Too tired for take-off (Globe & Mail)

[Martin Tamme]

The reason I ask is that the Guidance Material for subpart 700 was first added to the TC website in October 2004. The published provisions of S740.17 at that time are the same as those in the current S740.17:

S740.17 Unforeseen Operational Circumstances (current)
Guidance Material - Subpart 700 (as at October 2004)

That is correct. The Guidance Material for subpart 700 was added to the TC website in October 2004. The provisions for "Unforeseen Operational Circumstances" were very vague to say in the least. Upon query from numerous organisations (including ACPA), Transport Canada updated the Guidance Material in early 2005 to reflect as to what they meant to say, and really define "UOC". That is the language which you found in the URL below. I have a copy of the letter that ACPA sent to TC in October 2004, with the December 2004 response from Michel Gaudreau.

Nevermind... I did find a version of the guidance you describe that was posted in early 2007:

S740.17 Unforeseen Operational Circumstances (as at January 2007)

It would be nice to know why the guidance material was changed over the years and why there is no indication that it has been changing...

That language remained throughout 2005, 2006, and part-way throughout 2007, after which TC changed it back very quietly to the previous ambiguous language, following an intensive lobbying effort from ATAC to remove passages that contain clarity. Why did TC do this very quietly? They didn't want people asking them what made them change their minds.


Needless to say, I still abide by rules of the definition that was removed.

[Jastapilot]

The fact that we will be unavoidably tired at times is the poorest excuse I've ever heard for not doing something about our F&DT regulations. It's like saying there will always be workplace accidents so we shouldn't bother about safety at all. And the controlled rest provision in the CAR's is no substitute for duty time regulations that recognize human physiology.

But Rockie! We're supposed to book off if we're fatigued! Remember? Pilots are ultimately responsible to make the call if they're fit to fly, right? Works like a charm...

[sky's the limit]

Pilots are ultimately responsible to make the call if they're fit to fly, right? Works like a charm...

Pilots are ultimately responsible for everything, and now with SMS, we're liable too....

stl

[Brantford Beech Boy]

The fact that we will be unavoidably tired at times is the poorest excuse I've ever heard for not doing something about our F&DT regulations. It's like saying there will always be workplace accidents so we shouldn't bother about safety at all. And the controlled rest provision in the CAR's is no substitute for duty time regulations that recognize human physiology.

But Rockie! We're supposed to book off if we're fatigued! Remember? Pilots are ultimately responsible to make the call if they're fit to fly, right? Works like a charm...

Sure does!

I've played the "fatigue" card a coupla times. Probably could have done the trips but I was legitimatley tired and frankly didn't feel like doing the trip. No biggie. Other crew was ready to roll.
Other than some good natured ribbing from the other crew, I've heard nary a contrary word from anyone.

What is that phrase Cat Driver is always sayin, "The hardest thing to teach is when to say "NO"" or sumthin like that?

BBB

[Rockie]

Most of us who have been around will not go if we're too tired, but that's a lesson we learn by having done it too many times already, and now have the benefit of experience and old age to say no. But back before I was a cranky old man I flew many, many trips that I shouldn't have.

That also doesn't help when you go to work feeling good thinking in good faith that you are fit for the trip only to have it extended to the full 14 hours, or you misjudged and feel like crap after 10 hours of night flying. We are not always the best judge as some posters here have proven, and regardless the rules aren't there to protect us. They are there to protect the public.

[Rubberbiscuit]

We are not always the best judge as some posters here have proven, and regardless the rules aren't there to protect us. They are there to protect the public.

I think the rules are designed with profitability in mind. That is why ATAC and CTA will continue to fight more stringent FTDT regulations. The above with respect to "Unforseen" proves just that.

[Rotten Apple #1]

So Rockie I guess your wishlist for duty reg changes would incluse less thab 14 hour duty days and less than 10 hrs duty when night flying. Is that a correct interpretation of your post above?

Any other things need to be changed? A sincere question (until this thread/G&M article I didn't realize there was a problem with my schedule/working conditions).

Some of our older pilots are working a 'reduced block' of 50 hrs or so (reduced benefits as well). Some of our other older pilots like Rockie just drop a pairing a month to avoid the fatigue he experiences.

