During Delegate Committee 4’s discussion, Capt. Eric Sparks (Ryan) asked Wykoff what qualifies as “acclimated.” Wykoff replied that being acclimated is the physiological location of a crewmember whose biorhythms and bodily functions are considered aligned with local time.

We have a scientific bibliography for every part of [the revised ALPA FTDT policy]. We can and will defend it on the basis of the science

ALPA Adopts New Policy to Fight Pilot Fatigue
November 3, 2009
Tired of being tired?
Then you’ll probably have more than a passing interest in the new ALPA policy on flight-time and duty-time limits and minimum rest requirements (hereafter shortened to FTDT) that the Association’s Executive Board passed unanimously on October 28. The changes will likely affect almost every ALPA member flying today.

The ALPA policy sets very specific goals for (1) FTDT regulatory reform, which is under way in the United States as you read this and likely to follow in Canada, and (2) negotiating rules on scheduling in future pilot contracts.

Pilot fatigue has been a major issue for ALPA since 1931, the year the Association was founded. The Department of Commerce had set monthly flight-time limits of 110 hours for pilots, but operators wanted 140 hours per month, while ALPA’s founder and first president, Capt. Dave Behncke, campaigned for 85 hours per month (ALPA prevailed in 1934).

But though pilot fatigue has always been an issue, it’s been particularly onerous during these several tough years since 9/11. ALPA’s leaders have heard this message five-square from members and their elected representatives.

In October 2008, ALPA’s Board of Directors reiterated that reducing pilot fatigue is one of the top priorities of the Association as spelled out in the ALPA-wide Strategic Plan. The BOD’s focus on fatigue was consistent with the most recent ALPA effort beginning in 2006 to update and promote the Association’s FTDT policy.

ALPA’s FTDT Committee has spent the last three years working with the International Federation of Air Line Pilots' Associations (IFALPA) and the International Civil Aviation Organization (ICAO), the aviation arm of the United Nations, to harmonize ALPA policy with ICAO and IFALPA recommendations that are based on a rational, scientific foundation. The new policy meets the mandate of ALPA’s long-time motto, Schedule with Safety, creating the foundation for sensible, science-based regulations to mitigate fatigue and improve pilot alertness. Coupled with the Association’s focus on contractual scheduling rules and related collective bargaining goals, we can improve the quality of work life with better daily, weekly, monthly, and annual schedules for our members.
Capt. Don Wykoff (Delta), ALPA’s executive administrator and chairman of the Association’s FTDT Committee, also co-chaired the FAA’s FTDT Aviation Rulemaking Committee (ARC), which, between mid-July and September 1, developed recommendations for the agency to use in developing proposed new FTDT rules.
As one of the principal architects of the new ALPA policy, Wykoff walked the Executive Board through the science and logic behind the policy changes.

Wykoff emphasized that, despite the recent renewed focus on pilot fatigue brought about by the NTSB investigation into the Colgan Air Flight 3407 crash on February 12 and FAA Administrator Randy Babbitt's creation of the FTDT ARC as a result, the new ALPA policy “is not a product of the past 60 days—it’s a product of three years of work through ICAO, IFALPA, and direction from our Board of Directors. It reflects current science and the need for increased pilot alertness and fatigue mitigation.”

Wykoff and other ALPA leaders recognized the need to change the Association’s FTDT policy to harmonize it with the policies of IFALPA and ICAO. Also, because the FAA was putting FTDT reform on the fast track, with a notice of proposed rulemaking (NPRM) promised by the end of this year, ALPA’s leaders needed to move deliberately but without delay to craft a policy that would be consistent with the Association’s response to the NPRM.

The new policy deals with seven major areas—rest, duty, extension of duty, cumulative fatigue, augmentation, reserve, and fatigue risk management systems (FRMS).

The eight pilots who made up Executive Board Delegate Committee 4—pilots from regional, national, flag, and cargo airlines—reviewed the proposed revisions to ALPA’s FTDT policy and discussed it in detail with Wykoff.

