Det Norske Veritas
Preliminary Analysis of
Impacts from Future Potential
FTL Regulatory Changes for
EMS
Report for EASA
Report D2 No: 3
23 August 2012
23 August 2012
Preliminary Analysis of Potential Regulatory Impacts - EMS i
EASA DNV & Circadian
DET NORSKE VERITAS LTD.
Preliminary analysis of impacts from future potential Palace House
FTL regulatory changes for EMS 3 Cathedral Street
for SE19DE London
Tel: +44 (0)20 7357 6080
EASA
Fax: +44 (0)20 7357 6048
Registered in England
Company No. 1503799
Report No.: D2, version 3
Indexing terms: Flight Time Limitations (FTL), Fatigue Risk, Emergency Medical Services (EMS)
Summary: This report is revised Deliverable D2.
Prepared by: Edward Smith Jena Pitman-Leung
Principal Consultant, DNV Consultant, Circadian
Steve Goodwin Acacia Aguirre,
Director, Circadian Medical Director, Circadian
Verified by: John Spouge Martin Moore-Ede
Principal Consultant, DNV CEO, Circadian
Approved by: Edward Smith
Principal Consultant, DNV
Date of issue: 23rd August 2012
Project No: PP027950 EASA Project No: EASA.2010.FC06-SC001
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Contents
1.0 Introduction ................................................................................................. 1
1.1 Background................................................................................................... 1
1.2 Objectives of D2 Report ................................................................................ 1
1.3 Scope of D2 Report ...................................................................................... 1
1.4 Structure of this Report - Deliverable D2 ...................................................... 2
1.5 Acknowledgements....................................................................................... 3
2.0 Methods for Analysing Impacts................................................................. 4
2.1 Analysing Safety Impacts ............................................................................. 4
2.2 Analysing Economic Impacts ........................................................................ 6
2.3 Analysing Social Impacts .............................................................................. 9
3.0 Hazard Identification ................................................................................ 11
3.1 General Fatigue Factors and EMS Specifics .............................................. 11
3.2 Helicopter EMS (HEMS) ............................................................................. 16
3.3 Aeroplane Emergency Medical Services (AEMS) ....................................... 23
4.0 Fatigue Risk in HEMS and AEMS Operations: Literature Review ........ 31
4.1 Duration of Duty Shift and Time Awake ...................................................... 31
4.2 Time of Day Effects and Night Duty ............................................................ 35
4.3 Cumulative Effects of Multiple Consecutive Duty Shifts.............................. 39
4.4 Sleep and Rest ........................................................................................... 42
4.5 Standby ...................................................................................................... 44
4.6 In-Flight Rest and Flightdeck Napping ........................................................ 45
4.7 Periodic Extended Rest .............................................................................. 47
5.0 HEMS Analysis.......................................................................................... 49
5.1 Duration of Duty Including Extensions ........................................................ 49
5.2 Time of Day Effects and Night Duty ............................................................ 56
5.3 Cumulative Effect of Multiple Consecutive Duty Shifts ............................... 60
5.4 Sleep/ Rest Off-Duty and Relaxation/ Napping On-Duty ............................ 65
5.5 Pilot in Command Discretion....................................................................... 72
5.6 Positioning and Travelling ........................................................................... 72
5.7 Circadian Disruption Due to Mixing Night and Day Shifts ........................... 73
6.0 AEMS Analysis.......................................................................................... 74
6.1 Duration of FDP and Extension – Non Augmented Crews ......................... 74
6.2 FDP Extension With Augmented Crew ....................................................... 80
6.3 Time of Day Effects and Night Duty ............................................................ 84
6.4 Home Standby ............................................................................................ 85
6.5 Pilot in Command Discretion....................................................................... 89
7.0 Conclusions .............................................................................................. 90
8.0 References ................................................................................................ 91
9.0 Acronyms/ Abbreviations ...................................................................... 100
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Appendix 1 EMS Safety Data
Appendix 2 CAS Modeling
Appendix 3 EMS Operational Data
Appendix 4 Example Shift Patterns, AEMS and HEMS
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Executive Summary
Introduction
A rulemaking task (hereafter referred to as RMT.0346) has started at the beginning of 2012
for the development of Flight Time Limitations and rest requirements (FTL) for Emergency
Medical Services (EMS). As part of this task a Regulatory Impact Assessment (RIA) has to
be developed. Under framework contract EASA.2010.FC06, EASA has requested that
DNV/Circadian conduct some preparatory data collection and preliminary impact analysis to
assist the future work on the RIA.
The focus of this report has been on the safety, economic and social impacts of potential
future rule changes for EMS. It addresses aeroplane and helicopter EMS (AEMS and
HEMS).
Method
For the safety impact analysis the approach has been as follows:
• Relevant fatigue hazards have been identified for HEMS and AEMS (preliminary –
this will need to be reviewed during the related rulemaking task process);
• Key issues relating to the hazards which may form part of future FTL regulatory
changes have been considered from a safety perspective; and
• These considerations have been based on scientific literature, if available, and the
use of Circadian’s CAS model to see how key parameters (e.g. shift duration) impact
on fatigue levels.
For the economic and social impact analyses, we have:
• Identified what are considered likely to be potential FTL changes with the most
significant economic and social impacts;
• Described the effects qualitatively and listed factors which are likely to affect the size
of the economic and social impact; and
• For selected impacts illustrated a process that would allow estimates of the scale of
the impacts once more robust data have been gathered.
Conclusions
EMS operations have certain higher risk characteristics relative to other aircraft operations
such as time pressures to reach and transport patients and flights made at short notice with
potentially challenging topographical features and weather conditions. In addition there are
aspects of flight time limitations and rest provisions that could lead to fatigue and increased
risk, e.g. requirements to extend a duty period to respond to an emergency.
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It is difficult to draw firm conclusions about the actual record of controlling fatigue risk in EMS
operations in Europe due to potential under-reporting of fatigue as a causal factor of
accidents/ incidents. The scientific literature and the modelling described in this report
indicate that operating to the extremes of the national FTL ranges1 currently allowable in
Europe could have a significant impact on fatigue and alertness. Hence harmonisation of
FTL provisions is likely to have safety impacts; in particular if the higher risk bounds of the
ranges are reduced there will be positive safety impacts.
With respect to economic and social impacts a large number of potential FTL changes have
been considered including harmonisation of:
• Maximum shift/ FDP durations
• Flexibility for shift/ FDP extensions due to EMS events
• Block hours over different time periods
• Extended rest requirements following extended shifts/ FDPs
• Availability of relief crews for HEMS night shifts
• Number of consecutive HEMS shifts (day/night)
• Periodic increases in rest
• How standby contributes to FDP and cumulative duty hours
• Reduced rest provisions
• Augmented crew arrangements.
This report provides information and preliminary analysis to be considered for the RIA
development for RMT .0346 on FTL for EMS with a view to assist in an overall balanced
assessment of safety, economic and social impacts.
1
The ranges in European EMS FTL provisions are described in tables in report D1. For AEMS, Table
3.2 presents the range of maximum FDPs with extensions which can exceed 18 hours under special
conditions, Table 3.3 contains the range of rest arrangements and Table 3.5 presents in-flight rest
arrangements and ranges of FDP durations with augmented crews. For HEMS, Table 3.6 indicates a
wide range of basic maximum FDPs and duty durations, Table 3.7 presents the range of rest
arrangements (basic, reduced and extended recovery) and Table 3.8 contains the range of
cumulative duty and block hours limits. Further FTL details are available in Appendix 2 of report D1.
These ranges are further described in Section 5 for HEMS and Section 6 for AEMS in this report.
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1.0 Introduction
1.1 Background
In December 2010 the European Aviation Safety Agency (EASA) published the Notice of
Proposed Amendment (NPA) No. 2010-14A on ‘Implementing Rules on Flight and Duty Time
Limitations and Rest Requirements for Commercial Air Transport (CAT) with Aeroplanes’.
Following extensive consultation the Comment Response Document (CRD) to NPA 2010-
14A was published in January 2012. Within the CRD is a Draft Opinion of EASA, Annex III,
PART-ORO (ORGANISATION REQUIREMENTS) covering Subpart — Flight and duty time
limitations and rest requirements. Section 1 of this contains General FTL requirements and
Section 2 is for Commercial Air Transport Operators. Also within the CRD is a Certification
Specification (CS) for Commercial Air Transport by Aeroplane — Scheduled and Charter
Operations, designated FTL 1.
The CRD has placeholders for Certification Specifications FTL 2, 3 and 4 covering
Emergency Medical Services (EMS) by aeroplane and by helicopter, Air Taxi and Single
Pilot Operations by aeroplane and other CAT operations by helicopters respectively.
A rulemaking task has started at the beginning of 2012 for the development of FTL for EMS.
The rulemaking task for Air Taxi and Single Pilot will begin third quarter of 2012 and the one
for other CAT operations by Helicopters is to follow in 2013.
To support the development of these rules EASA procedures require the preparation of
Regulatory Impact Assessments (RIAs) similar to the one published in NPA 2010-14A.
These RIAs will be undertaken with the support of the respective Rule Making Groups
(RMGs).
Under framework contract EASA.2010.FC06 EASA has requested that DNV/Circadian
conduct some preparatory data collection and preliminary impact analysis to assist the future
work on the RIAs. Prior to the current report DNV/Circadian have produced Deliverable D1
which was a survey from eight European NAAs of FTL provisions used for EMS in their
States.
1.2 Objectives of D2 Report
The main objective of this report, Deliverable D2, is to produce preliminary analysis of the
impacts of potential future FTL regulations concerning EMS. This analysis is intended to
assist the RMG on EMS in their future discussions, the development of potential regulatory
options and the preparation of the RIAs.
1.3 Scope of D2 Report
The scope of this preliminary analysis is to study, in the context of future potential FTL
proposals:
• Safety impacts;
• Economic impacts; and
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• Social impacts.
In the future RIAs other impacts including environmental, the degree of proportionality
between the proposed measures and the impacts and the impact on regulatory
harmonisation will also need to be taken into account.
It is not the purpose of this report to develop options for regulatory changes – this will be
undertaken in future RMT activities. Hence rather than analyse the impact of defined
options, in this report we look at key issues/ parameters (e.g. the duration of Flight Duty
Period, FDP) and analyse how safety, economic costs and social impacts will vary if this
issue/ parameter is changed. This will assist the future choice and analysis of options.
No attempt is made in this report to combine the analysis of different impacts (e.g. safety
and economics) via one of the accepted RIA methods such as multi-criteria analysis. This is
to be completed as part of RMT .0346 activities.
This report addresses aeroplane and helicopter EMS (AEMS and HEMS). Future reports
will cover:
• Air Taxi and Single Pilot Operations (Aeroplanes) – Deliverable D3.
• Other Commercial Air Transport Operations by Helicopters – Deliverable D4.
Ultra Long Range (ULR) operations are used by some AEMS operators in Europe but are
considered ex-scope in this report. ULR operations will be subject to a separate Rule
Making Task in the future. Also the combination of AEMS and Air Taxi operations are not
analysed in this report.
This report considers EMS crew covered under FTL as pilots and technical crew members.
1.4 Structure of this Report - Deliverable D2
The rest of this report is structured as follows:
• Section 2 provides an overview of how the preliminary impact analysis has been
conducted.
• Section 3 identifies and classifies HEMS and AEMS fatigue hazards.
• Section 4 is a literature review covering aviation references relevant to EMS and
general industry references on shift work as this is considered particularly relevant to
HEMS operations.
• Section 5 analyses the key HEMS hazards and the main issues related to these
hazards.
• Section 6 analyses the key AEMS hazards and the main issues.
• Section 7 presents conclusions.
• Sections 8 and 9 provide references and acronyms.
• The Appendices contain supporting data namely:
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o Appendix 1 – EMS Safety Data, descriptions of fatigue aspects of relevant
accidents.
o Appendix 2 – Circadian Alertness Simulation (CAS) modeling description.
o Appendix 3 – EMS operational data on numbers of missions, aircraft, crew,
operators etc. (partial, not a comprehensive, picture of Europe).
o Appendix 4 – example HEMS and AEMS working patterns.
1.5 Acknowledgements
Large amounts of information was provided by representatives of the eight surveyed NAAs,
i.e. Czech Republic, France, Germany, Norway, Poland, Spain, Switzerland and the UK. In
addition, when NAAs were not able to respond they provided details of operator personnel
who were able to fill in gaps. We would like to thank all these people for their time and
assistance.
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2.0 Methods for Analysing Impacts
2.1 Analysing Safety Impacts
A direct method for analysing safety impacts from FTL regulatory changes would be:
• To estimate current safety risk levels in European EMS operations from appropriate
accident/ incident data.
• To analyse how potential changes to FTL regulations would affect this historical risk
estimate either based on relevant data or expert judgement.
A problem with this direct approach, as revealed in the NPA 2010-14 RIA (EASA, 2010) is
that:
• The data are statistically insufficient to directly deduce potential benefits of rule
changes;
• The data are statistically insufficient to detect current and future safety risks,
especially as fatigue related events may be masked under “human factor-related
incidents” or they are not reflected at all in these data.
Two European EMS accidents reports which refer to fatigue (or the possibility of fatigue) are
described in Appendix 1 from public domain sources. In addition EASA’s Safety Analysis
Section conducted a search of the EASA copy of the ICAO ADREP data base. This
uncovered one further European accident and 2 non-European EMS occurrences where
fatigue appears to have been a factor. These 5 events equate to 1.3% of the 395 EMS
occurrences in the data base. Four of these five events were fatal accidents. 28% of the
395 EMS occurrences in the data base were fatal accidents. Thus fatigue appears to be a
contributory cause in 3.6% of fatal EMS accidents. These relatively low percentages for the
contribution of fatigue to overall occurrence and accident rates should be treated with some
caution for the reasons noted above; in particular reports may not identify fatigue even
though it could have been a factor to some degree.
One event from 2005 in the UK (described in Appendix I) reveals the potential difficulty of
pilots on home standby managing their rest so that they do not become excessively fatigued
when they are called out, particularly at night. Another occurrence was also related to a pilot
remaining awake all day before a helicopter nighttime shift.
Even with the caveats about under-reporting of fatigue as a causal factor it would appear
from the occurrence data that the controls that have been in place to manage fatigue in
European EMS have generally been effective . Compared to the social benefits from EMS
operations in terms of patient safety and health (see below), the overall safety balance (flight
safety v patient safety) is very positive.
Because of this lack of data relating to the exact contribution of fatigue a similar approach to
that adopted in the NPA 2010-14 RIA has been adopted in this report, i.e.:
• Relevant fatigue hazards have been identified for HEMS and AEMS (preliminary –
this will be reviewed during the RMT.0346 process);
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• Key safety issues relating to each hazard which may form part of future FTL
regulatory changes have been considered from a safety perspective;
• These considerations have been based on scientific literature, if available, the use of
Circadian’s CAS model (see Appendix 2) and Circadian’s expertise in the field of
fatigue.
The CAS software models alertness based on three physiological processes:
• circadian time of day;
• sleep-wake balance and sustained wakefulness; and
• sleep inertia.
Based on the hours worked, the CAS model estimates sleep duration and placement around
these restrictions. Within the hours worked CAS can apply varying degrees of alertness
decrease to emulate varying workloads. For fixed wing operations CAS assumed higher
workload during the take-off and landing phase of the flight. For helicopter operations the
entire flight was assumed to be more demanding and more fatiguing.
CAS then provides simulation results as either direct alertness averages per given time
period (usually duty periods) or an aggregate Fatigue Score which summarizes the entire
pattern into one number.
To establish a consistent basis for comparison between the multiple diverse duty-rest and
scheduling options considered in this study the following assumptions have been made in
the CAS settings used for this analysis.
1. The settings are based on the average working age person, and individual variations
in circadian chronotype (e.g. morningness-eveningness, unrestricted sleep duration,
sleep quality, adaptive flexibility of circadian sleep-wake pattern and napping
propensity) are not considered. Thus actual fatigue scores and alertness levels may
be higher or lower than estimated in this CAS analysis depending on the individual
chronotype of each individual. Much of sleep science research has been based on
college students, as a matter of convenience; but this population has a significantly
different circadian sleep profile compared to the majority of working age (25-65 year
old) subjects. We have based our modeling on data from this post-college age
population.
2. It is assumed that no active fatigue risk mitigations are in place, and the individuals
modeled act as a person not trained and or practicing sleep-alertness management.
Thus with populations of individuals who are actively practicing fatigue risk
management, this CAS analysis will overestimate the fatigue score and
underestimate the levels of alertness.
The safety impact analyses are described in Section 5.0 for HEMS and Section 6.0 for
AEMS.
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2.2 Analysing Economic Impacts
2.2.1 Overall Scale of EMS Activity
Based on the data that could be collated, approximately 200,000 HEMS and AEMS missions
are flown annually in Europe. There are over 360 HEMS helicopter bases in Europe with
additional fixed-wing ambulance bases chiefly providing cross-border or inter-continental
services such as medical repatriation. (http://www.ehac.eu/index.html).
Extra details about activity levels were sought from the eight States surveyed in D1 and this
was supplemented by data available on public websites. Annual missions by State are
summarized in Table 2.1 below. Not all the surveyed States were able to provide data. The
values in Table 2.1 account for about 75% of the estimated 200,000 missions per year in
Europe.
Table 2.1: Annual Missions By State (partial picture only)
State HEMS AEMS Total Comments
15000 private Minimum estimate for HEMS, AEMS
France +11800 public data difficult to obtain
Germany 84671 1020 85691 Based on data from 3 operators
Data based on only 1 operator.
Netherlands 2100 Assuming 2 flights = 1 mission.
Data based on 1 operator and
military missions. Another operator
probably contributes about half as
Norway 10663 8988 19651 much again in Norway.
Poland 4417 327 4743 Assuming 2 flights = 1 mission.
Data based on 1 operator. Two
Switzerland 10797 1052 11849 other operators in State.
UK 17500 1500 19000 Minimum value for AEMS
Total
(rounded) 157000 13000 170000
Appendix 3 has more details on numbers of aircraft, crew and operators.
2.2.2 Business Models
Appendix 3 shows that there are many different EMS operators in Europe. These operators
have a variety of business models which affect their costs. The different EMS business
models in Europe include the following options, sometimes in combinations:
• Government funded (via Civil and Military), examples include:
o Scottish Ambulance Service is the UK’s only government funded air
ambulance service.
o Poland’s LPR is funded by the government through the Ministry of Health but
run independently.
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o Helicopters operated by the Ministry of the Interior in Germany are staffed by
German Police pilots performing emergency responses when required.
o Royal Norwegian Air Force provides an air ambulance service.
o Norwegian Luftambulanse is funded primarily by grants from four regional
health authorities.
• Donation/ Charity based, e.g.:
o The air ambulance service in England and Wales is funded by charities
organized into regions.
o REGA in Switzerland is non-profit receiving no government subsidies and
obtains funds from patrons and donations as well as fees for service from
insurance companies and liable parties.
o The DRF’s AEMS and HEMS operations in Germany are not completely
covered by public health insurance and also need the support of sponsoring
members and donations.
• Fee based – in this model operators charge fees for their EMS services. These fees
can be covered by travel or health insurance companies, liable parties or public
health services. Some organisations mix this model with additional donations as
noted above.
• Independently supported – a business or outside organization can fund the EMS
service. An example of this is ADAC, Germany’s largest automobile club, which
funds the operation of many air ambulances.
• Shared cost model – some EMS operators share aircraft, pilots and facilities with
other organisations. Examples include the UK’s Wiltshire and Sussex Air Ambulance
services which part share their helicopter operations with the Police.
As well as the different business models there are other factors that will affect operating
costs around Europe and between different operators:
• Different types of mission in different States (e.g. aiding a ski injury as compared to a
road traffic accident);
• Different utilization of crews – in some locations close to a high density of people and
roads for example pilots may fly more missions per unit time than a pilot based in a
remote location;
• Whether medical staff are included within the overall personnel costs of an EMS
operator or whether they are outside funded within health care services;
• Whether crew and facilities are shared with other operators (e.g. police) and whether
crew are leased or are full time personnel.
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2.2.3 Crew Cost Estimates
The main impacts of FTL and rest regulatory changes are likely to be on crew costs.
Therefore the sections below focus on this and look at data on the percentage contribution to
overall operating costs of crew costs. Crew costs cover salary and non-salary such as
pensions. Any changes in crew numbers will also impact costs associated with recruitment,
training and checking of crew.
Given the many business model variations and other factors listed above a range of
operating costs is to be expected. The percentage contribution of crew costs to overall
operating costs will also be expected to vary.
Estimates for this percentage contribution have been obtained directly from NAAs and
operators. All 8 States were asked. Some States referred us to operators for this
information.
Table 2.2: Estimates of Crew Costs As Percentage of Overall Operating Costs
State/ Operator % contribution to overall Comment
operating costs from
crew related costs
State 1 15% Estimate for AEMS based
on data from an operator
and judged appropriate
also for HEMS
Operator 1 20% Estimate based on AEMS
Operator 2 32% For HEMS
Operator 3 18% (range 12%-24%) Estimated based on total
personnel costs from
Annual Report and
assumptions about crew
costs vs average personnel
costs
Operator 4 20-25% For HEMS
Operator 5 11% For HEMS
Operator 6 14% For AEMS
A number of annual reports from operators have been reviewed2 but crew costs are not split
out as a separate item in the accounts.
Another method of deriving crew related costs would be via pilot salary surveys. A
comprehensive survey, covering many different types of operations including EMS was
2
Including those of Norsk Air Ambulance, REGA, Scottish Ambulance Service and Yorkshire Air
Ambulance
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carried out in the US (Professional Pilot, 2011). However no equivalent European survey
has been found.
It should be noted that there could also be other more subtle economic impacts associated
with changes to FTL and rest requirements, e.g.:
• EMS crew jobs could be made less or more attractive, for example, by changing the
number of rest days available, affecting the number of flying hours or leading to
changes in salary.
• In areas where there is competition for helicopter crew, e.g. where EMS is competing
with the offshore industry (where salaries are generally higher), this could lead to a
shortage of crew for EMS with a consequent knock-on impact to EMS service
provision.
• If there is a need for more crew arising from FTL changes it may be a challenge to
find such crew from the immediate locality. It may be difficult for crew to travel from
further afield depending on FTL constraints regarding travel times.
• The impact on the number of flying hours can also affect job satisfaction and how
motivated/ bored personnel become.
In the absence of more robust data, these impacts are not considered explicitly in the
sections below.
2.2.4 Analysis Method for HEMS and AEMS
It is not possible to analyse all possible economic impacts of all conceivable future FTL
regulatory changes. Therefore the subsections under HEMS (Section 5.0) and AEMS
(Section 6.0) have for the safety issues identified under each hazard:
• Identified what are considered likely to be those FTL changes with the most
significant economic impacts;
• Described the effects qualitatively and listed factors which are likely to affect the size
of the economic impact; and
• For selected impacts illustrated a process that would allow estimates of the scale of
the impacts once more robust data have been gathered.
2.3 Analysing Social Impacts
As noted above, the overall social impact of EMS in Europe has been very large in terms of
safety and health benefits to ill and injured persons. The detailed data from States and
operators shows approximately 1 person treated/ transported per mission and hence the
200,000 missions per year translates into millions of patients attended and transported over
the last 10 years in Europe. The literature (e.g. Taylor et al, 2010) indicates a widespread
range (0% to 22%) in EMS effectiveness in terms of percentage of lives saved per mission.
The studies of EMS effectiveness have lots of variations including:
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• Location type such as dense urban infrastructure, rural infrastructure, etc. One of the
studies that found 0% benefit was in London UK, another was in Nova Scotia,
Canada.
• Patient groups – e.g. one US study focused on obstetric patients only whereas others
looked across all patient types.
• Criteria – the study from Varkaus Finland quotes “HEMS attendance was ‘life saving
or beneficial’ in 22% of patients – so 22% may be an overestimate for saving lives.
The paper by Taylor et al (2010) makes clear that it is very hard to compare these studies:
“Given the variation inherent in the health systems in which HEMS operate, synthesis and
extrapolation of study findings across differing health environments is difficult. To address
economic and clinical evidence in relation to HEMS, future research that is tailored to
account for local system factors is required.”
If the average value for the percentage of lives saved per mission is taken to be the middle
of the range above, 10%, it can be inferred that a very large number of fatalities have been
averted through EMS.
Clearly, given this very large benefit in terms of patient safety, the impacts of proposed FTL
changes on EMS service provision need careful analysis in future RMT activities. A
proposal to improve flight safety via an FTL change could potentially cause a degradation in
EMS service provision and reduction in the number of patients treated/ transported.
The analysis method for social impacts has been analogous to the one above for economic
impacts, i.e.
• Identified what are considered likely to be those FTL changes with the most
significant social impacts;
• Described the effects qualitatively and listed factors which are likely to affect the size
of the social impact; and
• For selected impacts illustrated a process that would allow future estimates of the
scale of the impacts on patient safety.
The focus has been on patient safety and health. There could be other social impacts, e.g.:
• Working conditions for crew;
• Employment impacts (job creation/ losses), closely linked to economic impacts;
• Need for relocation or more/ less travelling as a result of FTL changes; and
• Impact on social life and work/ life balance.
These have been identified where relevant.
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3.0 Hazard Identification
3.1 General Fatigue Factors and EMS Specifics
Fatigue is an impairment of mental and physical function manifested by a cluster of
debilitating symptoms, usually including excessive sleepiness, reduced physical and mental
performance ability, depressed mood and loss of motivation, which may result from a variety
of causes including:
• Sleep deprivation/circadian phase effects: Fatigue develops as the result of an
extended time awake (acute sleep deprivation), or reduced time asleep, or disrupted
or poor quality sleep (partial sleep deprivation), time awake in the Window of
Circadian Low (WOCL) or from the cumulative effect of multiple days with shortened
or disrupted sleep such as may occur in jobs with extended work hours, irregular
schedules or with night duty (chronic sleep deprivation).
• Heavy stressful physical or mental effort: Fatigue occurs as the result of
extended hours of work with heavy muscular activity (e.g. marathon runner),
continued stress or danger (e.g. combat fatigue) or intense mental exertion (e.g.
EMS operations in challenging conditions) which occurs either during the task or as a
rebound effect after the task, in proportion to the relative fitness (and/or prior training)
of the individual.
• Sleep disorders: Fatigue manifested as excessive daytime sleepiness is the most
common presenting complaint in sleep disorders, such as obstructive sleep apnoea,
restless legs syndrome, narcolepsy or most of the other 85 different sleep disorders
listed in the International Classification of Sleep Disorders (2005).
• Illness or disease: Fatigue is common in many diseases and illnesses (ranging
from flu to cancer) which may occur as a direct result of the metabolic or other
systemic pathophysiological disturbances of that disease, as a secondary
consequence of sleep disturbances caused by other symptoms such as pain, nausea
etc., or as the primary presenting complaint (e.g. chronic fatigue syndrome).
• Therapeutic side-effect: Fatigue is a commonly listed side-effect of prescription or
over-the-counter pharmacological drugs, or may occur as the result of other
therapeutic interventions (e.g. surgical procedure).
• Stimulant drug usage: Fatigue often occurs as a person rebounds after the initial
euphoria, increased energy or “high” induced by illegal, over-the counter (e.g.
Redbull, NoDoz etc.) or prescription stimulant pharmacological substances.
Unlike the engineering use of the word “fatigue” which is used to describe irreversible failure
of a material as a result of stresses over an extended period of time, the medical definition of
“fatigue” usually refers to a loss of physiological and psychological function as a result of
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extended wakefulness, heavy work, excessive stimulation, illness or stress which can
usually be reversed in whole or in part by rest, sleep, treatment or recovery from the
condition that caused it.
For this report we will use the ICAO definition of fatigue:
A physiological state of reduced mental or physical performance capability resulting from
sleep loss or extended wakefulness, circadian phase, or workload (mental or physical
activity) that can impair a crew member's alertness and ability to safely operate an aircraft or
perform safety related duties.
In this report we have not considered sleep disorders, illness and disease, therapeutic side
effects or stimulant drug usage. Workload is considered in terms of its direct effects on
fatigue.
During sleep the human brain cycles through distinct stages, each characterized by changes
in the electrical activity of the brain. When we are awake and alert, the electrical brain waves
measured by electro-encephalography3 (EEG) are fast (13 to 35 cycles per second) and
random, but as we become drowsy the brain waves start to slow into a regular “alpha”
pattern (of 8 to 12 cycles per second), which is exaggerated when we close our eyes. The
first stage of sleep is when we start slipping into a semiconscious state, called stage 1 sleep,
characterized by a further slowing of the brainwave rhythm to the “theta” range of 3 to 7
cycles per second, but in which we remain vaguely aware of our surroundings. We may even
convince ourselves that we are still awake and in control of our consciousness - a dangerous
misperception if we are on duty in a critical job.
From stage l we progress unknowingly into stage 2, a light level of sleep in which bursts of
electrical activity called K-complexes and sleep spindles intrude into the EEG. Finally, after
30 to 40 minutes, we sink into the deepest stages of sleep (called stages 3 and 4) in which
the brain waves slow down to 0.5 to 2 cycles per second and are magnified in their
amplitude. These deep slow waves are called delta waves.
We do not linger for long in delta sleep. In fact, we tend to oscillate in a 90- to 100-minute
cycle between the lighter and deeper stages of sleep interspersed with bouts of dreaming in
which the brain waves suddenly speed up to an awake-like pattern and the eyes start
moving rapidly from side to side. This stage, called rapid eye movement (REM) sleep, may
occur four or times a night, building in duration as dawn approaches. Thus one may have
four or five distinct dreams per night.
The stage of sleep from which you awake determines your condition on arousal. If you are in
the deepest stages of delta sleep, you will feel groggy and disoriented on awakening, and
suffer significant “sleep inertia” or impaired functioning for ten or twenty minutes or more. If
you are in stage 1 or 2 sleep, you are much more likely to wake up alert and refreshed.
Likewise you are more likely to remember a dream if you awake during a REM sleep stage.
Those factors which are most likely to affect sleep deprivation and circadian phase effects
include:
3
the recording of electrical activity along the scalp
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1. Time of day according to the individual’s own circadian phase
An individual’s level of alertness and sleepiness varies over the course of the 24–
hour day in a predictable circadian (approximately 24-hour) pattern with the greatest
sleepiness in the early hours of the morning before dawn (typically 1AM-6AM), and a
second lesser period of sleepiness in mid-afternoon (often referred to the “post-lunch
dip” or the “siesta hour”). Numerous studies have shown that transportation and
other accidents caused by fatigue have a peak time of risk relative to circadian phase
around 1-6 AM and secondary time of risk approximately from 1-4 PM (Horne, 1995;
Langlois, 1985).
It is not the clock time on the wall that determines these daily biological cycles of
sleepiness and alertness. The time of day according to a person’s circadian
pacemaker (biological clock) is called the “circadian phase”, which is shifted by
exposure to light in other time zones or to a lesser extent during night duty activities.
Even in people who are not travelling across time zones, an habitual early bed time
and early arising time on both work days and weekends/rest days is associated with
an earlier (or “advanced”) circadian phase, and a pattern of maximum sleepiness and
alertness that is shifted to earlier hours, as compared to someone who habitually
stays up and sleeps in late, who will have a late (or “delayed”) circadian phase.
2. Chronotype of the individual
Individuals vary considerably in their orientation to day and night on a morningness-
eveningness scale and in their required sleep duration for recuperation (Duffy, 1999;
Horne, 1976; Aesbach, 1999). Morning types tend to rise early and they feel and
perform best during the morning hours. Evening types tend to rise late in the morning
and they feel at their best late in the evening. It has been shown that these
characteristics are genetic in nature, and independent of age, sex and ethnic heritage
(Katzenberg,1999). As discussed earlier we have used default settings representing
the average person in this analysis and have not simulated individual chronotypes.
3. Length of time since awakening from last sleep episode
When a person first wakes up from sleep there is a period of grogginess or
sleepiness that resolves typically in less than half an hour. This is referred to as
“sleep inertia”. Once a person has fully recovered from the residual sleep inertia from
his or her last sleep period the drive for sleep builds with time until the next sleep
period occurs. Eventually the extended time spent awake results in a strong sleep
pressure. This is referred to as the homeostatic drive to sleep. However, sleep
propensity, or the likelihood of falling asleep, is determined by a combination of the
homeostatic drive and the other factors listed here. As a result sleep propensity does
not simply relate to the length of time awake which drove the original FDT
regulations. In reality, the circadian and homeostatic drives to sleep interact. This
produces peaks in relative alertness in mid-morning and early evening, separated by
an early afternoon “post-lunch” dip in alertness or siesta hour. This circadian-
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homeostatic interaction also causes the precipitous drop in alertness after midnight
when an employee begins his first night duty period following several days of night-
time sleep and daytime wakefulness.
4. Duration of the previous consolidated sleep period
The effectiveness of a sleep period in quenching the level of sleepiness that an
individual has accumulated over the previous day(s) is determined by the sleep
period’s duration, as well as by the quality of sleep obtained (see factor #6 below).
The average adult needs 7-8 hours of sleep per day to maintain average levels of
daytime alertness. However, there are considerable inter-individual differences, with
some individuals needing as much as 9 hours per day, while others only need 6
hours. Significant increases in daytime sleepiness are found for most people when
the nocturnal sleep length is reduced below 5 hours, or when reduced sleep duration
occurs for two or more successive nights. In the CAS analysis we have used default
settings representing the average person.
5. Timing of sleep episode
In addition to the duration of sleep, the timing of the sleep episode is a key factor.
Due to the influence of circadian phase, sleep is more effective and its quality better
at some times of the day than at others. As noted above, it is also important to
consider the time of day according to a person’s biological clock, (i.e. his or her
“circadian phase”) not only in predicting or assessing the level of sleepiness, but also
in judging the duration and quality of sleep that is obtained by sleeping at a particular
time of day.
Because of the strong effect of the circadian system, sleep duration is also highly
dependent on the circadian time of day. For example, there are certain times of day
when it is difficult to obtain more than four hours sleep, even under ideal conditions,
after extended periods of time awake, and with the most highly motivated individual.
The studies of Akerstedt and Gillberg (1986) are particularly instructive. They studied
working age subjects (comparable to EMS personnel) who were given an opportunity
to sleep under ideal conditions (quiet comfortable bedroom) during rest periods which
started at various times of day or night. When the rest period began at 11PM at the
end of a normal day of 16 hours continuously awake, they slept on average for 8
hours, as one would expect given the unlimited sleeping opportunity. However the
later the rest period began after 11PM, the shorter was the sleep duration as a result
of the strong circadian time of day effect. Thus when the rest period began at 3 AM
(after 20 hours continuously awake) they achieved only 6.5 hours sleep, when rest
began at 7 AM (after 24 hours continuously awake) they obtained only 4.5 hours
sleep; when rest began at 11 AM (after 28 hours continuously awake) they got only 4
hours sleep.
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6. Quality of sleep in the previous sleep period
The quality of sleep at night also influences the sleepiness level on the subsequent
day. When sleep is disturbed by deviations from typical sleep characteristics, this
results in increased sleepiness the following day.
Many factors may influence these characteristics of sleep quality, including the time
of day or night that sleep is attempted, the environmental conditions in which one is
sleeping, and the existence of any clinical sleep disorders or other medical
conditions.
To ensure adequate sleep, the sleeping environment should be both physically
comfortable and psychologically conductive to sleep. People usually sleep better in
their own bedroom than in an unfamiliar environment. One of the most important
challenges many transportation employees face is the requirement to sleep away
from home. In other words a transportation employee sleeping in their own bed on
their regular nightly schedule and routine will have significantly higher sleep quality
than the same person sleeping away from home in unfamiliar circumstances at an
unusual time of day. In this analysis CAS takes into account the timing of sleep. It
does not consider the effect of sleep disorders.
7. Cumulative effect of sleep duration and quality over the past week
A person’s sleepiness level on a given day is most strongly influenced by the quality
and duration of the last sleep episode. However, the sleep pattern during the
preceding week will also affect sleepiness level. It is also well recognized that days-
off, where there is no substantial restriction on the opportunity for unrestricted sleep,
allow a person to recover fully from all accumulated sleep debt. The number of days
required depends on the level of sleep deprivation, but in most circumstances two
consecutive nights of sleep has been determined to be sufficient.
When a person follows a regular sleep-wake schedule, that is, going to bed and
waking up at approximately the same hour every day, this helps to synchronize his or
her sleep/wake and other circadian rhythms to that regular schedule.
Thus a regular daily pattern of bedtime and awake time, and a regular routine of
exposure to light and dark will cause a person’s circadian sleep-wake rhythm to
become optimally synchronized to the time of day that they are going to bed – even if
that time of day is not a typical or traditional time. This synchronization will promote
optimal sleep quality and consequently minimize sleepiness at the time of the day the
crew member wishes to be most alert.
In addition there are EMS specific factors that can impact on or combine with these fatigue
factors:
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• EMS operations are often time sensitive and crucial to getting a critically ill or injured
patient to a medical facility as efficiently as possible which may influence a flight crew
to fly under operational or fatigue related circumstances that they otherwise would
not. It should be noted that the effect of adverse operational circumstances might be
underestimated by a fatigued pilot.
