An Aviation Sector Perspective The Parliamentary Office of Sleep and Health An Aviation Sector Perspective The Parliamentary Office of Science and Technology 16 October 2018 Dr Rob Hunter Head of Flight Safety British Airline Pilots’ Association

The aviation context Regulation (and deregulation) Safety versus productivity Shifting shift work Taboos Why aviation is (or has been) so safe

European regulation (and deregulation) The control of pilots’ hours of duty Ostensibly 3, but in effect 2 components to the regulations – The so-called “prescriptive” rule set, a complex esoteric rule set that describes quantitatively what is allowed. E.g. max 900 hrs/yr . This “allows” very fatiguing rosters to be created, except that there is.. An overarching rule set that pilots must not fly when too fatigued and airlines mustn’t roster pilots to do fatiguing duties. (But this component creates a “catch 22”and it is otherwise ineffective because of its firm requirements to do nebulous things and there being no definition of “too fatigued”…it is a “paper tiger”) ..and increasingly.. An exemption from the prescriptive rule set that allows a bespoke assessment of the risk and the level of the risk by the airline, a so-called Fatigue Risk Management System (FRMS). But this component is unproven and is hugely vulnerable to conflicting interests; commercial (owned science), regulatory, etc.

Safety versus productivity Drucker – “ The first duty of an organisation is to survive”

Historical revisionism; the debate over regulated levels of safety versus operator determined levels of safety is not new. The Norwood and Plimsoll lines “You’ve got to draw the line somewhere”

The debates in Parliament were so intense and drew so much interest from the public that when a symbol for the London Underground was selected it was based on the Plinsoll line…and when a canvas shoe with a rubber sole was guaranteed to be waterproof if the water didn’t come above a line above its sole it was called..

Airline plot of a pilot’s predicted level of effectiveness Airline plot of a pilot’s predicted level of effectiveness. Pilot disciplined for declining the duty of 07/05/2014; the airline held that he was lying about his fatigue Effectiveness at landing similar to 4x legal alcohol limit

Air Accidents Investigation Branch Report, Serious Occurrence, G-TCBC, 17 August 2013 “When he reported for this duty at 0500 hrs , he believed he was as well rested as could be expected for that time in the morning.. Examination of his roster indicated that on the day before the incident he had been on home standby from 0900 hrs to 1500 hrs but had not been called to work”

BALPA polling results of 500 airline pilots, September 2011 Have you ever involuntarily fallen asleep on the flight deck during 2 crew operations? Yes = 43% ..and if yes, have you ever woken to find the other pilot asleep? Yes = 31%

Reporting of involuntary sleep on the flight deck Mandatory reports CAA, (entire UK fleet) 2 reports 1984 – 2014 (Approx. 1/100 000 000 flying hours) BALPA Fatigue App, (96 pilots in August 2017) 71 reports (Approx. 1/200 flight hours) Reality ?? 1 in 20 flight hours

Crew sleep patterns of cockpit napping during transatlantic flights, P Crew sleep patterns of cockpit napping during transatlantic flights, P. Cabon et al . XVIth International Symposium on Night and Shiftwork, 17- 21 November 2003, Santos, Brazil. This electroencephalography study was done to investigate the effects of cockpit “rest” a euphemism for sleeping on the flight deck. The red ellipse shows that when the Captain was taking his planned sleep the First Officer, who should have been awake, was in fact also asleep.

Why aren’t fatigue related accidents happening all the time Why aren’t fatigue related accidents happening all the time? – How errors are trapped https://www.youtube.com/watch?v=aJ2RzS8_q4A Captain awake for 19 hours at time of incident

Thank-you robhunter@balpa.org