Rockie, exactly how many hard hours a month are you flyingj and on what type of equipment? Perhaps that might explain why you're so tired.

John

[Martin Tamme]

Perhaps that might explain why you're so tired.

John

John:

I hate to point out the obvious, but there is a difference between being tired & fatigued. You've already admitted that you've suffered from fatigue while flying, otherwise why the need for catnaps?




Here is a difference between being tired and being fatigued:


http://www.airlinepilotcentral.com/reso ... 24258.html






Fatigue is a debilitating condition that affects your ability to process complex thoughts. When you are fatigued you have passed slow thinking and gone directly to "stupid." The inherent danger of fatigue is that your body may feel OK, but your mind is not able to perform at the same level. So how do you know if you are fatigued if you can’t think clearly?

This is the danger of trying to determine if you are fatigued based on how you feel. As professionals we tend to base our decisions on lessons learned from prior experience. This can be counterproductive as it relates to fatigue. There is a chance that you have been fatigued in an aircraft in the past and nothing bad happened. Do this a few times and your perception of the risk involved in operating while fatigued is skewed in a very dangerous direction. This is further compounded by our current fatigue management system in aviation that relies on the crewmember to make the very difficult decision that they are fatigued. Is it really smart to require the “stupid” person to make difficult, complex decisions?

The good news is that science is finally starting to catch up with our operating environment and we now have some tools that can help you operate safer. As far back as 1997 researchers realized a direct correlation between cognitive ability and mental acuity for those under the influence of alcohol and those suffering from fatigue.

Research shows that people that have been awake for 17 hours have the mental acuity of a person with a blood alcohol content (BAC) of 0.05%. Those that have been awake for 21 hours equate to a BAC of 0.08%. Both of these BAC exceed the legal limit for a professional pilot. [1]

So how can this information be useful for a crewmember? Before every single duty period look back to the time that you last awoke from a restorative sleep cycle (> 5 hours of sleep) and count the hours awake. Then add the hours until you expect to be released into rest. This total equals your total hours awake. If it exceeds 17 hours you are in danger of being fatigued.

Thinking another way, if you have had less than 7 hours sleep in the previous 24 hours counting from the end point of your duty period, you are operating with the mental acuity of a legally intoxicated pilot.

A second tool that has been published recently by scientific researchers is that a person is likely to not suffer the debilitating effects of fatigue if their duty period does not exceed the total amount of sleep of the previous 48 hours. In other words, add together the total amount of sleep received in the previous 48 hours, and this total should equal the maximum time on duty . [2]

For example, if during the previous 48 hours you slept six (6) hours one sleep cycle and seven (7) hours during a second cycle you should expect that any duty period that exceeds thirteen (13) hours would put you in a fatigue state.

Notice that neither of these two tools asks how you “feel.” When you are fatigued you are "stupid," and asking unquantifiable questions of a person having trouble making decisions is not smart. Is it appropriate to ask an intoxicated person how they feel? So does it make any more sense to ask yourself how you feel when what really matters is whether you will be fatigued at the end of your duty period?

Use the two tools in the graphic above to reach a scientific conclusion that can help you decide if you are safe to continue on duty. These tools will only be effective if you use them proactively to prevent yourself from operating while fatigued.

Finally, remember that these tools do not take into account multiple time zone shifts, or dealing with an accumulated sleep debt.

[Rotten Apple #1]

Why the need for a NASA nap?

Referencing your post, I can tell you that at times when I've flown in a 2 crew environment, the NASA nap (Does ACPA permit you to use them BTW?) has helped immensely in restoring my alertness. I might use it coming out of YYT in the morning as I already posted. And as I already stated, there's not much any change in regs will do to avoid me being tired (NOT fatigued!) at that time of day.

Martin, what limits does ACPA place on flying/rest that are more stringent than CARS? Sincere question. And does ACPA want to change CARS to reflect what it has in the CA, or what?

I'm starting to wonder if it isn't safer for the rest of the industry if AC keeps the age 60 retirement rule. Seriously, tired, and old...

[Rotten Apple #1]

http://science.nasa.gov/headlines/y2005/03jun_naps.htm

NASA Naps

NASA-supported sleep researchers are learning new and surprising things about naps.

