FAA Office of Aerospace Medicine 
Civil Aerospace Medical Institute 

Report No: DOT/FAA/AM-23/11

Title and Subtitle: UAS Air Carrier Operations Survey: Fatigue

Report Date: March 2023

Authors: Durham, J., Hu, P., Baumgartner, H., Nesthus, T.

Abstract: There is an increasing demand to utilize unmanned aircraft systems (UAS) for new applications currently outside the scope of written regulation, such as taxi services, package delivery, and crop dusting. The Code of Federal Regulations on Aeronautics and Space (14 CFR) are restrictive to air carrier applications for UAS. In particular, small UAS (sUAS) regulations (14 CFR § 107 [Federal Regulation for Commercial sUAS]) do not explicitly address air carrier operations (codified under 14 CFR § 121 [Federal Regulation for Air Carriers and § 135[Federal Regulation for Commuter Air Operations]). Duty time, shift work, and fatigue requirements have been extensively researched in manned operations, but recent and continuing developments in UAS applications and UAS automation have resulted in changes to work elements, and ultimately to operator fatigue. This Market Survey regarding UAS operator fatigue will help inform future policy and regulations associated with UAS operations so that novel applications of UAS can be integrated safely into the National Airspace System (NAS).Survey results found a majority of organizations have 10 or fewer drone operator pilots with an average of 7 years of experience. The majority of respondents indicated that the anticipated average in-flight time for air carrier delivery operations is 30 min or less and that for air taxi services the anticipated average in-flight time is higher, at 1 hour or less. A majority of respondents disagreed that fatigue represents a safety concern, but expressed some variation on how much time on duty is risky for operator fatigue. Respondents indicated that they work relatively regular weeks with 1-3 days off between shifts and routine breaks during shifts. A large proportion of respondent organizations provide fatigue awareness and fatigue management training, and also appear to provide mechanisms for reporting crewmember fatigue when it represents a safety concern. However, a majority of organizations do not maintain records about the prevalence of fatigue even though a majority of respondents reported experiencing fatigue themselves while on duty and that workload and work schedules might be factors contributing to fatigue while on duty. Recommendations for standardizing UAS duty time, shift work, fatigue awareness and educational requirements are suggested for supporting the safe and efficient integration of UAS into the NAS.

Key Words: unmanned aircraft systems, duty time, shift work, operator fatigue, air carrier operations, human factors, pilot flight duty

No. of Pages: 93