Originally Posted by
Sluggo_63
That’s the problem with fatigue, sometimes/often you don’t know you’re fatigued until it’s too late. That’s why 117 is prospective. It uses science to give the best predictor of human fatigue and prevents an airline from scheduling something that will likely cause a human to be fatigued.
That’s absolutely not true. The FAA decision to cut cargo out was purely economic, by their own admission. When the original NPRM was announced, the FAA was clear, “there are no psychological differences between pilots who fly cargo planes and pilots who fly passenger planes.”
After air cargo carriers vehemently protested the inclusion of air cargo in the proposed FAR 117, the FAA released the final rule. Cargo was cut out and in their press release, this is what they said. “Covering cargo operators under the new rule would be too costly compared to the benefits generated in this portion of the industry.” They went on to say “the projected cost for all-cargo operations is $306 million . . . . The projected benefit of avoiding one fatal all-cargo accident ranges between $20.35 million and $32.55 million, depending on the number of crewmembers on board the aircraft.”
That was my point. The FAA agreed the cost to implement 117 at a cargo carrier is higher. Why? Because our system form IS different than a pax carrier. We DO fly more at night...so comparing how good 117 was at a pax carrier is not a useful comparison to the impact on our system.
Yes, our bodies are affected by fatigue just like any other pilot. I won’t argue that...But it simply came down to a cost benefit analysis. The benefit gained by going to 117 was not worth the cost. For the pilots who don’t necessarily want 117 as it exists for cargo, it is simply because we evaluate the possible gains as not being worth the cost to us.
You may not like the fact that it ultimately is a cost benefit analysis but every operation that does a risk assessment most definitely weighs the costs vs the potential reward. Science would support that never flying at night and only flying 4 hours per day between 9am and 1pm will decrease fatigue related accidents. It would have added safety benefit of allowing maintenance more time to fix our planes. However the cost to the airlines and flying public would be too great. That’s extreme yes but it illustrates the point. We can argue where the line of safe operations is relative to cost but to deny it exists isn’t based in reality.
I agree that fatigue is insidious. 117 doesn’t change that. You still may have to make the judgement call that you are fatigued under 117 due to a myriad of circumstances that still comply with 117.