• EMS operations are often conducted under challenging conditions, e.g. HEMS are at
low altitudes and under varied weather conditions. Operations can be in rural or
urban settings, in mountainous and non-mountainous terrain, during the day and
night and in IFR and VMC conditions. Remote sites may be unfamiliar to pilots and
for HEMS operations trees, buildings, wires and uneven terrain at remote sites can
cause high workload.
The UK AAIB report (AAIB, 2006) into a 2005 AEMS accident states:
“Air ambulance flights occupy a unique position within the public transport framework, and
the operation of such flights may at times entail a greater level of overall risk. Although air
ambulance flights are subject to the same regulations as other public transport flights, they
are, by their very nature, more likely to have to operate under adverse circumstances. Fixed-
wing air ambulance flights are also more likely to operate over the more remote areas of the
United Kingdom, where aerodromes tend to be smaller and less well equipped, and where
weather factors may be less favourable. Flights are often made at short notice outside of
normal operating hours, and with an additional time pressure on crews which is not present
with other types of operation.”
3.2 Helicopter EMS (HEMS)
The general characteristics of HEMS of relevance to fatigue and FTL are considered to be:
• On demand operations at very short notice
• Standby conducted at the HEMS base
• Multiple (very) short missions (could be as many as 20 short flights in a few hours)
• Mostly VFR operations often in unpredictable operational conditions to unknown
landing sites and under time pressure
• Night flights involving use of Night Vision Imaging Systems (NVIS)
• HEMS bases operated typically with fixed duty hour shifts. The fixed duty hour shifts
can depend on the latitude of the base as this influences daylight hours.
• Depending on emergency scenarios there may be a need to extend beyond the
planned FDP/ shift duration
• Some HEMS bases are daytime operations only – others operate 24/7
• Significant variability on FDP, duty times and rest times across European States (see
Report D1)
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• Generally single pilot aided by additional crew member conducting navigation and
other flight safety related tasks (could be a second pilot at night).
For more details on HEMS working patterns see Appendix 4.
Table 3.1 identifies hazards that appear relevant to HEMS. Potential mitigations have been
identified. Comments based on the information supplied by NAAs and operators about the
characteristics of HEMS have been included where relevant. These hazards and mitigations
are preliminary and will be reviewed during the future RMT .0346 process.
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Table 3.1: Preliminary HEMS Hazard Identification
Grouping Hazards and Descriptions Potential Mitigations Comments
A. Time awake/ 1. Duration of FDP/shift too a. Limits on maximum duration of HEMS shift/
Long (extended) shifts and FDPs are
Duration of duty long leading to fatigue FDP (including extensions)
allowed in some States and are likely
b. Limits on number of missions or daily flying
to be a potential peak fatigue issue.
(relating to homeostatic (including EMS related time
process principally) extension) c. Requiring full rest before an extended shift D1 shows significant variability
d. Extended rest after a long duration shift/ FDP between States.
See Literature Review in N.B. standby at HEMS base (after the event)
The impact of shift duration and the
Section 4.1. included in shift duration e. Limiting the frequency of long extended shifts
number of missions has been analysed
per week or per month (cumulative fatigue
in Section 5.1 and the impact of a
control)
break between missions.
f. FRMS (general – applicable to all hazards)
g. Relief pilot for single pilot operations when an The impact of shifts encroaching the
extension is invoked WOCL is considered in Section 5.2.
h. Prohibiting combining EMS shift extension
with extension due to split duty Impact of controlled naps considered
i. Limiting number of persons on aircraft during in Section 5.4.1.
extensions
j. Controlled napping and relaxation during
ground breaks
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Grouping Hazards and Descriptions Potential Mitigations Comments
2. PIC reacts to a. Maximum limits on PIC extension (duration
PIC discretion can be used to extend
circumstances on the day to and frequency)
FDPs/ shifts, to finish a mission or
extend FDP/shift b. A non-punitive process for a PIC to reduce a
return the helicopter to base. Could
excessively leading to shift duration and/or increase rest in the case
potentially lead to long duration duties.
fatigue of fatigue
c. Reporting to the NAA when the extension is
Considered in Section 5.5.
above a certain threshold
d. Guidance to the NAA on this subject
e. Training on fatigue to support PIC in the
decision process, e.g. the potential risks of
PIC extensions, techniques for self-evaluation
of fatigue, pressures likely to be encountered,
etc.
f. FRMS including awareness training for
commanders
3. On-ground break (“ad-hoc See Hazard A1 above + Use of on-ground breaks is used in
split duty”) used to extend some States to justify extension of
the FDP/shift excessively a. Establish minimum consecutive number of HEMS shift to durations considered in
leading to fatigue hours for break Section 5.1.
b. Establish how hours of the break contribute to
daily shift duty time or FDP
c. Suitable accommodation for the break
d. Take account of split duty for subsequent rest
calculation
e. Limitation on number of missions after the
split
4. Extended FDP/ shift due Not relevant to HEMS Not relevant to HEMS
to in-flight rest leads to
fatigue
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Grouping Hazards and Descriptions Potential Mitigations Comments
5. Ground duties in addition a. Limitations on combined flight and ground Included in HEMS shift duration
to flight duties extend day’s duties (included in HEMS shift durations) analysis in Section 5.1.
duties excessively.
B. Time of Day Effects 1. Night shifts leading to a. Napping before night shifts. See Section 5.2.
fatigue b. Limiting shift/FDP hours.
(relating to circadian c. Limit number of missions (flying hours) per N.B. Early starts and late finishes are
process principally) night shift. built into the shift patterns considered
d. Training on how to manage night shift work in Section 5.1
See Literature Review in (e.g. use of caffeine, meals, staying active,
Section 4.2. etc.) and when to recognize that one is
fatigued (e.g. to be wary of relaxation after
delivery of patient and ignoring level of
fatigue).
e. Availability of relief pilots to take over if a crew
member realizes they are too fatigued or if
flying hours limit is reached.
f. Using two pilots at night.
g. Controls over consecutive night shifts (see
Cumulative Fatigue below).
h. Additional rest
2. Circadian disruption – a. Extended and recovery rest See Section 5.7.
mixing night and day shifts b. Limiting mixing of night and day duties
3. Time Zone de- Not relevant to HEMS Not relevant to HEMS
synchronisation
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Grouping Hazards and Descriptions Potential Mitigations Comments
C. Cumulative 1. Cumulative fatigue arising a. Limitations on consecutive days and weekly See Section 5.3.
from consecutive day shifts duty hours The impact of a variety of existing
See Literature Review in b. Longer term cumulative limits HEMS shift patterns are analysed to
Sections 4.3 and 4.7. c. Minimum number of days off per month assess their impact on cumulative
d. Rest periods periodically extended fatigue.
e. Spreading out duty as evenly as possible – Any working pattern leads to a
difficult for on-demand EMS service combination of transient and
cumulative fatigue.
2. Cumulative fatigue arising See Hazards C1 + B1 for relevant mitigations + See Section 5.3.
from consecutive night shifts a. Special limits on consecutive night shifts
3. On-ground breaks during a. Take account of HEMS base standby time in See Section 5.4.1.
HEMS shifts not considered cumulative duty and rest calculations
adequately in cumulative
duty calculations
D. Rest and Sleep Off 1. Lack of rest opportunity a. Set minimum rest period and sleep See Section 5.4.2
Duty and rest at sub-optimal opportunity between duties
periods (in relation to basic b. Set minimum duration for reduced rest (if Includes insufficient time to rest/ sleep
(relating to homeostatic rest and reduced rest) used) in between shifts
process principally but c. Augmentation of rest and/or reduction in max.
affected by circadian FDP/shift following reduced rest
process ) d. Limit frequency of reduced rest occasions
e. Limit number of missions following reduced
See Literature Review in rest
Section 4.4.
E. Relaxation and Naps 1. Overlong nap and a. Awareness training about effect of length of Relaxation and napping mainly
On Duty insufficient time awake nap on sleep inertia considered as a mitigation to hazard
(relating to Sleep Inertia could lead to sleep inertia as A.1 and analysed in Section 5.4.1.
process principally) mission begins Role as a potential hazard considered
in literature in Section 4.6.2.
See Literature Review in
Sections 4.5 and 4.6.
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Grouping Hazards and Descriptions Potential Mitigations Comments
F. Positioning and a. Inclusion of positioning immediately before See Section 5.6
1. Positioning before an
Travelling flight duty in the FDP
FDP causing lack of rest
(related to time awake
and excessive time awake
and cumulative effects
and hence fatigue
and homeostatic process
principally)
a. Post-FDP positioning should be limited to See Section 5.6
2. Positioning immediately
prevent excessive duty day
after an FDP leading to
b. FDP and post-FDP positioning to be taken
excessively long duty
into account for subsequent rest period
periods with potentially a
cumulative effect
a. Nomination of a home base for each crew See Section 5.6
3. Excessive travelling time
member
b. Ensuring a protected 8 hour sleep opportunity
c. Counting travel time in excess of a limit (e.g.
60 minutes) as duty time (or positioning).
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3.3 Aeroplane Emergency Medical Services (AEMS)
The AEMS operations in Europe appear to be split into two broad types in terms of key
characteristics of relevance to fatigue and FTL.
1. Home standby. This appears to be the most commonly used form in Europe with the
following characteristics:
• Short call standby
• Possibly intercontinental flights
• Potentially long multiple sectors in FDP
• Potentially ULR (ex-scope in this report)
• Consequent use of augmented crews and in-flight rest
• Flight crews acclimatized to local time of departure zone
• AEMS pilots called out for duty on 25 - 60% of home standby days
• Flying (block) hours and duty time could be relatively low compared to that of air taxi
or airline pilots.
2. Airport standby. In a few locations AEMS is effectively providing a “HEMS-type”
service in areas where HEMS coverage is not practical because of the remote
location and large distances that need to be covered (e.g. Norway). It can be
characterized by:
• Short response times
• Shorter, primarily domestic, flights
• Varied shift patterns, different numbers of consecutive days and shift hours.
For both these types of standby the AEMS service:
• Is on demand operation upon short notice
• Can be multiple sectors
• Depending on emergency scenarios, may need to extend beyond planned FDP.
For more AEMS working pattern details see Appendix 4.
Table 3.2 identifies hazards that appear relevant to AEMS. Potential mitigations have been
identified. Comments based on the information supplied by NAAs and operators about the
characteristics of AEMS have been included where relevant. As with HEMS these hazards
and mitigations are preliminary and will be reviewed during the future RMT .0346 process.
Tables 3.1 and 3.2 also show where the hazards are covered in the report.
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Table 3.2: Preliminary AEMS Hazard Identification
Grouping Hazards and Potential Mitigations Comments
Description
A. Time awake/ 1. Duration of FDP too long a. Limits on maximum duration of FDP (including
Long (extended) FDPs are allowed in
Duration of duty leading to fatigue extensions)
some States and are likely to be a
b. Modifying FDP according to number of sectors
potential peak fatigue issue.
(relating to homeostatic (including EMS related and/ or limits on daily flying time
process principally) extension) c. Requiring full rest before an extended FDP D1 shows significant variability
d. Extended rest after a long duration FDP (after between States.
See Literature Review in the event)
The impact of FDP duration and
Section 4.1. e. Limiting the frequency of long extended FDPs
WOCL encroachment have been
per week or per month (cumulative fatigue
analysed in Section 6.1 and the impact
control)
of a break between missions.
f. FRMS (general – applicable to all hazards)
g. Relief pilot for single pilot operations when an
extension is invoked
h. Prohibiting combining EMS shift extension
with extension due to split duty
i. Limiting number of persons on aircraft during
extensions
j. Controlled napping and relaxation during any
ground breaks
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Grouping Hazards and Potential Mitigations Comments
Description
2. PIC reacts to a. Maximum limits on PIC extension
PIC discretion can be used to extend
circumstances on the day to b. A non-punitive process for a PIC to reduce a
FDPs, to finish a mission or return the
extend FDP excessively shift duration and/or increase rest in the case
aircraft to base. Could potentially lead
leading to fatigue of fatigue
to long duration FDPs.
c. Reporting to the NAA when the extension is
above a certain threshold
Considered in Section 6.5.
d. Guidance to the NAA on this subject
e. Training on fatigue to support PIC in the
decision process, e.g. the potential risks of
PIC extensions, techniques for self-evaluation
of fatigue, pressures likely to be encountered,
etc.
f. FRMS including awareness training for
commanders
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Grouping Hazards and Potential Mitigations Comments
Description
3. Extended FDP due to in- a. Maximum duration of FDP with augmented See Section 6.2.
flight rest (augmented crew) crew (including extensions) dependent on
leads to fatigue type of onboard rest facilities and number of
additional crew carried
b. Setting minimum standards for in-flight rest
facilities
c. Minimum rest period onboard required
d. Specifying minimum rest durations at
destination and home
e. Additional compensation time at home over
and above the standard rest time
f. Sleep opportunities at home base after long
missions (to mitigate home travel risks)
g. Promote and pay for use of public transport
after long missions
h. Limiting the frequency of such extended FDPs
with augmented crew
i. Limiting the number of sectors.
4. On-ground break used to a. Establish minimum consecutive number of Survey data (see Appendix 4)
extend the FDP excessively hours for break indicated that split duty is either never
leading to fatigue b. Establish how hours of the break contribute to used by AEMS operators or very
FDP infrequently. However, on-ground
c. Suitable accommodation for the break breaks have been modeled in Section
d. Take account of split duty for subsequent rest 6.1 and on-ground breaks considered
calculation in HEMS shift durations (Sections 5.1
e. Limitation on number of missions after the and 5.4.1).
split
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Grouping Hazards and Potential Mitigations Comments
Description
5. Standby at home followed a. Take account of standby time in maximum See Sections 6.1 and 6.4.
by FDP leads to excessive FDP
time awake b. Limit on standby duration N.B. Airport standby much less
c. Standby management procedures so operator common for AEMS compared to
Unpredictability of home avoids placing crew on repeated 24 hr HEMS (HEMS issues under Section
standby can cause duration standbys, and preferential use of 5.4.1).
difficulties in being fully persons on standby who should be better
rested before FDP rested.
d. FRMS and crew’s individual management of
rest during standby – a FRMS can help raise
crew’s awareness of the importance of
napping, avoiding heavy home working tasks,
etc.
6. Ground duties in addition a. Limitations on combined flight and ground AEMS pilots generally called out from
to flight duties extend day’s duties (included in HEMS shift durations) home standby. For AEMS based on
duties excessively. airport standby, see analysis of shift
duration including ground duties in
Section 5.1.
B. Time of Day Effects 1. WOCL encroachment a. Limiting maximum FDP duration based on See Sections 6.1 and 6.3.
WOCL encroachment
(relating to circadian
process principally) 2. Circadian disruption – a. Extended and recovery rest See Section 5.7.
mixing duty transitions b. Limiting mixing of night and day flights
See Literature Review in between early/ late/ night
Section 4.2. duties
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Grouping Hazards and Potential Mitigations Comments
Description
3. Time Zone de- a. Duty restrictions and rest (home and away) Even for AEMS missions involving
synchronisation based on number of time zones multiple time zone crossings, pilots will
b. Limit max FDP according to day time and generally stay acclimatised to home
degree of acclimatization base time as mission will involve either
c. Minimum time set before a crew would be back to back flights or minimum time at
considered time zone acclimatized destination to ensure patient is brought
d. FRMS of particular importance to take back as soon as possible.
account of time zone specifics and specific
route patterns of a long range AEMS operator
e. Limiting number of alternating east-west
rotations per month and providing additional
rest when these happen
C. Cumulative 1. Cumulative fatigue / sleep a. Limitations on consecutive days and weekly See discussions in Section 5.3;
debt builds up duty hours although in context of HEMS, build-up
See Literature Review in b. Longer term cumulative limits of fatigue over consecutive days/
Sections 4.3 and 4.7. Includes effect of FDPs on c. Minimum number of days off per month nights working and longer term
consecutive days/ nights d. Rest periods periodically extended cumulative limits in Section 5.3 are
(even though unlikely to e. Spreading out duty as evenly as possible – also of relevance to AEMS.
extend to several days due difficult for on-demand EMS service
to on-demand nature of f. Providing additional rest if frequency of FDPs N.B. States surveyed in D1 showed
service) encroaching WOCL exceeds a certain limit adherence to Subpart Q on cumulative
g. Limiting the frequency of WOCL encroached hours for AEMS. Annual hours for
FDPs – again potentially difficult for on- AEMS pilots are generally significantly
demand EMS service lower than for scheduled airline pilots.
2. Home standby not a. Take account of home standby time in See Section 6.4.
considered adequately in cumulative duty and rest calculations
cumulative duty calculations
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Grouping Hazards and Potential Mitigations Comments
Description
D. Rest and Sleep Off 1. Lack of rest opportunity a. Set minimum rest period and sleep See discussions in Section 5.4.2;
Duty and rest at sub-optimal opportunity between duties although in context of HEMS, analysis
periods (in relation to basic b. Set minimum duration for reduced rest (if of basic rest and reduced rest patterns
(relating to homeostatic rest and reduced rest) used) in Section 5.4.2 are of relevance to
process principally but c. Augmentation of rest and/or reduction in max. AEMS as well.
affected by circadian FDP following reduced rest
process ) d. Limit frequency of reduced rest occasions
e. Limit number of missions following reduced
See Literature Review in rest
Section 4.4.
E. Relaxation and Naps 1. Overlong nap and a. Awareness training about effect of length of Role as a potential hazard considered
On Duty insufficient time awake nap on sleep inertia in literature in Section 4.6.2.
(relating to Sleep Inertia could lead to sleep inertia
process principally) during flights
See Literature Review in
Section 4.5 and 4.6.
F. Positioning and a. Inclusion of positioning immediately before See Section 5.6
1. Positioning before an
Travelling flight duty in the FDP
FDP causing lack of rest
(related to time awake
and excessive time awake
and cumulative effects
and hence fatigue
and homeostatic process
principally)
a. Post-FDP positioning should be limited to See Section 5.6
2. Positioning immediately
prevent excessive duty day
after an FDP leading to
b. FDP and post-FDP positioning to be taken
excessively long duty
into account for subsequent rest period
periods with potentially a
cumulative effect
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Grouping Hazards and Potential Mitigations Comments
Description
a. Nomination of a home base for each crew See Section 5.6
3. Excessive travelling time
member
b. Ensuring a protected 8 hour sleep opportunity
c. Counting travel time in excess of a limit (e.g.
60 minutes) as duty time (or positioning).
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4.0 Fatigue Risk in HEMS and AEMS Operations: Literature Review
This section reviews the peer-reviewed research literature in operator fatigue with a special
emphasis on aviation operations, and on HEMS and AEMS operations where relevant
studies are available. The main contributors to operator/crew fatigue and their interactions
are discussed in the following sections.
4.1 Duration of Duty Shift and Time Awake
4.1.1 Overview
The relationship between duty length and fatigue is complex, and cannot be reduced to a
simple formula, as it is complicated by circadian phase, time awake since last sleep,
chronotype and the other factors discussed in Section 3.1.
The length of duty directly impacts the accumulation of fatigue whilst on duty since it goes
along with “time awake” which is directly related to fatigue. This “time awake” also explains
that the length of duty has to be looked at in conjunction with “time of day” since for night
duties sleep often ends hours before the duty start, whereas for day duty pilots usually start
with “freshly charged batteries” in terms of recent sleep. The length of duty also determines
at what time of day the opportunity for rest and sleep occurs. This is important since sleep
outside the window of circadian low is usually of lower quality and less beneficial.
When evaluating duty or shift duration, it should be noted that longer shifts not only affect
time on duty, but also may reduce the amount of time off between shifts, and impact sleep
duration and recovery. The amount and distribution of time off between both consecutive
work days and blocks of work days is an important factor of the shift system. Accumulated
sleep deprivation (i.e. a “sleep debt”) can occur during blocks of consecutive shifts. This
requires that individuals are provided with an opportunity to recover from the work set, and
have adequate unrestricted time for sleep to recover from any accumulated sleep debt.
There are a series of factors that should be taken into account when analyzing duty or shift
duration in aviation operations, including the influence of number of sectors, augmented
crews and the possibility of in-flight rest (Section 4.6) and time of day effects (Section 4.2).
Because HEMS operations are often based around shifts, the literature from other industries
concerning shiftwork is reviewed below in addition to aviation specific literature.
4.1.2 Shift Duration Literature Across All 24/7 Industries
The main issue with shift duration is whether fatigue risk (and the associated risk of incidents
and injuries) increases with increased shift length. A review of the scientific literature shows
that most studies found increased fatigue with longer duty periods, and a number of studies
have shown an increased risk of accidents at the end of the shift. However, the increase is
not linear, and usage of breaks within a shift has been shown to be effective in decreasing
accident risk during that shift as described below in section 4.1.2.2. Moreover, other studies
have found that there is also increased risk at the beginning of the shift, and within 2-4 hours
of the start of a shift.
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4.1.2.1 8-Hour versus 12-Hour Shift Comparisons
Most of the scientific literature on shift duration is focused on the comparison between 8-h
and 12-h shifts, since these shift lengths are the most common in most shiftwork
environments. While in some studies shifts up to 12 hours have been shown not to affect
performance negatively (Smith et al. 1998), most studies have found an increased level of
fatigue and sleepiness, especially during the final few hours of the shift (Rosa and Bonnet
1993, Rosa 1995, Fisher et al. 2000, Son et al. 2008).
However, there is agreement that, in most circumstances, shift durations up to 12 hours do
not represent a significant risk increase, compared to 8- h shifts provided the total hours
worked per week is the same. This is because the completion of weekly work hours in a
fewer number of days means that there are more off-duty days per week on 12 hour shifts,
and this allows more time to recover from any accumulated sleep debt as compared to the
fewer number of days off-duty on 8 hour shifts.
4.1.2.2 Accident Risk and Shift Length
Some scientific studies have indicated that there is an increased risk of incidents in the 9th
to 12th consecutive hour of work (Spencer et al., 2006). However, other studies have found
that the relative frequency of incidents does not increase linearly from the first to the last
hour of the shift. Furthermore, often there is an increased risk not only at the end of the shift,
but also during the first or second hour (Hanowski et al., 2009; Folkard, 1997) until the
operator gets focused. A review of shiftwork studies analyzing the relative incident risk over
time on duty found a slight increase from the second to the 5th hour, a decrease in the 6th
hour and then risk increased in an approximately linear fashion with time on duty, and in the
12th hour was more than double than during the first eight hours (Folkard and Tucker, 2003).
The authors also suggested that a more comprehensive evaluation of the risk associated
with time on duty should take into account the effect of breaks. Their study analysed the
effects of breaks on injuries in an industrial setting and found that breaks reduced accident
risk, and that risk increased substantially and almost linearly between successive breaks,
both during day and night shifts. The authors concluded that different factors need to be
considered in combination when evaluating risk associated with night work, and for example,
a 12-h night shift that included frequent rest breaks might be safer than an 8-h shift with only
a single, mid-shift break (Folkard and Tucker, 2003).
4.1.2.3 Shifts Exceeding 12 hours
Schedules with shifts longer than 12 hours are less common across a range of industries
(except in the trucking industry, where drivers are allowed to be on duty up to 14 hours per
day, and a 10-hour rest before the following shift is enforced) and generally not
recommended on a regular basis.
The safety of 14 consecutive hours on duty in a safety-critical position was endorsed by the
FMCSA in the trucking Hours of Service regulations (Department of Transportation Report
2003). After much research (US Federal Register, 2005) and consultation, these U.S.
trucking industry regulations, introduced in 2004, allow drivers to be on duty a maximum of
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14 consecutive hours per day. However it should be noted that these regulations also
enforce a minimum of 10 hours rest after each 14-hour duty period. This is also the pattern
for FTL in the US for CAT operations.
Shifts of 16 hours or longer are unusual, except in emergency situations. For instance, the
U.S. Nuclear Regulatory Commission (2001) sets the limit at 16 h in a 24-h period, provided
that this is an occasional event. The international FRMS standard for the oil industry
(American Petroleum Institute, 2010) states that extended shifts (greater than 14 hours) shall
occur only to avoid unplanned unmanned safety critical positions or accomplish unplanned
safety critical tasks. It also states that in the case of 14-16 hour shifts, a minimum of 8 hours
off before next shift is required, and for shifts greater than 16 hours, a minimum of 10 hours
off before the next shift. It also requires that extended shifts shall in no case exceed 18
hours and that that there should be not more than 1 extended shift longer than 14 hours per
work set. Some studies have found that 16-hour shifts may be worked without significantly
increasing fatigue, provided that adequate countermeasures are taken during and after the
shift, such as allowing a nap during the shift and scheduling at least one day off after the
shift (Takahashi et al., 1999).
4.1.3 Review of Aviation Scientific Literature: Duration of FDP in Non-Augmented Crews
In the aviation industry, duty periods of 12 hours and longer are becoming increasingly
common in commercial aviation. In recent years the introduction of Ultra-Long-Range flights
(in excess of 16 hours flight time) have become more frequent. In addition, extended duty
periods may also occur in EMS operations. Many studies in the aviation industry (e.g. Samel
et al (1997), Spencer and Robertson (1999), Goode (2003)) have found that extended duty
periods in non-augmented operations are associated with elevated fatigue levels and
increased accident risk at the end of the duty period.
The risk of aviation accidents increases with time of duty. A large U.S. study analysed
human factors related accident data over a period of 21 years for which a 72-hour history of
pilot activities prior to the accident was available. The distribution of these pilot work
schedules was compared to a large reference sample of all pilot work patterns. The data
showed that for duties of 10-12 hours the relative risk of an accident was 1.7 times higher
than for all duties, and for duties of 13 hours or more, the relative risk was over 5.5 times
higher. In addition, while 20% of human factors accidents occurred to pilots who had been
on duty for 10 hours or more, only 10% of pilot duty hours occurred during that time (Goode,
2003). As noted in Section 4.1.1 the relationship between duty length and fatigue risk is
complex; in particular in the context of the Goode 2003 paper the rest requirements under
Part 121 will have influenced the fatigue risk as well as the duty lengths and hence the
relationships derived in this paper need to be treated with caution when the rest
requirements are significantly different from those applicable to this study.
NTSB investigations have found that long duty days (over 13 hours) are associated with a
disproportionate amount of accidents, compared to duty periods of less than 13 hours. The
longer the crews are awake, the more errors they commit, especially cognitive errors such
as decision making (NTSB, 1994).
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Limited use of 18-h shifts has been studied in HEMS. Thomas et al. (2006) evaluated sleep
and cognitive performance of helicopter rescue flight nurses, comparing 12-hour versus 18-
hour shifts during a 72-hour duty schedule: either three consecutive 12-hour night shifts or
two consecutive 18-hour (0700 to 0100) shifts separated by a 24 hour rest period. The data
showed that provided that adequate daily sleep (at least 7 hours per day) is obtained, there
was no difference or decline in the cognitive function of the nurses working 12-hour or 18-
hour shifts during a 72-hour schedule.
There is some agreement that FDP limits should be 12-14 hours, with recommendations for
specific situations. An early study (Dinges, 1996) recommends that an extended cumulative
flight duty period should be limited to 12 hours within 24 hours (in the context of a 10-hour
max FDP recommendation) and that it should be accompanied by additional restrictions and
compensatory off-duty period. The Paper for the European Transport Safety Council (ETSC)
states that there is no objection to an FDP of 12 hours during the day, but does not support
FDPs as long as 14 hours for early starts (Akerstedt, 2003). The Moebus Aviation report
(Moebus, 2008) recommends that a single maximum daily FDP should never exceed 13
hours (and then only under specific favourable conditions) and that extension provisions
above this should be excluded. However, in the report there is no account taken of the
increased rest period required by Subpart Q in case of an extension of 1 hour to an FDP (2
hours before + 2 after or 4 hours after the extended FDP).
4.1.4 Influence of Number of Sectors
There is consensus that multi-segment flights are a major contributor to fatigue. However,
there is still controversy on when fatigue countermeasures, such a reduction of maximum
FDP, should be implemented and on the magnitude of the reduction.
A number of studies have shown that fatigue increases with the number of sectors (Powell et
al., 2007; Spencer and Robertson, 2000; Bourgeois-Bougrine et al., 2003a&b). Prolonged
duty periods (multi-segments flights over a sequence of 4 to 5 days) was cited as a major
contributor to fatigue by 53% of short-haul pilots completing a questionnaire assessing
perceived causes of fatigue (Bourgeois-Bougrine et al., 2003a&b). In a study that evaluated
fatigue in two-pilot operations with no overnight duties pilots were asked to complete a
questionnaire and validated fatigue and sleepiness scales at top of descent on the last
sector of the duty. The most important factors affecting fatigue were length of duty and
number of sectors, which increased fatigue in a linear fashion (Powell et al., 2007).
The need to decrease the FDP if there are a significant number of sectors is confirmed by
many scientific studies. The Subpart Q requirement on maximum allowable FDP is based on
a 30-minute reduction after the second sector.
However, the scientific literature does not give a uniform answer to the question of at which
sector number should the reduction begin. For example, while Spencer (2000) finds no
difference with respect to fatigue between one and two sectors, Powell (2008) states that
fatigue increases from the second sector.
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There is no agreement on how large should be the reduction. While some studies have
recommended a reduction of 45 minutes per sector (Spencer, 2002), other studies
recommend shorter reductions.
4.2 Time of Day Effects and Night Duty
4.2.1 Overview
There is extensive data on the increased risks associated with night duty shifts across
multiple industries. For example, the relative incident risk across different shifts found that
risk increased in an approximately linear fashion across shifts. Compared to the morning
shift, the increased risk was 18.3% for the afternoon shift and 30.5% on the night shift
(Folkard and Tucker, 2003).
There is consensus that overnight flights and night duty are especially vulnerable to severe
fatigue, since flying time occurs during the WOCL, the circadian phase with lowest alertness
and performance. In addition, these effects are compounded by the sleep deprivation
associated with working during the night and sleeping during the day. The detrimental effects
of sleep deprivation, time since sleep, and the WOCL can lead to severe fatigue with
increasing time on task. Furthermore, fatigue during homebound flights is often exacerbated
in unacclimatised crews, who had during layovers a sleep shorter and of poorer quality than
at home.
Another issue to be taken into account is the time of departure of the flight. Early start flights
present a challenge, since they usually result in shorter sleep before the flight, mainly due to
the fact that pilots do not advance bedtime to compensate for the early wake up time. Over
the 24 hour day, there are two periods when alertness is high, during the morning and early
evening. These periods are called “sleep forbidden zones”, because it is difficult to fall
asleep at these times. This makes it difficult to advance bedtime. There is agreement that
early starts are associated with sleep deficit and increased fatigue, especially in the case of
consecutive early starts.
4.2.2 Overnight Flights and Night Duty
4.2.2.1 Increased Fatigue and Accident Risk During Night Duty
Many studies have documented the increased risk of fatigue in overnight aviation operations.
Field studies of single-sector two-crew operations have shown that some crews were having
difficulty remaining awake during overnight duties of 11 hours or more (Samel et al., 1997a;
Spencer & Robertson, 1999). A survey of long-haul pilots found that pilots reported night
flights as a major contributor to fatigue by 59% of pilots, especially schedules involving
overnight outbound and inbound flight with daytime layovers (Bourgeois-Bougrine et al.,
2003). Another study assessing pilots’ fatigue using a validated scale found that fatigue
ratings were greater on longer trips (except where mitigated by adding an extra pilot) and on
overnight sectors (Powell et al., 2011). The Moebus Aviation report (Moebus, 2008), based
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on a review of scientific studies, notes that during night hours fatigue increases and vigilance
decreases more markedly with ongoing duty hours than during the day.
4.2.2.2 Night Operations and Pilot Error
The negative impact of night duties was clearly demonstrated in a study analyzing the hours
of the day when pilots working in a commercial airline made the most errors (de Mello et al.,
2008). Errors were analysed using data from flight operation quality assurance systems,
including the following errors: operational deviations and/or errors, procedural errors and
maintenance faults and mistakes in procedures. The data showed that the risk of pilot errors
increased by almost 50% in the period from 0:00 to 5:59, relative to the morning period 6:00-
11:59.
Several studies have focused on HEMS and accident risk at different times of the day. An
extensive review and risk assessment of HEMS accidents highlighted the increased risk of
overnight operations. The study found that even though 38% of HEMS flight occur at night,
49% of accidents occurred during night-time hours (NTSB, 2006). An evaluation of human-
error-related HEMS accidents in the US (1990-2003, accidents that occurred during en-
route, transport and repositioning) showed that night-time accidents were twice as likely to
be associated with fatalities as daytime accidents, 44.7% compared to 22.9% (Boquet et al.,
2006). The NTSB, 2006 report states that fatigue (lack of rest, extended hours) could be a
causal factor. It should be noted that factors other than fatigue will be important risk
contributors at night including visibility.
Based on data from scientific research, some experts have suggested that FDT limits could
be different for daytime and night-time duties, with longer duty period during daytime
(although a single FDP should never exceed 13 hours) than during overnight duties,
depending on the start time and the amount of sleep obtained and acclimatization to local
time (Samel et al., 1997, Spencer and Robertson, 2007). An early study (Dinges, 1996)
recommended that there be no extended flight duty period that encroached on any portion of
circadian low. Spencer and Robertson (1999) strongly supported that non-augmented duty
overnight should not exceed 10 hours, and suggested that 12 hours is acceptable for 2-crew
operations during daytime.
4.2.2.3 Factors Contributing to Increased Fatigue During Night Duties
Longer periods of wakefulness before duty: One of the factors contributing to increased
fatigue in overnight flights is an increased period of wakefulness before duty, especially if
crews are not able to take an afternoon nap. A study of a simulated ULR flight found that
pilots who departed at night, after being awake for at least 13.5 hours, had significantly
reduced reaction times compared to pilots who departed during the morning hours, after
about 3.5 hours of wakefulness. Pilots in the overnight flights were especially impaired
during the first half of the flight, due both to sleep and circadian factors that were promoting
sleep. However, towards the end of the flight, with increased hours of continued
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wakefulness, performance decrements were seen in both morning and night departure
groups (Caldwell et al., 2006).
Consecutive night duties: The risk associated with overnight flights may increase with
recurrent night duties because studies show that shift workers seldom obtain the same
amount of sleep during the day they would normally obtain when sleeping at night (Folkard
et al., 2005).
Duration of duty period and number of segments: A study evaluating fatigue in two-pilot
operations flying 1-2 sectors duties that ranged from 3 to 12 hours total duty time asked
pilots to complete a questionnaire and validated fatigue and sleepiness scales at top of
descent on the last sector of the duty. The strongest influence on fatigue was time of day,
with the highest levels during the WOCL (02:00-06:00). Fatigue also increased with length of
duty and number of sectors. Moreover, the study found that time of day also affected level of
fatigue at start of duty and the rate at which fatigue levels increased. For example, fatigue
level after 12 hours for duties starting between 06:000 and 12:00 was already exceeded
after 3 hour on duty for duties starting between 00:00 and 03:00 (Powell et al., 2008).
Thus the scientific literature strongly supports the need for reducing the maximum FDP for
WOCL encroachment. This supports the approach taken in Subpart Q and in the CRD
2010-14.
4.2.3 Early Start Flights
Time of day effects occur not only on overnight duties. Early start flights also present a
challenge, since they usually result in shorter sleep before the flight.
With shift start times before 6:00 a.m., achieving the required seven to eight hours of sleep
can be difficult for most people, and these shifts have great potential for contributing to
workers’ sleep deprivation (Kecklund & Akerstedt, 1995). This results in increased fatigue
and consequently increases the risk of errors and accidents during the morning shift. One
reason for reduced sleep before an early morning shift is that, irrespective of what time the
shift starts, many people go to bed at their usual bedtime (Moores, 1990). However, the
main reason is that it is difficult to fall asleep in the early evening. Lavie (1986) described a
“sleep forbidden zone,” during the evening, related to the circadian rhythm of alertness,
which results in making it very difficult to fall asleep at that time.
The effect of early start times on sleep and alertness in short-haul pilots has been confirmed
by several studies. For example, a survey found that for short-haul pilots, successive early
wake-ups was cited as a major contributor to fatigue by 41% of pilots (Bourgeois-Bougrine et
al., 2003). Spencer and Montgomery, (1997) found that time of day was the most important
factor affecting sleep duration and quality. The mean duration of sleep episodes starting
between 21:00 and 01:00 was greater than 7 hours. As start of sleep was progressively
delayed, its duration decreased to 2.5 hours with starts between 17:00 and 18:00. When a
duty period started before 09:00 the duration of the preceding sleep period was reduced.
