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Old 11-10-2009, 08:40 PM   #1  
PEACH
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Default ALPA and Pseudo-Science on FTDT

Here's a recent release from ALPA regarding the new Flight Time Duty Time review and ALPA's participation on the FAA's Aviation Rulemaking Committee.

Aside from a hearty round of self adulation for ALPA, I was surprised to hear the ALPA chair's quote about the "science" behind his committee's effort.

Quote:
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.
Biorhythms and bodily functions. Really?

ALPA had a seat at the table and they went for the junk science solution. Is it any wonder this committee won't actually publish any of the citations?

Quote:
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
Great - start defending. Until then, Count me as a disappointed skeptic.

The Skeptic's Dictionary - Skepdic.com

Quote:
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.”
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Old 11-10-2009, 11:38 PM   #2  
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I don't think it is junk science. The UK and JAR rules are based on similar scientific studies. The proposal I have seen is almost, if not the same, duty period limitations that JAR uses.
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Old 11-15-2009, 09:28 AM   #3  
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About thirty years ago there was some pseudo-scientific flap about biorhythms, with a thirty day cycle and a seven day cycle and some such, and supposedly if you charted these you could identify coming good days and bad days.

I think that ALPA is talking about circadian rhythms, which has to do with the normal 24 hour sleep cycle.

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Old 11-15-2009, 03:25 PM   #4  
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Originally Posted by PEACH View Post
Biorhythms and bodily functions. Really?
He meant to say: "The purity and essence of our natural bodily fluids" And then he hung up...
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Old 03-30-2010, 09:12 AM   #5  
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ALPA has also endorsed changing the 8 hour fly day to 9 hours. That is going to KILL a lot of 3rd pilot jobs such as Caribbean turns. BUT it will help some senior DALPA screws do turns instead of overnights.
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Old 03-30-2010, 09:20 AM   #6  
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Originally Posted by Wheels up View Post
ALPA has also endorsed changing the 8 hour fly day to 9 hours. That is going to KILL a lot of 3rd pilot jobs such as Caribbean turns. BUT it will help some senior DALPA screws do turns instead of overnights.
Yeah, that is interesting. How is flying an additional hour contribute to improve the current duty and rest requirement? I thought the whole point was that we, as pilots are already overworked and fatigue is an insidious form of performance deterioration. I am definitely against increasing 8 to 9 flying hours per day. That would defeat the whole purpose of limiting the maximum duty hours per day to 12. Besides, like you said, that would negate the need for additional pilot hiring.
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Old 03-30-2010, 09:31 AM   #7  
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Originally Posted by Lighteningspeed View Post
Yeah, that is interesting. How is flying an additional hour contribute to improve the current duty and rest requirement? I thought the whole point was that we, as pilots are already overworked and fatigue is an insidious form of performance deterioration. I am definitely against increasing 8 to 9 flying hours per day. That would defeat the whole purpose of limiting the maximum duty hours per day to 12. Besides, like you said, that would negate the need for additional pilot hiring.
You guys aren't taking the proposed rule changes as a whole. They will be FAR superior to what we have now. Yes, you will be able to fly up to 9 hours with a 2-man crew--but only if your signin is within very strict windows in your local base time, respecting circadian rhythms.

Overall, these new proposed rules, if implemented, will be a great improvement. For starters, they are actually based on science, not just some arbitrary number jotted down in the 1950s. Second, for early signins or late in the night duty days, they are actually far more restrictive than the FARs we have right now (which strangely enough, are rarely criticized by the same posters bewailing the proposed FT changes).

These proposed FT/DT changes will be good for the pilot profession, and actually drag the FARs into the 21 century.

Lament it all you like, I guarantee you that a year after they are implemented (if ever) we will all be glad for the change.
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Old 03-30-2010, 09:40 AM   #8  
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Originally Posted by Herkflyr View Post
You guys aren't taking the proposed rule changes as a whole. They will be FAR superior to what we have now. Yes, you will be able to fly up to 9 hours with a 2-man crew--but only if your signin is within very strict windows in your local base time, respecting circadian rhythms.

Overall, these new proposed rules, if implemented, will be a great improvement. For starters, they are actually based on science, not just some arbitrary number jotted down in the 1950s. Second, for early signins or late in the night duty days, they are actually far more restrictive than the FARs we have right now (which strangely enough, are rarely criticized by the same posters bewailing the proposed FT changes).

These proposed FT/DT changes will be good for the pilot profession, and actually drag the FARs into the 21 century.

Lament it all you like, I guarantee you that a year after they are implemented (if ever) we will all be glad for the change.
Just so there is no misunderstanding here. I am all for the new Duty and Rest requirement rule. Having said that I am against increasing 8 to 9 flight hours per day. 9 hour flight per day rule only benefit wide body senior people. I think 8 hours of flying per day is fatiguing enough. No need to add an hour on top of that just so senior widebody people can make that extra bucks.

What I am for is limiting the Maximum duty day to no more than 12 hours, minimum overnight no less than 11 hours, rest period should not start while waiting for the hotel van, it should start when you check in at your hotel, among other things.
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Old 03-30-2010, 09:40 AM   #9  
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Quote:
Originally Posted by Lighteningspeed View Post
Yeah, that is interesting. How is flying an additional hour contribute to improve the current duty and rest requirement? I thought the whole point was that we, as pilots are already overworked and fatigue is an insidious form of performance deterioration. I am definitely against increasing 8 to 9 flying hours per day. That would defeat the whole purpose of limiting the maximum duty hours per day to 12. Besides, like you said, that would negate the need for additional pilot hiring.
Guys,

Not that I don't think you've read the proposals on the floor, but seeing as there is so much information out there right now, you may want to re-read the conditions. The duty and flight time, will be predicated on time of show based on your domicile. I have a hard time keeping up with everything myself, and I'm not necessarily advocating an increase in our flying time per day, but when you look at the science behind it, it's clear that 9 hours of flying between the hours of 9am and say 8pm (duty included) is a whole lot different than 9 hours of flying starting at 5am.

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