue. Ms Hersman said the NTSB had consistently called for the issue to be treated more seriously, and has had it on its most-wanted list of transportation safety improvements since its inception in 1990. She lamented that fatigue-related decisions reflected the economics of the industry, rather than the science of fatigue and human performance. She concluded that: "Flying tired is flying dangerously, and it is a practice that needs to end". As a result of the tragic loss of life, action on pilot fatigue from the US regulator finally took place. In December 2011, the Federal Aviation Authority proposed new flight-time limitations that will, in almost every respect, take a more safety conscious approach than the European ones.
This graph shows rules that would apply to flights leaving Dublin flying westbound to the United States. The upper blue line represents the maximum duty, dependent on the start-time of day, that a European pilot could fly. The lower red line represents the same limits that would apply to an American crew. The blacked curved line in between is what is called the Karolinska sleepiness scale. Anything above this line, is reckoned by Karolinska scientists, will result in medium to severe fatigue. We call this the North Atlantic safety gap, which will open between European and American air safety. We would like to ask EASA if European pilots are capable of working longer hours while remaining safe. What is it about US pilots that they are governed by the scientifically-established limits of human physiology, yet European pilots are not? Why do US passengers deserve a greater level of safety? As pilots, we are the final line of defence, and we do not want to be the weakest link.
I am sure all members of the committee are familiar with the miracle on the Hudson - a catastrophic double-engine failure shortly after take-off from New York's LaGuardia Airport. The US captain, Chesley Sullenberger, landed a stricken Airbus A320 in the Hudson River, saving all the passengers and crew.
Many fatigue-related accidents have happened before Colgan, but Colgan was the final straw. It was a tragic lesson, but the US is now moving towards science-based FTL schemes. This will afford American passengers the protection they deserve. European passengers deserve the same protection, but EASA is doing the opposite. It has decided to ignore seven decades of scientific research, two separate scientific reviews of its proposals involving 13 of the pre-eminent European experts in the area of aircrew fatigue. EASA is placing a bet that everything will be okay. Let us hope it is right. Let us hope it does not take a European Colgan case to prove EASA wrong. European passengers deserve better than that.