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The sleep loss amounted to approximately 30 minutes for every hour that the duty period
advanced between 09:00 and 05:00. Subjective sleep quality was also reduced for duty
periods starting before 07:00. During schedules involving consecutive early starts, the sleep
deficit accumulated and alertness tended to deteriorate. Another study showed that the
duration of sleep prior to an early start was reduced by almost one hour for report times
between 07:00 and almost two hours for report times between 05:00 and 06:00. The
subsequent sleep deficit had a clear effect on fatigue. Duties starting before 09:00 were
associated with increased fatigue throughout the following duty period, and that fatigue also
increased during schedules that included several consecutive duties starting at 08:00 or
earlier (Spencer and Robertson, 2002). A recent study found that the lowest amount of sleep
was obtained prior to duty periods starting between 04:00 and 05:00 (5.4 hours), and the
greatest for duty periods starting between 09:00 and 10:00 (6.6 hours). The data indicate
that approximately 15 minutes of sleep are lost for every hour that the start of duty is
advanced prior to 09:00. Moreover, self-rated fatigue at the start of duty was highest for duty
periods starting between 04:00 and 05:00 and lowest for duty periods starting between
09:00 and 10:00 (Roach et al., 2012).
4.2.4 Day-Night Shift Transitions
Another important factor is the number of day-night transitions, that is, from sleeping at night
and being active during daytime to sleeping during the day and being active at night.
The underlying issue is that physiological rhythms do not shift immediately when
transitioning from day to night shift and vice versa. Research studies have shown that
circadian rhythms can shift approximately one hour per day when working night shifts, but
coming back to the daytime routine the adjustment is faster, about two hours per day. During
the transition, there is a misalignment of the circadian rhythms, which translate into malaise
and increased fatigue. Earlier studies found that the change from night to day shift may
cause as much discomfort as a change in the other direction (Akerstedt et al 1977). Recent
studies have confirmed these results. For example, a study conducted on off-shore oil rigs
evaluated adaptation and re-adaptation to night shifts and day shifts, and found that the
return to day shift led to an increase in sleepiness and worsening of sleep, but they improved
gradually during the week (Bjorvant et al. 2006).
Several research studies have studied the transition from day to night shift without rest days
in between and found that in these circumstances, the first night shift is the most difficult shift
in a sequence of consecutive shift. The studies showed that the impairment in the ability to
sustain focus, decrease in subjective alertness and decrease in visual search sensitivity
were more pronounced during the first night shift than in subsequent shifts (Santhi et al
2007). Thus, increasing the number of transitions may result in increased frequency of
problems.
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4.3 Cumulative Effects of Multiple Consecutive Duty Shifts
There is contradictory data on the effects of consecutive duty shifts on fatigue and
performance. The results of the studies are not conclusive: while some studies found
increased accident risk over consecutive nights, other studies found lower risk and improved
performance over the first few days, and some did not find any significant changes across
consecutive nights. There are multiple factors that explain the divergent results including the
amount of sleep individuals obtain between shifts, the time on task (length of shift), and the
time of day of the shift. These factors are considered below.
4.3.1 Review of Cumulative Fatigue Across All Industries
The effects of consecutive day and night shifts on fatigue involve different sets of factors and
are therefore considered separately.
Day shifts: An early study (DERACHS, 1999) showed a gradual increase in subjective
fatigue that occurs over seven consecutive work days. The increase in fatigue was much
more pronounced with an early starting time (6 am) than with a late start (9am) (75%
increase compared to 40% increase). Workers reported that they needed 1 day off to
recover from working 3 consecutive shifts with an early start, and 2 days off to recover from
5 consecutive early shifts. However, other studies suggested that risk is not substantially
greater with up to seven consecutive 12-h day shifts (Persson et al. 2003, 2006a&b). The
results from these studies suggest that for day shift, an early shift start has more impact on
fatigue than time on duty. In addition, early starts, which are likely to be associated with
greater sleep deprivation, require longer rest periods (days off between blocks of shifts) to
recover from the cumulative fatigue.
Night shift: A more significant concern relates to the number of consecutive night shifts,
since they are usually associated with higher levels of fatigue than day shifts (Akerstedt,
1995). Working too many consecutive night shifts can cause an accumulation of sleep
deficit, which can cause both health and safety issues (Knauth, 1997). This accumulation of
sleep debt over consecutive periods of shortened day time sleep is counterbalanced by the
adaptation of the sleep/wake cycle after working several consecutive night shifts. The
adjustment of the circadian physiological rhythms to night work among individuals working
consecutive night shifts is seldom complete, and permanent night shift systems are unlikely
to result in sufficient adjustment in most individuals to benefit health and safety (Folkard,
2008).
This counterbalance between accumulated sleep debt and partial circadian adaptation either
results in an increased risk over successive night shifts if sleep is not well managed, or
decreases risk if good sleep management practices are followed. As a result the literature
contains data which reaches apparently contradictory sets of conclusions. To avoid the
cumulative effects of sleep deprivation the best practice is to train the employees on optimal
sleeping strategies and provide opportunities for sleep (appropriate time and facilities for
sleep). In this way the accumulated effects on performance can be minimised.
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1. Studies showing increased risk over successive nights. A series of studies have
found increased risk over consecutive night shifts. A review of seven studies (mainly of 8-h
shifts) found an increased risk from the first to the fourth night. One study found a continuous
deterioration of performance during five consecutive night shifts (Tilley et al., 1982). Another
study showed that overall, there was a gradual increase in fatigue over 5-6 nights
(DERACHS, 1999). A review of shiftwork studies analyzing the relative incident risk over
successive shifts found that, compared to the first night shift, on average, risk was 6% higher
on the second night, 17% higher on the 3rd night and 36% higher on the 4th night. Studies
evaluating the risk on day/morning shift also found an increased risk over consecutive shifts,
but the increase was substantially smaller than over night shifts (Folkard and Tucker, 2003).
A meta-analysis of several studies of operations without an FRMS indicated that accident
and injury risk can increase over consecutive night shifts (Folkard & Lombardi, 2006).
2. Studies showing decreased risk over successive nights. However, under optimal
sleep conditions, the sleep debt that accumulates during consecutive night shifts is relatively
small and does not exacerbate decrements in night-time performance resulting from other
time-of-day factors. Based on laboratory studies, as well as field studies, it has been
reported that for employees with diurnal patterns (active during daytime, sleeping at night),
the first night shift after days off is the most difficult (Santhi et al., 2007; Lamond et al., 2004;
Baker, 1995), and that alertness and performance is increased on subsequent nights. One
study, evaluating four consecutive 11-h shifts, found three different patterns of fatigue on
consecutive night shifts, reflecting the loads of the reticular activating system,
musculoskeletal, and central nervous system respectively. While the musculoskeletal fatigue
increased over consecutive night shifts, the other two patterns showed significant
improvement over consecutive night shifts (Kubo et al., 2008). When sleep loss is
minimised, employees’ performance adapts as their circadian rhythms adapt (Lamond et al.,
2003). One study found that performance in the night shift increased from the first to the third
night shift, probably reflecting an adjustment of circadian rhythms. However, there was a
decrease of productivity toward the 5th shift, which is most likely due to an accumulation of
sleep deficit. A different study found an increase on production quality from the first to the 5th
night shift, while another found an increase in human error from the first to the 6th night shift,
and a lower error rate on the 7th shift (Knauth, 1995). Other studies (Vinogradova et al.
1975, Wagner 1988) analyzing longer spans of consecutive night shifts reported a decrease
in risk from the 4th to the 5th night, which was maintained until the 7th and final night shift.
4.3.2 Review of Aviation Scientific Literature on Cumulative Fatigue
The same opposing conclusions on the effects of successive nights of duty have been
shown in aviation studies. When the normal pattern of sleep is disrupted, aviation studies
have found that the development of cumulative fatigue tends to increase during consecutive
periods of duty, especially for long duties, early starts, late finishes and overnight duties,
(Spencer and Robertson 2000, Spencer and Robertson 2002). However one of the few
studies so far carried out of cargo operations where aircrew is experienced at routinely
operating at night found that fatigue levels on the first night were higher than on nights two,
three and four (Spencer MB et al 2004),. This was in contrast to the results of a study on
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passenger charter flights, which showed a slight increase over three consecutive nights
(Spencer MB & Robertson KA, 2000).
The Moebus Aviation report (Moebus, 2008) notes that the development of cumulative
fatigue tends to be increased during consecutive periods of duty, especially for long duties or
when early starts, late finishes or overnight duties are involved that disrupt the normal
pattern of sleep. It suggests that it is sensible therefore to limit the number of duties and/or
reduce the maximum FDP of these duties when they run consecutively, especially where
they are close to maximum FDP limits. Following a sequence of consecutive duties
mitigating strategies could involve scheduling a rest day including one local night. The author
proposed additional limits to those in Subpart Q, i.e. a duty hours limit over 14 consecutive
days and a block hours limit per 12 consecutive months. Limits on these (slightly modified
from those proposed in the Moebus Aviation report) are included in CRD 2010-14 although,
as noted in NPA 2010-14 (EASA, 2010) there is a lack of scientific evidence and the limits
are rather based on judgements of what appears “reasonable”.
Helicopter operations: There are only a few studies on sleep and fatigue during
consecutive days of pilot duty in helicopter operations. For example Gander et al (1998)
evaluated helicopter crews operating during daytime in the North Sea (4-5 day trips). Crews
reported a reduction in sleep duration by nearly 1 hour on duty days. On duty days, crews
reported higher overall fatigue and greater fatigue by the end of the day, compared to pre-
trip days. The higher overall fatigue levels on post-trip could reflect an accumulation of
subjective fatigue across the 4-5 day trips. Crews also reported lower activation and poorer
mood at the end of duty days than at the end of pre-tip days, and staying on duty longer
increased the effect.
HEMS: A detailed study of sleep deficit and cumulative fatigue was carried out of HEMS
crew in Germany (Samel et al, 2004). Helicopter-based emergency medical services in
Germany can be required to operate from sunrise to sunset, requiring up to 15.5 hours of
continuous duty during the summer months for pilots, who could work for seven consecutive
days. Over the 7-day duty period there was an increase of sleep deficit and stress:
• Mean sleep duration was found to decrease from 7.8 h to 6 h or less, resulting in a
cumulative sleep loss of about 15 h over the 7-day period.
• Sleep latencies (time that it takes to fall asleep) decreased progressively, reflecting
increased fatigue and need to sleep.
• The need for sleep was rated higher on duty days 2 to 6.
• Workload ratings increased progressively.
• The secretion of stress hormones (adrenalin, noradrenalin, and cortisol) increased
significantly by 50 to 80%.
• Cortisol and noradrenalin excretion also remained elevated for the two post-duty
days.
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The authors concluded that the shortness of rest times with the progress of a duty period of
7 days consequently resulted in reduced sleep times and that this was the main reason for
increased strain and stress. They concluded that the workload from the flight operations
generally did not contribute to the increased strain and stress to the same extent as the
cumulative sleep deprivation.
Figure 4.1: Sleep duration during 11 day study period for EMS pilots, including 7 days
of consecutive duty (from Samel at al., 2004)
4.4 Sleep and Rest
In a shift based system such as used widely for HEMS, the duration of a rest period between
consecutive work periods is related to the duration of the shifts. Consequently, longer work
periods result in shorter rest periods (for example, 12-h off between consecutive 12-h shifts,
compared to 16-h off between consecutive 8-h shifts). Research studies have found a high
correlation between the duration of the rest period and the amount of sleep obtained during
it. This is important because one of the key factors to mitigate fatigue is to obtain adequate
sleep during time off.
Scientific data demonstrated that shortened sleep every day (less than 7-8 hours) for one or
two weeks (Belenky et al., 2003; van Dongen et al., 2003) produced significant cognitive
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decrements. Limiting sleep to six hours or less over successive nights resulted in a
cumulative dose-dependent deficit in performance. Individuals who obtained less than four
hours of sleep per night showed increased lapses in performance and reduced speed and
accuracy when completing performance tasks, while those who obtained seven or more
hours of sleep were able to maintain adequate levels of performance over 14 consecutive
days. Other studies have documented the negative impact on health, mood, and safety of
chronic sleep deprivation (Oginska & Pokorski, 2006; Leproult et al., 2003; Garbarino et al.,
2002).
A single day with a shortened sleep in a person who otherwise has been obtaining adequate
sleep can be tolerated without excessive fatigue risk. However, the number of days when
these short sleep episodes occur must be strictly limited because shortened sleep episodes
over consecutive days results in chronic sleep deprivation. Four hours of sleep has been
suggested as the minimum amount of sleep required to sustain adequate performance levels
during a single day (Belenky et al., 2003), although performance levels are lower than in
people able to sleep for eight hours. Insufficient sleep, poor sleep quality and long work
hours have been found to be both independently and synergistically associated with
workplace injury risk (Nakata, 2011). An epidemiological study (Lombardi et al., 2010)
showed the impact on health and safety of the combination of chronic sleep deficit and
extended working hours. Using 7-8 hours of sleep as reference, the adjusted injury risk
increased gradually with shorter sleep duration (from an odds ratio of 1.4 for 6-7 hours of
sleep to an odds ratio of 2.7 for less than 5 hours of sleep).
The rest period between shifts should provide enough time for obtaining adequate sleep. A
series of studies have shown that rest periods of 10 hours or less between consecutive shifts
result in short sleep episodes, sometimes only 3-5 hours of sleep. It should be taken into
account the time of day of the rest period, since rest between work periods that occur during
daytime result in less sleep than rest at night (Kurumatani et al.,1994; Wylie et al., 1997).
Roach et al (2003) evaluated the effects of duration (12, 16 and 24 hours) and timing of rest
periods between consecutive shifts, as well as the interaction between these two factors.
The study participants (locomotive engineers) worked irregular rosters, with work episodes
having an average duration of 8.4 hours. 44% of work periods started between 04:00 and
12:00, 34% between 12:00 and 20:00, and 22% between 20:00 and 04:00. Overall, the
results showed that total sleep increased with longer rest periods. For 12-h and 16-h rest
periods more sleep was obtained during rest periods that occurred during nighttime. For 24-
h rest periods, longer sleep was obtained for rest periods starting 04:00-06:00 and 10:00-
12:00. This is because individuals who finished a shift in the morning and started another
shift the following morning (that is, that changed from night to day shift) often were able to fit
two sleep episodes in the 24-h rest period (one after the work shift and another before the
day shift).
One means of mitigating the effects of a long (extended) FDP, post-event, is to provide a
longer rest afterwards. Clearly this does not help during the extended FDP, but it can
mitigate subsequent effects. An early study (Dinges, 1996) recommends that the required
off-duty period should be extended by the same duration of the flight duty period extension.
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There may be occasions when EMS operations may require reduced rest. The Moebus
Aviation report (Moebus, 2008) notes that any reduced rest arrangement is likely to result in
increased fatigue levels following the reduced rest. The report recommends that reduced
rest is only allowed as part of a comprehensive FRMS, and that the FRMS would need to
take account of a wide range of factors including both the time spent commuting and the
influence of the body clock on sleep duration. In addition, it recommends that any reduced
rest that is less than 12 hours long should include the entire WOCL period, and that
consideration should be given to ensuring that the subsequent flight duty is not too onerous
and to specifying an absolute minimum reduced rest period, even in the presence of an
FRMS.
4.5 Standby
4.5.1 Standby at Base/ Airport
There are differing approaches to how airport standby should be treated with respect to FDP
and duty time contributions. Moebus (2008) notes that there is no scientific evidence to
suggest that airport standby should be considered as any less fatiguing than flight duty and
that further research is needed in this area. It concludes that time spent in airport standby
should normally count 100% as flight duty when calculating the maximum FDP. It further
recommends that standby count as 50% FDP if adequate rest facilities are provided, and
FRMS is in place. However, detailed scientific justifications are not provided in this report on
this issue and there is a general lack of scientific evidence about the impact of different
airport standby facilities.
The Principles and guidelines for duty and rest scheduling in Commercial Aviation ‘NASA
Study’ (Dinges, 1996) in contrast recommends that airport standby should be considered as
duty but does not provide a rationale for this.
This uncertainty is reflected in the range of European States’ provisions covering HEMS
described in D1.
For HEMS key issues covering standby at base are how relaxation and napping during on-
ground breaks can mitigate fatigue during shifts and how naps could lead to sleep inertia
impacting missions. Sleep inertia refers to the fact that it takes a certain amount of time to
fully wake up after sleeping. Sleep inertia is associated with impaired alertness and
performance. Usually sleep inertia would dissipate in 10-15 minutes, but it may take longer if
the person wakes up from deep sleep or is sleep deprived. Only a few studies have
analysed napping in helicopter pilots. These studies found that helicopter pilots took naps
only rarely during their on-call duty (Samel at al., 2004; Gander et al., 1998). This could be
related to the difficulty of napping when fully kitted and the need to attend missions at short
notice. However, it is noteworthy that in the EMS helicopter pilots study, naps were more
frequent on duty days 5 and 6. Moreover, the average nap duration increased during the
work week, from 6 minutes on duty day 2 to 30 minutes on duty day 7 (Samel at al., 2004).
The benefits and hazards of napping are further considered in section 4.6.2.
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4.5.2 Standby at Home and Elsewhere
Short call home standby (may lead to an assignment without an intervening rest period) is
used by many European AEMS operators (see Appendix 4). Long call home standby (at
least 10 hours before start of an assigned duty) is not considered below as safety impacts
are not considered so significant and is not so relevant to EMS on-demand operations.
The Principles and guidelines for duty and rest scheduling in Commercial Aviation ‘NASA
Study’ (Dinges, 1996) does not consider ‘on call reserve status’ as duty, but recommends
that ‘a …. 8 hour sleep opportunity’ should be protected from interruption by assignment to a
flight duty period.
Crew Factors in Flight Operations XI: A Survey of Fatigue Factors in Regional Airlines
Operations (Co, E., 1999) notes that the nature of flying on reserve means that
crewmembers must respond when called for duty, thus creating unpredictability in their
schedules. This unpredictability can lead to sleep loss, for example, when a call for duty
occurs when a sleep period was planned. As evidence that sleep loss occurred,
crewmembers reported getting 5.6 h of sleep before duty on average—2.3 h less than their
normal average sleep.
Very little other scientific research covers this topic. However, Akerstedt/Gillberg (2003) have
shown that there is a direct effect on being on standby and the lowered quality of
recuperative sleep.
4.6 In-Flight Rest and Flightdeck Napping
This section evaluates separately in-flight rest and controlled napping in the cockpit.
4.6.1 In-flight Rest
Augmented crews allow pilots to use in-flight rest and obtain sleep in order to maintain
alertness and reduce fatigue. Numerous studies noted below have shown that both objective
physiological measures and subjective ratings of alertness demonstrate improvement
following an in-flight rest taken during periods of sustained wakefulness and that in-flight rest
can also reduce or delay expected performance decrements.
A number of studies have evaluated frequency and duration of in-flight sleep. For example, a
study of in-flight rest during trans-Atlantic flights compared two and three-pilot crews. It found
that sleep duration was longer in augmented crews: 38 minutes in outbound flights, and 1 h
06 minutes in homebound flights, compared to 26 min and 54 minutes respectively in non-
augmented crews. Shorter in-flight sleep was associated with lower performance at top-of-
descent for 2-pilot crews (Eriksen et al., 2006).
There is some debate on how much in-flight rest is used and the quality of sleep obtained.
Roach and colleagues have conducted a series of studies on these issues. They estimated
that in-flight sleep provides pilots with 70% as much recovery as duration-matched bed sleep
(Roach et al., 2010). In a subsequent study, they evaluated frequency of in-flight sleep. Their
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data showed that pilots obtained 1.8 hours of sleep (27% of rest time) during duty periods
with low fatigue likelihood and 3.7 hours of sleep (54% of rest time) during duty periods with
extreme fatigue likelihood. The results indicated that pilots obtain more sleep during periods
when fatigue is likely to be high (Roach et al., 2011).
There seems to be some controversy in how much of the time spent in the bunk is actually
sleep. For example, while TNO considers that 75% of the time spent in a bunk may be
counted as actual sleep, an FAA report (AC No: 120-100 Basics of Aviation Fatigue AFS-
200, 2010) states that flight crews who had a 7 hour sleep opportunity obtained, on average,
only 3 hours 25 minutes of bunk sleep.
The TNO report “Extension of flying duty period by in-flight relief” (Simon, 2007)
recommends to allow an extension of the FDP based on the duration of the rest period
available to the pilot and on the environment which is available for rest. It also concludes that
the allowable extension should depend on whether the crew is acclimatised. These
conclusions are reflected by the Moebus Aviation report (2008).
The TNO report also recommends that if augmentation is only by one additional pilot, the
maximum FDP should be 16 hours. Finally, the TNO report proposes to give no credit to rest
in an economy seat, although no data are available concerning onboard sleep in a normal
economy class seat. However, based on laboratory data and ergonomic considerations,
sleep in an economy seat is considered to be degraded to 0% of bunk/Class I seat because:
• The seat does not recline more than 40 degrees and has no adequate foot and leg
rest which diminishes the probability of recuperative sleep;
• Space around the seat is not sufficient to create adequate separation from
passengers or guarantee any privacy;
• A majority of passengers are unable to sleep at all in an economy seat. Some
succeed in obtaining some sleep, but they often feel a general malaise after sleeping
in a cramped position.
4.6.2 Controlled Napping
Brief structured nap breaks during extended-hour work shifts have been shown to be an
effective operational strategy. Timing and duration of naps can be designed for optimal
impact on alleviating fatigue. As with in-flight rest, napping will be most efficient when sleep
occurs during the WOCL. An important consideration in terms of scheduling is the duration
of the beneficial effects obtained. Studies suggest that a nap can maintain or improve
subsequent performance and physiological alertness from 2 to 12 hours following the nap.
Experiments have examined naps of varying lengths, and there seems to be a dose-
dependent effect: more sleep is associated with greater beneficial effects.
However, some studies suggest that shorter naps can be just as or more effective than
longer ones; recommendations range from 20- to 60-minute duration. Shorter naps (10-20
minutes) are also less likely to be associated with the phenomenon of sleep inertia (a short
period of impaired alertness upon awakening). This is because in this amount of time, the
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individual will usually remain in light sleep and would not reach deep sleep. It is easier to
wake up from light sleep and the individual will regain full alertness faster than waking up
from deep sleep. In the case of long naps, sleep periods of approximately 90 minutes allow
the completion of a full sleep cycle, and the individual wakes up from light sleep or REM
sleep, which minimizes sleep inertia. On the other hand, naps of 40-60 minutes would result
in the individual waking up from deep sleep, and that will result in more severe and long
lasting sleep inertia. Sleep inertia can be associated with a performance decrement lasting
for a few minutes to 35 minutes, though effects usually seem to dissipate in about 10 to 15
minutes (Robertson and Stone, 2002, Rosekind et al 1994).
A series of studies have proved the effectiveness of napping as a fatigue countermeasure in
the aviation industry, and ICAO has stated that controlled napping is a valuable mitigation
strategy that can temporarily relieve the symptoms of sleep loss (ICAO, 2011).
A joint study by the National Air and Space Administration (NASA) and the Federal Aviation
Administration examined the effect of a planned cockpit rest period during long-haul flights.
Two crews flying the same sequence of four scheduled flights were compared. One group
was allowed a 40-minute nap opportunity (one crew member at a time), whereas the other
group followed their normal activities. Pilots slept on 93% of the opportunities, falling asleep
in 5.6 minutes on average and sleeping for 25.8 minutes on average. Crew assigned to the
nap group showed better performance and higher physiological alertness on objective
measures during the last 90 minutes of the flight (critical descent and landing phases of the
flight) than did the control group (Rosekind et al, 1994).
The FAA authorises in-flight rest for flight crews if there is an augmented crew, so that two
pilots are on the flight deck when the augmented crew is resting. The FAA does not
authorise naps in the cockpit, however, other carriers and authorities do.
4.7 Periodic Extended Rest
How much rest an individual needs between blocks of working days is related to the number,
timing, and length of consecutive shifts he or she works. Allowing more time off after
extended blocks of night shifts is important because night shifts are more fatiguing, and
sleep debt more prevalent, than with day shifts. There is agreement that a 24-h period
including one single night is usually not enough to fully recover from a series of consecutive
work days, and that the number of consecutive days off should increase with consecutive
work days.
Several studies have found that two full nights of sleep were usually enough to recover from
sleep deprivation and return to baseline levels of sleep structure and waking performance
and alertness (Carskadon & Dement, 1979). Shiftwork researchers have shown that at least
two unrestricted sleep episodes are needed to recover after a series of shifts and that at
least 3 days, including 3 overnight sleep episodes, are necessary to recover from 7
consecutive night shifts (Knauth, 1997). Another study (Totterdell et al., 1995) showed that
alertness and performance were more impaired on the first three days back at work following
a single rest day, as compared to two or three rest days.
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It is thus usually recommended that time off between blocks of work days should allow two
days with nocturnal sleep (Health and Safety Executive, 2006; Knauth,1997). This is due to
the fact that night-time sleep occurs at the time when circadian rhythms are conducive to
sleep, and thus sleep episodes are longer and more restorative. An off-duty period of 36
hours after daytime shifts and 48 hours after night shifts are required to allow shiftworkers to
obtain these two nocturnal sleep episodes.
Folkard (2000) recommends that having worked two or three consecutive night shifts it is
important that staff are able to have sufficient sleep to fully recover. This requires two full
nights’ sleep after the consecutive night shifts, without an early start after the second night.
In order to ensure this is achieved (and commuting time does not leave too short a period for
rest), it is considered optimum that 54 hours or more should elapse between the end of the
consecutive night shifts and the next shift.
The Principles and guidelines for duty and rest scheduling in Commercial Aviation ‘NASA
Study’ (Dinges, 1996) recommends that if two or more flight duty periods within a 7-day
period encroach on all or any portion of the Windows of Circadian Low, then the standard
off-duty period (36 continuous hours within 7 days) be extended to 48 hours recovery.
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5.0 HEMS Analysis
The following fatigue factors and hazards from Table 3.1 are addressed in this section:
5.1 Duration of duty (including extensions) – hazard A1, duration of FDP/ shift too long
leading to fatigue
5.2 Time of day effects – hazard B1, night shifts and WOCL encroachment
5.3 Cumulative effect of multiple consecutive shifts – hazard C1, consecutive day duties
and C2, consecutive night duties
5.4 Relaxation and napping on-duty (5.4.1) relating to hazard E1 and as a mitigation to
hazard A1 and sleep and rest off duty (section 5.4.2) covering hazard D1
5.5 Pilot in Command (PIC) discretion – hazard A2, PIC discretion leading to too long an
FDP/ shift
5.6 Positioning and travelling – hazards F1, F2 and F3.
5.7 Circadian disruption due to mixing night and day duties – hazard B2
5.1 Duration of Duty Including Extensions
HEMS operations are generally based around duty time restricted shifts. Examples are
given in Appendix 4. Some States have FDP restrictions whereas others restrict the duty
time at the base (see D1). The analysis below is based on the modeling of shift duty time.
Implications for FDP can be derived from the modeling assumptions concerning when the
first flight starts and last flight ends in the shift.
5.1.1 Safety Impacts of Changes of Duty Duration and Extensions
The key issues associated with hazard A1 from Table 3.1 are considered to be:
i. Duration of shift and fatigue level
ii. Day shift v night shift (encroachment of the WOCL) – see Section 5.2
iii. Duration of extended rest after an extended shift and impact of breaks during a shift –
see Section 5.4
iv. Impact of number of missions/ flying time
Additional mitigations associated with this hazard are summarized in Table 3.1.
5.1.1.1 Duration of Shift and Fatigue Level
Literature Review
The relationship between duty length and fatigue is complicated by circadian phase, time
awake, chronotype and the other factors discussed in Section 3.1. The literature in Section
4 from across industries indicates that shifts up to 12 hours are not necessarily higher risk
than 8 hour shifts if appropriate mitigations are put in place. Shifts longer than 12 hours are
relatively rare across industries. The limited evidence from EMS nursing staff of 18 hour
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shifts operated for short periods indicated that they did not impact on cognitive function.
However, 15.5 hour daytime shifts operated by EMS pilots over 7 days did lead to evidence
of cumulative fatigue (see Section 5.3). From the airline industry there appears a consensus
that daytime FDPs exceeding 12-14 hours will lead to increasing fatigue and risk. The
number of sectors in an FDP and WOCL encroachment (night duties) will be important
fatigue contributing factors.
CAS modeling
Crew operating HEMS shifts experience quite different fatigue issues from airline pilots.
Helicopter flying involves a different task workload from fixed wing operations. The shift
patterns are very different from airline flight patterns in terms of times of day. Therefore
some modeling using CAS was considered useful.
CAS has not been validated for helicopter operations in the same manner as it has for fixed
wing operations (see Appendix 2). However, with this caveat some modeling is considered
useful as it provides relative insights.
The crew workload has been modeled as equivalent to take off and landing for a fixed wing
aircraft all through the helicopter flight. The following 5 scenarios have been modeled.
1. Duty Shift 07:00 – 17:00 (10 hours): flights starting one hour after beginning the
shift - 20 x 15 minute missions spaced evenly throughout the shift.
2. Duty Shift 07:00 – 17:00 (10 hours): flights starting one hour after beginning the
shift - 5 x 15 minute missions spaced evenly throughout the next 3 hours of the shift
(termed “Flight Sequence 1”) and another 5 x 15 minute missions spaced evenly
throughout the final 3 hours of the shift (termed “Flight Sequence 2”).
3. Duty Shift 07:00 – 19:00 (12 hours): flights starting one hour after beginning the
shift - 5 x 15 minute missions spaced evenly throughout the next 3 hours of the shift
and another 5 x 15 minute missions spaced evenly throughout the final 3 hours of the
shift.
4. Duty Shift 07:00 – 21:00 (14 hours): flights as above.
5. Duty Shift 07:00 – 23:00 (16 hours): flights as above.
Scenarios 1 and 2 look at the influence of different numbers of flying hours during the shift
and scenarios 2-5 investigate the influence of shift length in the range 10-16 hours and finish
time.
The graph in Figure 5.1 shows the alertness at the end of the two flight sequences (Flight
Seq. 1 and Flight Seq. 2) for scenarios 2-5 and the alertness at the end of the last flight for
Scenario 1.The alertness at the end of Sequence 1 is unchanging as expected as it occurs
at the same time of day (11:00) after the same workload (number of missions). The
alertness at the end of Sequence 2 shows little change up to 12 hours and then decreases
significantly. The effect of flying 10 or 20 flights of 15 minutes during day is not that strong in
the context of a 10 hour shift but this finding should be treated with caution as HEMS
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workload modeling is less well understood/ validated. Alertness at the end of the longest
shift (18hrs, 7:00-23:00) is just below the point where people would generally choose to go
to sleep.
Figure 5.1 – End of shift alertness is lower with shifts over 12hours. Alertness is shown at
the end of either the first or second sequence of flights. See text above for scenario descriptions.
The results from the CAS modeling looks broadly in line with the literature. Moving
significantly above 12 hours shift duration does introduce extra fatigue and risk and would
generally be undertaken only with good reason, e.g. responding to an emergency late in the
shift (see D1 survey).
5.1.1.2 Impact of Number of Missions/ Flying Time
Another factor affecting fatigue is number of missions or amount of flying time. Unfortunately
it is difficult to translate the literature, which is mostly aimed at the influence of the number of
sectors on airline pilot fatigue, to the HEMS field. The need to decrease FDP if there are a
significant number of sectors is confirmed by many studies (see Section 4.1.4). The Subpart
Q requirement on maximum allowable FDP is based on a 30-minute reduction after the
second sector.
Because of the on-demand nature of EMS, the numbers of missions in a shift could vary
widely. One would expect increased HEMS flying hours to cause increased fatigue, other
factors being equal. However, the strength of that dependence is difficult to derive from the
literature or modeling.
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In terms of current national provisions some States do have daily flying limits applicable to
HEMS (e.g. UK and France < 8 hours per 24 hours, see D1 for others). Presumably these
limits have been set based on accumulated operational experience.
5.1.1.3 Other Potential Mitigations/ Factors
In addition to limits on shift/ FDP duration and daily flying hours other potential mitigations
could be incorporated into the FTL options. These may include:
• Extended rest after a long duration FDP/ shift (see Section 5.4.2.2)
• Limiting the frequency of long extended shifts per week or per month
• Requiring full rest before the extended shift
• FRMS (general – applicable to all hazards)
• Relief pilot for single pilot operations when an extension is invoked
• Prohibiting combining EMS shift extension with extension due to split duty
• Controls over extensions due to split duty/ on-ground breaks, e.g. minimum
consecutive number of hours for break before it can lead to an extension, etc.
• Limiting number of persons on aircraft during extensions
• Controlled napping at base.
5.1.2 Economic Impacts of FTL Changes for Duty Duration and Extensions
Those economic impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below (Table 5.1).
Table 5.1: Economic Impacts Associated with Potential Changes to Duty Durations
and Extensions
Potential Reference situation Identification of generic Factors which will affect
change in Europe economic impacts size of impacts
Harmonisation Based on the survey of Changes to basic The change in shift length/
of basic 8 States in Europe maximum shift length maximum FDP proposed
maximum duty (D1) HEMS duty shift arising from relative to current practice in
length in lengths vary from 9.5 harmonization could feed each State/ operator will
Europe for to 13 hours and FDPs into changed pilot costs determine the size of the
HEMS vary from 8 to 12 assuming that service economic impact.
hours depending on levels are to be As a hypothetical extreme
State, number of maintained. example a decrease in
pilots, duty start time average shift length from 12
and consecutive hours to 8 hours would
number of days duty. translate into a 50% increase
in crew costs assuming there
was no spare capacity for
filling the extra shift.
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Potential Reference situation Identification of generic Factors which will affect
change in Europe economic impacts size of impacts
Restricting Based on the survey of Operators with 24/7 bases Social impacts probably more
flexibility to 8 States in Europe in normal circumstances significant.
extend shifts/ (D1) extensions vary will have enough crew to
FDPs to meet from 0 up to 4 hours cover shifts. The main
medical depending on State reason for extending a
emergencies and type of shift is if a helicopter is in
emergency. the middle of a mission
and is in a better position
to continue and bring a
patient back to hospital for
example rather than have
a new crew get ready and
proceed from the base.
Therefore any changes in
this flexibility would not
necessarily have any
significant impact on crew
numbers or economic
impacts (except for
extended rest
requirements described
below).
Harmonisation Based on the survey of If limits are placed on The size of the economic
of flying hours 8 States in Europe flying hours per day which impact of changing the
per day (D1), flying hours per are more or less maximum allowable daily
day vary from 5 to 8 restrictive relative to the flying hours will depend on
hours depending on current flying patterns this the demand compared to the
State, number of pilots could impact the number proposed regulatory limits.
and time of day of duty of crew required to For example if crew currently
start. maintain EMS service never fly more than 5 hours
levels. per shift, then reducing the
limit from 8 hours to 7 hours
would have no effect. If crew,
however, frequently
experience daily flying hours
in the range 7-8 hours this
change could have a
significant impact on the
requirement for extra crew or
else impact service provision.
Harmonisation Based on the D1 Changes to the amount of The percentage of shifts that
of required survey the required rest following an extended get extended beyond
extended rest rest after an extended shift will affect crew proposed regulatory change.
after an FDP/ shift can vary availability. If a new
extended shift/ from = FDP/ duty requirement for extended How much spare crew
FDP length up to 48 hours rest following an extended capacity operators have to
depending on State. shift is introduced then cover such events currently.
extra crew may need to
be made available to
cover such an event.
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Given the range of potential mitigations and options that the future RIA may develop there
could be more economic impacts than identified in the table above.
An indication of the process for determining the economic impacts of proposed changes is
illustrated by the following example relating to flying hours per day:
• Assume a regulatory change harmonises daily flying to Z hours.
• Assume that for an operator X% of shifts involve flying in excess of Z hours.
• Assume that effectively the last Y% of affected shifts are curtailed as a result of this
change.
• As a simple estimate the amount of increased crew cover will need to be about X/100
× Y% to maintain service levels although the knock-on effects may be greater
especially for smaller operators with less capacity for covering contingencies. This
might in the extreme lead to changes in the whole shift pattern.
• Based on information from Section 2.2 it is estimated that crew costs are about 20%
of total operating costs (although there appears quite a significant range from 15% to
over 30%).
• Thus the impact on overall operating costs from this change with the simple
assumptions above would be approximately 20/100 × X/100 × Y% increase. Clearly if
the whole shift pattern needs to be changed, the cost impact could be greater.
Under AEMS, Section 6.1, there is an additional example calculation relating to regulations
requiring changes to extended rest following extended shifts/ FDPs.
5.1.3 Social Impacts of FTL Changes for Duty Duration and Extensions
Those social impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below (Table 5.2).
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Table 5.2: Social Impacts Associated with Potential Changes to Duty Durations and
Extensions
Potential Reference Identification of generic Factors which will affect
change situation in social impacts size of impacts
Europe
Harmonisation Based on the For any changes it seems N/R unless there are
of basic survey of 8 States reasonable to assume that, if significant economic impacts.
maximum duty in Europe (D1) practical, the aim will be
length in HEMS duty shift maintain service levels with
Europe for lengths vary from minimal impact on patient
HEMS 9.5 to 13 hours safety and health. If the
and FDPs vary economic impacts are very
from 8 to 12 hours severe in a negative sense this
depending on could consequently cause
State, number of negative impacts on the EMS
pilots, duty start service to the public.
time and
consecutive Economic impacts could lead
number of days to jobs created or lost.
duty.