June 3, 2005: Space travel is sleepless work.

Despite NASA recommendations that astronauts sleep 8 hours a day, they usually don't. Strange sights and sounds, the stress of riding a powerful rocket, the lack of a normal day-night cycle--all these things tend to keep space travelers awake. Studies show that astronauts typically sleep 0.5 to 2.5 hours less than they do on Earth.

Right: Could you sleep like this?

Although many astronauts report feeling fully rested after only six hours of sleep, the fact is, sleeplessness can cause irritability, forgetfulness and fatigue--none of which astronauts need to deal with while piloting complicated 'ships that hurtle through space at tens of thousands of miles per hour.

The solution seems simple: Take a nap.

But naps are a double-edged sword. Sometimes napping can leave you feeling even drowsier than before. If your body enters a deep sleep, trying to wake after only an hour or so can be very unpleasant, and you might remain groggy for some time afterward. This is called "sleep inertia."

Why do naps sometimes backfire? Researchers don't yet know the physical causes of sleep inertia, but they would like to be able to predict, at least, when it's going to strike. This could help doctors prescribe naps of the right time and duration for drowsy people in high-risk professions.

Helping astronauts nap was the goal of a recent series of experiments funded by NASA in cooperation with the National Space Biomedical Research Institute. In those experiments, led by David Dinges, a professor at the University of Pennsylvania School of Medicine, 91 volunteers spent 10 days living on one of 18 different sleep schedules, all in a laboratory setting. The sleep schedules combined various amounts of "anchor sleep," ranging from about 4 to 8 hours in length, with daily naps of 0 to 2.5 hours.

To measure how effective the naps were, the scientists gave the volunteers a battery of tests probing memory, alertness, response time, and other cognitive skills throughout the experiment. They also measured things like core body temperature and hormone levels in blood and saliva, all of which fluctuate in a natural daily cycle known as a person's "biological clock."

In general, they found, longer naps were better. No surprise there. But they also found that some cognitive functions benefited more from napping than others:

"To our amazement, working memory performance benefited from the naps, [but] vigilance and basic alertness did not benefit very much," says Dinges.

"Working memory," he explains, "involves focusing attention on one task while holding other tasks in memory ... and is a fundamental ability critical to performing complex work [like piloting a spaceship]. A poor working memory could result in errors."

For vigilance and alertness, which involve the ability to maintain sustained attention and to notice important details, they found that the total amount of sleep during 24 hours remained the most important factor.

Another interesting finding was that naps didn't work as well for volunteers on a nocturnal schedule. Sleep schedules for some of Dinges' subjects were flipped, so that anchor sleep occurred when their bodies thought it was daytime. The nap, then, fell in the middle of biological nighttime. This simulated what might happen when an astronaut's biological clock is out of sync with the mission schedule.

These out-of-sync volunteers had a very hard time waking from naps, and the grogginess of sleep inertia lasted for up to an hour. Some sleep inertia did occur after naps on a normal schedule too, notes Dinges, but the inertia after a nighttime nap was much more severe.

The ultimate goal, says Dinges, is to tie all these data together into a mathematical model of naps. Such a model, written as a computer program, could prescribe effective naps compatible with the scheduling demands of a mission. Not only astronauts would benefit from such a program, but also doctors, pilots, firefighters … the list goes on.

Such a program is still in the future. Meanwhile, Dinges notes another finding of their study: Naps are a short-term fix, offering only temporary boosts in mental acuity. "They cannot replace adequate recovery sleep over many days," he says.

In the end, there's no substitute for 8 sweet hours of shut-eye.

[Rockie]

Jonny

Since you're quoting NASA perhaps you should look at the rest of the research they, and dozens of other organizations have conducted on this subject over the years. You might also want to look at the NTSB's recommendations for the last number of years as well. The physiological effects of fatigue and its relationship to duty times and circadian rhythm are ridiculously well documented, and presuming you are a human being you are only deluding yourself if you think it doesn't apply to you. Naps don't cut it.

Is your position the same as the Westjet pilots as a group? I would ask them myself but I don't know who represents you.

