"Fatigue Risk Management "
J. Randolph Babbitt, Montreal, Quebec
August 30, 2011

International Civil Aviation Organization Fatigue Risk Management Symposium


Remarks as prepared for delivery

President (Roberto) Kobeh (President of ICAO), Mr. (Mervyn) Fenando, Mr. (Don) Wykoff, and distinguished delegates --

Thank you for that kind introduction.  I am pleased to be back in Montreal, and I appreciate the opportunity to participate in the International Civil Aviation Organization's Fatigue Risk Management Symposium.

Like aviation itself, fatigue is global.  It doesn't discriminate on the basis of nationality.  Its effect on the people who operate our global aviation system is the same, regardless of whose flag is on the tail of the airplane.  That's why ICAO long ago established basic international standards that require each Contracting State to have regulations on flight time, flight duty periods, overall duty periods, and rest periods for flight and cabin crew members.  

There are different approaches to complying with the ICAO standard—and that's why it's so beneficial to have gatherings like this one.  Safety is our top priority in aviation, and events that let us share our best information and best practices for managing fatigue and mitigating its risk contribute to achieving that goal.

In that spirit, I'd like to spend a few minutes today sharing some information and updates on what the United States Federal Aviation Administration is doing in the area of fatigue risk management and mitigation.

Let me first bring you up to date on the status of our flight duty and rest rulemaking effort.  I have been pushing for pilot flight and duty time changes since I was President of the Air Line Pilots Association in the 1990s. 

The FAA has also tried over the years to put forward changes in its flight, duty and rest regulations.

When I became FAA Administrator, one of my top priorities was to finally make those changes a reality.

We are currently working on a final rule which will ensure pilots have more opportunity for rest.  This will benefit the pilots and the travelling public.

We are working aggressively to get this rule out as soon as possible.

Let me give you some background on how we got here.

In June of 2009 following the crash of Colgan Air 3407, the agency chartered the Flight and Duty Time Limitations and Rest Requirements Aviation Rulemaking Committee (ARC), comprised of labor, industry, and FAA representatives.  Its charge was to develop recommendations based on current fatigue science and a thorough review of international approaches to this issue. 

The ARC's recommendations led to development and publication of a new Notice of Proposed Rulemaking last September.  Our NPRM focuses on education, awareness, and mitigation—all based on updated research and science on fatigue.   Some key elements:   

  • It proposed to establish one set of flight time limitations, duty period limits, and rest requirements for pilots in part 121 air carrier operations.  At its most basic level, the FAA's proposal aims to ensure that pilots have an opportunity to obtain sufficient rest to perform with the level of safety we all expect. 
  • It would adjust flight duty periods based on time of day in order to mitigate known detriments to performance during "back-side-of-clock" operations.  
  • It would provide credit for fatigue-mitigating strategies and equipment, such as improved sleep facilities
  • It provides air carriers with flexibility by permitting a limited extension of the flight duty period. 
  • Consistent with the focus of this symposium, it would allow a certificate holder to customize its flight operations based on a scientifically-validated demonstration of fatigue-mitigation and its impact on a flight crew member's ability to safely fly beyond the restrictions of the proposed rule.

And the proposal includes provisions for proper FAA oversight.  For instance, in order to assure that carriers are properly scheduling a flight crew member's work days, we proposed to require periodic reporting to the FAA in certain cases where limits were exceeded.

The FAA’s Notice of Proposed Rulemaking also includes an optional Fatigue Risk Management System (FRMS). There are a lot of positive aspects to a Fatigue Risk Management System. 

  • First, it provides an adaptive, data driven continuous improvement program to manage fatigue risk in a specific operational setting. 
  • Second, it is based on science and empirical findings. 
  • Third, it uses multi-layered defensive strategies to mitigate and manage the risk from fatigue. 
  • Fourth, it provides for flexibility and innovation – air carriers can propose methods in addition to the measures required by law. 

An FAA-approved FRMS can augment specific flight time, duty time, and rest period requirements with alternative procedures that demonstrate a level of safety equal to, or greater than, the rules.  And it is a step toward performance-based regulatory oversight.

We at the FAA are committed to ensuring that pilots are fit and rested when they report for duty.

The changes we seek have been a long time in coming and we are close to getting it done.

We will continue to work diligently with our global aviation partners in ICAO at this event, and beyond, to enhance our collective knowledge of fatigue risk management. 

There is much for us to learn from each other. 

I look forward to hearing the findings of this distinguished gathering, and to our continued collaboration to advance global aviation safety. 

Thank you.  

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