Restricting Based on the If changes lead to reduction in The percentage of shifts/
flexibility to survey of 8 States this flexibility then it could take FDPs that get extended
extend shifts/ in Europe (D1) longer to reach and transport beyond proposed regulatory
FDPs to meet extensions vary patients in events which occur change.
medical from 0 up to 4 close to shift duty/ FDP limits.
emergencies hours depending The percentage of these
on State and type No other social impacts extended shifts/ FDPs that do
of emergency. considered significant. actually “save lives” – would
expect this percentage to be
high as event needs to be
urgent to justify shift/ FDP
extension.
Harmonisation Based on the As above, for any changes it N/R unless there are
of flying hours survey of 8 States seems reasonable to assume significant economic impacts,
per day in Europe (D1), that, if practical, the aim will be e.g. if uneconomic to arrange
flying hours per maintain service levels with cover, might need to close
day vary from 5 to minimal impact on patient HEMS base after pilot has
8 hours safety and health. If the reached daily flying hours
depending on economic impacts are very limit.
State, number of severe in a negative sense this
pilots and time of could consequently cause
day of duty start. negative impacts on the EMS
service to the public.
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Potential Reference Identification of generic Factors which will affect
change situation in social impacts size of impacts
Europe
Harmonisation Based on the D1 Some missions may not be The size of the change in
of required survey the possible and patient health required extended rest
extended rest required rest after could be affected directly. compared to current
after an an extended FDP/ provisions.
extended shift/ shift can vary If extra rest days cannot be
FDP from = FDP/ duty covered due to economic The frequency of extended
length up to 48 constraints then service levels shifts/ FDPs.
hours depending would be affected indirectly.
on State. The amount of crew cover an
Economic impacts could lead operator has to accommodate
to jobs created or lost. extended rests.
An indication of the process for determining the social impacts of proposed changes is
illustrated by the following example relating to restricting duration of extended shifts/ FDPs:
• Assume that a regulatory change leads to a reduction in extensions from X hours
maximum shift to Y hours maximum shift.
• Assume that an operator currently experiences extended shifts between X and Y
hours duration Z per year.
• Assume that for 10% of these events the extension allowed a patient’s life to be
saved (see Section 2.3).
• The social impact of this regulatory change for this operator would be approximately
Z × 10/100 extra patient fatalities per year.
5.2 Time of Day Effects and Night Duty
5.2.1 Safety Impacts of FTL Changes for Night Duty
Literature Review
Night duties present a special challenge, since flying time occurs during the WOCL, the
circadian phase with lowest alertness and performance. In addition, these effects are
compounded by the sleep deprivation associated with working during the night and sleeping
during the day (Samel et al., 1997, Spencer & Robertson, 1999). The detrimental effects of
sleep deprivation, time since sleep, and the WOCL can lead to severe fatigue with
increasing time on task.
CAS modeling
The caveat from above about lack of model validation for helicopter operations should again
be highlighted. However, modeling is considered helpful for a relative comparison between
day and night shifts. Scenario specific assumptions are as follows:
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• Day shift (scenario 3 in Section 5.1.1.1) – 12 hours duration from 0700 to 1900. 2
sequences of 5 missions each between 0800 and 1100 and 1600 and 1900.
• Night shift – 12 hours duration from 1900 to 0700. 2 sequences of 5 missions each
between 2000 and 2300 and 0400 and 0700.
Figure 5.2: Alertness is lower at the end of Flight Sequence 1 and 2 during night shifts.
Alertness is shown at the end of the first and second sequence of flights. Flight sequence 1
begins 1hr after shift start, and consists of five evenly distributed 15min flights in 3hr. This is
followed by a 5hr break where is the pilot is expected to be awake. Flight sequence 2 consists of
five evenly spaced 15min flights in 3hr ending at the end of the shift.
The graph in Figure 5.2 indicates that:
• The second flight sequence around the time of the WOCL for the night shift has a
very low alertness score.
• HEMS operations during the night appear to present key fatigue challenges based on
this modeling.
• Fewer missions during the night than the day are probably to be expected and hence
a comparison between day and night with the same numbers of missions is probably
rather unrealistic – however the broad findings are still considered relevant.
Figure 5.3 below presents another graph showing the percentage of time spent fighting
sleep while flying. This emphasizes the potential fatigue challenge of night duties.
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Figure 5.3 – Pilots spend more time experiencing low alertness during night shifts. Pilots
flying the night shift spend 50% of their time in low alertness. This corresponds to the entire
length of Flight Sequence 2.
This modeling ties in with the literature reviewed in section 4.2.2.2 which indicated a
disproportionally high rate of HEMS accidents at night. Section 3.1 refers to transportation
studies that show peaks risks around 1-6 AM.
Potential mitigations in addition to limiting duty hours for night shifts could include:
• Napping before night shifts;
• Training on how to manage night shift work and when to recognize that one is
fatigued (e.g. to be wary of relaxation after delivery of patient and ignoring level of
fatigue);
• Limiting the number of missions (or flying hours) per night shift (if the limit is reached,
the pilot would have to be relieved by a pilot on home standby);
• Availability of relief pilots to take over if a crew member realizes they are too fatigued
or a flying hours limit is reached;
• Controls over consecutive night shifts (see Section 5.3 below for safety analysis);
• Using two pilots at night;
• Additional rest.
5.2.2 Economic Impacts of FTL Changes for Night Duty
Those economic impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below.
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Table 5.3: Economic Impacts Associated with Changes to Night Shift Provisions
Potential change Reference Identification of generic Factors which will affect
situation in economic impacts size of impacts
Europe
Harmonisation of the The typical Changes could alter the Depends how different
maximum number of number of ratio of rest days to proposed regulations are
consecutive night consecutive night working days and affect from current practices and
shifts shifts appears to crew productivity. what impact there is on ratio
vary from 3 – 7 of rest days to working days.
(see Appendix 4).
For smaller operators
impacts could be
proportionally larger.
Specifying a Current situation Likely to lead to changed The current amount of cover
requirement for in Europe not requirements for crew that an operator typically
availability of relief known. cover and impact crew carries. If an operator has a
crew to take over at numbers and costs lot of cover already there
night for fatigued directly. might be a low economic
colleagues (who impact.
have reached a
defined limit or who Alternatively an operator
declare themselves could shut a base until the
too fatigued) next shift starts (see social
impacts below).
Harmonisation of the Typical durations See Table 5.1 above for See Table 5.1 above
maximum duration of currently set at 12 impact of duty shift
night shifts hours (see duration changing.
Appendix 4).
5.2.3 Social Impacts of FTL Changes for Night Duty
Those social impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below.
Table 5.4: Social Impacts Associated with Changes to Night Shift Provisions
Potential change Reference Identification of generic Factors which will affect
situation in social impacts size of impacts
Europe
Harmonisation of the The typical Provided operator can still Depends how different
maximum number of number of cover all the shifts, proposed regulations are
consecutive night shifts consecutive service provision levels from current practices.
night shifts should not be affected.
appears to Working patterns of crew
vary from 3 – 7 may be altered which
(see Appendix could affect travel time/
4). time at home if they
typically stay at the base
for the whole sequence of
shifts.
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Potential change Reference Identification of generic Factors which will affect
situation in social impacts size of impacts
Europe
Specifying a Current If insufficient relief crew, Frequency of such events.
requirement for situation in base may need to close if
availability of relief crew Europe not crew reports too fatigued.
to take over at night for known.
fatigued colleagues
(who have reached a
defined limit or who
declare themselves too
fatigued)
Harmonisation of the Typical See Table 5.2 above for See Table 5.2 above
maximum duration of durations impact of duty shift
night shifts currently set at duration changing.
12 hours (see
Appendix 4).
5.3 Cumulative Effect of Multiple Consecutive Duty Shifts
5.3.1 Safety Impacts of FTL Changes Related to Cumulative Fatigue
The key issues associated with this hazard are:
i. Number of consecutive days/ hours in week
ii. Cumulative sleep deprivation, e.g. cumulative shift hours overlapping with WOCL
iii. Other cumulative limits
iv. Other potential mitigations
5.3.1.1 Number of Consecutive Days/ Hours in Week and Cumulative Sleep Deprivation
Literature Review
The scientific research on the links between fatigue and the subsequent risk of accident and
injuries over consecutive work days is reviewed in Section 4.3. The development of
cumulative fatigue tends to increase during consecutive periods of duty, especially for long
duties, early starts, late finishes and overnight duties, when the normal pattern of sleep is
disrupted (Spencer and Robertson 2000, Spencer and Robertson 2002).
A wide variety of HEMS operating patterns is shown in Appendix 4 with respect to
consecutive days working and rest days. A high level modeling approach is adopted below.
CAS modeling
The following shift patterns were modeled for 5 consecutive days, all shifts starting at 07:00,
10 x 15 minute missions in each shift all evenly spaced throughout:
• 10 hours duty and 14 hours rest (7.5hrs sleep)
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• 12 hours duty and 12 hours rest (7.5hrs sleep)
• 14 hours duty and 10 hours rest (7.5hrs sleep)
• 16 hours duty and 8 hours rest (6hrs sleep)
• 18 hours duty and 6 hours rest (4hrs sleep)
Figure 5.4 indicates that for shifts up to 14 hours, the fatigue score stays at a relatively low
level over this 5 day period. The fatigue score is calculated as a weighted sum of 11
individual factors including the average alertness on duty, number of recovery breaks per
week, hours on duty per week, number of time zone crossings and others. A number of
these factors are sensitive to cumulative fatigue. Figure 5.4 indicates that cumulative fatigue
rises rapidly as shift length exceeds 16 hours consistent with the scientific literature.
Figure 5.4 – Cumulative fatigue is highest after 5 consecutive 16 or 18hr shifts. Shift
length and time-of-day factors combine to make 16-18hr shifts more challenging than 10-
14hr shifts.
A nighttime shift pattern of 12 hours duty beginning at 19:00 running for 7 consecutive days
with 10 x 15 minute missions in each shift was also modeled. Figure 5.5 shows the
alertness at the end of shift for days 1 to 7. The alertness at the end of the shifts actually
increases slightly from Days 1 to 4 and then levels off to Day 7. Cumulative effects of
fatigue are likely obscured in this modeling scenario by 1) time of day effects and 2) a “floor
effect”. Floor effects are seen when it is unlikely for alertness (for example) to go much
lower. CAS assumes that the subject being modeled will not fall asleep on the job, however
subjective feelings of alertness may be lower at shift end over the course of the seven days.
However, all these alertness values at the end of shift are low. It should be noted that the
average alertness across all the shift hours is at about 40-45, i.e. significantly above the end
of shift values in Figure 5.5.
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Figure 5.5 – Alertness improves slightly then levels off during consecutive night
shifts. However, all scores are low. Pilots fly seven consecutive 12hr night shifts with 10 x
15min flights spaced evenly throughout the entire shift.
5.3.1.2 Other Cumulative Limits
Monthly and annual limits are generally built up from weekly limits with rest days added in. It
is very difficult to relate cumulative fatigue to longer term limits either from scientific literature
or modeling.
Moebus Aviation’s report (Moebus, 2008) proposed additional limits to those in Subpart Q,
i.e. a duty hours limit over 14 consecutive days and a block hours limit per 12 consecutive
months. Limits on these (slightly modified from those proposed in the Moebus Aviation
report) are included in CRD 2010-14 although, as noted in NPA 2010-14 (EASA, 2010) there
is a lack of scientific evidence and the limits are rather based on judgments of what appears
“reasonable”. Operational experience with respect to EMS will be important to allow filling in
the gaps from the scientific literature and modeling.
5.3.1.3 Other Potential Mitigations
Other potential mitigations could be incorporated into the options for managing cumulative
fatigue. These may include:
• Minimum number of days off per month – there is a lack of scientific evidence
regarding the impact of this measure on cumulative fatigue. There are a variety of
provisions for HEMS in Table 3.7 of Deliverable D1. The Working Time Directive
requires a minimum of 7 days off per month.
• Spread out duty as evenly as possible – good practice but difficult to apply in
EMS.
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• Rest period increased periodically – while various scientific studies highlight the
benefit of two nights of recovery sleep to resume baseline levels of sleep structure
and waking performance and alertness, HEMS patterns can be quite varied (see
Appendix 4 and Table 3.7 of D1). One of the cycles in France for example can have
12 consecutive days of onsite standby followed by 6 days’ rest.
5.3.2 Economic Impacts of FTL Changes Related to Cumulative Fatigue
Those economic impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below.
Table 5.5: Economic Impacts Associated with Potential Changes to Cumulative Limits
Potential Reference situation Identification of generic Factors which will
change in Europe economic impacts affect size of impacts
Harmonised As per Subpart Q with New regulations on Depends on how
limits on weekly, some national cumulative limits, if different current hours compare
monthly, annual additions (see Table from current practices, will to whatever new limits
duty/ flying hours 3.8, D1) lead to crew reaching limits are proposed. For
more quickly/ slowly and smaller operators with
impacting the productivity and less crew, effects are
costs of crew. likely to be
proportionally larger.
See illustrative graph
Figure 5.6 below.
Harmonisation of Large national New regulations on minimum Size of impact will
minimum number variations in rest days number of days off, if different depend on difference
of rest days per per month and from current practices, will between proposed
month and/ or periodic increases in directly impact crew regulations and current
periodic rest rest periods (see productivity and required crew practice.
period increases Table 3.7, D1) numbers to maintain EMS
service level. See AEMS Section 6.1
for illustrative example
of impact of changing
number of rest days.
Figure 5.6 illustrates how the impact of cumulative limit changes could be different for
operators working at or close to the cumulative limits (“At limits”) already and those who
have some slack in the cumulative hours their crews are working (“Under Limits”). For those
working at existing limits, e.g. 2000 duty hours per year, a rule reduction in this limit will
directly lead to increased crew costs. For an operator whose crew are on average at 1600
duty hours per year, for example, Figure 5.6 below illustrates how it is only when the limit
reduces to this level that costs will increase significantly.
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Figure 5.6: Illustrative Graph of Impact of Cumulative Limit Changes on Operating
Costs
5.3.3 Social Impacts of FTL Changes Related to Cumulative Fatigue
Those social impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below.
Table 5.6: Social Impacts Associated with Potential Changes to Cumulative Limits
Potential Reference situation in Identification of generic social Factors which
change Europe impacts will affect size
of impacts
Harmonisation on As per Subpart Q with For any cumulative limits changes Depends how
limits on weekly, some national it seems reasonable to assume that different
monthly, annual additions (see Table service levels will be maintained, if proposed
duty/ flying hours 3.8, D1) practical, with minimal impact on regulations are
patient safety and health. from current
limits.
If economic impacts are severe,
this could affect EMS service levels
and could affect job security.
In addition crew members work/ life
balance could be affected by
changes.
Harmonisation of Large national As above As above
minimum number variations in rest days
of rest days per per month and periodic
month and/ or increases in rest
periodic rest periods (see Table 3.7,
period increases D1)
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5.4 Sleep/ Rest Off-Duty and Relaxation/ Napping On-Duty
5.4.1 On-Duty HEMS base standby
5.4.1.1 Safety Impacts of FTL Changes
The key issues associated with this hazard are:
i. Value to be given to standby/ on-ground breaks within duty hours or FDP
ii. Quality of relaxation/ napping while on standby (relates to available facilities)
Given that HEMS operations are usually based on duty hours restricted shifts the issues of
maximum base standby duration and rest following standby are part of shift duty duration
(covered in Section 5.1) and rest following duty shifts (covered in Section 5.4.2 below).
Value to be given to standby/ on-ground breaks within duty hours or FDP
In those States surveyed where the regulations are based on daily duty time limits, there are
examples of the standby time at base being counted 100% towards duty (e.g. France) and
where it is counted 50% towards duty (e.g. Czech Republic).
In those States surveyed where regulations/ provisions use FDP limits for HEMS, there are
examples where all the standby time at base for immediate readiness counts to the FDP
(e.g. UK), where the FDP is interrupted when there is a break exceeding 1 hour (e.g.
Switzerland) or exceeding 2 hours in suitable accommodation (e.g. Germany).
As discussed in the Literature review (Section 4.5) there are contradictory recommendations
concerning how airport standby should be treated with respect to FDP and duty time
contributions. Moebus Aviation (2008) notes that there is ‘no scientific evidence to suggest
that airport standby should be considered as any less fatiguing than flight duty and that
further research is needed in this area’. It concludes that ‘time spent in airport standby
should normally count 100% as flight duty when calculating the maximum FDP’. The
Principles and guidelines for duty and rest scheduling in Commercial Aviation ‘NASA Study’
(Dinges, 1996) contradicts Moebus Aviation’s conclusions and recommends that ‘airport
standby should be considered as duty’.
This uncertainty is reflected in the range of European States’ provisions covering HEMS.
Relaxation/ napping while on base standby
If taken between flights, a brief nap can benefit alertness and performance. The nap should
be limited to 15-20 minutes, or 90 minutes, and allow 10-15 minutes recovery from any
potential sleep inertia. The potential benefits of a nap in improving alertness and
performance during routine operations, with a resulting increase in safety margin, may
outweigh the potential negative effects of a short period of sleep inertia.
A potential negative consequence is that the nap can theoretically disrupt the duration or
quality of a later sleep period. Providing fatigued employees with an opportunity for a nap
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before driving home at the end of a shift will theoretically decrease the risk of accidents while
driving fatigued.
This topic has been explored further using CAS modelling applied to naps during HEMS
standby. The following scenarios were modeled to investigate in-shift naps:
• Scenario 5 from Section 5.1.1.1 – i.e. 16 hours shift duration from 0700 to 2300. 2
sequences of 5 missions each.
• Scenario 9 = Scenario 5 but with a nap inserted into the middle of the shift. The nap
was placed between the two flight sequences, it was 90min long, and occurred
between 14:00-15:30. That is probably the best time to take a nap, since it occurs
during the “post lunch dip”, when the threshold to fall asleep is lower.
The results are shown in Figure 5.8 below. This graph indicates that the 90 min mid-shift
nap is effective in raising alertness for the second half of the shift. It should be noted
however, that a nap of 90 min is probably on the high side – naps of 30 minutes or less will
be more common and additional modeling of 30 minute naps indicates less benefit than the
90 minute naps (data not shown).
5.4.1.2 Economic Impacts of FTL Changes to HEMS Base Standby
Those economic impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below.
Table 5.7: Economic Impacts Associated with Potential Changes to Base Standby
Provisions
Potential Reference situation Identification of generic Factors which will
change in Europe economic impacts affect size of impacts
How airport In some States in D1 If a regulatory change leads to Depends on amount of
standby time survey standby at base airport standby contributing airport standby and how
contributes to contributed 100% to 100% instead of 50% to current cumulative
cumulative duty cumulative duty time cumulative duty time (for hours compare to limits.
time whereas for Czech example) this could lead to
Republic it counts as crew reaching cumulative duty For those operators so
50% contribution. time limits more quickly, affected this could be
thereby reducing average crew significant.
availability.
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Potential Reference situation Identification of generic Factors which will
change in Europe economic impacts affect size of impacts
How airport In some States in D1 For those States/ operators The significance of this
standby time survey standby at base allowing breaks in missions of would depend on
contributes to contributed 100% to a certain length and quality to current patterns of
FDP and shift FDP and shift duty interrupt/ extend the FDP or missions/ breaks and
duty time time, in others with shift, if this provision were how much benefit
breaks between removed, effective FDP/ shift operators are currently
missions of 1-2 hours duration would be reduced. deriving from this
there was a 0% flexibility.
contribution with May be more of a social
suitable crew facilities. impact for some
operators who only use
these breaks to extend
shift when there is a
critical mission need.
Quality of No data obtained so If a proposed regulation Scale of impact will
airport standby far. required operators to upgrade depend on proposed
facilities facilities, this would have a regulatory requirements
direct impact in terms of compared to existing
capital costs and possibly facilities and number of
extra running/ maintenance bases affected (N.B.
costs for the facilities. approximately 360
HEMS bases in
Europe).
5.4.1.3 Social Impacts of FTL Changes to HEMS Base Standby
Those social impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below.
Table 5.8: Social Impacts Associated with Potential Changes to Base Standby
Provisions
Potential Reference situation in Identification of generic Factors which will
change Europe social impacts affect size of impacts
How airport In some States in D1 If crew members reach their Depends how different
standby time survey standby at base cumulative limits earlier or later proposed regulations
contributes to contributed 100% to that will impact the number of are from current
cumulative duty cumulative duty time pilots required. If this leads to practices.
time whereas for Czech a need for more pilots and
Republic it counts as there are not sufficient pilots Depends also on
50% contribution. available, or they cannot be amount of airport
afforded economically, then standby and how
service provision may current cumulative
decrease. hours compare to
limits.
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Potential Reference situation in Identification of generic Factors which will
change Europe social impacts affect size of impacts
How airport In some States in D1 If FDPs/ shifts are effectively The significance of this
standby time survey standby at base shortened, there may be a would depend on
contributes to contributed 100% to reduction in times for which current patterns of
FDP and shift FDP and shift duty time, certain HEMS bases can be missions/ breaks and
duty time in others with breaks open if extra crew cover cannot how much benefit
between missions of 1- be provided economically or operators are currently
2 hours there was a 0% there may be extra delays in deriving from this
contribution with responding to certain missions. flexibility.
suitable crew facilities.
Quality of No data obtained so far. It seems reasonable to assume N/R unless significant
airport standby that service levels will be economic impacts
facilities maintained, if practical, with
minimal impact on patient
safety and health
5.4.2 Sleep and Rest Off-Duty
This subsection addresses the following hazard groupings:
• Lack of rest opportunity associated with basic rest and reduced rest
• Lack of extended rest following an extended FDP/ shift
5.4.2.1 Safety Impacts of FTL Changes to Basic and Reduced Rest
Literature Review
How much rest an individual needs between blocks of working days is related to the number,
timing, and length of the consecutive shifts he or she works. Allowing more time off after
extended blocks of night shifts is important because night shifts are more fatiguing, and
sleep debt more prevalent, than with day shifts. There is agreement in the literature that a 24
hour period with one single night is usually not enough to fully recover from a series of
consecutive work days. Instead, two consecutive days and nights off (48hrs) with unlimited
sleep opportunity is usually enough to dissipate any cumulative sleep debt (see Section 4.7).
CAS Modeling
To indicate the potential impact of 2 periods of reduced rest within a week’s shift pattern
CAS modeling has looked at the following sequence of day shifts (60 hours duty in week
total):
• 10 hours duty and 14 hours rest at home
• 15 hours duty and 9 hours rest at base in suitable accommodation
• 10 hours duty and 14 hours rest at home
• 15 hours duty and 9 hours rest at base in suitable accommodation
• 10 hours duty and 14 hours rest at home
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Figure 5.7 shows the alertness at the end of shift for the 5 days. The average alertness
across all hours is high for these day shifts. The modeling indicates very little difference
between alertness at the beginning of the shift on days 1-5 with the fatigue score varying
from 76 to 79. The predicted sleep periods are as follows:
Day 1 - work 07:00-17:00, sleep 22:15-6:00
Day 2 - work 07:00-22:00, sleep 23:00-6:00
Day 3 - work 07:00-17:00, sleep 22:30-6:00
Day 4 - work 07:00-22:00, sleep 23:00-6:00
Day 5 - work 07:00-17:00, sleep 22:30-6:30
On the normal duty days (3 and 5) of 10 hours, alertness at the end of the shift has
recovered from the previous reduced rest days. This assumes that the crew has managed 7
hours sleep at the base on days of reduced rest. This appears sufficient in this scenario to
prevent significant cumulative fatigue. However, the data from Samel et al (2004) with HEMS
crew in Section 4.3.2 shows what can happen if sleep drops below 6 hours per night for
consecutive days.
Figure 5.7 – Alertness at end of shift shows that two periods of reduced rest in week
do not have significant cumulative effects in this scenario . Pilots fly five consecutive
day shifts with 15min flights spaced evenly throughout the shifts. Shift length on days 1, 3,
and 5 is 10hr, allowing 14hr rest at home. Shift length on Days 2 and 4 is 15hr, allowing 9hr
rest taken at the base in sleeping accommodation.
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5.4.2.2 Safety Impacts of FTL Changes Related to Extended Rest Following Extended
FDP/ Shift
One means of mitigating the effects of a long (extended) shift, post-event, is to provide a
longer rest afterwards. Clearly this does not help during the extended shift, but it can
mitigate subsequent effects.
In terms of the scientific literature, The Principles and guidelines for duty and rest scheduling
in Commercial Aviation ‘NASA Study’ (Dinges, 1996) recommends that ‘the ….. required off-
duty period should be extended by the same duration of the flight duty period extension’.
In the UK at least 48hrs must elapse between the end of one extended HEMS air ambulance
FDP and the start of another.
CAS modeling
The following scenarios were modeled to investigate post shift extended rest:
• Scenario 5 in Section 5.1.1.1 – 16 hours duration from 0700 to 2300. 2 sequences of
5 missions each.
• Running scenario 5 for 2 consecutive days
• Running scenario 5 twice but with an additional 24 hour rest in between.
Figure 5.8 indicates that:
• Having two long shifts on consecutive days does lead to a reduction in alertness at
the end of day 2 compared to the end of day 1.
• An extra 24 hours rest brings alertness levels at the end of the second long day back
up to the levels at the end of the first day. So in this scenario an extra 24 hours rest
is an effective mitigation for an extended HEMS shifts.
Figure 5.8 – Alertness during a 16hr shift is improved by a nap mid-shift, and marginally
by 24hr extra rest between shifts. Alertness is shown at the end of either the first or second
sequence of flights. Flight sequence 1 begins 1hr after shift start, and consists of six evenly
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distributed 15min flights in 3hr. This is followed by a 9hr break where is the pilot is expected to be
awake. Flight sequence 2 consists of six evenly spaced 15min flights in 3hr ending at the end of
the shift. 16hr Shift is a single 16hr shift from 7:00-23:00. 16hr shift: 90min nap mid-shift is a
single 16hr shift with a 90min nap in the middle of the 9hr break. Two consecutive 16hr shifts
refers to two consecutive 16hr shifts with no naps. 16hr shift, 24hr rest, 16hr shift is two 16hr
shifts with no naps and a 24hr additional rest between them.
5.4.2.3 Other Potential Mitigations:
In addition to setting minimum rest periods and limits on reduced rest, other potential
mitigations for lack of rest that could be considered are:
• Augmentation of rest period following reduced rest
• Reduced maximum FDP/ shift following reduced rest
• Limiting the frequency of reduced rest occasions
• Limiting the length and number of missions after reduced rest (probably not practical
for HEMS).
5.4.2.4 Economic and Social Impacts of FTL Changes to Off-Duty Rest
Those economic impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below.
Table 5.9: Economic and Social Impacts Associated with Potential Changes to Off
Duty Rest Provisions
Potential Reference situation in Identification of generic Factors which will
change Europe impacts affect size of impacts
Removing Minimum reduced rest May need extra pilots to Frequency with which
possibility for varies from 8 hours to ensure bases are open on time reduced rests are
reduced rest 11 hours depending on next day. Alternatively base currently taken.
State. may need to stay shut while
(N.B. 6 hours has been pilots catch up with their full Whether base is
set in Switzerland as rest affecting service provision daytime only or 24/7
minimum time to get and impacting patient safety and current level of
“enough” sleep between and health. contingency crew
flights on a 48 hour shift cover.
period – but not
officially classed as
reduced rest. See Table
3.7, D1.)
Setting As above. If the proposed regulatory As above.
minimum minimums are significantly
hours for different from current national
reduced rest rules, the impacts could be
similar to row above.
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5.5 Pilot in Command Discretion
5.5.1 Safety Impacts of FTL Changes to PIC Discretion
The facility for the PIC to extend an FDP or shift is considered in the ranges of shifts
modeled above (see Section 5.1.1.1). As well as providing maximum limits on this extension
other potential mitigations could be:
• A non-punitive process for a PIC to reduce a shift duration and/or increase rest in the
case of fatigue
• Training on fatigue to support PIC in the decision process (part of FRMS)
• Reporting to the NAA when the extension is above a certain threshold
• Guidance to the NAA on this subject.
5.5.2 Economic Impacts of FTL Changes to PIC Discretion
The main impact would be related to the duration of the extension period that is under the
PIC’s discretion. The economic impact of changing extended FDP/ shift limits is considered
already above in Section 5.1.
Other economic impacts will be related to the setting up and administration of any new or
updated processes related to training, reporting and guidance.
5.5.3 Social Impacts of FTL Changes to PIC Discretion
See Section 5.1 for social impacts of reducing flexibility for extensions.
5.6 Positioning and Travelling
The relevant hazards are:
• Positioning before an FDP/ shift which could lead to excessive time awake towards
the end of a mission
• Positioning immediately after an FDP/ shift which could lead to excessively long duty
periods with a cumulative effect
• Excessive travelling time
For HEMS operations, positioning will be relatively infrequent. Positioning to another base to
cover for staff shortage might be an example. When it does occur then the following
mitigations are relevant:
• Counting position duties as FDP when immediately prior to FDP
• Rest being based on the duty hours which counts positioning in full
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These mitigations appear consistent with current provisions in Europe.
The potential for excessive traveling times is relevant to HEMS as for other operations. The
following mitigations are likely to be relevant:
• Nomination of a home base for each crew member
• Ensuring a protected 8 hour sleep opportunity
• Counting travel time in excess of a limit (e.g. 60 minutes) as duty time (or
positioning).
Depending on the current situation in terms of HEMS crew travel times and what changes
are proposed there could be significant impacts. If many crew are travelling significantly
greater than a chosen limit (e.g. 60 minutes) then introducing such a limit could have
economic impacts in terms of increasing duty hours and hence rest requirements. If this
causes movement of crew closer to bases there could also be social impacts. Hence a
clearer picture in terms of current crew travel to and from HEMS bases would be valuable to
assess potential impacts.
5.7 Circadian Disruption Due to Mixing Night and Day Shifts
As noted in Section 4.2.4 transitioning from day to night shifts and vice versa can cause
problems. During the transition there is a misalignment of the circadian rhythms which leads
to malaise and increased fatigue. Research studies (Santhi et al 2007) have studied the
transition from day to night shift without rest days in between and found that the first night
shift is most problematic with impairment in the ability to sustain focus, decrease in
subjective alertness and decrease in visual search sensitivity more pronounced than in
subsequent shifts.
A number of the European States surveyed in D1 have provisions for rest days between
series of shifts. In France for example a set of 7 consecutive day shifts would be followed by
7 consecutive rest days before a series of night shifts would be undertaken. For other
States see Appendix 2 of D1. The provision of rest days in between these transitions is an
important mitigation for this cause of circadian disruption. Limiting the frequency of such
transitions would also be a mitigation but may be difficult to achieve depending on
operational factors and crew resources.
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6.0 AEMS Analysis
The following fatigue factors and hazards from Table 3.2 are addressed in this section:
6.1 Duration of FDP and Extension for non-augmented crew – hazard A1, duration of
FDP too long leading to fatigue, including A2, A4, A5 as possible causes of long
periods awake
6.2 Duration of FDP and Extension for augmented crew – hazard A3, extended
augmented crew FDP leads to fatigue
6.3 Time of Day Effects and Night Duty – hazard B1, WOCL encroachment
6.4 Home standby – how the unpredictability of home standby can contribute to long
periods awake, hazard A5, and how it could contribute to cumulative fatigue, hazard
C2
6.5 Pilot in Command Discretion – hazard A2, PIC discretion leading to too long an FDP
6.1 Duration of FDP and Extension – Non Augmented Crews
6.1.1 Safety Impacts of FTL Changes for FDP Duration and Extensions
The key issues associated with hazard A1 are:
i. Length of FDP and fatigue level
ii. Length of extended rest after an extended FDP
iii. Encroachment of WOCL (see section 6.3)
iv. Impact of number of sectors
v. Other potential mitigations.
6.1.1.1 Length of FDP and Fatigue Level
Literature Review
See Section 5.1.1.1.
CAS modeling
As some States and AEMS operators make use of extended FDPs that are significantly
longer than those allowed in Subpart Q, modeling of longer FDPs is considered useful to
future rule making discussions.
FDPs in the range 11 to 20 hours have been considered with non-augmented crews. The
scenario specific assumptions are:
• Two sectors of 5 hours each, first flight starting 30 minutes after start of FDP and
second flight ending at end of FDP, with half hour post flight duties
• Full rest before FDP
• Pilots assumed to stay awake during gap in 2 sectors
• No time-zone complications for this scenario
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Three different finish times for the FDP have been selected, 0600 (worst case in terms of
alertness), 13.00 and 21.00. The graph below shows alertness at the end of the last flight for
these 3 different finish times with the different FDP durations.
Figure 6.1 indicates that:
• Alertness at the end of the last flight is heavily dependent on circadian time-of-day as
expected.
• For the finish time where alertness is highest (2100) there is a large variation in
alertness depending on FDP length between 11 hours (score of 76) and 20 hours
(score of 32). Above 13 hours duration the alertness score starts to decrease
steadily.
• For the other two end times of 0600 and 1300 there is less variation with FDP
duration. In the case of 0600 the alertness is very low (<10 “bottomed out”) for all the
durations modeled. A combination of FDP greater than 11 hours flown with an
unaugmented crew and ending at 0600 will lead to low levels of alertness. Additional
mitigations may be applied by crew in such circumstances, such as controlled
napping when sanctioned. For 1300 the alertness varies from 38 to 27.
These findings seem broadly consistent with the literature in Section 4 indicating significant
increases in risk as FDP begins to exceed 12-14 hours. The combination of literature and
modeling shows that if EMS extensions are granted beyond 13 hours, flight safety risks are
likely to increase. This needs to be balanced in some way with the medical benefits to
patients and the public of extended EMS FDPs.
Figure 6.1 – Alertness at end of FDP depends on FDP length and time-of-day of FDP end.
Alertness is shown at the end of Flight 2. Flight 1 is a 5hr flight starting 30min after shift start.
This is followed by a break of varying lengths where the pilot is expected to stay awake. Flight 2
is a 5hr flight that ends at the end of the shift. FDPs of 11, 13, 15, 17, 19, and 20hr end at either
6:00, 13:00, or 21:00 and start at varying times accordingly.
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6.1.1.2 Length of Extended Rest After an Extended FDP
One means of mitigating the effects of a long (extended) FDP, post-event, is to provide a
longer rest afterwards. Clearly this does not help during the extended FDP, but it can
mitigate subsequent effects.
In terms of the scientific literature, The Principles and guidelines for duty and rest scheduling
in Commercial Aviation ‘NASA Study’ (Dinges, 1996) recommends that ‘the ….. required off-
duty period should be extended by the same duration of the flight duty period extension’.
Other literature in Section 4 notes the importance of two nights sleep to recover from peak
fatigue.
In the UK at least 48hrs must elapse between the end of one extended air ambulance FDP
and the start of another. Pilot can fly 3 air ambulance extended FDPs in any 28 consecutive
days. In France, if the FDP is greater than 14 hours, subsequent rest must be at least 24
hours including a local night except if reduced rest provisions are applied. In Norway a FDP
of up to 17 hours (maximum) would be followed by a rest of at least 17 hours.
In one of the Swiss EMS operators there is the concept of Compensation Time added on
top of the obligatory rest period. This is calculated using formulae which take account of the
extended FDP duration, the number of crew members and whether the FDP included part or
all of the night. The Compensation Time on top of the standard rest time can vary from 3
hours to 48 hours depending on these factors.
6.1.1.3 Impact of Number of Sectors
The need to decrease the FDP if there are a significant number of sectors is confirmed by
many scientific studies (see Section 4.1.4). The Subpart Q requirement on maximum
allowable FDP is based on a 30-minute reduction after the second sector. AEMS pilots can
fly multiple sectors and it is reasonable to believe that this will have a similar effect on them
as for scheduled and charter pilots. A reduction of FDP based on the number of sectors is
part of some national provisions and Subpart Q is applicable to AEMS in many States as
described in D1.
6.1.1.4 Other Potential Mitigations
In addition to limits on FDP duration, extended rest and modifying maximum FDP depending
on numbers of sectors, other potential mitigations for long duration FDPs could be
incorporated into the RIA options. These may include:
• Requiring full rest before the extended FDP (assumed in modeling above)
• FRMS (general for all hazards)
• Relief pilot for single pilot operations when an extension is invoked
• Prohibiting combining EMS operations FDP extension with extension due to split duty
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• Controls over extensions due to split duty/ on-ground breaks, e.g. minimum
consecutive number of hours for break before it can lead to an extension, etc.
• Ensuring that the most strict limits apply when extensions are used for mixed
operations (e.g. air taxi and EMS)
• Limiting number of persons on aircraft during extensions
• Limiting the frequency of such extended FDPs
• Controlled napping and relaxation during any ground breaks between mission sectors
• Records to NAA of extensions and NAA oversight measures.
6.1.2 Economic Impacts of FTL Changes for FDP Duration and Extensions
Those economic impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below (Table 6.1).