[Rotten Apple #1]

Rockie. My opinions is my opinions as a man who has gone to work and got work done throughout his working career. I speak for no one. Especially not for the 1000 pilots who work for the same employer as I do. Of course, at your outfit you're all of one mind, no?

I'm going to go out on a limb and presume by your reticence that a) no NASA nap (at least legally) for you, and b) you are fresh out of recommendations for changes to the duty/rest regs.

Bottom line, if i'm fatigued (probably as a result of a chronic condition) I'll book off. If I woke up in the middle of the night and had trouble sleeping for a bit, I'll probably deal with it and leave that to you to figure out how.

You guys have negotiations coming up or something?

[Martin Tamme]

Martin, what limits does ACPA place on flying/rest that are more stringent than CARS? Sincere question.

The Air Canada Collective Agreement limits are closer to what ICAO is recommending. The one-size of 14-hours duty limit does not fit all circumstances: Our duty periods vary from 9-hours to 14-hours depending on the time one checks-in and the type of flying being conducted. For example, our duty period is limited to 9 hours (max 3 legs) or 10 hours (max 2 legs) if the report time is prior to 5AM.

Report times between 17:30 & 19:30 limits the duty period to 12 hours (As such, a YYZ-LAX or YYZ-SFO turn is prohibited during the night hours, but is legal during the daytime hours).

Report times between 19:30 & 22:00 limits the duty period to 11 hours. After 22:00, the duty period limit is 10 hours.

All oceanic crossings (more than 4 times zones away) limits the duty period to 12 hours.

All landings after 2 AM (local time in which the duty period started) finishes the duty period. As such, we can't do the red-eye from YYC to YYZ, and then do the 7 AM departure (out of YYZ) back to YYC.


Naturally, duty periods can be extended if an augmented pilot is carried.


P.S. Yes, we are permitted to take NASA naps, but that doesn't address the bigger picture.

[Rockie]

Jonny

Your presumptions are wrong. I make frequent use of the NASA nap and strongly encourage my FO's to as well. What I do not do is use them as justification for inadequate and archaic F&DT regulations which is where we differ.

My own recommendations for regulatory change would include much shortened duty days for check-ins after 18:00. Similarly shortened duty days for increasing number of sectors. I would eliminate the pilot augment provision allowing a one hour extension unless it was returned to its pre 1998 version that you can read here: http://www.tc.gc.ca/civilaviation/regse ... 720002.htm

I would vastly overhaul the reserve regulations and close the loophole allowing pilots to sit on reserve all day and then get called to work all night. I would require by regulation scheduling that uses the best science available in planning rest around circadian rhythm factors. I would require all these regulations apply to FA's and maintenance engineers as well.

I could spend days filling this board up with recommendations, all of it based on absolute and abundant scientific research into human physiology and fatigue. But you get the point and I believe I've answered your question.

Now, can you get an official position on this issue from your pilot association so that we can all know how much we can, or cannot count on Westjet pilots support?

[Rubberbiscuit]

My own recommendations for regulatory change would include much shortened duty days for check-ins after 18:00. Similarly shortened duty days for increasing number of sectors. I would eliminate the pilot augment provision allowing a one hour extension unless it was returned to its pre 1998 version that you can read here: http://www.tc.gc.ca/civilaviation/regse ... 720002.htm

I would vastly overhaul the reserve regulations and close the loophole allowing pilots to sit on reserve all day and then get called to work all night. I would require by regulation scheduling that uses the best science available in planning rest around circadian rhythm factors. I would require all these regulations apply to FA's and maintenance engineers as well.

+1

I also believe in restricting number of consecutive redeyes and imposing longer minimum rest before and after such flights.

[Rotten Apple #1]

Thank you Martin and Rockie.

Rockie, it might be that our two operations are too far apart in types of flying/route etc to compare some things.

i.e. WJ pilots don't do reserve. We don't do augmented flights. The time zone thing is applicable to a degree to our Hawaii flights. And perhaps to our early east coast flights (I'm a BC resident).

I wouldn't know who to call at WJ to speak about fatigue and rest etc. I'm sure there are contacts that can be made easily. Anyway, good luck with improving things as you see them.