During his presentation to Delegate Committee 4, Wykoff said, “The number one question in my inbox—and I’ve acquired a lot of new pen pals—is, ‘Why the heck did you do that?’”—i.e., accept a flight time limit of 9 hours for pilots who report for work between 7 a.m. and 12:59 p.m. and will fly 1–4 legs during that duty period. He explained that the ALPA FTDT Committee couldn’t find good science to defend a flight-time limit of 8 hours, but lots of good science to defend a flight duty period limit based on time of report. Nevertheless, the committee thought that setting a hard limit on block time was necessary, and it’s important to note that the flip side of the ALPA policy on flight time limits sets 7 hours as the maximum for pilots reporting to work between 2000 and 0459 at their base or where they are acclimated.

During Delegate Committee 4’s discussion, Capt. Eric Sparks (Ryan) asked Wykoff what qualifies as “acclimated.” Wykoff replied that being acclimated is the physiological location of a crewmember whose biorhythms and bodily functions are considered aligned with local time.

Sparks said his pilot group, flying under supplemental rules, often falls into the situation in which “deadheading is not considered rest, but it’s not duty.” Wykoff responded that one of “the fundamental questions” regarding the FAA’s NPRM and final rule on FTDT is, “Will [the FAA] make them, the cargo and supplemental airlines, conform to the same rules as all other operators, as we believe they should, or will [the FAA] give them the ‘carve out’ they want to keep?”

Capt. Mark Segaloff (Colgan Air) asked how closely the NPRM will match this proposal. Wykoff said, “We won’t know what’s in the NPRM until the FAA publishes it. I don’t want anybody to fall in love with any of these numbers I’ve put up here—but I really hope the numbers stay the same [in the final FAA rule], for example, 9–13 hours of flight duty period, [with the position on the charts perhaps moving a bit].”

Capt. Andy Forsythe (Capital Cargo) asked, “What if the NPRM or the final rule isn’t good?” Wykoff responded, “If the [FAA] does a good job writing a regulation from [the FTDT ARC’s] recommendations, I think we ought to have a really world-leading regulation. We have a scientific bibliography for every part of [the revised ALPA FTDT policy]. We can and will defend it on the basis of the science.”

First Officer Carla Widman, Colgan MEC vice-chairman observing the Delegate Committee 4 discussion, asked Wykoff whether the proposed ALPA policy change, if incorporated into a final FAA rule, would hurt regional pilots because they’d have to fly more days per month. “We ran the numbers for regional airlines,” Wykoff explained. “We found that if we increased minimum rest to 12 hours, it would add, on average, four duty periods per month to a regional pilot’s schedule—but if we adopted 10 hours as the minimum rest requirement, that would add only about a quarter of a duty period per month. So we have weighed all these things and have attempted to find a proper balance.”

As Wykoff told the Executive Board plenary session, “We want to be science-based, but the truth is, there is not enough scientific knowledge to answer every question. At times we have had to rely on our experience. And no one can come close to claiming the amount of experience we pilots have had with living with fatigue on the line.”
Capt. Scott Stratton (FDX), chairman of Delegate Committee 4, presenting the unanimous endorsement of Delegate Committee 4 on this agenda item to the full Executive Board, talked about the need to balance science, experience, and “the realities of the world in which we live…. We think this proposed policy change strikes that balance.”

The full Executive Board, having been well briefed on the new policy, the background behind it, and the policy’s implications, accepted the unanimous recommendation of Delegate Committee 4 and voted unanimously as well to adopt the new policy.

Stratton’s final words to his fellow members of Delegate Committee 4 are worth noting. “This is huge,” Stratton said of the revised ALPA FTDT policy, “but I really believe we are engaged in a triathlon. Some people think this is the end; it’s not. It’s a good beginning. We just finished the swim; now we have to bike and run.”