Table 6.1: Economic Impacts Associated with Potential Changes to FDP Duration
Provisions
Potential Reference situation in Identification of generic Factors which will
change Europe economic impacts affect size of
impacts
Harmonisation Based on the survey of Changes to basic max. FDP Size of impact will
of basic max. 8 States in Europe (D1) duration (including impact of depend on how close
FDP duration FDPs vary from 8 to 14 WOCL encroachment or to FDP limits
hours depending on number of sectors) could lead operators currently fly.
State, number of pilots, to the need for augmented If close to the limits
FDP start time and crew and hence changes in and limits change then
number of sectors. pilot costs or if dramatically could be significant
reduced could make certain need for more/ less
missions impossible. crew.
Harmonisation Based on the survey of The main reason for extending Social impacts more
in flexibility to 8 States in Europe (D1) is if an aeroplane is in the significant.
extend FDPs to extensions vary from 0 middle of a mission and is in a
meet medical up to 4 hours better position to continue and
emergencies depending on State bring a patient back to hospital
and type of emergency. for example rather than have a
new crew get ready and
proceed from the airport/ base.
Therefore any changes in this
flexibility would not necessarily
have any significant impact on
crew numbers or economic
impacts (except for extended
rest requirements described
below).
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Potential Reference situation in Identification of generic Factors which will
change Europe economic impacts affect size of
impacts
Harmonisation Based on the D1 Changes to the amount of rest The percentage of
of required survey the required rest following an extended FDP will FDPs that get
extended rest after an extended FDP affect crew availability. If a extended beyond
after an can vary from = FDP new requirement for extended proposed regulatory
extended FDP up to 48 hours rest following an extended change.
depending on State. FDP is introduced then extra
crew may need to be made How much spare crew
available to cover such an capacity operators
event. have to cover such
events currently.
An indication of the process for determining the economic impacts of proposed changes is
illustrated by the following example relating to additional extended rests following extended
FDPs:
• Assume that a regulatory change leads to an additional 24 hours rest being allotted
whenever an extended FDP beyond X hours is flown.
• Assume that each crew member experiences an extended FDP exceeding X hours
for Y times a year.
• The change will lead to an average of Y extra rests days (24Y extra rest hours) per
year per crew member.
• Data from 2 states indicates that an AEMS crew member will average about 1300
duty hours per year.
• If the extra rests reduce duty time directly, this would cause a 24Y/1300 × 100%
reduction in crew productivity. In practice extra operational data would be needed
about the impact of extra rests on duty time.
• When data is available this could be combined with information from Section 2.2
where it is estimated that crew costs are about 20% of total operating costs (although
with a significant range from 15% to over 30%).
6.1.3 Social Impacts of FTL Changes for FDP Duration and Extensions
Those social impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below (Table 6.2).
Table 6.2: Social Impacts Associated with Changes to FDP Duration Provisions
Potential Reference situation in Identification of generic Factors which will
change Europe social impacts affect size of
impacts
Harmonisation Based on the survey of If dramatically reduced could See row below.
of basic max. 8 States in Europe (D1) make certain AEMS missions
FDP duration FDPs vary from 8 to 14 impossible.
hours depending on
State, number of pilots,
FDP start time and
number of sectors.
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Potential Reference situation in Identification of generic Factors which will
change Europe social impacts affect size of
impacts
Harmonisation Based on the survey of If changes lead to reduction in The percentage of
in flexibility to 8 States in Europe (D1) this flexibility then it could take FDPs that get
extend FDPs to extensions vary from 0 longer to reach and transport extended beyond
meet medical up to 4 hours patients in events which occur proposed regulatory
emergencies depending on State close to FDP limits. change.
and type of emergency.
No other social impacts The percentage of
considered significant. these extended FDPs
that do actually “save
lives” – would expect
this percentage to be
high as event needs to
be urgent to justify an
FDP extension.
Harmonisation Based on the D1 If extra rest days cannot be The size of the
of required survey the required rest covered due to economic change in required
extended rest after an extended FDP constraints then service levels extended rest
after an can vary from = FDP would be affected. compared to current
extended FDP up to 48 hours provisions.
depending on State. Economic impacts could lead
to jobs created or lost. The frequency of
extended FDPs.
The amount of crew
cover an operator has
to accommodate
extended rests.
An indication of the process for determining the social impacts of proposed changes is
illustrated by the following example relating to restricting duration of extended FDPs:
• Assume that a regulatory change leads to a reduction in extensions from X hours
maximum extended FDP to Y hours maximum FDP.
• Assume that an operator currently experiences extended FDPs between X and Y
hours duration Z times per year.
• Assume that for 10% of these events the extension allowed a patient’s life to be
saved.
• The social impact of this regulatory change for this operator would be approximately
10/100 × Z extra patient fatalities per year.
As with the equivalent HEMS calculation these assumptions would need to be replaced by
actual data from operators and health services to enable actual social impacts to be
estimated.
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6.2 FDP Extension With Augmented Crew
6.2.1 Safety Impacts of Changes for Extended FDP due to Augmented Crew
The key issues associated with this hazard are:
i. Length of FDP and fatigue level
ii. Length of extended rest after an extended FDP
iii. Availability and quality of in-flight rest facilities
iv. Other potential mitigations.
6.2.1.1 Length of FDP and Fatigue Level
Literature Review
Some issues with extended duration FDP’s can be avoided by augmenting the crew during
long flights with an additional crew member(s). Augmented crews allow pilots to take in-flight
rest and obtain sleep in order to maintain alertness and reduce fatigue.
Numerous studies have shown that both objective physiological measures and subjective
ratings of alertness demonstrate improvement following an in-flight rest taken during periods
of sustained wakefulness and that sleep can also reduce or delay expected performance
decrements (Simon, 2007). Timing and duration of rest/ sleep can be designed for optimal
impact on alleviating fatigue.
CAS modeling
As some States and AEMS operators make use of augmented crew FDPs that are
significantly longer than those allowed in Subpart Q, modeling of longer FDPs is considered
useful to future rule making discussions.
FDPs in the range 11 to 20 hours have been considered with 3 person augmented crews.
The scenario specific assumptions are:
• Two sectors of 5 hours each, first flight starting 30 minutes after start of FDP and
second flight ending at end of FDP, half hour post flight duties
• Full rest before FDP
• 90 minute sleeps as part of inflight rests were placed in the middle of each flight
• No time-zone complications for this scenario
As in section 6.1.1.1 three different finish times for the FDP have been selected, 0600 (worst
case in terms of alertness), 13:00, and 21.00. Figure 6.2 shows alertness at the end of the
last flight for these 3 different finish times for augmented and non-augmented crew.
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Figure 6.2: Impact of FDP duration on alertness at end of Augmented Crew FDP
Effect of FDP Duration on End of Flight Alertness - With or Without
Augmentation
100
Alertness at End of Flight 2
90
80 6:00 Shift End
70 6:00 Shift End + Inflight sleep
60 13:00 Shift End
50 13:00 Shift End + Inflight sleep
40 21:00 Shift End
21:00 Shift End + Inflight sleep
30
20
10
0
11hr 13hr 15hr 17hr 19hr 20hr
FDP Duration
The graph indicates that:
• For the end time where alertness is highest (2100) crew augmentation is effective in
maintaining alertness at the end of the second flight (compared to Figure 6.1 with
non-augmented crew).
• In the case of 06:00 end time the alertness is low even with augmentation and at this
finish time the alertness shows only weak dependence with FDP duration.
• Alertness is at intermediate levels with an afternoon (13:00) end time and
augmentation shows clear benefits.
6.2.1.2 Length of Extended Rest After an Extended FDP
See Section 6.1.1.2 above for relevant scientific literature.
In the UK, an additional 'day off' (minimum 34 hours which includes 2 local nights) must be
taken on completion of the full rest entitlement after an extended crew augmented FDP for
AEMS.
In France, the minimum rest at home base following extended crew augmented FDP is 48
hours with 2 local nights.
6.2.1.3 Other Potential Mitigations
Other potential mitigations could be incorporated into the RIA options. These may include:
• Specifying minimum rest durations at destination and at home
• Additional compensation time over and above the standard rest time
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• Sleep opportunities at the airport after long missions
• Promote and pay for use of public transport after long missions which mitigates the
risk of car accidents for AEMS flight crew
• Technical criteria for in-flight rest facilities
• Minimum duration of rest period onboard required
• Limiting the frequency of such extended augmented FDPs
• Limiting the number of sectors.
6.2.2 Economic Impacts of FTL Changes for Augmented Duty Duration and Extensions
Those economic impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below (Table 6.3).
Table 6.3: Economic Impacts Associated with Potential Changes to Augmented FDP
Provisions
Potential Reference situation in Identification of generic Factors which will
change Europe economic impacts affect size of
impacts
Harmonising FDPs up to 34 hours If a change requires 4 crew Size of impact will
FDP hours for for ULR (ex-scope) and instead of 3 to fly an FDP of a depend on how close
augmented crew up to 18 hours for non- certain number of hours this to FDP limits
and/ or ULR. will clearly lead to increased operators currently fly.
requirements for crew costs. If close to the limits
onboard rest and limits change then
facilities Alternatively operators may could be significant
choose to upgrade onboard need for more/ less
rest facilities (if practical) to crew.
achieve desired FDPs with
available crew with
consequent capital costs.
Harmonising The required rest after Changes to the amount of rest The percentage of
extended rest an extended FDP can following an extended FDP FDPs that get
after an vary from = FDP up to may affect crew availability. If extended beyond
augmented 48 hours depending on a new requirement for proposed regulatory
FDP State (greater for ULR). extended rest following an change.
augmented FDP is introduced
then extra crew may need to How much spare crew
be made available to cover capacity operators
such an event. have to cover such
events currently.
An indication of the process for determining the economic impacts of proposed changes is
illustrated by the following example relating to additional extended rests following extended
augmented FDPs:
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• Assume that a regulatory change leads to an additional 12 hours rest being allotted
whenever an extended augmented FDP beyond X hours is flown.
• Assume that each crew member experiences an augmented FDP beyond X hours Y
times per year.
• The change will lead to an average of 12Y hours extra rest per year per crew
member.
• This can be used to assess the impact on crew costs and overall operating costs as
per the other illustrative examples above.
6.2.3 Social Impacts of FTL Changes for Augmented Duty Duration and Extensions
Those social impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below (Table 6.4).
Table 6.4: Social Impacts Associated with Potential Changes to Augmented FDP
Provisions
Potential Reference situation in Identification of generic Factors which will
change Europe social impacts affect size of
impacts
Harmonising FDPs up to 34 hours Could make it difficult/ The percentage of
FDP hours for for ULR (ex-scope) and impossible to reach certain augmented FDPs that
augmented crew up to 18 hours for non- patients. For example, an extend beyond
and/ or ULR. operator may need to fly into a proposed regulatory
requirements for conflict zone where it is change.
onboard rest dangerous to stay over for a
facilities night and/or this would put The percentage of
patient at further risk. In such these augmented
cases the ability to fly an FDPs that do actually
extended FDP using crew “save lives” – would
augmentation may be the only expect this percentage
solution. to be high as event
needs to be urgent to
justify mission.
Harmonising The required rest after For any changes it seems N/R unless there are
extended rest an extended FDP can reasonable to assume that significant economic
after an vary from = FDP up to service levels will be impacts.
augmented 48 hours depending on maintained with minimal
FDP State (greater for ULR). impact on patient safety and
health.
If extra rest days cannot be
covered due to economic
constraints then service levels
would be affected.
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6.3 Time of Day Effects and Night Duty
6.3.1 Safety Impacts of FTL Changes Relating to WOCL Encroachment
There is consensus within the scientific literature and from operational experience that the
length of the FDP should be reduced if sleep is restricted, e.g. if a crew member cannot
sleep during the WOCL and then finds it difficult to sleep at other times of the day. The CAS
modeling in Section 6.1.1.1 shows low alertness for FDPs ending at the end of the WOCL.
The review of AEMS FTL provisions in D1 showed that the States either followed Subpart Q
or had a similar approach to reducing FDP for WOCL encroachment which is a mitigation for
transient effects.
Other potential mitigations aimed at cumulative fatigue include:
• Providing additional rest – e.g. if two or more FDPs encroach the WOCL during a
week, the weekly rest could be extended from 36 hours to 48 hours. This could
include other periods of extended rest not necessarily weekly.
• Limiting the frequency of such WOCL encroached FDPs – generally given the
relatively low frequency of AEMS missions such frequency limits may not be so
effective.
Mitigations aimed at both transient and cumulative fatigue are:
• Planning to optimize sleep opportunity (a Subpart Q provision) – this is hard to
guarantee for an on-demand service such as EMS.
• Personnel trained to recognize fatigue and respond appropriately (see HEMS section
on night duties, section 5.2.1).
6.3.2 Economic Impacts of FTL Changes Relating to WOCL Encroachment
The major potential impacts are judged to be any future rule changes affecting:
• Additional rest to compensate for WOCL encroachment – the economic impact will
be the equivalent of that described in Table 6.1 for Extended Rest after Extended
FDP and the illustrative calculation of impacts of extra rest time after Table 6.1.
• Changes in the manner that FDP is adjusted if WOCL is encroached – the economic
impact will be equivalent to changing the maximum FDP duration shown in Table 6.1.
6.3.3 Social Impacts of FTL Changes Relating to WOCL Encroachment
The major potential social impacts are judged to be any future rule changes affecting:
• Additional rest to compensate for WOCL encroachment
• Changes in the manner that FDP is adjusted if WOCL is encroached
These will be equivalent to those described in Table 6.2.
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6.4 Home Standby
The use of short call home standby is used by many European AEMS operators (see
Appendix 4). Long call home standby (at least 10 hours before start of an assigned duty) is
not considered below as safety impacts are not considered so significant and is not so
relevant to EMS on-demand operations.
6.4.1 Safety Impacts of FTL Changes Relating to Home Standby
The key issues associated with this hazard are:
i. Maximum duration of standby
ii. Taking account or not of standby time in FDP hours and duty hours and subsequent
rest calculations
iii. Other potential mitigations.
6.4.1.1 Maximum Duration of Standby
In terms of the scientific literature the Principles and guidelines for duty and rest scheduling
in Commercial Aviation ‘NASA Study’ (Dinges, 1996) does not consider ‘on call reserve
status’ as duty, but recommends that ‘a protected 8 hour sleep opportunity’ should be
protected from interruption by assignment to a flight duty period.
Crew Factors in Flight Operations XI: A Survey of Fatigue Factors in Regional Airlines
Operations (Co, E., 1999) notes that: ‘The nature of flying on reserve means that
crewmembers must respond when called for duty, thus creating unpredictability in their
schedules. This unpredictability can lead to sleep loss, for example, when a call for duty
occurs when a sleep period was planned. As evidence that sleep loss occurred,
crewmembers reported getting 5.6 h of sleep before duty on average—2.3 h less than their
normal average sleep.’
The survey in D1 revealed maximum short call home standby durations of 12 hours and 24
hours (sometimes renewable for 2 or more days). The degree to which crew can obtain 8
hours sleep during a 24 hours standby is unclear.
If an operator is using different standby types it can be possible to use the crew on 24 hours
standby as a “last resort” and hence minimize the chance that their sleeps will be disturbed
(see below under “Other potential mitigations”). Hence the scale of safety significance and
the impact of changing maximum standby duration is uncertain.
Thus this is an issue where operational experience will have a large input in future RMT
discussions rather than the scientific literature or modeling. A key question is – does
operational experience (and any outputs from FRMSs) show that AEMS pilots are able to get
7-8 hours sleep when on 24 hour standbys?
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6.4.1.2 Taking Account of Standby Time in FDP Hours, Duty Hours and Subsequent Rest
Calculations
There is very little scientific research covering this topic. However, Torsvall and Akerstedt
(1988) showed that sleep quality is affected in ships’ engineers based on whether they are
on-call or not. Changes in sleep quality were noted before any alarms went off, suggesting
that sleep was disrupted in anticipation of being called out for duty.
The survey in D1 revealed wide variation in this issue. Clearly reducing the allowable FDP
length to allow for some/ all of the standby time before a callout will, on average, reduce the
chance of crew fatigue. However, it will also reduce the ability of the AEMS operator to
provide a service to a patient and/ or have economic impacts (see below). Accounting for
home standby hours in duty hours (either in full or in part) would not clearly have significant
flight safety benefits for AEMS crew. In general AEMS crews fly less annual hours than
other types of pilots and cumulative fatigue is less of an issue than peak fatigue after long
missions. New provisions that lead to extra rest requirements might affect pilot competence
and hence flight safety if crew hours drop too low.
Thus this is an issue where operational experience will again have a large input in future
RMT discussions rather than the scientific literature or modeling. Key questions include –
does operational experience (and any outputs from FRMSs) show that AEMS pilots are able
to manage time at home so they do not arrive fatigued for FDPs, what fatigue training and
awareness do they receive concerning home standby and do they obtain sufficient overall
rest to manage cumulative fatigue? Fatigue training and awareness could cover use and
quality of afternoon naps, effect of meal and drinks, effects of home based tasks on fatigue,
etc.
6.4.1.3 Other Potential Mitigations
Other potential mitigations include:
• FRMS and crew’s individual management of rest during standby – a FRMS can help
raise crew’s awareness of the importance of napping, avoiding heavy home working
tasks, etc.
• Management of standby so operator avoids placing crew on repeated 24 hr duration
standbys, and preferential use of persons on standby who should be better rested.
6.4.2 Economic Impacts of FTL Changes Relating to Home Standby
Those economic impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below.
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Table 6.5: Economic Impacts Associated with Potential Changes to Home Standby
Provisions
Potential Reference situation in Identification of generic Factors which will
change Europe economic impacts affect size of
impacts
Harmonised Varied national If limit on standby duration is The extent will
limit on standby provisions up to a reduced (e.g. 24 hours to 12 depend on what
duration maximum of 24 hours hours) this is likely to increase standby patterns
(see Appendix 2, D1). pilot costs although this may operators are
vary depending on what extent currently using and
standby counts towards how much reliance is
cumulative duty and how the being placed on
standby shifts are organised. longer home
. standbys.
Harmonisation Varied national If home standby which does Frequency of
of the provisions for not lead to a duty is followed by standbys.
contribution of contribution of home a rest period (e.g. in
standby to FDP, standby to FDP and accordance with Duration of extra rest
duty hours and cumulative duty hours ORO.FTL.235) and no rest has periods following
subsequent rest can vary from 100% to been accorded before, there standby based on
calculations 0%, depending on will be a reduction in average proposed change.
State and associated crew availability and a need for
factors (see Appendix higher crew costs to maintain
2, D1). EMS service level.
An indication of the process for determining the economic impacts of proposed changes is
illustrated by the following example relating to additional rests following home standby that
does not lead to duty:
• Assume that a regulatory change leads to a new requirement for X hours rest
following a Y hour home standby.
• Assume an average of Z days home standby per crew member, with average of Y
hours per standby.
• New requirement would introduce Z × X hours of extra rest per year.
In addition operational data would be needed on how often a mission occurs immediately
after a standby period and hence whether the extra rest would increase required crew
numbers.
6.4.3 Social Impacts of FTL Changes Relating to Home Standby
Those social impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below.
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Table 6.6: Social Impacts Associated with Potential Changes to Home Standby
Provisions
Potential Reference situation Identification of generic Factors which will
change in Europe social impacts affect size of impacts
Harmonised Varied national 24 hour standby can have a The size of impact will
limit on standby provisions up to a negative social effect for crew depend on what
duration maximum of 24 hours relative to 12 hour standby as standby patterns
(see Appendix 2, D1). it does not allow relaxation operators are currently
time, e.g. going out in the using and how much
evening. On the other hand reliance is being
having to conduct 12 hour placed on longer home
standbys twice as often as 24 standbys.
hour standbys can also have
social impacts for crew.
For any changes it seems
reasonable to assume that
EMS service levels will be
maintained with minimal
impact on patient safety and
health unless economic
impacts mean that cover has
to be reduced.
Harmonisation Varied national If a rule change leads to home Frequency of standbys
of the provisions for standby contributing to and distribution of
contribution of contribution of home subsequent FDP if called out, callouts during the
standby to FDP, standby to FDP and this may reduce the ability of standby periods.
duty hours and cumulative duty hours the operator to fly sufficient
subsequent rest can vary from 100% to hours to respond to Contribution of standby
calculations 0%, depending on emergency in a timely manner. to subsequent FDP
State and associated based on proposed
factors (see Appendix Additional crew may enable change.
2, D1). patient service provision to
stay the same (e.g. through Percentage of missions
providing augmented crew), which cannot be flown
but may be uneconomic to as allowable FDP is no
maintain. longer sufficient –
relates to distribution of
Reaching cumulative duty hour distances of
limits earlier or later could also emergencies from
impact service provision. home base.
An indication of the social impacts of proposed changes is illustrated by the following
calculation relating to home standby contributing to subsequent FDPs:
• Assume a regulatory change requires standby to contribute to FDP if called out after
X hours and FDP is shortened by the amount of standby time exceeding X hours.
• Assume an average of 80 days home standby per crew member (see Appendix 4),
and assume called out on 50% of standbys.
• Assume conditional probability of being called out after X hours of standby is 50%.
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• Assume chance of mission no longer being possible because of effective FDP
shortening is Y%.
• From the above assumptions 80 × 0.5 × 0.5 × Y/100 additional times per year an
individual crew member will not be able to respond to a mission.
This simple illustrative example can be replaced with more realistic data in the future.
6.5 Pilot in Command Discretion
The safety, economic and social impacts for FTL rule changes in AEMS PIC discretion will
be similar to those under HEMS PIC discretion in Section 5.5.
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7.0 Conclusions
EMS operations have certain higher risk characteristics relative to other aircraft operations
such as time pressures to reach and transport patients and flights made at short notice with
potentially challenging topographical features and weather conditions. In addition there are
aspects of flight time limitations and rest provisions that could lead to fatigue and increased
risk, e.g. requirements to extend a duty period to respond to an emergency.
It is difficult to draw firm conclusions about the actual record of controlling fatigue risk in EMS
operations in Europe due to potential under-reporting of fatigue as a causal factor of
accidents/ incidents. The scientific literature and the modelling described in this report
indicate that operating to the extremes of the national FTL ranges4 currently allowable in
Europe could have a significant impact on fatigue and alertness. Hence harmonisation of
FTL provisions is likely to have safety impacts; in particular if the higher risk bounds of the
ranges are reduced there will be positive safety impacts.
With respect to economic and social impacts a large number of potential FTL changes have
been considered including harmonisation of:
• Maximum shift/ FDP durations
• Flexibility for shift/ FDP extensions due to EMS events
• Block hours over different time periods
• Extended rest requirements following extended shifts/ FDPs
• Availability of relief crews for HEMS night shifts
• Number of consecutive HEMS shifts (day/night)
• Periodic increases in rest
• How standby contributes to FDP and cumulative duty hours
• Reduced rest provisions
• Augmented crew arrangements.
This report provides information and preliminary analysis to be considered for the RIA
development for RMT .0346 on FTL for EMS with a view to assist in an overall balanced
assessment of safety, economic and social impacts.
4
See report D1 tables and Appendix 2 for these ranges.
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9.0 Acronyms/ Abbreviations
Term Description
AAIB Aircraft Accident Investigation Board
ADAC Allgemeiner Deutscher Automobil-Club e.V.
ADREP (ICAO’s) Accident Data Reporting system
AEMS Aeroplane Emergency Medical Services
API American Petroleum Institute
CAA Civil Aviation Authority
CAP Civil Aviation Publication
CAS Circadian Alertness Simulator
CAT Commercial Air Transport
CM Crew Member
CRD Comment Response Document
CS Certification Specification
DNV Det Norske Veritas
DRF Deutsche Rettungsflugwacht e.V./German Air Rescue
EASA European Aviation Safety Agency
EEG Electro-encephalography
EHAC European HEMS and Air Ambulance Committee
EMS Emergency Medical Services
ETSC European Transport Safety Council
EU OPS European Union (Safety Regulations) Commercial Air Transportation Operations
FAA Federal Aviation Administration
FDP Flight Duty Period
FDT Flight Duty Time
FMCSA Federal Motor Carrier Safety Administration
FRM(S) Fatigue Risk Management System
FTL Flight Time Limitations
HEMS Helicopter Emergency Medical Services
h or hrs hours
ICAO International Civil Aviation Organisation
IFR Instrument Flight Rules
IR Implementing Rules
JAR OPS Joint Aviation Requirements on Commercial Air Transportation Operations
LPR Lotnicze Pogotowie Ratunkowe
MSLT Multiple Sleep Latency Test
MWT Maintenance of Wakefulness Test
NAA National Aviation Authority
N/A Not Applicable
NASA National Air and Space Administration
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Term Description
NM Nautical Miles
NPA Notice of Proposed Amendment
N/R Not Relevant
NTSB National Transportation Safety Board
NVG Night Vision Goggles
NVIS Night Vision Imaging System
PIC Pilot In Command
REGA Swiss Air Ambulance
REM Rapid Eye Movement
RIA Regulatory Impact Assessment
RMG Rule Making Group
SRG Safety Regulation Group
TNO Nederlandse Organisatie voor Toegepast Natuurwetenschappelijk Onderzoek (Netherlands
Organisation for Applied Scientific Research)
ULR Ultra Long Range
VFR Visual Flight Rules
VMC Visual Meteorological Conditions
WOCL Window Of Circadian Low
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Appendix 1 – EMS Safety Data
EMS Accidents with Fatigue as a Causal Factor
Two European EMS accident reports were identified by DNV/ Circadian which contain
significant text on fatigue and its possible role in the respective events. These reports were
identified through search of public domain websites of accident investigation boards and
information sent by the NAAs surveyed. In addition DNV/ Circadian identified three
references to NTSB investigations on EMS accidents in the USA which are described below.
EASA’s Safety Analysis Section also conducted a search of the EASA copy of the ICAO
ADREP data base. This uncovered one further European accident and 2 non-European
EMS occurrences where fatigue appears to have been a factor.
Europe Event 1 – Scotland 2005
http://www.aaib.gov.uk/cms_resources.cfm?file=/Summary%20%20AAR%202-
2006%20Pilatus%20Britten-Norman%20BN2B-26%20Islander,%20G-BOMG.pdf
On 15 March 2005, a Britten-Norman Islander aircraft crashed into the sea while descending
toward Campbeltown Airport in western Scotland. The aircraft was operating an air
ambulance flight5 on behalf of the Scottish Ambulance Service. The pilot and paramedic
both died in the crash. Given the relevance of this accident to the current study quotes are
taken from the UK AAIB report below.
AAIB Report No: 2/2006 Report on the accident to Pilatus Britten-Norman BN2B-26 Islander,
G-BOMG, West-north-west of Campbeltown Airport, Scotland, on 15 March 2005
Abstract/ Summary
“The Glasgow based Islander aircraft was engaged on an air ambulance task for the
Scottish Ambulance Service when the accident occurred. The pilot allocated to the flight
had not flown for 32 days; he was therefore required to complete a short flight at Glasgow to
regain currency before landing to collect a paramedic for the flight to Campbeltown Airport
on the Kintyre Peninsula.
Poor weather at Campbeltown Airport necessitated an instrument approach. There was
neither radar nor Air Traffic Control Service at the airport, so the pilot was receiving a Flight
Information Service from a Flight Information Service Officer in accordance with authorised
procedures. After arriving overhead Campbeltown Airport, the aircraft flew outbound on the
approach procedure for Runway 11 and began a descent. The pilot next transmitted that he
had completed the ‘base turn’, indicating that he was inbound to the airport and commencing
an approach.
5
Air ambulance flights are defined in CAP 371 as “When the sole reason for the flight is to carry an ill
or injured person to a recognized medical facility, or the carriage of a human organ necessary for a
transplant operation.”
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Nothing more was seen or heard of the aircraft and further attempts at radio contact were
unsuccessful. The emergency services were alerted and an extensive search operation was
mounted in an area based on the pilot’s last transmission. The aircraft wreckage was
subsequently located on the sea bed 7.7 nm west-north-west of the airport; there were no
survivors.
The investigation identified the following causal factors:
1. The pilot allowed the aircraft to descend below the minimum altitude for the aircraft’s
position on the approach procedure, and this descent probably continued unchecked until
the aircraft flew into the sea.
2. A combination of fatigue, workload and lack of recent flying practice probably contributed
to the pilot’s reduced performance.
3. The pilot may have been subject to an undetermined influence such as disorientation,
distraction or a subtle incapacitation, which affected his ability to safely control the aircraft’s
flightpath.”
AAIB Section on Pilot rest
“The pilot was rostered for a night standby duty on 14 March 2005, to be conducted from
home and commencing at 2300 hrs. He had finished a two week leave period on 12 March,
and had been rostered for a day off on the 13 March. During his leave he had gone on
holiday to Italy with his family, returning to the UK on 9 March and travelling home on 12
March. He spent the remainder of the weekend at home with his family. On the evening of
13 March he had retired at about 2245 hrs and had an uninterrupted night’s sleep. On the
day of the 14 March the pilot awoke at about 0645 hrs and spent the day attending to
domestic tasks. He was called at 2136 hrs by the operations officer and notified of the
intended flight. He dressed and drove to work, arriving at about 2220 hrs. There was no
indication that the pilot attempted or achieved any sleep during the day or early evening.”
The aircraft took off about 23.30 after a short currency flight. The crash happened 15 March
2005 at 0018 hrs.
AAIB Section on Pilot fatigue
“The pilot was well rested prior to the day of the accident flight, and had achieved a normal
sleep pattern for the 72 hours prior to the accident. He reportedly achieved about seven
hours 45 minutes of sleep during the night and was not known to have suffered from any
sleep disorders that may have reduced the quality of his sleep. The average human adult
physiologically requires about eight hours of sleep for optimal performance and alertness, so
the pilot was probably close to maximum ‘sleep credit’ at the start of the day.
Although he had been rostered a night standby duty, the pilot was called only infrequently on
such duties and did not normally aim to achieve any sleep during the day. Such seems to be
the case on the day of the accident. The difficulty of achieving sleep during the day
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preceding an initial night duty is well recognised, and for many individuals the best that can
be achieved is a period of rest.
How long an individual remains awake is a physiological factor that can affect performance
and alertness. Generally, performance and alertness can be maintained up to 12 hours of
wakefulness, after which some reduction in performance occurs. Sixteen to 17 hours of
continuous wakefulness can be associated with significantly reduced performance and
alertness. At the time of the accident the pilot had been awake for 17 hours 15 minutes and
is therefore likely to have been suffering from fatigue to some extent.”
Europe Event 2 – Spain 2004
http://www.fomento.gob.es/NR/rdonlyres/7B20C57F-249F-4265-978D-
A412E1FA5707/11987/2004_016_A_ENG.pdf
Comisión de Investigación de Accidentes e Incidentes de Aviación Civil, INFORME
TÉCNICO A-016/2004 “Accidente ocurrido el 30 de marzo de 2004 al helicóptero Eurocopter
SA-365-N1, matrícula EC-GJE, en el término mun. de San Bartolomé de Tirajana (Las
Palmas)”
This accident led to five fatalities 3 crew and 2 passengers. Whether fatigue was a
contributor is unclear from the report. However, the report includes this text:
“It seems that the day of the accident the pilot had rested at least during 8 h. The day before,
he did not carry out any flight. The last «flight» was done on 24 March in a flight simulator in
France. After that course, he had 3 days off (considering that 25 March was devoted to
travelling) until he started working again on 29 March. It is therefore considered that short-
term fatigue was not a factor in this accident. It is always difficult to carry out a detailed
analysis of the so called long-term fatigue, normally associated to 12-hour shifts in 24-hour
services along 20 continuous days, with short expected response times when called for an
assignment. This process may affect the performance of pilots that spend long periods of
inactivity in the same base waiting for a flight to be carried out on demand, followed by short
periods of intense activity after an emergency call. This situation may be aggravated if not
optimum resting facilities are provided during such long periods.
Even if such condition existed, it would be very difficult to establish its direct influence in the
accident. However, in any case, it is considered convenient to issue a safety
recommendation to the DGAC to review the organization and procedures of the emergency
medical services of the operator in the Canary Islands regarding activity periods and resting
conditions to be sure that the possibility of long term fatigue for the involved pilots is
minimized.
REC 04/05. It is recommended to the DGAC of Spain that they review the organization and
procedures of the emergency medical service of the operator in the Canary Islands, in
particular regarding activity periods scheduling, change of shifts between pilots, and
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provision of suitable resting places for the flight crews for both day and night shifts, with the
intend of minimizing the possibility of long term fatigue.”
USA Event 1, 2004
Reference: National Transportation Safety Board. 2006. Special Investigation Report on
Emergency Medical Services Operations. Special Investigation Report NTSB/SIR-06/01.
Washington, DC.
Abstract: This report discusses safety issues identified during the Safety Board’s special
investigation of 55 emergency medical services (EMS) aircraft accidents that occurred in the
United States between January 2002 and January 2005. Safety issues discussed in this
report focus on less stringent requirements for EMS operations conducted without patients
on board, a lack of aviation flight risk evaluation programs for EMS operations, a lack of
consistent, comprehensive flight dispatch procedures for EMS operations, and no
requirements to use technologies such as terrain awareness and warning systems to
enhance EMS flight safety.
Dodge City, Kansas
On February 17, 2004, about 0256 central standard time, a Beech BE-B90 twin engine
airplane, N777KU, operated by Ballard Aviation, Inc., was destroyed when it impacted terrain
about 5 nautical miles (nm) northwest of Dodge City Regional Airport (DDC), Dodge City,
Kansas. The pilot, flight nurse, and flight paramedic were killed. The 14 CFR Part 91
positioning flight departed Wichita Mid-Continental Airport (ITC), Wichita, Kansas, about
0210 and was en route to DDC. Night VMC prevailed. The flight was on an IFR flight plan,
but the pilot cancelled the IFR flight plan about 37 miles east of DDC and proceeded under
VFR.
The Safety Board’s investigation revealed that the pilot had been awake for as long as 21
hours at the time of the accident. Additionally, the accident occurred 14.5 hours after his duty
day began. Recorded radar data indicate that the airplane initiated a gradual, straight-line
descent toward the airport but flew past the airport before descending into the ground. No
communications from the airplane were made during this descent, which suggests that the
pilot was fatigued.
The Safety Board determined that the probable cause of this accident was the pilot’s failure
to maintain clearance with terrain due to pilot fatigue (lack of sleep).
USA Event 2, 2010
NTSB Identification: CEN10MA367
Nonscheduled 14 CFR Part 135: Air Taxi & Commuter operating as air ambulance
Accident occurred Sunday, July 04, 2010 in Alpine, TX
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Aircraft: CESSNA 421B
Injuries: 5 Fatal.
The airplane impacted terrain shortly after takeoff. The extended landing gear and flaps
degraded the climb performance of the airplane. The pilot held an airline transport pilot
certificate and had recent night flight experience. According to family members, the pilot
normally slept from 2230 or 2300 to 0700; the accident occurred at 0015. Although the
investigation was unable to determine how long the pilot had been awake before the
accident or his sleep schedule in the three days prior to the accident, it is possible that the
pilot was fatigued, as the accident occurred at a time when the pilot was normally asleep.
The company did not have, and was not required to have guidance or a policy addressing
fatigue management.
The National Transportation Safety Board determines the probable cause(s) of this accident
as follows: The degraded performance of the airplane due to the pilot not properly setting the
flaps and retracting the landing gear after takeoff. Contributing to the accident was the pilot’s
fatigue.
USA Event 3, 2010
March 2010 crash of Hospital Wing helicopter, Brownsville Tennessee, 3 fatalities
Pilot was nearing the end of a 12-hour shift when the crash occurred. The NTSB findings
said that fatigue may have been a contributing factor to his error in judgment. The helicopter
flew into the "gust front" of an approaching thunderstorm, an area "prone to extreme low-
level wind shear," the NTSB said.
"Based on these conditions, the helicopter likely encountered severe turbulence from which
there was no possibility of recovery, particularly at low level," the NTSB stated.
"The pilot made a risky decision to attempt to outrun the storm in night conditions which
would enable him to return the helicopter to its home base and end his shift there, rather
than choosing the safer alternative of parking the helicopter in a secure area and exploring
alternate transportation arrangements or waiting for the storm to pass and returning to base
after sunrise when conditions improved," the report said.
"This decision-making error played an important causal role in this accident," the report said.
The Brownsville crash occurred just before dawn, a period the NTSB said "can be
associated with degraded alertness." But the report said the NTSB was "unable to determine
whether or to what degree fatigue contributed to the pilot's faulty decision to attempt to
outrun the storm."
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Appendix 2 – CAS Modeling
Introduction
Circadian Technologies, Inc. has developed a Circadian Alertness Simulation (CAS) model
that allows the assessment of fatigue risk based on sleep-wake patterns. Since the model
includes an algorithm that predicts the most likely sleep pattern given a specific work pattern,
it allows the evaluation of duty patterns for fatigue-related risk.
The impact of duty patterns on the alertness level and the resulting fatigue risks of an
individual pilot are relatively uncertain and difficult to calculate analytically, especially if the
individual sleep characteristics of the employee are not known. Here, the application of a
simulation tool is particularly useful. Simulation models help us to understand when
situations of extreme fatigue risk occur and why.