And no, don't count on my support necessarily. I'm content on spotting safety problems and using our SMS to report them. I believe in SMS at our level. As far as fatigue issues generally, I don't believe there is a one-size-fits-all solution for all pilots on all equipment in all countries. How would I know what a metro driver or air ambulance pilot needs at his/her work?

Right now I have the best job I have ever had and I'm not exactly in a rush to change things. An airline pilot job still beats most things out there that I can think of. It really is that good, for those that aren't so fortunate. I was lucky to have a mid career break from flying courtesy of the C3 shutdown. Perhaps that makes my perspective different from Martin's or Rockie's.

[Rockie]

You don't know who the people running your association are? Really?

[Mig29]

Thanks Martin for that excerpt from your company's duty limitations procedure.

It's good to see that some companies are above the crowed and TC regulations.

[ea306]

Hey Johnny, Long time no see.


One thing that would be a progressive step forward is if one day a focus could be put on rest periods that are circadian friendly.

Length of Duty Day and Window Of Circadian Low (EU OPS refer to as WOCL: 00:00am to 06:00am) are only part of the issue for fatigue. What gets overlooked is the length of time between duty periods.

At times I have come to the conclusion that some schedulers seem to think that if 12 hours off duty is good....then 24 must be even better!....uh...not so much!

24 hours rest between Off Duty and On Duty is not so desirable. In fact...to the contrary. No matter what time your duty day starts.

If a 14 hour duty day is finished at say 4am or 5 or 6am and then one is scheduled to report for duty 24 hours later around those times; in that scenario your body is ready to go back to sleep just about the time when the alarm is going off..your body is not wanting to get up and certainly you will not be well rested for a new duty day. At least that is the way it is for me.

In a nutshell: One cannot be expected to get two proper nights sleep in a 24 hour period. This scenario holds true whether you fly 8 time zones or none.

Here is an example I have seen all too often over the years:
A 12 to 14 hour Duty Day ends at 5:00am, you are in a hotel by 6:15am and sleep from 7am to 2pm. (7 hours)...... Then after a few hours activity (5 hours later), you would need to get your night's sleep started by 7pm to wake up at 3am to be rested for duty starting at 4:00am. A 3am wake up for a 3:45am shuttle to the airport for a 5:00am departure. It's just an example, but I am sure you all get what I am saying. Typically I lay there awake and do not fall asleep until about 1am.....

Generally a 16 hour rest period or 32 hour rest period is easier on my sleep pattern than a 24 hour rest period.

Of course the CARS give no consideration to Circadian Rhythms and appropriate rest time between duty periods other than a minimum rest time between duty periods.

Thoughts Guys?


David

[jjj]

ea306, excellent post.

Johnny D, excellent posts.

Rockie, Johnny Dangerous makes a few good points that seem to be lost on you. Waiting for regulatory change to filter back down to your organization to effect positive change is rather futile in the short term. WS manages duty rules/rest issues internally. Effecting change is the
responsibility of the operator. Every operator has the freedom to manage rest scientifically and schedule to a higher standard that the CARS. WS does not schedule to the limits of the CARS. Mistakes have been made but eventually the flawed pairings get filtered out.

As far as participating in regulatory change, the ACPA and the WJPA stay in touch.

The organizations that really need the regulatory change are the ones who don't take the interests of their pilots to heart.

Later.

JJJ

[Rotten Apple #1]

Rockie, I mean this very sincerely, so think about what it implies when I say: "WestJet (the corporation) employs me, not the WJPA".

If I have a problem with anything, my first go-to call/email is to a management level employee. Or I utilize the means that the company has put at my disposal.

I certainly respect the work done on my behalf by the members of the WJPA executive, and I could give you a couple of names off the top of my head of people who have been involved with it for a number of years. But it's the company to whom I look for guidance from or to forward flight safety concerns to.

It's been a learning process for me, coming from a couple of unionized outfits, to learn to trust that my managament has my interests at heart. But it has come to that realization for me. For a number of reasons.

Gotta go. Leaving Kelowna in an hour and a half on a port pairing with a YYT layover tonight of 30 hours. Saturday morning departure at 0620 local. Back home Kelowna Saturday at 11:00 a.m.

I'll let you know about the fatigue thing leaving YYT. Car rented for tomorrow to tire myself out sightseeing, for an early bedtime tomorrow night.

John