operations under Part 171. After this crash, the industry was forced to look at how fatigue affected pilots personal abilities and their reactions to circumstances that arise in the air and on the ground.
The new regulations changed a lot and also strengthen things that where already set in place. In this posting, I will do my best to summarize the major changes and how its different from the past regulations. However, for the entirety of the new regulation, visit this site for the final action and ruling on this matter.
https://www.faa.gov/regulations_policies/rulemaking/recently_published/media/2120-AJ58-FinalRule.pdf
- The new rule covers different requirements based on operations at different times of day. Their main changes have to deal with removing the distinction between domestic, supplemental, and flag passenger operations in the thought that pilot fatigue has causing factors that are universal in the industry. It also touches on that pilots, and companies, are equally responsible for reducing fatigue. airlines must do so by offering a safer resting environment for the pilots, and for the pilots to use the resources provided by their company.
- Companies have already been instructed to have fatigue related training courses such as the effects of fatigue on pilots. The new regulation will also enforce carries to update their educational programs every 2 years.
- Flight duty period (FDP) is now limited to 8-9 hours of flight control time (Actual flight time) depending on what time of day the pilots FDP begins. This FDP can very for Augmented (Increased) Operations, if the company provides flight crew of 4, and adequate on- board sleeping areas for pilots.
- Reserve and unaugmented operations: provided that the total number of hours a flight crew member may spend in a flight duty period and reserve availability period may not exceed 16 hours or the maximum applicable flight duty period table plus four hours, whichever is less.
(Air Line Pilots Association, Int’l.)
- The regulation allows for extended FDP in the event that unforeseen situations arise after take off. A 30 minute "buffer window" is attached to the FDP for certain situations
- Split duty times that benefit night time operations now bust be at least 3 hours long and scheduled in advanced. Flight crew must rationally evaluate their ability to complete their assigned duties prior to the flights.
- For pilots who begin flying at night, the FAA determined that 2 hour night time sleep periods improves pilot performance for up to 5 consecutive night flight operations.
- Rest: Carriers will be required to provide their crew with a 10-hour rest opportunity prior to commencing a duty period that includes flying. This includes at least 8 hours of uninterrupted flight time if a long commute is involved. In addition, the length of continuous time off during a 7-day period has been extended from 24 hours under the existing rules to 30 hours.
The final rule does not apply to all-cargo operations, although those carriers have the ability to fly under the new rules if they so choose. When first proposed, cargo operations where going to be included, however, the white house administration ordered the FAA to remove them (Goelz, J. H).
Cargo operations continue to fall under Part 121, Subparts Q, R and S.
Cargo operations continue to fall under Part 121, Subparts Q, R and S.
(1) 1,000 hours in any calendar year;
(2) 100 hours in any calendar month;
(3) 30 hours in any 7 consecutive days;
(4) 8 hours between required rest periods.
-More exceptions can be found in the regulations
(14 CFR 121.471)
For the sake of the pilots who fly cargo operations, I do feel that cargo industries should be included in the new regulations. The pilots are flying the same aircrafts, leaving from the same airports, and landing at the same airports that are used for all operations. Everyone gets tired at different times, and who's to say cargo pilots shouldn't get the same rights as those who are flying passengers. However, the cargo industry is a heavy 24/7 operation, which tends to lean on pilots making more flight at times that may require it. If anything, the hours should be a little less strict as the commercial airlines, but more strict then current regulations.
Now with that being said, I see that more often then not, the problem that arises with cargo operations is that the plane wasn't loaded correctly and the pilots where doomed from the start. Flights like National Airlines Flight 102 (April 29,2013) was carrying military vehicles and equipment. After stopping off at their fuel stop, the aircraft took off again and had some of the cargo shift during take off. the pilots couldn't regain control of the plane and crashed, killing all 7 crew members. UPS Airlines flight 6 (September 3, 2010) had cargo catch fire in the cargo hold with no fire detection or suppression system to alert the pilots. Smoke filled the cockpit and both pilots where not able to fly the plane resulting in the lost of their lives. Now, the fire in the cargo hold was fueled by the oxygen tanks that ruptured and then fueled the fire in an area which would have no other oxygen source to allow a fire to start or continue if ignited. So in theory, no fire detection or suppression system should have been needed. Because of this, we have changed what and how we load into airplanes for safety measures. So if anything, there needs to be more training on loading procedures and how to tie down cargo so that shifting during flight would never be possible.
From a management perspective, I feel that any more requirements, which would limit the amount of flying that a pilot could do, would hurt the cargo industry. With the current pilot shortages, this would limit the amount of cargo flights could make, losing them money. However, Safety should be and is our industries number one priority, and if pilot error due to fatigue is liked to current FDP for cargo pilots, then something should be done.
14 CFR 121.471 - Flight time limitations and rest requirements: All flight crew members. (n.d.). Retrieved January 31, 2018, from https://www.law.cornell.edu/cfr/text/14/121.471
Air Line Pilots Association, Int’l. (n.d.). GUIDE TO PART 117 FLIGHT TIME LIMITATIONS AND REST REQUIREMENTS. Retrieved from http://www3.alpa.org/portals/alpa/committees/ftdt/Part-117-Flight-Time-Limitations-and-Rest-Requirements.pdf
Goelz, J. H. (2014, September 11). Cargo pilot hours should be regulated, too: Column. Retrieved January 31, 2018, from https://www.usatoday.com/story/opinion/2014/09/11/cargo-pilot-airline-safety-fatigue-regulations-commercial-column/15474061/
Huerta, M. P. (2011, December 11). Flight crew Member Duty and Rest Requirements . Retrieved January 31, 2018, from https://www.faa.gov/regulations_policies/rulemaking/recently_published/media/2120-AJ58-FinalRule.pdf
You explanation of the Colgan Air accident was helpful and clear, I appreciate the fact that you used a graph and paraphrased the actually FAR that resulted from it. I also liked how you referenced some other accidents that may have been avoidable if there were FAR's similar to these in place back then.
ReplyDeleteI want to take the time to mention that in the National Airlines Flight 102 accident all of the crew members were from Michigan. This is general knowledge and I'm sure if you did research on the crew members you would probably know this. Although what is personal to me about this accident is that I knew the pilot in command of that aircraft; Jeremy Lipka. He was a friend of my fathers and believe it or not, is the reason that I want to pursue aviation. Now it might sound strange that a person that die piloting an aircraft in 2013 is the same guy that got me to dedicate my life to the same job; because it even sounds strange to me. But I can honestly say that Jeremy was such a good guy and a skilled pilot that his inspiration is enough to over power the idea of potentially perishing from hitting the ground going 200+ miles per hour. Long story short, your use of visual aids and real life scenarios helped keep my interest and I liked reading your blog because of it.