CAS – Model Concept
The CAS concept is based on the Three-Process Model of sleep regulation. A homeostatic
component, a circadian component, and a sleep inertia component are combined to
calculate an alertness curve. Figure 1 through 3 show the steps in the process between
activity data (horizontal bars), the alertness calculation and the results output. Alertness at
any specified point in time is entirely a function of all preceding data points. It therefore
includes the effects of acute and cumulative fatigue.
Figure 1: Duty-Rest data without sleep
Based on the calculation of alertness, CAS5 predicts a sleep/wake pattern by triggering
sleep when alertness reaches a certain lower threshold. The algorithm assumes sleep and
calculates the subsequent data points assuming sleep until an upper wake-up threshold or
an activity block (e.g., work, commuting) is reached. This capability was used for the model
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validation and it allows the analysis of data where there is no information about the person’s
actual sleep pattern (e.g. duty logs, time and attendance data, proposed work schedules).
Figure 2: Duty-Rest data with sleep (black blocks)
After CAS5 has added sleep into the duty pattern, the model can now calculate an alertness
value based on the three processes mentioned before:
• Alertness decreases during duty and non-sleep and increases during sleep
(homeostatic component)
• Alertness fluctuates throughout the day (circadian component)
• Alertness is temporarily lowered after sleep depending on length of sleep and level of
alertness on wake-up (sleep inertia component).
Figure 3: Alertness curve based on Sleep-Wake-Duty pattern
The CAS5 model can adjust various parameters of the model to reflect individual sleep
profile properties (morning vs, evening type, long sleeper vs. short sleeper, habitual wake-up
time, napping propensity, etc.). These adjustments affect the alertness calculation. However,
at a planning stage there cannot be an individual profile since it is not known which specific
person will work any of the simulated patterns.
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The calculated alertness can then be used to analyze specific moments or periods in time,
i.e. alertness at the end of a duty period, alertness during a scheduled flight/sector.
Figure 4: Sleepiness During a Specified Duty Pattern
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Appendix 3 – EMS Operational Data
Operational data concerning the scale of EMS activities has been obtained from the
following States:
• UK
• Poland
• Czech Republic
• Norway
• France
Some States did not have ready access to such data and provided Operator details to
contact. In addition, publicly available websites were used to supplement the data search.
UK – source direct information from NAA
Data Required HEMS Aeroplane EMS
(AEMS)
Number of missions per year in State
(either typical year or last year) 17 500 550 with largest
operator (at least
another 1000 with other
operators)
Number of flightcrew flying EMS in State 60 (line pilots) 13 – with largest
operator
Number of aircraft flying EMS in State 30 6 - with largest
operator
Number of operators flying EMS in State 6 32 (too many to give
answers to the number
of flight crew and
aircraft)
Names of (main) operators
Operator 1 Bond Air Services (C) AirMed (C) Only
specific AirMed figures
given
Operator 2 Police Air Services (C) CEGA (C)
Operator 3 Sloanes (C) Loganair (C)
etc Premiar (C) Manhattan Jet
Management (C)
If too many operators to list, a few of the The UK has 32
larger ones is sufficient. operators who hold
approval under their
FTL scheme to conduct
AEMS flights
• Solely EMS services (S), or
• Combined with Air Taxi or another type of operation (C)
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Poland – source direct information from NAA
Data Required HEMS Aeroplane EMS
(AEMS)
Number of missions per year in State
(either typical year or last year) 8833 flights 653 flights
Number of flightcrew flying EMS in State
- -
Number of aircraft flying EMS in State
23 2
Number of operators flying EMS in State
1 1
Names of (main) operators
Operator 1 SP ZOZ Lotnicze SP ZOZ Lotnicze
Pogotowie Ratunkowe Pogotowie Ratunkowe
Czech Republic – source direct information from NAA
Data Required HEMS Aeroplane EMS
(AEMS)
Number of missions per year in State Private information Private information
(either typical year or last year)
Number of flightcrew flying EMS in State Private information Private information
Number of aircraft flying EMS in State Approx. 16 Approx. 12
Number of operators flying EMS in State 3 (2 main ones below) 5
Names of (main) operators
ALFA-HELICOPTER, s.r.o. (C ) --
DSA, a.s. (C ) (C )
SILESIA Air, s.r.o. -- (C )
AEROTAXI, s.r.o. -- (C )
AIR BOHEMIA, a.s. -- (C )
AIR PRAGUE, s.r.o. -- (C )
If too many operators to list, a few of the
larger ones is sufficient.
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Norway – source direct information from NAA
N.B. HEMS data below just relates to missions and aircraft from Norsk Luftambulanse and
the military, not Lufttransport which provides other services as well as EMS. Lufttransport
transported just over 10,000 patients in 2007 (see http://www.lufttransport.no/) which is
about half the amount carried by Norsk Luftambulanse.
Data Required HEMS Aeroplane EMS
(AEMS)
Number of missions per 8579 (2009) 8988 (2009)
year in State (either + 2084 Military missions
typical year or last year)
Number of flightcrew
flying EMS in State
Number of aircraft flying 11 8
EMS in State +12 military
Number of operators 2 1
flying EMS in State +military
Names of (main)
operators
Operator 1 Lufttransport AS (C) Lufttransport AS
http://www.lufttransport.no/ (C)
Operator 2 Norsk Luftambulanse AS (S)
http://www.norskluftambulanse.no/forsiden/
om-nla/kort-fortal/nla-as/
France - source direct information from NAA
N.B. 1 Part of the service (be it medical transportation, under CAT rules, or HEMS, under
part CAT+ part SPA rules) is provided by civil servants (“Protection civile”, “Gendarmerie”...)
The flights performed by these state services are not to comply with CAT nor Part SPA rules.
The vast majority of these flights is performed by the 39 helicopters owned by the “Protection
civile”. In 2011, the “Protection civile” realized 11 800 emergency medical missions.
Yet, these missions are not limited to medical services (e.g. “search and rescue”, “police”,
“fire protection”).
N.B. 2 Part of the service is provided by “private” helicopters, performed under OPS rules.
The table below only refers to these helicopters, which, furthermore, are all hospital based.
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Only HEMS data are readily available. Data for aeroplanes are far more difficult to gather as
they may be conducted flights other than EMS.
Data Required HEMS
Number of missions per year in State No statistics available.
(either typical year or last year) Yet, one of the most important operators indicates
4 500 missions with 10 helicopters (which is a
little bit more than 1 mission/helicopter/day).
On can conservatively infer from the number of
“private” helicopters operated in France that there
are more than 15 000 missions per year
Number of flightcrew flying EMS in State No statistics available.
Yet, given the number of hospital bases to which
helicopters are dedicated and assuming 3 to 5
pilots for each base, that leads to at least 150 Full
Time Equivalent
Number of aircraft flying EMS in State Around 40
Number of operators flying EMS in State Mainly 5
Names of (main) operators
Operator 1 Groupe SAF (SAF Hélicoptères +Helicap)
Around 10 hospital bases
Operator 2 Mont Blanc Helicoptères
Around 10 hospital bases
Operator 3 INAER
Around 10 hospital bases
Operator 4 Helicoptères de France
7 hospital bases
Operator NHV Helicoptères de France
2 hospital bases
If too many operators to list, a few of the
larger ones is sufficient.
Notes
Most helicopters used for HEMS or ambulance fly between 400h and 600h. The helicopter
that flew most last year flew 800h (Marseille hospital)
All operators mentioned above have different activities : CAT (touristic flights or Air Taxi),
Specialised Operations. Some are also Type Rating Training Organisations. Yet, it does not
mean that pilot switch from an activity to another activity. Once a pilot has begun its cycle,
he is not supposed to change activity.
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REGA in Switzerland – source www.rega.ch/en/about-us/in-brief.aspx and Annual Report
Key figures 2011
Total number of missions 14,240
- Missions by helicopter 10,797
- Missions by ambulance jet 1,052
- Other missions* 2,391
Number of patrons (in millions) 2.380
Number of employees** 319
Number of helicopter bases 13
* Other missions: transports by ambulance, organ transports by taxi, missions on behalf of
the Swiss Alpine Club (SAC), Speleo-Secours, Redog etc.
** Full and part time employees as at December 2010 (Job Count)
Number of helicopters – 17
Number of ambulance jets - 3
N.B. Two other EMS providers in Switzerland are Air-Zermatt (www.air-zermatt.ch) and Air-
Glaciers (www.air-glaciers.ch)
ANWB of Netherlands – source www.anwb-maa.nl
4200 HEMS flights a year
Largest provider of air ambulance EMS in Netherlands
6 helicopters (4 in active use, 2 in reserve)
27 pilots included in 36 staff members
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Germany
Operator A
Data Required HEMS Aeroplane EMS
(AEMS)
Number of missions per year 38,366 rescue missions,
(2011) involving helicopter 469
missions at 31 HEMS
bases in Germany,
Austria and Denmark
Number of pilots flying EMS
144 16
(160 in total including
AEMS pilots)
Number of aircraft flying EMS
Over 50 helicopters 3
Number of patients attended/
transported per year 460
Operator B
Data Required Aeroplane EMS (AEMS)
Number of missions per year 551
(either typical year or last year)
Number of pilots flying EMS 27
Number of aircraft flying EMS 4
Number of patients attended/ transported per year 1426
Operator C
Data Required HEMS
Number of missions per year 46305
(either typical year or last year)
Number of pilots flying EMS 140
Number of aircraft flying EMS 48
Number of patients attended/ transported per year 42229 patients
17057 transported by
helicopter
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Appendix 4 – Example Shift Patterns, AEMS and HEMS
AEMS
Two distinct patterns of AEMS operations are seen in Europe.
1. Based on short call home standby – this is described in the presentation made to
the EASA Stakeholder Meeting (“Flight Time Limitation (A)EMS, RMT.0346,
RMT.0429 & RMT.0430” by Urs Nagel, Chairman AEMS Working Group, Head of
Jet Operation and Chief Pilot, Swiss Air Ambulance). Further information has
been obtained from NAAs and operators.
2. Based on short call airport/ base standby – described in information obtained
from NAAs and operators (Norway, Poland, UK - Scotland).
Based on short call home standby
Home standby patterns:
• Operator 1 uses 11, 14.5 or 24 hour durations. 7 days of standbys/ duties and
then 3-4 days’ rest.
• Operator 2 uses 24 hour standbys with 5 days on, 2 days’ rest.
• Operator 3 uses 24 hour standbys, 3 blocks of 6 consecutive days of standby
separated by 3 blocks of 4 days’ rest.
• In the UK most operators use 4, 6 or 8 hours standby typically starting at 0600
and rolling through the day (so 0600-1400, 1400-2200, 2200-0600 for example).
• In Spain – typical standby from 0800 to 2000.
Amount of home standby per year:
• Operator 1 for 2011 was 1375 standby hours per flight crew.
• UK home standby is 63 days averaged over the operators although contactable
days are frequently used for air ambulance coverage and this would double this
figure.
• Spain – around 180 home standby days per year.
Callout probability:
• Operator 1: flight crew are called out for 52% of standby days.
• Operator 2: 50-60%
• Operator 3: 45%
• In the UK the value is 25% for the largest air ambulance operator, but for those
with mixed air taxi the value would be higher.
• In Spain: 30-60%
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Typical call up times for duty are 60, 90 or 120 minutes.
In terms of flights and FDPs:
• Operator 1: FDPs can range from 4 hours covering domestic operations up to
and in excess of 20 hours in order to reach New Zealand for example. The
number of sectors within an FDP could vary from 1 to 6 typically and from 15
minutes up to 8 hours 15 minutes (maximum endurance of the AEMS aircraft).
Operator 1 conducts some 70 Ultra Long Range (ULR) operations per year (N.B.
ULR operations are ex-scope for this study).
• Operator 2: FDP durations 13-14 hours. Typically 4-6 sectors per FDP with
sectors of 2-3 flight hours. No ULR operations.
• Operator 3: FDPs with typically 7 sectors of 1.5 to 2.0 hours. Some ULR
operations.
• In the UK a typical sector would range from 1.5 hours (European only operations)
up to 5 hours. Some of the multi-sector long haul FDPs may go up to 18 hours
(beyond which it would be ULR).
• Spain – typical sectors of approximately 1.5 hours. No ULR.
Typical annual hours for AEMS pilots:
• Operator 1: 2011 values of 1180 duty hours and 427 flight (block) hours per flight
crew.
• Operator 2: 800 duty hours (standby not counted as duty).
• Operator 3: 700 duty hours (standby not counted as duty).
• For UK operators a value of 1400 duty hours was provided.
• Spain – 1000 duty hours including training.
Based on short call airport/ base standby
Norway, Poland and Scotland make use of airport/ base standby for AEMS.
In Norway the shift pattern is more like that used for HEMS (see below):
• Shifts involve 24 hours a day at base, one week on, one week off, one week on,
two or three weeks off.
• Active duty time up to 14 hours in any 24 hours.
• Average sector length 10 minutes to 2 hours, average about 35 minutes.
In Scotland, the AEMS day shift is based on airport standby - pilots cover consecutive shifts
between 0700 hrs and 2100 hrs, normally at 30 minutes readiness in the crew rest room at
the airport. The night shift is from home standby.
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Typical annual hours for AEMS pilots involved in these shorter range operations:
• Norway 1800 duty hours.
• Poland 1900 duty hours.
HEMS
In this section examples of HEMS shift patterns from European States and operators are set
out. HEMS is based on very short call from HEMS bases.
Switzerland
The FTL System in Switzerland is based on a flat rate recording regulation. Depending on
the time of the “Airport Standby” period during a 24 hour-day a flat rate has to be recorded
as “Duty Time”. Some example schedules are given below:
Flat Rate Duty Time over the year
a) Fix Airport Standby Time: 0800 h to 1800 h 9.5 hours
Max. 15 duty/ standby days per month
b) Or changing duty times as follows:
January – March: 0800 h to 1730 h
April – June: 0800 h to 1830 h
July – August: 0800 h to 1930 h 9.5 hours
September – October: 0800 h to 1830 h
November – December: 0800 h to 1630 h
Max. 5 duty/ standby days per period and max 15 duty/ standby days per
month
c) Or changing duty times as follows:
Summer: 01.04. – 31.10. 0800 h to 2200 h
Winter: 01.11. – 31.3. 0800 h to 2000 h 13 hours
Max. 2 duty/ standby days per period and max 11 duty/ standby days per
month
If the Airport Standby Time is extended to 14 hours the recording flat duty time over the year
has to be increased to 13 hours of flight duty time.
The duty pattern in c) is typically used at bases in the non-mountainous parts of Switzerland.
Extensions into the night beyond 2200 are relatively common in such bases. The shorter
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daily duty times in a) and b) are typical of the HEMS bases serving the mountainous parts of
Switzerland.
France
In France, duty hours and on-site standby can be organised in three different cycles:
1. Weekly cycle (calendar week from Monday to Sunday): comprising 5 on site standbys, by
day only (no night standby) between periodic rests (periodic rest being : 24h+rest generated
by previous on site standby)). Eg. On site standbys from Monday to Friday of week 1 then 2
days of rest (Saturday and Sunday), then 2 days of rest on week 2 (Monday and Tuesday)
and 5 days of on site standbys from Wednesday to Sunday.
2. 18 weeks cycle : comprising on site standbys, by day only (no night standby), limited to
12 consecutive days between periodic rests.
3. 12 weeks cycle: comprising on site standbys, by day or by night, limited to 7 consecutive
on site standbys, between periodic rests. Between two periodic rest, the on-site standbys
shall be only be day or only by night (no mixing).
Periodic rest
- Cycle 1 : two consecutive days (0h-24h) after 5 consecutive days of planned on site
standbys
- Cycle 2 : 6 consecutive days (0h-24h) after 12 consecutive days of on site standby
- Cycle 3 : 7 consecutive days (0h-24h) after 7 consecutive days of on site standby
Duration of duties :
- Daily limit for on site standby :
-12h maximum for flight technical crew members (including flight crew)
- Additional limits:
Cycle 1 : 12h per 24h
Cycle 2 : 12h per 24h
Cycle 3 : 14h per 24h
UK
HEMS shifts are daytime only, normally of 10 hours duty time, but crew may be up to 12
hours at the HEMS base. These are usually worked as a 4 on/ 4 off pattern with a 60 hour
limit per 7 consecutive days.
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Norway
Operators operate 24 hours a day at base, 1 week on/ 2 week off/ 1 week on/ 3 weeks off.
Maximum active duty per 24 hours period is 14 hours during summer and 13 hours during
winter.
Czech Republic
There are two types of bases:
• 24hrs operations – arranged around 2 shifts of 12 hours each
• VFR daytime - 1 shift covering period from sunrise to sunset
Poland
Again there are two types of bases:
• 24hrs operations – arranged around 2 shifts of 12 hours each, 0700 to 1900 and
1900 to 0700.
• Daytime from 0700 to 2300 arranged as two shifts on 0700 to 1500 and 1500 to
2300.
Operator 1
The day shift starts at 06.30, handover is at 07.00, the crew work through to 19.00, with
handover until 19.15 (12.75 hours at base).
The night shift starts at 18.30, handover at 19.00, work until 07.00, handover until 07.15
(12.75 hours at base).
A shift can stretch to 15.5 hours if there is a flight at the end of shift. However this is only
permitted if the pilot has had a break of at least 2 consecutive hours that day.
3 consecutive day or 3 night shifts typically. Minimum of 3 days off, maximum of 6.
Typical roster would be 3 days on, 3-6 off, 3 nights on 3-6 off. Operator does not roster day
and night in consecutive shifts.
Operator does not allow more than 1.5 hours travel before a shift.
Operations from dusk until dawn are conducted using Night Vision Goggles (NVG).
Typically 5-6 calls per day.
Annual duty including training = 1710 hrs (121 shifts)
Annual flight hrs = 120 hrs
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FTL only allows for a reduced rest period of 8 hrs and 30 min. If rest is reduced to less than
10 hrs the maximum commute time is 15 minutes, if rest is reduced to 9hrs and 30 min or
less, sleeping at the base is obligatory.
Operator 2
Typical roster would be 3-4 days on, 2-3 days off.
Minimum of 24 hours rest between a series of days and nights.
Annual duty = 1900 hrs (160 duties per year)
Annual flight hrs = 120 hrs
Minimum rest of 9 hours provided that suitable accommodation is available at the HEMS
base.
Operator 3
The bases are either on day-duty or 24-hour-duty.
On 24-hour-bases two 12-hour-shifts are worked. During daytime there is one pilot and one
HEMS Crew Member, during night-times there are two pilots. There are eight pilots per
base. Usually pilots work 7 days and have 7 days off. During the wintertime (longer night
time), the day pilot stays longer and/or one of the night pilots begins earlier and works 14
hours.
Day-duty means starting work at sunrise – 30 minutes (earliest 6:30 AM) until sunset + 15
minutes. On some bases in summertime sunset can be as late as 21:45. So the day begins
at 6:30 AM and ends at 10:00 PM, which is 15.5 hours duration. There are three pilots per
base. In summertime a pilot works a maximum of 4 days and has at least 2 days and
normally 7 days off (except if a colleague has vacation).
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Preliminary Analysis of
Impacts from Future Potential
FTL Regulatory Changes for
Air Taxi and Single Pilot
Operations
Report for EASA
Report D3 No: 3
28 September 2012
28 September 2012
Preliminary Analysis of Potential Regulatory Impacts – Air Taxi and Single Pilot
EASA DNV & Circadian
DET NORSKE VERITAS LTD.
Preliminary analysis of impacts from future potential Palace House
FTL regulatory changes for Air Taxi and Single Pilot 3 Cathedral Street
Operations SE19DE London
for Tel: +44 (0)20 7357 6080
Fax: +44 (0)20 7357 6048
EASA
Registered in England
Company No. 1503799
Report No.: D3, version 3
Indexing terms: Flight Time Limitations (FTL), Fatigue Risk, Air Taxi and Single Pilot Operations
Summary: This report is revised Deliverable D3.
Prepared by: Edward Smith Jena Pitman-Leung
Principal Consultant, DNV Consultant, Circadian
Steve Goodwin Acacia Aguirre,
Director, Circadian Medical Director, Circadian
Verified by: Suk Rathore Martin Moore-Ede
Senior Consultant, DNV CEO, Circadian
Approved by: Edward Smith
Principal Consultant, DNV
th
Date of issue: 28 September 2012
Project No: PP027950 EASA Project No: EASA.2010.FC06-SC001
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Contents
1.0 Introduction ................................................................................................. 1
1.1 Background................................................................................................... 1
1.2 Objectives of D3 Report ................................................................................ 1
1.3 Scope of D3 Report ...................................................................................... 1
1.4 Structure of this Report ................................................................................. 2
1.5 Acknowledgements....................................................................................... 3
2.0 Methods for Analysing Impacts................................................................. 4
2.1 Analysing Safety Impacts of FTL Changes ................................................... 4
2.2 Analysing Economic Impacts of FTL Changes ............................................. 6
2.3 Analysing Social Impacts of FTL Changes ................................................. 11
3.0 Hazard Identification ................................................................................ 12
3.1 General Fatigue Factors ............................................................................. 12
3.2 Air Taxi Operational Data and Characteristics ............................................ 17
3.3 Single Pilot Specifics .................................................................................. 19
4.0 Fatigue Literature Review ........................................................................ 29
4.1 Overview ..................................................................................................... 29
4.2 Duration of Duties and Time Awake ........................................................... 30
4.3 Time of Day Effects, Early Starts and Night Duty ....................................... 35
4.4 Cumulative Effects of Multiple Consecutive Duties ..................................... 42
4.5 Sleep and Rest ........................................................................................... 45
4.6 Standby ...................................................................................................... 47
4.7 In-flight Rest and Flightdeck Napping ......................................................... 48
4.8 Periodic Extended Rest .............................................................................. 51
4.9 Travelling and Positioning ........................................................................... 53
5.0 Hazard Analysis ........................................................................................ 55
5.1 Hazard A1, Duration of FDP Too Long Leading to Fatigue ........................ 56
5.2 Hazard A3, Extended FDP with Augmented Crew/ In-Flight Rest Leads to
Fatigue ........................................................................................................ 60
5.3 Hazard A4, On-Ground Break (Split Duty) used to Excessively Extend FDP
Leading to Fatigue ...................................................................................... 63
5.4 Hazard B1, WOCL Encroachment .............................................................. 65
5.5 Hazard B2, Circadian Disruption due to Mixing Day and Night FDPs ......... 67
5.6 Hazard B3, Time Zone Desynchronisation ................................................. 68
5.7 Hazard C1, Cumulative Fatigue due to Consecutive FDPs ........................ 70
5.8 Standby Related Hazards ........................................................................... 73
5.9 Hazard D1, Lack of Sleep Opportunity ....................................................... 78
5.10 Relaxation and Naps During On Ground Breaks ........................................ 79
5.11 Hazard A2, Pilot in Command Discretion .................................................... 80
5.12 Positioning and Travelling Related Hazards ............................................... 81
6.0 Conclusions .............................................................................................. 84
7.0 References ................................................................................................ 85
8.0 Acronyms/ Abbreviations ........................................................................ 94
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Appendix 1 Air Taxi and Single Pilot Safety Data with Fatigue as a Causal Factor
Appendix 2 CAS Modeling Description
Appendix 3 Survey of National FTL Provisions
Appendix 4 CAS Modeling Scenarios
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Executive Summary
Introduction
A rulemaking task (hereafter referred to as RMT.0429) will begin in the third quarter of 2012
for the development of Flight Time Limitations and rest requirements (FTL) for Air Taxi and
Single Pilot operations by aeroplane. As part of this task a Regulatory Impact Assessment
(RIA) has to be developed. Under framework contract EASA.2010.FC06, EASA has
requested that DNV/Circadian conduct some preparatory data collection and preliminary
impact analysis to assist the future work on the RIA.
The focus of this report has been on the safety, economic and social impacts of potential
future rule changes for Air Taxi and Single Pilot operations.
Method
For the safety impact analysis the approach has been as follows:
• Relevant fatigue hazards have been identified for Air Taxi and Single Pilot operations
(preliminary – this will need to be reviewed during the related rulemaking task
process);
• Key issues relating to the hazards which may form part of future FTL regulatory
changes have been considered from a safety perspective; and
• These considerations have been based on scientific literature, if available, and the
use of Circadian’s CAS model to see how key parameters (e.g. FDP duration) impact
on fatigue levels.
For the economic and social impact analyses, we have:
• Identified what are considered likely to be potential FTL changes with the most
significant economic and social impacts;
• Described the effects qualitatively and listed factors which are likely to affect the size
of the economic and social impact; and
• For selected impacts illustrated a process that would allow estimates of the scale of
the impacts once more robust data have been gathered.
Conclusions
Air Taxi Operations (ATXO) have certain characteristics that can potentially create
challenges to managing fatigue hazards. These characteristic include:
• On demand operations with the majority at short notice;
• Large amount of standby at home with a relatively low chance on average of being
called out;
• Frequent change of schedule/routing; this can include duty start times being put back
or brought forward;
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• Many of the flights (especially on the small and light jet segments) leave in the
morning and come back in the evening. In between, pilots are often waiting in crew
rest facilities or on the aircraft on split duty;
• Passenger requirements can lead to planned on-ground breaks being curtailed or
alternatively ad-hoc split duties being needed;
• Considerable use is made of positioning of crew and aircraft relative to scheduled
flights; and
• Significant time zone (TZ) crossings occur for long range ATXO.
A survey of eight European States has showed that there is a range of national provisions
addressing split duty, additional rest for TZ crossings, reduced rest, in-flight rest and standby
at the airport and elsewhere.
Single Pilot Operations (SPLO) occur in the Air Taxi, scheduled airline and Aeroplane
Emergency Medical Services (AEMS) sectors. They have the potential for leading to
additional workload relative to multiple crew and hence could impact fatigue. Thus long
duration flights/ FDPs are addressed in some national provisions in a variety of ways.
Given the range of national FTL provisions for ATXO and SPLO, European harmonisation of
these FTL provisions is likely to have safety, economic and social impacts. These are
investigated at a preliminary level in this report.
This report provides information and preliminary analysis to be considered for the RIA
development for RMT. 0429 on FTL for Air Taxi and Single Pilot operations with a view to
assist in an overall balanced assessment of safety, social and economic impacts.
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1.0 Introduction
1.1 Background
In December 2010 the European Aviation Safety Agency (EASA) published the Notice of
Proposed Amendment (NPA) No. 2010-14A on ‘Implementing Rules on Flight and Duty Time
Limitations and Rest Requirements for Commercial Air Transport (CAT) with Aeroplanes’.
Following extensive consultation the Comment Response Document (CRD) to NPA 2010-
14A was published in January 2012. Within the CRD is a Draft Opinion of EASA, Annex III,
PART-ORO (ORGANISATION REQUIREMENTS) covering Subpart — Flight and duty time
limitations and rest requirements. Section 1 of this contains General FTL requirements and
Section 2 is for Commercial Air Transport Operators. Also within the CRD is a Certification
Specification (CS) for Commercial Air Transport by Aeroplane — Scheduled and Charter
Operations, designated FTL 1.
The CRD has placeholders for Certification Specifications FTL 2, 3 and 4 covering
Emergency Medical Services (EMS) by aeroplane and by helicopter, Air Taxi and Single
Pilot Operations by aeroplane and other CAT operations by helicopters respectively.
A rulemaking task has started at the beginning of 2012 for the development of FTL for EMS.
The rulemaking task for Air Taxi and Single Pilot will begin in the third quarter of 2012 and
the one for other CAT operations by Helicopters is to follow in 2013.
To support the development of these rules EASA procedures require the preparation of
Regulatory Impact Assessments (RIAs) similar to the one published in NPA 2010-14A.
These RIAs will be undertaken with the support of the respective Rule Making Groups
(RMGs).
Under framework contract EASA.2010.FC06 EASA has requested that DNV/Circadian
conduct some preparatory data collection and preliminary impact analysis to assist the future
work on the RIAs. Prior to the current report DNV/Circadian have produced Deliverable D1,
which was a survey from eight European NAAs of FTL provisions used for EMS in their
States, and D2 which was a preliminary analysis of impacts from future potential FTL
regulatory changes for EMS.
1.2 Objectives of D3 Report
The main objective of this report, Deliverable D3, is to produce a preliminary analysis of the
impacts of potential future FTL regulations concerning Air Taxi and Single Pilot Operations.
This analysis is intended to assist in future RMT discussions, the development of potential
regulatory options and the preparation of the RIAs. As part of this task a survey of eight
European States was undertaken concerning national FTL provisions relevant to Air Taxi
and Single Pilot operations.
1.3 Scope of D3 Report
The scope of this preliminary analysis is to study, in the context of future potential FTL rule
making proposals:
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• Safety impacts;
• Economic impacts; and
• Social impacts.
In the future RIAs other impacts including environmental, the degree of proportionality of the
proposed measures and regulatory harmonisation will also need to be taken into account.
It is not the purpose of this report to develop options for regulatory changes – this will be
undertaken by the RMG. Hence, rather than analyse the impact of defined options, in this
report we look at key issues/ parameters and analyse how safety, economic costs and social
impacts will vary if this issue/ parameter is changed. This will assist the future choice and
analysis of options.
No attempt is made in this report to combine the analysis of different impacts (e.g. safety
and economics) via one of the accepted RIA methods such as multi-criteria analysis. This is
to be completed as part of RMT.0429 activities.
This report addresses Air Taxi and Single Pilot Operations. Other reports cover:
• Emergency Medical Services (EMS) – Deliverables D1 and D2 as described above.
• Other Commercial Air Transport Operations by Helicopters – future Deliverable D4.
The combination of Aeroplane EMS and Air Taxi operations are not analysed in this report.
1.4 Structure of this Report
The rest of this report is structured as follows:
• Section 2 provides an overview of how the preliminary impact analysis has been
conducted.
• Section 3 identifies and classifies relevant hazards.
• Section 4 is a literature review covering aviation references and general industry
references where relevant.
• Section 5 analyses the key Air Taxi and Single Pilot hazards and the main issues
related to these hazards.
• Section 6 presents conclusions.
• Sections 7 and 8 provide references and acronyms.
• The Appendices contain supporting data namely:
o Appendix 1 – Air Taxi and Single Pilot Safety Data, descriptions of fatigue
aspects of relevant accidents.
o Appendix 2 – Circadian Alertness Simulation (CAS) modeling description.
o Appendix 3 – FTL survey data from eight European States on ATXO and
SPLO.
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o Appendix 4 – details of the scenarios modeled in CAS.
1.5 Acknowledgements
Large amounts of information were provided by representatives of the European Business
Aviation Association (EBAA) and the eight surveyed NAAs, i.e. Czech Republic, France,
Germany, Norway, Poland, Spain, Switzerland and the UK. We would like to thank all these
people for their time and assistance.
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2.0 Methods for Analysing Impacts
2.1 Analysing Safety Impacts of FTL Changes
A direct method for analysing safety impacts from FTL regulatory changes would be:
• To estimate current safety risk levels in European Air Taxi and Single Pilot operations
from appropriate accident/ incident data.
• To analyse how potential changes to FTL regulations would affect this historical risk
estimate either based on relevant data or expert judgement.
A problem with this direct approach, as revealed in the NPA 2010-14 RIA (EASA, 2010) is
that:
• The data are statistically insufficient to directly deduce potential impacts of rule
changes;
• The data are statistically insufficient to detect current and future safety risks,
especially as fatigue related events may be masked under “human factor-related
incidents” or they are not reflected at all in these data.
EASA’s Safety Analysis Section conducted a search of the EASA copy of the ICAO ADREP
data base. This data base contains 215 air taxi operations occurrences between March 2,
1998 and March 21, 2012. Only one accident could be associated to pilot fatigue, i.e. in
0.5% of air taxi occurrences pilot fatigue was involved.
With regards to aeroplane single pilot operations EASA’s copy of ICAO ADREP data base
contains 32046 occurrences registered until March 21, 2012. Pilot fatigue is indicated as a
contributory factor of an occurrence in 139 events. Expressed as a percentage, 0.4% of
single pilot aeroplane occurrences can be related to pilot fatigue. The same percentage is
obtained if occurrences only in EASA Member States are considered. However, EASA’s
Safety Analysis Section notes the following caveats:
• Data derived from the EASA copy of the ICAO ADREP data base does not mean that
fully comprehensive information on fatigue incidents and accidents in air taxi and
single pilot aeroplane operations is obtained. From past experience, it is known that
often the investigations into light aircraft accidents do not go into such
comprehensive and deep analysis as for large aircraft accident investigations.
Therefore, it is very likely that fatigue issues in single pilot operations accidents are
hidden under other human factors related causes of occurrences.
• Few operators have introduced fatigue management systems as a part of their
operations. Pilots are not always aware of the principles of fatigue management.
Therefore, there are reasonable grounds to believe that occurrences in some cases
were not classified as fatigue when fatigue may in fact have been a contributor.
The narratives for several pilot fatigue related occurrences identified by EASA’s Safety
Analysis Section and by DNV-Circadian are presented in Appendix 1. These descriptions
show the impact of:
• Cumulative fatigue from working a long pattern of consecutive days.
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• Time zone crossings and Circadian time of day.
• Night flying with little prior sleep.
• Long flying hours during a day for a single pilot.
• Pilots on home standby inadequately managing their rest so that they become
excessively fatigued when they are called out, particularly at night.
• Cumulative fatigue due to high workload activity such as intensive single pilot
operations.
Because of this lack of data relating to the exact contribution of fatigue a similar approach to
that adopted in the NPA 2010-14 RIA has been adopted in this report, i.e.:
• Relevant fatigue hazards have been identified for Air Taxi and Single Pilot Operations
(preliminary – this will be reviewed during the RMT.0429 process);
• Key safety issues relating to each hazard which may form part of future FTL
regulatory changes have been considered from a safety perspective;
• These considerations have been based on scientific literature, if available, the use of
Circadian’s CAS model (see Appendix 2) and Circadian’s expertise in the field of
fatigue.
The CAS software models alertness based on three physiological processes:
• circadian time of day;
• sleep-wake balance and sustained wakefulness; and
• sleep inertia.
Based on the hours worked, the CAS model estimates sleep duration and placement around
these restrictions. Within the hours worked CAS can apply varying degrees of alertness
decrease to emulate varying workloads. For fixed wing operations CAS assumes higher
workload during the take-off and landing phase of the flight.
CAS then provides simulation results as either direct alertness averages per given time
period (usually duty periods) or an aggregate Fatigue Score which summarizes the entire
pattern into one number.
To establish a consistent basis for comparison between the multiple diverse duty-rest and
scheduling options considered in this study the following assumptions have been made in
the CAS settings used for this analysis.
1. The settings are based on the average working age person, and individual variations
in circadian chronotype (e.g. morningness-eveningness, unrestricted sleep duration,
sleep quality, adaptive flexibility of circadian sleep-wake pattern and napping
propensity) are not considered. Thus actual fatigue scores and alertness levels may
be higher or lower than estimated in this CAS analysis depending on the individual
chronotype of each individual. Much of sleep science research has been based on
college students, as a matter of convenience; but this population has a significantly
different circadian sleep profile compared to the majority of working age (25-65 year
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old) subjects. We have based our modeling on data from this post-college age
population.
2. It is assumed that no active fatigue risk mitigations are in place, and the individuals
modeled act as a person not trained in nor practicing sleep-alertness management.
Thus with populations of individuals who are actively practicing fatigue risk
management, this CAS analysis will overestimate the fatigue score and
underestimate the levels of alertness.
The safety impact analyses are described in Section 5.0.
2.2 Analysing Economic Impacts of FTL Changes
2.2.1 Scale of Air Taxi Operations in Europe
2.2.1.1 Overall Economic Contribution to Europe
In a recent presentation (EBAA, 2012) it is noted that in 2011 there were 654,514
movements of Business Aviation (BA) in Europe based on EUROCONTROL data. In order
to estimate the proportion of BA traffic that could be classified as Air Taxi reference is made
to EUROCONTROL’s analysis of 2009 BA data (EUROCONTROL, 2010). In this reference
45% of BA traffic was found to be “non-scheduled commercial” and all this traffic involved
aircraft with 19 or less passenger seats. EASA’s proposed definition for Air Taxi is “Non-
scheduled, on demand commercial operations with an aeroplane with a passenger seating
configuration of 19 or less.”
Thus it is estimated that in 2011 there were 654,514 x 0.45 = 295,000 air taxi movements in
Europe. It is estimated that this represents approximately 3% of all movements in the EU;
BA traffic in total represents just over 7% of all movements (EBAA, 2012). EUROCONTROL
expects business aviation to pass 8% of total movements around 2015 (EUROCONTROL,
2010).
A PwC report (PwC, 2008) commissioned by the EBAA concluded that the BA sector
contributed a total of €19.7bn in annual gross value added (GVA) to the European economy
in 2007, accounting for approximately 0.2% of the combined gross domestic product (GDP)
of the European Union (EU), Norway and Switzerland. This overall value was made up of:
• Direct impact – which corresponds to the contribution to the European economy
created by business aviation aircraft-related manufacturing, operations and
maintenance. This reflects the industry’s visible presence in Europe. This contributed
€5.6bn.
• Indirect impact – which is created by the purchase of goods and services by firms
directly involved in the business aviation industry. These are the benefits that accrue
‘up-stream’ in the business aviation supply chain, such as when aircraft
manufacturers buy metal and plastic for their product. This contributed €4.8bn.
• Induced impact – this is the additional contribution to the economy resulting from
increased expenditure by the workforce employed directly and indirectly by the
business aviation industry. The income earned by these employees is spent on
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various goods and services, leading to further economic activity and employment.
This contributed €9.3bn.
In approximate terms the air taxi part of BA might be expected to have an economic footprint
about half that of the values above given that 45% of BA movements is made up air taxi
operations.
The PwC report further determined that the BA sector represents 164,000 jobs in aircraft
manufacturing and operations and maintenance generating salaries of €5.7bn.
For this project, EBAA has supplied the following estimates relating to BA as a whole:
• Number of European Operators 850 approximately
• Number of aircraft 4300 approximately
• Number of pilots 10 750 (based on an average of 2.5 pilots per
aircraft)
2.2.1.2 Analysis by States
In terms of breaking down the European number of movements by States, EUROCONTROL
provides an analysis of BA traffic by State for 2009 (EUROCONTROL, 2010). Figure 2.1
provides graphs of these data.
Figure 2.1: Breakdown of Daily BA traffic by European State (from EUROCONTROL,
2010)
There is no equivalent set of graphs purely for air taxi, but similar patterns are expected.
As part of the survey of FTL provisions during this project some States have also been able
to provide information on the volume of air taxi operations.
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Table 2.1: Air Taxi Operational Data from States
State Air Taxi Operational Data
Flights/ Flight No. of Operators No. of Aircraft No. of Pilots
hours
Poland 6697 flights/ 5 27 61
8230 flight hours
Spain 71 631 flight 27 102 Not available
hours
UK Not available 60 approx. Not available Not available
2.2.1.3 Size of Operators
The EBAA commissioned Alertness Solutions to examine fatigue factors in European
Business Aviation Operations (Alertness Solutions, 2011). As part of that study a survey of
several hundred Business Aviation pilots was conducted. One of the background questions
asked was how many pilots are employed by your company. The responses are shown
below which provide an indication of the distribution of operator sizes in Europe.
Table 2.2: Distribution of Pilot Numbers for Business Aviation Operators
Number of pilots employed by BA operator
10 or less 11-30 31-60 61-100 More than 100
Number of 160 239 117 88 52
pilot
responses
% of pilot 24% 36% 18% 13% 8%
responses
2.2.2 Single Pilot Operations
Based on responses from the surveyed NAAs, single pilot operations are associated with Air
Taxi operations, scheduled operations, AEMS and flights landing at the same airfield where
they took off.
2.2.2.1 Air Taxi
EBAA has no specific data on single pilot operations within air taxi or BA operations. It was
considered a marginal activity by EBAA within their membership.
Some of the NAAs were able to provide estimates on single pilot operations within Air Taxi.
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Table 2.3: Operational Data on SPLO for Air Taxi
State Single Pilot Air Taxi Operational Data
Flights/ Flight No. of Operators No. of Aircraft No. of Pilots
hours
Poland Approx. 4 15 35
1560 flights/
950 flight hours
Spain Only one operator is authorised for conducting single pilot operations.
However, it has not operated air taxi services up to now. It has been
conducting aerial services.
UK Not available Approximately: Not available Not available
15 operators have
aircraft that only
require a single
pilot for CAT work
5 operators only
have aircraft that
need a single pilot
In Poland about half the aircraft and pilots involved in air taxi are involved in single pilot
operations. In Spain there are no current air taxi single pilot operations. In the UK, about
25% of air taxi operators have aircraft capable of single pilot operations. Thus, based on the
limited received data the picture is varied in different European States. Further data
collection on single pilot operations would be desirable.
2.2.2.2 Scheduled Operations
In France, single pilots are involved in some scheduled operations. Examples include:
• Finist’air an airline providing scheduled passenger flights between Brest and
Ouessant as well as air taxi operations and freight transport. The airline operates
Cessna 208 Caravans.
• St. Barth Commuter an airline based in the Caribbean operating Cessna 208
Caravans and Britten-Norman Islanders.
In the UK single pilot operations apply to scheduled services around the Highlands and
Islands (e.g. Loganair and Hebridean Air Services) and the Channel Islands.
No other data on scheduled single pilot operations were obtained during the survey of NAAs
and relevant associations.
2.2.2.3 AEMS
During the preparation of report D2 on EMS, data were received from France and UK that
single pilot AEMS operations take place in those States and that relevant FTL provisions are
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in place. Poland stated that single pilot AEMS operations did not occur in that State. No
other specific information on single pilot operations in AEMS was obtained during the EMS
survey.
2.2.2.4 Other Services
France and Germany have noted that flights landing at the same airfield where they took off
take place as single person operations in addition to the services above.
2.2.3 Crew Cost Estimates
The main impacts of FTL and rest regulatory changes are likely to be on crew costs. Crew
costs cover salary and non-salary such as pensions, social security, benefits such as
medical insurance and expenses. Any changes in crew numbers will also impact costs
associated with recruitment, training and checking of crew.
None of the NAAs nor the EBAA were able to provide specific Air Taxi data on crew costs as
a proportion of total operator costs. One of the States provided an estimate for a combined
AEMS/ Air Taxi provider of 15% of total operating costs relating to crew costs. In the
absence of further data a range of 10% to 30%, similar to that for AEMS in D2 is considered
reasonable.
It should be noted that there could also be other more subtle economic impacts on operators
associated with changes to FTL and rest requirements, e.g.:
• Air Taxi or Single Pilot jobs could become less or more attractive, for example, by
changing the number of rest days available, affecting the number of flying hours or
leading to changes in salary.
• In areas where there is competition for crew, this could affect the availability of crew
for Air Taxi with a consequent knock-on impact on service viability.
• If there is a need for more crew arising from FTL changes it may be a challenge to
find such crew from the immediate locality. It may be difficult for crew to travel from
further afield depending on FTL constraints regarding travel times.
• The impact on the number of flying hours can also affect job satisfaction and how
motivated/ bored personnel become.
In the absence of more robust data, these impacts are not considered explicitly in the
sections below.
In addition to direct economic impacts on Air Taxi operators, there could also be indirect or
induced economic impacts as indicated in Section 2.2.1.1.
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2.2.4 Analysis Method for Air Taxi and Single Pilot Operations
It is not possible to analyse all possible economic impacts of all conceivable future FTL
regulatory changes. Therefore the subsections in Section 5.0 have, for the safety issues
identified under each hazard:
• Identified what are considered likely to be those FTL changes with the most
significant economic impacts;
• Described the effects qualitatively and listed factors which are likely to affect the size
of the economic impact; and
• For selected impacts illustrated a process that would allow estimates of the scale of
the impacts once more robust data have been gathered.
2.3 Analysing Social Impacts of FTL Changes
The types of social impacts considered in the report are:
• Working conditions for crew;
• Employment impacts (job creation/ curtailment), closely linked to economic impacts;
• Need for relocation or more/ less travelling as a result of FTL changes; and
• Impact on social life and work/ life balance.
The analysis method for social impacts has been analogous to the one above for economic
impacts.
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3.0 Hazard Identification
3.1 General Fatigue Factors
Fatigue is an impairment of mental and physical function manifested by a cluster of
debilitating symptoms, usually including excessive sleepiness, reduced physical and mental
performance ability, depressed mood and loss of motivation, which may result from a variety
of causes including:
• Sleep deprivation/circadian phase effects: Fatigue develops as the result of an
extended time awake (acute sleep deprivation), or reduced time asleep, or disrupted
or poor quality sleep (partial sleep deprivation), time awake in the Window of
Circadian Low (WOCL) or from the cumulative effect of multiple days with shortened
or disrupted sleep such as may occur in jobs with extended work hours, irregular
schedules or with night duty (chronic sleep deprivation).
• Heavy stressful physical or mental effort: Fatigue occurs as the result of
extended hours of work with heavy muscular activity (e.g. marathon runner),
continued stress or danger (e.g. combat fatigue) or intense mental exertion which
occurs either during the task or as a rebound effect after the task, in proportion to the
relative fitness (and/or prior training) of the individual.
• Sleep disorders: Fatigue manifested as excessive daytime sleepiness is the most
common presenting complaint in sleep disorders, such as obstructive sleep apnoea,
restless legs syndrome, narcolepsy or most of the other 85 different sleep disorders
listed in the International Classification of Sleep Disorders (2005).
• Illness or disease: Fatigue is common in many diseases and illnesses (ranging
from flu to cancer) which may occur as a direct result of the metabolic or other
systemic pathophysiological disturbances of that disease, as a secondary
consequence of sleep disturbances caused by other symptoms such as pain, nausea
etc., or as the primary presenting complaint (e.g. chronic fatigue syndrome).
• Therapeutic side-effect: Fatigue is a commonly listed side-effect of prescription or
over-the-counter pharmacological drugs, or may occur as the result of other
therapeutic interventions (e.g. surgical procedure).
• Stimulant drug usage: Fatigue often occurs as a person rebounds after the initial
euphoria, increased energy or “high” induced by illegal, over-the counter (e.g.
Redbull, NoDoz etc.) or prescription stimulant pharmacological substances.
Unlike the engineering use of the word “fatigue” which is used to describe irreversible failure
of a material as a result of stresses over an extended period of time, the medical definition of
“fatigue” usually refers to a loss of physiological and psychological function as a result of
extended wakefulness, heavy work, excessive stimulation, illness or stress which can
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usually be reversed in whole or in part by rest, sleep, treatment or recovery from the
condition that caused it.
For this report we use the ICAO definition of fatigue:
A physiological state of reduced mental or physical performance capability resulting from
sleep loss or extended wakefulness, circadian phase, or workload (mental or physical
activity) that can impair a crew member's alertness and ability to safely operate an aircraft or
perform safety related duties.
In this report we have not considered sleep disorders, illness and disease, therapeutic side
effects or stimulant drug usage. Workload is considered in terms of its direct effects on
fatigue.
During sleep the human brain cycles through distinct stages, each characterized by changes
in the electrical activity of the brain. When we are awake and alert, the electrical brain waves
measured by electro-encephalography1 (EEG) are fast (13 to 35 cycles per second) and
random, but as we become drowsy the brain waves start to slow into a regular “alpha”
pattern (of 8 to 12 cycles per second), which is exaggerated when we close our eyes. The
first stage of sleep is when we start slipping into a semiconscious state, called stage 1 sleep,
characterized by a further slowing of the brainwave rhythm to the “theta” range of 3 to 7
cycles per second, but in which we remain vaguely aware of our surroundings. We may even
convince ourselves that we are still awake and in control of our consciousness - a dangerous
misperception if we are on duty in a critical job.
From stage 1 we progress unknowingly into stage 2, a light level of sleep in which bursts of
electrical activity called K-complexes and sleep spindles intrude into the EEG. Finally, after
30 to 40 minutes, we sink into the deepest stages of sleep (called stages 3 and 4) in which
the brain waves slow down to 0.5 to 2 cycles per second and are magnified in their
amplitude. These deep slow waves are called delta waves.
We do not linger for long in delta sleep. In fact, we tend to oscillate in a 90- to 100-minute
cycle between the lighter and deeper stages of sleep interspersed with bouts of dreaming in
which the brain waves suddenly speed up to an awake-like pattern and the eyes start
moving rapidly from side to side. This stage, called rapid eye movement (REM) sleep, may
occur four or times a night, building in duration as dawn approaches. Thus one may have
four or five distinct dreams per night.
The stage of sleep from which you awake determines your condition on arousal. If you are in
the deepest stages of delta sleep, you will feel groggy and disoriented on awakening, and
suffer significant “sleep inertia” or impaired functioning for ten or twenty minutes or more. If
you are in stage 1 or 2 sleep, you are much more likely to wake up alert and refreshed.
Likewise you are more likely to remember a dream if you awake during a REM sleep stage.
Those factors which are most likely to affect sleep deprivation and circadian phase effects
include:
1
the recording of electrical activity along the scalp
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1. Time of day according to the individual’s own circadian phase
An individual’s level of alertness and sleepiness varies over the course of the 24–
hour day in a predictable circadian (approximately 24-hour) pattern with the greatest
sleepiness in the early hours of the morning before dawn (typically 1AM-6AM), and a
second lesser period of sleepiness in mid-afternoon (often referred to the “post-lunch
dip” or the “siesta hour”). Numerous studies have shown that transportation and
other accidents caused by fatigue have a peak time of risk relative to circadian phase
around 1-6 AM and secondary time of risk approximately from 1-4 PM (Horne, 1995;
Langlois, 1985).
It is not the clock time on the wall that determines these daily biological cycles of
sleepiness and alertness. The time of day according to a person’s circadian
pacemaker (biological clock) is called the “circadian phase”, which is shifted by
exposure to light in other time zones or to a lesser extent during night duty activities.
Even in people who are not travelling across time zones, an habitual early bed time
and early arising time on both work days and weekends/rest days is associated with
an earlier (or “advanced”) circadian phase, and a pattern of maximum sleepiness and
alertness that is shifted to earlier hours, as compared to someone who habitually
stays up and sleeps in late, who will have a late (or “delayed”) circadian phase.
2. Chronotype of the individual
Individuals vary considerably in their orientation to day and night on a morningness-
eveningness scale and in their required sleep duration for recuperation (Duffy, 1999;
Horne, 1976; Aesbach, 1999). Morning types tend to rise early and they feel and
perform best during the morning hours. Evening types tend to rise late in the morning
and they feel at their best late in the evening. It has been shown that these
characteristics are genetic in nature, and independent of age, sex and ethnic heritage
(Katzenberg, 1999). As discussed earlier we have used default settings
representing the average person in this analysis and have not simulated individual
chronotypes.
3. Length of time since awakening from last sleep episode
When a person first wakes up from sleep there is a period of grogginess or
sleepiness that resolves typically in less than half an hour. This is referred to as
“sleep inertia”. Once a person has fully recovered from the residual sleep inertia from
his or her last sleep period the drive for sleep builds with time until the next sleep
period occurs. Eventually the extended time spent awake results in a strong sleep
pressure. This is referred to as the homeostatic drive to sleep. However, sleep
propensity, or the likelihood of falling asleep, is determined by a combination of the
homeostatic drive and the other factors listed here. As a result sleep propensity does
not simply relate to the length of time awake which drove the original FDT
regulations. In reality, the circadian and homeostatic drives to sleep interact. This
produces peaks in relative alertness in mid-morning and early evening, separated by
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an early afternoon “post-lunch” dip in alertness or siesta hour. This circadian-
homeostatic interaction also causes the precipitous drop in alertness after midnight
when an employee begins his first night duty period following several days of night-
time sleep and daytime wakefulness.
4. Duration of the previous consolidated sleep period
The effectiveness of a sleep period in quenching the level of sleepiness that an
individual has accumulated over the previous day(s) is determined by the sleep
period’s duration, as well as by the quality of sleep obtained (see factor #6 below).
The average adult needs 7-8 hours of sleep per day to maintain average levels of
daytime alertness. However, there are considerable inter-individual differences, with
some individuals needing as much as 9 hours per day, while others only need 6
hours. Significant increases in daytime sleepiness are found for most people when
the nocturnal sleep length is reduced below 5 hours, or when reduced sleep duration
occurs for two or more successive nights. In the CAS analysis we have used default
settings representing the average person.
5. Timing of sleep episode
In addition to the duration of sleep, the timing of the sleep episode is a key factor.
Due to the influence of circadian phase, sleep is more effective and its quality better
at some times of the day than at others. As noted above, it is also important to
consider the time of day according to a person’s biological clock, (i.e. his or her
“circadian phase”) not only in predicting or assessing the level of sleepiness, but also
in judging the duration and quality of sleep that is obtained by sleeping at a particular
time of day.
Because of the strong effect of the circadian system, sleep duration is also highly
dependent on the circadian time of day. For example, there are certain times of day
when it is difficult to obtain more than four hours sleep, even under ideal conditions,
after extended periods of time awake, and with the most highly motivated individual.
The studies of Akerstedt and Gillberg (1986) are particularly instructive. They studied
working age subjects (comparable to flight crew personnel) who were given an
opportunity to sleep under ideal conditions (quiet comfortable bedroom) during rest
periods which started at various times of day or night. When the rest period began at
11PM at the end of a normal day of 16 hours continuously awake, they slept on
average for 8 hours, as one would expect given the unlimited sleeping opportunity.
However the later the rest period began after 11PM, the shorter was the sleep
duration as a result of the strong circadian time of day effect. Thus when the rest
period began at 3 AM (after 20 hours continuously awake) they achieved only 6.5
hours sleep, when rest began at 7 AM (after 24 hours continuously awake) they
obtained only 4.5 hours sleep; when rest began at 11 AM (after 28 hours
continuously awake) they got only 4 hours sleep.
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6. Quality of sleep in the previous sleep period
The quality of sleep at night also influences the sleepiness level on the subsequent
day. When sleep is disturbed by deviations from typical sleep characteristics, this
results in increased sleepiness the following day.
Many factors may influence these characteristics of sleep quality, including the time
of day or night that sleep is attempted, the environmental conditions in which one is
sleeping, and the existence of any clinical sleep disorders or other medical
conditions.
To ensure adequate sleep, the sleeping environment should be both physically
comfortable and psychologically conductive to sleep. People usually sleep better in
their own bedroom than in an unfamiliar environment. One of the most important
challenges many transportation employees face is the requirement to sleep away
from home. In other words a transportation employee sleeping in their own bed on
their regular nightly schedule and routine will have significantly higher sleep quality
than the same person sleeping away from home in unfamiliar circumstances at an
unusual time of day. In this analysis CAS takes into account the timing of sleep. It
does not consider the effect of sleep disorders.
7. Cumulative effect of sleep duration and quality over the past week
A person’s sleepiness level on a given day is most strongly influenced by the quality
and duration of the last sleep episode. However, the sleep pattern during the
preceding week will also affect sleepiness level. It is also well recognized that days-
off, where there is no substantial restriction on the opportunity for unrestricted sleep,
allow a person to recover fully from all accumulated sleep debt. The number of days
required depends on the level of sleep deprivation, but in most circumstances two
consecutive nights of sleep has been determined to be sufficient.
When a person follows a regular sleep-wake schedule, that is, going to bed and
waking up at approximately the same hour every day, this helps to synchronize his or
her sleep/wake and other circadian rhythms to that regular schedule.
Thus a regular daily pattern of bedtime and awake time, and a regular routine of
exposure to light and dark will cause a person’s circadian sleep-wake rhythm to
become optimally synchronized to the time of day that they are going to bed – even if
that time of day is not a typical or traditional time. This synchronization will promote
optimal sleep quality and consequently minimize sleepiness at the time of the day the
crew member wishes to be most alert.
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3.2 Air Taxi Operational Data and Characteristics
3.2.1 Operational Data Relevant to FTL
Data were received from the EBAA and 3 States that help characterise Air Taxi operations in
Europe. These data are summarised in Table 3.1 below.
The EBAA data are for Business Aviation as a whole rather than specific to Air Taxi and are
drawn from the Alertness Solutions report (2011).
Table 3.1: Air Taxi Flight and Duty Characteristics
Issue Survey Responders
EBAA Poland Spain UK
Average duty 1188 820 717 -
hours per year
Average flying 339 630 285 -
(block) hours per
year
Home Standby Contactable: 98d/yr 70d/yr 144d/yr -
Standby: 73d/yr
25% chance of callout
Daily Duty 9h average FDP max of 11h for FDP 8h -
Durations medium ac and 13h average
20% reported that 12h+
for long range
was typical
No. of sectors 2.4 average 3-4 for medium ac 3 average -
per duty
1-2 for long range
Average sector - 2-5h for medium ac 3h average -
duration
2-11h for long range
Time zone 0-3 typically, 1 flight per 2-5 for medium ac For 5 -
crossings month crossing 4-6 TZs operators may
2-11 for long range
have TZ
13% reported TZ
changes of 4-6
crossings >6 in last
hours
month
Frequency of 53% reported split duty in - - -
split duty last month – average of 3
split duties in that month
Duration of split Typical length of ground - - -
duty break – 5.3h
Mean typical total duty
time – 12.9h (4 hours
longer than average non-
split duty) – standard
deviation of 5.8h about
the mean
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Issue Survey Responders
EBAA Poland Spain UK
Airport standby Very rare Not much used. Not much Not much
used. used.
In-flight rest For long range flights Yes for long range Not much Only a
used. couple of
operators
have in-
flight rest
facilities
Consecutive Very rare as on-demand No - No
nights or operations
consecutive
earlies/lates
Reduced rest Rarely. It happens when Yes No No
Air-Taxi operations provision
include a late positioning in CAP
at the end of the day in 371
preparation for a morning
start the following day.
Travel time Average travel time from - - -
home to home base of
1.5 hours
Positioning 65% of responders said - - -
that their company pre-
positioned crew.
3.2.2 Air Taxi Characteristics
The general characteristics of Air Taxi operations in Europe of relevance to fatigue and FTL
are considered to be:
• On demand operations;
• Majority at short notice;
• Large amount of standby at home with relatively low chance on average of being
called out;
• Frequent change of schedule/routing; this can include duty start times being put back
or brought forward;
• Many of the flights (especially on the small and light jet segments) leave in the
morning and come back in the evening. In between, pilots are often waiting in crew
rest facilities on split duty;
• Passenger requirements can lead to planned on-ground breaks being curtailed or
alternatively ad-hoc split duties being needed;
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• Air taxi pilots on average fly significantly fewer flying hours per year than scheduled
airline pilots;
• Considerable use is made of positioning of crew and aircraft relative to scheduled
flights;
• Generally aircraft used for Business Aviation may be considered to have higher
levels of comfort (e.g. with respect to noise and pressurisation) than scheduled
airliners; and
• Time zone crossings are an issue as can be seen from Table 3.1.
As well as these characteristics the EBAA survey (Alertness Solutions, 2011) found that 18%
of responders held jobs in addition to Business Aviation flying. They recorded a mean of 48
hours per month conducting these other jobs.
In broad terms these characteristics can lead to peaks in workload and pressures on rest
times which combined with the potentially unpredictable/ disruptive nature of the work could
lead to transient fatigue. Cumulative fatigue, on average, will be less of an issue than for
scheduled airline pilots, but obviously still needs to be considered in FTL rule making.
Table 3.2 identifies hazards that appear relevant to Air Taxi operations. Potential mitigations
have been identified. Comments based on the information supplied by NAAs and
associations about the characteristics of Air Taxi have been included where relevant. These
hazards and mitigations are preliminary and will be reviewed during the future RMT .0429
process.
3.3 Single Pilot Specifics
Based on the limited amount of data received, the distinctive characteristics of single pilot
operations relate to the generally shorter flights and duties. This applies to all types of
operations, not just air taxi. SPLO will mainly be domestic or intra-European flights. Some
single pilot air taxi operations do entail multi-day trips as far as the Middle East and hence
TZ crossings can still be relevant. The other hazards identified in Table 3.2 below are also
considered relevant apart from in-flight rest/ augmented crew. Mitigations and comments
specific to SPLO are highlighted with bold underlined text.
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Table 3.2: Preliminary Air Taxi and Single Pilot Operations Hazard Identification
Grouping Hazards and Potential Mitigations Comments
Description
A. Time Awake/ A1. Duration of FDP too a. Limits on maximum duration of FDP (including
Long (extended) FDPs can occur in
Duration of Duty long leading to fatigue extensions)
air taxi operations (see Table 3.1)
b. Modifying FDP according to number of sectors and/
and are likely to be a potential peak
(relating to homeostatic (including extensions) or limits on daily flying time
fatigue issue.
process principally) c. Not allowing reduced rest before an extended FDP
d. Extended rest after a long duration FDP (after the The impact of FDP duration and
See Literature Review in event) WOCL encroachment have been
Section 4.2. e. Limiting the frequency of long extended FDPs per analysed in Section 5.1.
week or per month (cumulative fatigue control)
f. FRMS (general – applicable to all hazards)
g. Napping and relaxation during any ground breaks
h. Ensuring that the most strict limits apply when
extensions are used for mixed operations (e.g. air
taxi and AEMS)
i. Records to NAA of extensions and NAA oversight
measures
j. For single pilot operations specific requirements
for FDP limits, maximum daily block hours,
maximum single flight/ sector time and restrictions
on extensions
k. Relief pilot for single pilot operations when an
extension is invoked
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Grouping Hazards and Potential Mitigations Comments
Description
A2. PIC reacts to a. Maximum limits on PIC extension
PIC discretion can be used to
circumstances on the day b. A non-punitive process for a PIC to reduce a FDP
extend FDPs, to finish a trip or
to extend FDP duration and/or increase rest in the case of fatigue
return the aircraft to base. Could
excessively leading to c. Reporting to the NAA when the extension is above
potentially lead to long duration
fatigue a certain threshold
FDPs.
d. Guidance to the NAA on this subject
e. Training on fatigue to support PIC in the decision
Considered in Section 5.11.
process, e.g. the potential risks of PIC extensions,
techniques for self-evaluation of fatigue, pressures
likely to be encountered, etc.
f. FRMS including awareness training for
commanders
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Grouping Hazards and Potential Mitigations Comments
Description
A3. Extended FDP due to a. Maximum duration of FDP with augmented crew See Section 5.2.
in-flight rest (augmented (including extensions) dependent on type of
crew) leads to fatigue onboard rest facilities and number of additional N/R for single pilot operations.
crew carried
b. Setting minimum standards for in-flight rest facilities
c. Minimum rest period onboard required
d. Setting a minimum continuous duration for in-flight
rest
e. Limiting Pilot Flying (PF) time in one FDP
f. Specifying minimum rest durations at destination
and home
g. Additional compensation time at home over and
above the standard rest time
h. Sleep opportunities at home base after long
missions (to mitigate home travel risks)
i. Promote and pay for use of public transport after
long missions
j. Limiting the frequency of such extended FDPs with
augmented crew
k. Limiting the number of sectors.
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Grouping Hazards and Potential Mitigations Comments
Description
A4. On-ground break a. Establish minimum consecutive number of hours for See Section 5.3.
(split duty) used to extend break
the FDP excessively b. Establish how hours of the break contribute to FDP For air taxi operations could have
leading to fatigue c. Placing limits on the extension time and total FDP ad-hoc breaks rather than planned
with split duty split duties, might be in aircraft and
d. Establishing limits for the duration of FDP before hence quality of rest may be
and after the break reduced + could be customer
e. Specifying standards for the rest facilities/ pressures to reduce/ change break.
accommodation during the break (including aircraft This applies also for single pilots
facilities if break taken on-board, e.g. noise levels, conducting ATXO, but not those
temperature, activities occurring on and around the conducting scheduled operations
aircraft, etc.) where such breaks are easier to
f. Numbers of breaks in one FDP plan.
g. Restriction on combining split duty with augmented
crew rules or reduced rest
h. Impact of travel time during break on FDP
extension
i. Time difference/ non-acclimatisation restrictions
j. Frequency of extended FDPs due to split duties
(e.g. in one week)
k. Whether a crew member can be pilot flying after a
certain FDP duration
l. Take account of split duty for subsequent rest
calculation
m. Pre-plan breaks
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Grouping Hazards and Potential Mitigations Comments
Description
A5. Standby (generally at a. Take account of standby time in maximum FDP See Sections 5.1 and 5.8.
home for AT, but could be b. Limit on standby duration
elsewhere) followed by c. Establish minimum rest after standby Air Taxi (AT) pilots spend high
FDP leads to excessive d. Establish different levels of readiness proportion of time on standby at
time awake e. Standby management procedures so operator home. This applies also for single
avoids placing crew on repeated 24 hr duration pilots conducting ATXO, but not
Unpredictability of home standbys, and preferential use of persons on those conducting scheduled
standby can cause standby who should be better rested. operations.
difficulties in being fully f. FRMS and crew’s individual management of rest
rested before FDP during standby – a FRMS can help raise crew’s On demand nature of Air Taxi
awareness of the importance of napping, avoiding Operations (ATXO) makes rest
heavy home working tasks, etc. planning difficult – could lead to
lack of rest prior to an FDP
(particular issue with FDP at night)
Focus is on short call standby as
presenting most significant potential
fatigue issues.
Airport Standby also considered in
Section 5.8
A6. Ground duties in a. Limitations on combined flight and ground duties ATXO pilots generally called out
addition to flight duties from home standby. However,
extend day’s duties EBAA survey shows that BA pilots
excessively. do have non-flight duties that can
extend duty time.
B. Time of Day Effects B1. WOCL encroachment a. Limiting maximum FDP duration based on WOCL See Sections 5.1 and 5.4.
encroachment
(relating to circadian
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Grouping Hazards and Potential Mitigations Comments
Description
process principally) B2. Circadian disruption – a. Extended and recovery rest See Section 5.5.
mixing duty transitions b. Limiting mixing of night and day flights
See Literature Review in between early/ late/ night
Section 4.3. duties
B3. Time Zone de- a. FDP restrictions and rest (home and away) based See Section 5.6.
synchronisation on number of time zones crossed
b. Limit max FDP according to day time and degree of Can get large time zone changes
acclimatization with Air Taxi and even long multi-
c. Minimum time set before a crew would be sector trips for Single Pilot (SP).
considered time zone acclimatized
d. FRMS of particular importance to take account of
time zone specifics and specific route patterns of a
long range ATXO operator
e. Limiting number of alternating east-west rotations
per month
f. Providing additional rest when alternating east-west
rotations happen
g. Trying to schedule flights to take account of TZ
desynchronisation (difficult for an on-demand
service such as ATXO)
h. Use of augmented crew to allow in-flight rest (N/R
for single pilot operations)
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Grouping Hazards and Potential Mitigations Comments
Description
C. Cumulative C1. Cumulative fatigue / a. Limitations on consecutive days See discussions in Section 5.7.
sleep debt builds up b. Limitations on weekly duty hours
See Literature Review in c. Longer term cumulative limits Although annual hours for AT pilots
Sections 4.4 and 4.8. Includes effect of FDPs d. Minimum number of days off per month are generally significantly lower
on consecutive days/ e. Rest periods periodically extended than for scheduled airline pilots,
nights (even though f. Spreading out duty as evenly as possible – difficult could still have cumulative fatigue
unlikely to extend to for on-demand AT service building over shorter time periods.
several days due to on- g. Providing additional rest if frequency of FDPs
demand nature of service) encroaching WOCL exceeds a certain limit
h. Limiting the frequency of WOCL encroached FDPs
– again potentially difficult for on-demand AT
service
i. Limit frequency of consecutive split duties
C2. Home/hotel standby a. Take account of home/ hotel standby time in See Section 5.8.
not considered cumulative duty and rest calculations
adequately in cumulative
duty and rest calculations
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Grouping Hazards and Potential Mitigations Comments
Description
D. Rest and Sleep Off D1. Lack of rest a. Set minimum rest period and sleep opportunity See discussions in Section 5.9.
Duty opportunity and rest at between duties
sub-optimal periods (in b. Setting different minima for rest period at home
(relating to homeostatic relation to basic rest and base and out of base to cover travelling time and
process principally but reduced rest) protect sleep opportunity
affected by circadian c. Set minimum duration for reduced rest (if used)
process ) d. Augmentation of rest and/or reduction in max. FDP
following reduced rest
See Literature Review in e. Limit frequency of reduced rest occasions
Section 4.5. f. Limiting the length and number of sectors after
reduced rest
g. Ensuring reduced rest encompasses entire WOCL
h. Specifying minimum accommodation requirements
for reduced rest
i. Not allowing rest reduction when FDP is extended
by in-flight rest or when there is crossing of multiple
time zones
j. Special rules if reduced rest is combined with split
duties
k. FRMS if reduced rest used
E. Relaxation and Naps E1. Overlong nap and a. Awareness training about effect of length of nap on Role as a mitigation and potential
On Duty insufficient time awake sleep inertia hazard considered in Section 5.10
(relating to Sleep Inertia could lead to sleep inertia
process principally) during flights In-flight rest N/R to SPLO
See Literature Review in
Section 4.6 and 4.7.
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Grouping Hazards and Potential Mitigations Comments
Description
F. Positioning and a. Inclusion of positioning immediately before flight See Section 5.12.
F1. Positioning before an
Travelling duty in the FDP
FDP causing lack of rest
(related to time awake ATXO involves more positioning
and excessive time awake
and cumulative effects than scheduled – see Table 3.1.
and hence fatigue
and homeostatic process
principally)
a. Post-FDP positioning should be limited to prevent See Section 5.12.
See Literature Review in F2. Positioning
excessive duty day
Section 4.9. immediately after an FDP
b. FDP and post-FDP positioning to be taken into ATXO involves more positioning
leading to excessively
account for subsequent rest period than scheduled – see Table 3.1.
long duty periods with
potentially a cumulative
effect
a. Nomination of a home base for each crew member See Section 5.12.
F3. Excessive travelling
b. Ensuring a protected 8 hour sleep opportunity
time
c. Counting travel time in excess of a limit (e.g. 60
minutes) as duty time (or positioning)
d. Napping during ground breaks to reduce fatigue at
the end of long days created by long duration FDPs
and travel
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4.0 Fatigue Literature Review
4.1 Overview
This section reviews the peer-reviewed research literature in fatigue with an emphasis on
aviation and on single pilot and air taxi operations where relevant studies are available. The
literature search did not identify many peer-reviewed studies on fatigue risk specifically in
single-pilot operations excluding single-pilot EMS operations (already covered in D2).
However, single-pilot operations face many of the same physiological and operational
contributors to pilot fatigue as other sectors of aviation. The main contributors to pilot fatigue
and their interactions are discussed in the following sections.
4.1.1 Air-Taxi Operations
The characteristics of air taxi operations set out in Section 3.2 can present fatigue
management challenges. Similar to commercial airline pilots, and the general shiftwork
population, air taxi pilots suffer from fatigue due to operational factors. A survey of European
business aviation pilots on behalf of EBAA (Alertness Solutions, 2011) found that 30% of
responding pilots experienced fatigue on a weekly basis and 46% on a monthly basis in flight
operations. Almost half admitted to nodding off in the cockpit. While these pilots are
generally successful at mitigating the effects of fatigue by using naps, caffeine, and other
countermeasures, over two thirds stated that they had received no formal training on how to
manage fatigue. Another survey of corporate/ business pilots found that 71% of pilots
admitted to nodding off in the cockpit during a flight (Rosekind et al., 2000).
In the United States, most research on air taxi operations has been done in Alaska. Alaska is
a unique environment with a less developed road infrastructure, rough terrain, unpredictable
weather, and a busy summer tourism season that requires a considerable number of air
taxis to connect the state. Surveys of Alaskan pilots show that fatigue is an issue – 22% of
pilots working for large air taxi operators and 13% of pilots working for small air taxi
operators admit to wanting to refuse to fly because of fatigue at least monthly (Conway,
2006).
In Europe, a survey of charter pilots for passenger operations and cargo operations (similar
in scope in some ways to air taxi operations) found that sleep quantity, quality, and alertness
was affected by scheduling practices including early starts, night duties, and shortened rest
periods, etc. (Spencer and Montgomery, 1997).
4.1.2 Single-Pilot Operations
Single-pilot operations are generally considered to be more challenging than multi-pilot
operations. Single-pilots often operate under high workload conditions, since the pilot
assumes multiple roles, e.g. navigator, radio operator, systems manager, meteorologist,
record keeper, etc. (AOPA Safety Advisor, 2006). A single-pilot must multi-task and has no-
one to assist him/ her under conditions of unexpected weather, high-density traffic, or other
circumstances that can quickly cause them to become overwhelmed. Some of the problems
that pilots face that are made more challenging in single-pilot operations include following
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and completing all pre-flight and in-flight checklist items, dealing with multiple tasks that may
lead to distraction and/or increased time pressure (which increases accident risk), missing
small pieces of knowledge that may be useful in a given circumstance, monitoring errors,
making and catching errors of omission, and missing automatic situational alerts from the
flightdeck (Deutsch and Pew, 2005).
These challenges have the potential for increasing workload and hence fatigue and also can
make single pilots more vulnerable to fatigue. While there are data looking at general single
pilot safety levels, there is a lack of data considering the relative fatigue related accident
rates between single and dual pilot operations. For example in a study investigating 25 years
of IFR accident data, the single-pilot crash rate was only slightly higher than the dual-pilot
crash rate (7.27 vs. 6.48 crashes per 100,000 takeoffs), however, the crash rate for single-
pilots during more challenging night-time flying was over 8 times higher (Bennett and
Schwirke, 1992). However, no direct link to fatigue was made in that study.
4.2 Duration of Duties and Time Awake
4.2.1 Overview
The relationship between duty length and fatigue is complex, and cannot be reduced to a
simple formula, as it is complicated by circadian phase, time awake since last sleep,
chronotype and the other factors discussed in Section 3.1.
The length of duty directly impacts the accumulation of fatigue whilst on duty since it goes
along with “time awake” which is directly related to fatigue. This “time awake” also explains
that the length of duty has to be looked at in conjunction with “time of day” since for night
duties sleep often ends hours before the duty start, whereas for day duty pilots usually start
with “freshly charged batteries” in terms of recent sleep. The length of duty also determines
at what time of day the opportunity for rest and sleep occurs. This is important since sleep
outside the window of circadian low (WOCL) is usually of lower quality and less beneficial.
When evaluating duty or shift duration, it should be noted that longer duty periods not only
affect consecutive hours on duty, but also may reduce the amount of time off between
duties, and impact sleep duration and recovery.
There are a series of factors that should be taken into account when analysing duty period
duration in aviation operations, including the influence of length and number of sectors
(section 4.2.4), time of day effects (section 4.3), and augmented crews and the possibility of
in-flight rest (section 4.7). Although air taxi and single pilot operations are not typically based
around shift schedules, their pilots can work long duty periods, and are subject to the same
types of risk with increasing duty/FDP length as shiftworkers in other industries. Thus, a
general discussion of relevant shiftwork research is provided, along with a review of
duty/FDP lengths in aviation.
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4.2.2 Shift Duration Literature Across All 24/7 Industries
The main issue with shift duration is whether fatigue risk (and the associated risk of incidents
and injuries) increases with increased shift length. A review of the scientific literature shows
that most studies found increased fatigue with longer duty periods, and a number of studies
have shown an increased risk of accidents at the end of the shift. However, the increase is
not linear, and usage of breaks within a shift has been shown to be effective in decreasing
accident risk during that shift as described below in section 4.2.2.2. Moreover, other studies
have found that there is also increased risk at the beginning of the shift, and within 2-4 hours
of the start of a shift.
4.2.2.1 8-Hour versus 12-Hour Shift Comparisons
Most of the scientific literature on shift duration is focused on the comparison between 8-h
and 12-h shifts, since these shift lengths are the most common in shiftwork environments.
While in some studies shifts up to 12 hours have been shown not to affect performance
negatively (Smith et al. 1998), most studies have found an increased level of fatigue and
sleepiness, especially during the final few hours of the shift (Rosa and Bonnet 1993; Rosa
1995; Fischer et al. 2000; Son et al. 2008).
However, there is agreement that in most circumstances, shift durations up to 12 hours do
not represent a significant risk increase, compared to 8-h shifts provided the total hours
worked per week is the same. This is because the completion of weekly work hours in a
fewer number of days means that there are more off-duty days per week on 12 hour shifts,
and this allows more time to recover from any accumulated sleep debt as compared to the
fewer number of days off-duty on 8 hour shifts.
4.2.2.2 Accident Risk and Shift Length
Some scientific studies have indicated that there is an increased risk of industrial incidents in
the 9th to 12th consecutive hour of work (Spencer et al., 2006). However, other studies have
found that the relative frequency of incidents does not increase linearly from the first to the
last hour of the shift. Furthermore, often there is an increased risk not only at the end of the
shift, but also during the first or second hour (Hanowski et al., 2009; Folkard, 1997) until the
operator becomes focused. A review of shiftwork studies analysing the relative incident risk
over time on duty found a slight increase from the second to the 5th hour, a decrease in the
6th hour and then risk increased in an approximately linear fashion with time on duty, and in
the 12th hour was more than double than during the first eight hours (Folkard and Tucker,
2003). The authors suggested that a more comprehensive evaluation of the risk associated
with time on duty should take into account the effect of breaks. Their study analysed the
effects of breaks on injuries in an industrial setting and found that breaks reduced accident
risk, and that risk increased substantially and almost linearly between successive breaks,
both during day and night shifts. The authors concluded that different factors need to be
considered in combination when evaluating risk associated with night work, and for example,
a 12-h night shift that included frequent rest breaks might be safer than an 8-h shift with only
a single, mid-shift break (Folkard and Tucker, 2003).
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4.2.2.3 Shifts Exceeding 12 hours
Schedules with shifts longer than 12 hours are less common across a range of industries
(except in the trucking industry, where drivers are allowed to be on duty up to 14 hours per
day, and a 10-hour rest before the following shift is enforced) and generally not
recommended on a regular basis.
The safety of 14 consecutive hours on duty in a safety-critical position was endorsed by the
Federal Motor Carrier Safety Administration (FMCSA) in the trucking Hours of Service
regulations (Department of Transportation Report 2003). After much research (US Federal
Register, 2005) and consultation, these U.S. trucking industry regulations introduced in 2004
allow drivers to be on duty a maximum of 14 consecutive hours per day. However it should
be noted that these regulations also enforce a minimum of 10 hours rest after each 14-hour
duty period. This is also the pattern for FTL in the US for CAT operations.
Shifts of 16 hours or longer are unusual, except in emergency situations. For instance, the
U.S. Nuclear Regulatory Commission (2001) sets the limit at 16 h in a 24-h period, provided
that this is an occasional event. The international FRMS standard for the oil industry
(American Petroleum Institute, 2010) states that extended shifts (greater than 14 hours) shall
occur only to avoid unplanned unmanned safety critical positions or accomplish unplanned
safety critical tasks. It also states that in the case of 14-16 hour shifts, a minimum of 8 hours
off before the next shift is required, and for shifts greater than 16 hours, a minimum of 10
hours off before the next shift. It also requires that extended shifts shall in no case exceed
18 hours and that that there should be not more than 1 extended shift longer than 14 hours
per work set. Some studies have found that 16-hour shifts may be worked without
significantly increasing fatigue, provided that adequate countermeasures are taken during
and after the shift, such as allowing a nap during the shift and scheduling at least one day off
after the shift (Takahashi et al., 1999).
4.2.3 Review of Aviation Scientific Literature: Duration of FDP in Non-Augmented Crews
Many studies in the aviation industry (e.g. Samel et al (1997a), Spencer and Robertson
(1999), Goode (2003)) have found that extended duty periods in non-augmented operations
are associated with elevated fatigue levels and increased accident risk at the end of the duty
period. Powell et al. (2007) found that fatigue levels in short-haul pilots (flying as a 2-pilot
crew) increase with duty lengths up to 10 hours (Figure 4.1). Fatigue was self-reported using
the Samn-Perelli scale of sleepiness (with 1 being the lowest, and 7 being the highest).
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Figure 4.1: Fatigue increases with duty duration in short-haul pilots. Reference:
Powell et al., 2007
Fatigue Score (7 point Samn-Perelli)
The risk of aviation accidents increases with time of duty. A large U.S. study analysed
human factors related accident data over a period of 21 years for which a 72-hour history of
pilot activities prior to the accident was available. The distribution of these pilot work
schedules was compared to a large reference sample of all pilot work patterns. The data
showed that for duties of 10-12 hours the relative risk of an accident was 1.7 times higher
than for all duties, and for duties of 13 hours or more, the relative risk was over 5.5 times
higher (see Figure 4.2). In addition, while 20% of human factors accidents occurred to pilots
who had been on duty for 10 hours or more, only 10% of pilot duty hours occurred during
that time (Goode, 2003). As noted in Section 4.1.1 the relationship between duty length and
fatigue risk is complex; in particular in the context of the Goode 2003 paper the rest
requirements under Part 121 will have influenced the fatigue risk as well as the duty lengths
and hence the relationships derived in this paper need to be treated with caution when the
rest requirements are significantly different from those applicable to this study.
NTSB investigations have found that long duty days (over 13 hours) are associated with a
disproportionate amount of accidents, compared to duty periods of less than 13 hours. The
longer the crews are awake, the more errors they commit, especially cognitive errors such
as decision making (NTSB, 1994).
Accident rate may also be linked to FDP length in air taxi operations. A survey of 153 air taxi
operators in Alaska categorized the operators by high or low fatal accident rate to determine
what factors contributed to a high fatality risk. The authors found that in addition to other
factors (age, experience, willingness to fly into unknown weather conditions), pilots for high
risk operators were flying more hours per day (approximately 13), and working more hours
per week (approximately 81) than low risk operators – more than 1 hour per day and 10
hours per week extra (Conway, 2006).
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Figure 4.2: The risk of having an accident increase with duty on time. Reference:
Goode, 2003
There is some agreement that FDP limits should be 12-14 hours, with recommendations for
specific situations. An early study (Dinges et al., 1996) recommends that an extended
cumulative flight duty period should be limited to 12 hours within 24 hours (in the context of a
10-hour max FDP recommendation) and that it should be accompanied by additional
restrictions and compensatory off-duty period. The Paper for the European Transport Safety
Council (ETSC) states that there is no objection to an FDP of 12 hours during the day, but
does not support FDPs as long as 14 hours for early starts (Akerstedt, 2003). The Moebus
Aviation report (Moebus, 2008) recommends based on the Goode, 2003 paper that a single
maximum daily FDP should never exceed 13 hours (and then only under specific favourable
conditions) and that extension provisions above this should be excluded. However, in the
report there is no account taken of the increased rest period required by Subpart Q in case
of an extension of 1 hour to an FDP (2 hours before + 2 after or 4 hours after the extended
FDP) and the generally more robust rest requirements and limitations for cumulative duty.
4.2.4 Influence of Number of Sectors
There is consensus that multi-segment flights are a major contributor to fatigue. However,
there is still controversy on when fatigue countermeasures, such a reduction of maximum
FDP, should be implemented and what should be the magnitude of the reduction.
A number of studies have shown that fatigue increases with the number of sectors (Powell et
al., 2007; Spencer and Robertson, 2000; Bourgeois-Bougrine et al., 2003). Prolonged duty
periods (multi-segments flights over a sequence of 4 to 5 days) was cited as a major
contributor to fatigue by 53% of short-haul pilots completing a questionnaire assessing
perceived causes of fatigue (Bourgeois-Bougrine et al., 2003). In a study that evaluated
fatigue in two-pilot short-haul operations with no overnight duties, pilots were asked to
complete a questionnaire and validated fatigue and sleepiness scales at top of descent on
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the last sector of the duty. The most important factors affecting fatigue were length of duty
and number of sectors, which increased fatigue in a linear fashion (Powell et al., 2007).
Air taxi pilots for European business aviation operations report that they fly an average of 2.4
sectors (see Table 3.1). Interpolating from results from the Powell 2007 study, the pilots
would experience the equivalent of a fatigue score of 3.5-4 on the Samn-Perelli scale of
sleepiness at the top of the descent period (Powell et al., 2007) (see Figure 4.3).
Figure 4.3: Fatigue increases linearly with the number of flight sectors flown at the
top of descent in short-haul pilots. Reference: Powell et al., 2007.
Fatigue Score (7 point Samn-Perelli)
The need to decrease the FDP if there are a significant number of sectors is confirmed by
many scientific studies. The Subpart Q requirement on maximum allowable FDP is based on
a 30-minute reduction after the second sector.
However, the scientific literature does not give a uniform answer to the question of at which
sector number should the reduction begin. For example, while Spencer and Robertson
(2000) find no difference with respect to fatigue between one and two sectors, Powell (2008)
states that fatigue increases from the second sector.
There is no agreement on how large should be the reduction. While some studies have
recommended a reduction of 45 minutes per sector (Spencer and Robertson, 2002), other
studies recommend shorter reductions.
4.3 Time of Day Effects, Early Starts and Night Duty
4.3.1 Overnight Flights and Night Duty
There is extensive data on the increased risks associated with night duty shifts across
multiple industries. For example, the relative incident risk across different shifts increased in
an approximately linear fashion. Compared to the morning shift, the increased risk was
18.3% for the afternoon shift and 30.5% on the night shift (Folkard and Tucker, 2003).
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There is consensus that overnight flights and night duty are especially vulnerable to severe
fatigue, since flying time occurs during the WOCL, the circadian phase with lowest alertness
and performance. In addition, these effects are compounded by the sleep deprivation
associated with working during the night and sleeping during the day. The detrimental effects
of sleep deprivation, time since sleep, and the WOCL can lead to severe fatigue with
increasing time on task. Furthermore, fatigue during homebound flights is often exacerbated
in un-acclimatised crews, who had a sleep shorter and of poorer quality during layovers than
at home.
EUROCONTROL data (shown in Section 5) shows fewer night departures for business
aviation than other aviation sectors. However, flying during the night hours does occur for
air taxi and single pilot operations and so is considered below.
4.3.1.1 Increased Fatigue and Accident Risk During Night Duty
Field studies of single-sector two-crew operations have shown that some crews were having
difficulty remaining awake during overnight duties of 11 hours or more (Samel et al., 1997b;
Spencer & Robertson, 1999). A survey of long-haul pilots found that 59% of pilots reported
night flights as a major contributor to fatigue, especially schedules involving overnight
outbound and inbound flights with daytime layovers (Bourgeois-Bougrine et al., 2003).
Another study assessing pilots’ fatigue using a validated scale found that fatigue ratings
were greater on long-haul versus short-haul flights (except where mitigated by adding an
extra pilot) and on overnight versus daytime sectors on long-haul flights (Powell et al., 2011).
Based on a review of scientific studies, the Moebus Aviation report (Moebus, 2008) notes
that during night hours fatigue increases and vigilance decreases more markedly with
ongoing duty hours than during the day.
4.3.1.2 Night Operations and Pilot Error
The negative impact of night duties was clearly demonstrated in a study analysing the hours
of the day when pilots working in a commercial airline made the most errors (de Mello et al.,
2008). Errors were analysed using data from flight operation quality assurance systems,
including the following errors: operational deviations and/or errors, procedural errors and
maintenance faults and mistakes in procedures. The data showed that the risk of pilot errors
increased by almost 50% in the period from 0000 to 0559, relative to the morning period
0600-1159.
Night approaches were found to increase the risk of single-pilot instrument flight rule (IFR)
crashes in three separate studies (Forsyth, 1978; Mortimer, 1995; Bennett and Schwirke,
1992). Bennett and Schwirke found that the single-pilot IFR crash rate was 8 times higher
during the night than during the day under IFR conditions (35.4 vs. 4.5 crashes per 100,000
takeoffs).
Based on scientific data, some experts have suggested that FDP limits could be different for
daytime and night-time duties, with longer duty period during daytime than during overnight
duties, depending on the start time and the amount of sleep obtained and acclimatization to
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local time (Samel et al., 1997b, Spencer and Robertson, 2007). An early study (Dinges et
al., 1996) recommended that there be no extended flight duty period that encroached on any
portion of the WOCL. Spencer and Robertson (1999) strongly supported that non-
augmented duty overnight should not exceed 10 hours, and suggested that 12 hours is
acceptable for 2-crew operations during daytime. A 13 hour FDP was also identified in this
reference as feasible if it occurred at a favourable circadian time. In an attachment to CRD
2010-14 (Spencer, 2011) Spencer states that a one-hour extension from 13 to 14 hours for
morning departures after 08:00 would be supported by fatigue data collected during The Haj
operation.
4.3.1.3 Factors Contributing to Increased Fatigue During Night Duties
Longer periods of wakefulness before duty: One of the factors contributing to increased
fatigue in overnight flights is an increased period of wakefulness before duty, especially if
crews are not able to take an afternoon nap, or if they are on standby and are called out to
fly, as is often the case with air taxi pilots. A study of a simulated ULR flight found that pilots
who had been awake for 13.5 hours before departing for nighttime flights had significantly
slower reaction times compared to pilots who departed during the morning hours after about
3.5 hours of wakefulness. Pilots in the overnight flights were especially impaired during the
first half of the flight, due both to sleep and circadian factors that promote sleep. However,
towards the end of the flight, with increased hours of continued wakefulness, performance
decrements were seen in both morning and night departure groups (Caldwell et al., 2006).
Consecutive night duties: The risk associated with overnight flights may increase with
recurrent night duties because studies show that shift workers seldom obtain the same
amount of sleep during the day they would normally obtain when sleeping at night (Folkard
et al., 2005). Consecutive night duties are rare for air taxi pilots, with the exception of cargo
pilots.
Duration of duty period and number of segments: A study evaluating fatigue in two-pilot
operations flying 1-2 sectors duties that ranged from 3 to 12 hours total duty time asked
pilots to complete a questionnaire and validated fatigue and sleepiness scales at top of
descent on the last sector of the duty. The strongest influence on fatigue was time of day,
with the highest levels during the WOCL (0200-0600). Fatigue also increased with length of
duty and number of sectors. Moreover, the study found that time of day also affected level of
fatigue at start of duty and the rate at which fatigue levels increased. For example, fatigue
level after 12 hours for duties starting between 0600 and 1200 was already exceeded after 3
hour on duty for duties starting between 0000 and 0300 (Powell et al., 2008).
Thus the scientific literature strongly supports the need for reducing the maximum FDP for
WOCL encroachment. This supports the approach taken in Subpart Q and in the CRD
2010-14.
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4.3.2 Early Start Flights
Time of day effects due to early start flights present a challenge, since they usually result in
shorter sleep before the flight, mainly due to the fact that pilots do not advance bedtime to
compensate for the early wake up time. There is agreement that early starts are associated
with sleep deficit and increased fatigue, especially in the case of consecutive early starts.
Early starts are common for air taxi pilots. The most common report for duty time for
European business aviation pilots is the window between 0600-0959 (80% of respondents),
and 40% of pilots report arriving for duty between 0200 and 0559 at least once a month
(Alertness Solutions, 2011; Figure 4.4).
Figure 4.4: Duty report times for European business aviation pilots during the last
month. Reference: Alertness Solutions, 2011.
With shift start times before 0600, achieving the required seven to eight hours of sleep can
be difficult for most people, and these shifts have great potential to contribute to pilots’ sleep
deprivation (Kecklund & Akerstedt, 1995). This results in increased fatigue and consequently
increases the risk of errors and accidents during the morning shift. One reason for reduced
sleep before an early morning shift is that, irrespective of what time the shift starts, many
people go to bed at their usual bedtime (Moores, 1990). However, the main reason is that it
is difficult to fall asleep in the early evening. Lavie (1986) described a “sleep forbidden zone,”
during the evening, related to the circadian rhythm of alertness, which makes it very difficult
to fall asleep at that time.
The effect of early start times on sleep and alertness in short-haul pilots has been confirmed
by several studies. For example, a survey found that for short-haul pilots, successive early
wake-ups was cited as a major contributor to fatigue by 41% of pilots (Bourgeois-Bougrine et
al., 2003). Spencer and Montgomery (1997) found that time of day was the most important
factor affecting sleep duration (see Figure 4.5) and quality. The mean duration of sleep
episodes starting between 2100 and 0100 was greater than 7 hours. As start of sleep was
progressively delayed, its duration decreased to 2.5 hours with starts between 1700 and
1800. When a duty period started before 0900 the duration of the preceding sleep period
was reduced. The sleep loss amounted to approximately 30 minutes for every hour that the
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duty period advanced between 0900 and 0500. Subjective sleep quality was also reduced
for duty periods starting before 0700. During schedules involving consecutive early starts,
the sleep deficit accumulated and alertness tended to deteriorate (Spencer and
Montgomery, 1997).
Figure 4.5: Relationship between sleep duration and sleep start time. Reference:
Spencer and Montgomery, 1997
Another study conducted on 476 British Midland Pilots based at London Heathrow and East
Midlands airport showed that the duration of sleep prior to an early start was reduced by
almost one hour for report times between 0700 and almost two hours for report times
between 0500 and 0600. The subsequent sleep deficit had a clear effect on fatigue. Duties
starting before 0900 were associated with increased fatigue throughout the following duty
period, and that fatigue also increased during schedules that included several consecutive
duties starting at 08:00 or earlier (Spencer and Robertson, 2002). A recent study on 70
short-haul pilots from Australian researchers found that the lowest amount of sleep was
obtained prior to duty periods starting between 0400 and 0500 (5.4 hours), and the greatest
for duty periods starting between 0900 and 1000 (6.6 hours). The data indicate that
approximately 15 minutes of sleep are lost for every hour that the start of duty is advanced
prior to 0900. Moreover, self-rated fatigue at the start of duty was highest for duty periods
starting between 0400 and 0500 and lowest for duty periods starting between 0900 and
1000 (Roach et al., 2012).
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4.3.3 Day-Night Duty Transitions
Another important factor is the number of day-night transitions, that is, from sleeping at night
and being active during daytime to sleeping during the day and being active at night.
The underlying issue is that physiological rhythms do not shift immediately when
transitioning from day to night shift and vice versa. Research studies have shown that
circadian rhythms can shift approximately one hour per day when working night shifts, but
coming back to the daytime routine the adjustment is faster, about two hours per day. During
the transition, there is a misalignment of the circadian rhythms, which translate into malaise
and increased fatigue. Earlier studies found that the change from night to day shift may
cause as much discomfort as a change in the other direction (Akerstedt et al 1977). Recent
studies have confirmed these results. For example, a study conducted on off-shore oil rigs
evaluated adaptation and re-adaptation to night shifts and day shifts, and found that the
return to day shift led to an increase in sleepiness and worsening of sleep, but they improved
gradually during the week (Bjorvant et al. 2006).
Several research studies have studied the transition from day to night shift without rest days
in between and found that in these circumstances, the first night shift is the most difficult shift
in a sequence of consecutive shift. The studies showed that the impairment in the ability to
sustain focus, decrease in subjective alertness and decrease in visual search sensitivity
were more pronounced during the first night shift than in subsequent shifts (Santhi et al
2007). Thus, increasing the number of transitions may result in increased frequency of
problems.
4.3.4 Time Zone Crossings and Circadian Desynchronization
An additional source of fatigue for air taxi pilots, particularly those who fly long-haul routes is
circadian desynchronization caused by rapid travel between multiple time zones, or “jetlag”.
Long-haul pilots cite flying night duties (59%) and jetlag (45%) as the two major contributors
to fatigue (Bourgeois-Bougrine, 2003). For these pilots, a single return flight can be as tiring
as a series of consecutive short-haul flight duties. The Moebus Report (2008) considers a
significant time zone crossing as one that covers more than 2 time zones within a single
FDP. European business pilots report that most flights cross 0-3 time zones, with about 1
flight per month crossing 4-6 time zones (Table 3.1).
4.3.4.1 Eastbound vs. Westbound Flights
The general consensus is that Eastbound flights are more fatiguing for pilots than
Westbound flights. This reflects the natural state of the circadian clock, which runs slightly
longer than 24hrs. Flying East shortens the day by several hours, whereas flying West
lengthens it, making it easier to fall asleep later than earlier for most people.
51% of European business aviation pilots report that fatigue is more of an issue on
Eastbound flights, compared to Westbound (8%) (Alertness Solutions, 2011).
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Another survey of long-haul pilots flying 3 day round trips between the UK and the East
Coast of the United States found similar results – pilots found it difficult to fly East with a
short layover, citing that early departures truncated sleep and made the inbound flight more
fatiguing (Spencer and Montgomery, 1995). Similarly, pilots flying from Australia to Los
Angeles and back found eastbound flights more fatiguing. A short layover (<40h) with
truncated sleep was unable to dissipate the effects of fatigue from the eastbound flight. As a
result, pilots slept more on the return flight, and performance on a vigilance task was
impaired (Lamond, 2006).
4.3.4.2 Recovery from Circadian Desynchronization
Pilots who cross multiple time zones in a single trip can take several days to recover after
returning. Some pilots find that while more fatiguing, trips with 5 or more time zone
transitions with shorter layovers only take approximately 3 days to recover from, since the
pilots’ circadian clock does not have a chance to adjust from local time to the new time zone
(Spencer and Montgomery, 1995). For example, charter flights from the UK to either the
Caribbean or the East coast of the United States that encompassed fewer than 3 layover
nights took pilots 3 days to return to baseline levels of alertness (Spencer and Montgomery,
1997).
Longer trips, such as the 5-7 day “Polar Route” between London and Tokyo, with a 24hr
layover in Anchorage Alaska, can dramatically alter the circadian clock. In one study, pilots
were pre-positioned in Tokyo for 1-3 days, but were unable to sleep well – only 28% of all
sleep periods were between 6-9hr long. After flying the polar route and returning to London,
measurements of the circadian body temperature rhythm showed that circadian phase was
altered in many of the pilots. In some pilots, it took five days for the circadian clock to realign
with local time (Stone, 1993; Spencer, 1991). Many similar experiments have been done to
assess the length of recovery after long international trips. For instance, one group of pilots
based in London were pre-positioned in Hong Kong (7hr time zone transition) for 9 days
before returning to London. Circadian temperature rhythms revealed that some pilots took 7
days for their clock to realign with London local time (Rogers, 1996). A similar experiment
with a 10hr time zone transition (London to Sydney Australia) found that pilots’ body clocks
were not in synch with local time (Figure 4.6) and took between 3-8 days to recover. In this
experiment they also showed that after returning to London, sleep duration and quality was
reduced and performance was reduced for up to 6 days after the return flight to London
(Spencer 1995).
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Figure 4.6: Difference between circadian phase of body temperature rhythm and local
time, and time of recovery after a 10hr Eastward transition. Reference: Spencer et al,
1995
The Moebus Report (2008) includes specific recommendations for rest periods following
trips with significant time zone crossings (>2 within an FDP). It recommends that the
minimum rest period during a layover should be 14hrs. If the return flight overlaps the
WOCL, pilots should receive two nights free of duty. The range of time off should also vary
depending on how long the layover is. The report recommends that pilots should receive rest
with 1 local night if the layover is <36hrs, and the number of time zone transitions is 5 or
less. The amount of rest increases with increasing layover length and time zone transitions
to a maximum of rest with 6 local nights to allow adjustment/recovery after a layover of
>132hrs and an 8-12hr time zone difference.
4.4 Cumulative Effects of Multiple Consecutive Duties
4.4.1 Overview
There is contradictory data on the effects of consecutive duty shifts on fatigue and
performance. The results of the studies are not conclusive: while some studies found
increased accident risk over consecutive nights, other studies found lower risk and improved
performance over the first few days, and some did not find any significant changes across
consecutive nights. There are multiple factors that explain the divergent results including the
amount of sleep individuals obtain between shifts, the time on task (length of shift), and the
time of day of the shift.
With some exceptions (e.g. pilots during a busy spring/summer tourist season) air taxi pilots
are less likely to work multiple consecutive FDPs than commercial airline pilots. However,
the effects of consecutive FDPs on fatigue will be discussed here, since the fatigue risks can
become significant under some circumstances.
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4.4.2 Review of Cumulative Fatigue Across All Industries
The effects of consecutive day and night shifts on fatigue involve different sets of factors and
are therefore considered separately.
Day shifts: An early study (DERACHS, 1999) showed a gradual increase in subjective
fatigue that occurs over seven consecutive work days. The increase in fatigue was much
more pronounced with an early starting time (6 am) than with a late start (9am) (75%
increase compared to 40% increase). Workers reported that they needed 1 day off to
recover from working 3 consecutive shifts with an early start, and 2 days off to recover from
5 consecutive early shifts. However, other studies suggested that risk is not substantially
greater with up to seven consecutive 12-h day shifts (Persson et al. 2003, 2006a&b). The
results from these studies suggest that for day shift, an early shift start has more impact on
fatigue than time on duty. In addition, early starts, which are likely to be associated with
greater sleep deprivation, require longer rest periods (days off between blocks of shifts) to
recover from the cumulative fatigue.
Night shift: A more significant concern relates to the number of consecutive night shifts,
since they are usually associated with higher levels of fatigue than day shifts (Akerstedt,
1995). Working too many consecutive night shifts can cause an accumulation of sleep
deficit, which can cause both health and safety issues (Knauth, 1997). This accumulation of
sleep debt over consecutive periods of shortened day time sleep is counterbalanced by the
adaptation of the sleep/wake cycle after working several consecutive night shifts. The
adjustment of the circadian physiological rhythms to night work among individuals working
consecutive night shifts is seldom complete, and permanent night shift systems are unlikely
to result in sufficient adjustment in most individuals to benefit health and safety (Folkard,
2008).
This counterbalance between accumulated sleep debt and partial circadian adaptation either
results in an increased risk over successive night shifts if sleep is not well managed, or
decreases risk if good sleep management practices are followed. As a result the literature
contains data which reaches apparently contradictory sets of conclusions. To avoid the
cumulative effects of sleep deprivation the best practice is to train the employees on optimal
sleeping strategies and provide opportunities for sleep (appropriate time and facilities for
sleep). In this way the accumulated effects on performance can be minimised.
1. Studies showing increased risk over successive nights. A series of studies have
found increased risk over consecutive night shifts. A review of seven studies (mainly of 8-h
shifts) found an increased risk from the first to the fourth night. One study found a continuous
deterioration of performance during five consecutive night shifts (Tilley et al., 1982). Another
study showed that overall, there was a gradual increase in fatigue over 5-6 nights
(DERACHS, 1999). A review of shiftwork studies analysing the relative incident risk over
successive shifts found that, compared to the first night shift, on average, risk was 6% higher
on the second night, 17% higher on the 3rd night and 36% higher on the 4th night. Studies
evaluating the risk on day/morning shift also found an increased risk over consecutive shifts,
but the increase was substantially smaller than over night shifts (Folkard and Tucker, 2003).
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A meta-analysis of several studies of operations without an FRMS indicated that accident
and injury risk can increase over consecutive night shifts (Folkard & Lombardi, 2006).
2. Studies showing decreased risk over successive nights. However, under optimal
sleep conditions, the sleep debt that accumulates during consecutive night shifts is relatively
small and does not exacerbate decrements in night-time performance resulting from other
time-of-day factors. Based on laboratory studies, as well as field studies, it has been
reported that for employees with diurnal patterns (active during daytime, sleeping at night),
the first night shift after days off is the most difficult (Santhi et al., 2007; Lamond et al., 2004;
Baker, 1995), and that alertness and performance is increased on subsequent nights. One
study, evaluating four consecutive 11-h shifts, found three different patterns of fatigue on
consecutive night shifts, reflecting the loads of the reticular activating system,
musculoskeletal, and central nervous system respectively. While the musculoskeletal fatigue
increased over consecutive night shifts, the other two patterns showed significant
improvement over consecutive night shifts (Kubo et al., 2008). When sleep loss is
minimised, employees’ performance adapts as their circadian rhythms adapt (Lamond et al.,
2003). One study found that performance in the night shift increased from the first to the third
night shift, probably reflecting an adjustment of circadian rhythms. However, there was a
decrease of productivity toward the 5th shift, which is most likely due to an accumulation of
sleep deficit. A different study found an increase on production quality from the first to the 5th
night shift, while another found an increase in human error from the first to the 6th night shift,
and a lower error rate on the 7th shift (Knauth, 1995). Other studies (Vinogradova et al.
1975, Wagner 1988) analysing longer spans of consecutive night shifts reported a decrease
in risk from the 4th to the 5th night, which was maintained until the 7th and final night shift.
4.4.3 Review of Aviation Literature on Cumulative Fatigue
The same opposing conclusions on the effects of cumulative fatigue have been shown in
aviation studies.
For instance, in contrast to an earlier study that did not find a cumulative fatigue effect of
early starts, Spencer and Robertson (2002) found an increase in cumulative fatigue over
consecutive early starts (prior to 0900). Intriguingly, less cumulative fatigue was seen after a
consecutive run of very early starts (prior to 0600). Also, while Spencer and Robertson
(2002) found an increase in fatigue over consecutive duty days – equivalent to an extra 40
minutes of duty per day, an earlier study found no evidence of cumulative fatigue in charter
pilots after 4 consecutive days of working a daytime schedule (Spencer and Montgomery,
1997).
After a sequence of night duties in cargo pilots, Spencer and Montgomery (1997) found that
sleep quality and alertness decreased, suggesting cumulative fatigue, but overall sleep
quantity increased. One of the few studies so far carried out of cargo operations where
aircrew is experienced at routinely operating at night found that fatigue levels on the first
night were higher than on nights two, three and four (Spencer MB et al 2004). This was in
contrast to the results of a study on passenger charter flights, which showed a slight
increase in fatigue over three consecutive nights (Spencer MB & Robertson KA, 2000).
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Despite the sometimes conflicting results of studies on cumulative fatigue in aviation, the
Moebus Aviation report (Moebus, 2008) takes the view that the development of cumulative
fatigue tends to increase during consecutive periods of duty, especially for long duties or
when early starts, late finishes or overnight duties are involved that disrupt the normal
pattern of sleep. It suggests that it is sensible therefore to limit the number of duties and/or
reduce the maximum FDP of these duties when they run consecutively, especially where
they are close to maximum FDP limits. Following a sequence of consecutive duties,
mitigating strategies could involve scheduling a rest day including one local night. The author
proposed additional limits to those in Subpart Q, i.e. a duty hours limit over 14 consecutive
days and a block hours limit per 12 consecutive months. Limits on these (slightly modified
from those proposed in the Moebus Aviation report) are included in CRD 2010-14 although,
as noted in NPA 2010-14 (EASA, 2010) there is a lack of scientific evidence and the limits
are rather based on judgements of what appears “reasonable”.
4.5 Sleep and Rest
4.5.1 Rest Between Consecutive Duty Periods in the General Working Population
Research studies have found a high correlation between the duration of the rest period and
the amount of sleep obtained during it. This is important because one of the key factors to
mitigate fatigue is to obtain adequate sleep during time off.
Scientific data demonstrated that shortened sleep every day (less than 7-8 hours) for one or
two weeks (Belenky et al., 2003; van Dongen et al., 2003) produced significant cognitive
decrements. Limiting sleep to six hours or less over successive nights resulted in a
cumulative dose-dependent deficit in performance. Individuals who obtained less than four
hours of sleep per night showed increased lapses in performance and reduced speed and
accuracy when completing performance tasks, while those who obtained seven or more
hours of sleep were able to maintain adequate levels of performance over 14 consecutive
days. Other studies have documented the negative impact on health, mood, and safety of
chronic sleep deprivation (Oginska & Pokorski, 2006; Leproult et al., 2003; Garbarino et al.,
2002).
A single day with a shortened sleep in a person who otherwise has been obtaining adequate
sleep can be tolerated without excessive fatigue risk. However, the number of days when
these short sleep episodes occur must be strictly limited because shortened sleep episodes
over consecutive days results in chronic sleep deprivation. Four hours of sleep has been
suggested as the minimum amount of sleep required to sustain adequate performance levels
during a single day (Belenky et al., 2003), although performance levels are lower than in
people able to sleep for eight hours. Insufficient sleep, poor sleep quality and long work
hours have been found to be both independently and synergistically associated with
workplace injury risk (Nakata, 2011). An epidemiological study (Lombardi et al., 2010)
showed the impact on health and safety of the combination of chronic sleep deficit and
extended working hours. Using 7-8 hours of sleep as reference, the adjusted injury risk
increased gradually with shorter sleep duration (from an odds ratio of 1.4 for 6-7 hours of
sleep to an odds ratio of 2.7 for less than 5 hours of sleep).
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The rest period between shifts should provide enough time for obtaining adequate sleep. A
series of studies have shown that rest periods of 10 hours or less between consecutive shifts
result in short sleep episodes, sometimes only 3-5 hours of sleep. It should be taken into
account the time of day of the rest period, since breaks between work periods that occur
during daytime result in less sleep than breaks at night (Kurumatani et al., 1994; Wylie et al.,
1997).
Roach et al (2003) evaluated the effects of duration (12, 16 and 24 hours) and timing of rest
periods between consecutive shifts, as well as the interaction between these two factors.
The study participants (locomotive engineers) worked irregular rosters, with work episodes
having an average duration of 8.4 hours. 44% of work periods started between 04:00 and
12:00, 34% between 12:00 and 20:00, and 22% between 20:00 and 04:00. Overall, the
results showed that total sleep increased with longer rest periods. For 12-h and 16-h rest
periods more sleep was obtained during rest periods that occurred during nighttime. For 24-
h rest periods, longer sleep was obtained for rest periods starting 04:00-06:00 and 10:00-
12:00. This is because individuals who finished a shift in the morning and started another
shift the following morning (that is, that changed from night to day shift) often were able to fit
two sleep episodes in the 24-h rest period (one after the work shift and another before the
day shift).
4.5.2 Rest between Consecutive Duty Periods in Pilots
One means of mitigating the effects of a long (extended) FDP post-event is to provide a
longer rest afterwards. Clearly this does not help during the extended FDP, but it can
mitigate subsequent effects. An early study (Dinges et al., 1996) recommends that the
required off-duty period should be extended by the same duration of the flight duty period
extension.
There may be occasions when air taxi and single pilot crew require reduced rest. However,
the Moebus Aviation report (Moebus, 2008) notes that any reduced rest arrangement is
likely to result in increased fatigue levels.
The report (2008) recommends that reduced rest is only allowed as part of a comprehensive
FRMS, and that the FRMS would need to take account of a wide range of factors including
both the time spent travelling and the influence of the body clock on sleep duration. In
addition, it recommends that any reduced rest that is less than 12 hours long should include
the entire WOCL period, and that consideration should be given to ensuring that the
subsequent flight duty is not too onerous and to specifying an absolute minimum reduced
rest period, even in presence of an FRMS.
4.5.3 Split Duty
Split duty is commonly used in air taxi operations (see Table 3.1), which could enable pilots
to take on-ground naps when they are not performing additional ground duties (including
Aeronautical Information updating, baggage handling, and administrative and documentation
duties).
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No research specifically examining fatigue and risk in pilots working a split duty was
identified during the literature search, however as discussed in section 4.2.3, any
circumstance that increases FDP length may result in increased fatigue. Long duty days
caused by split duty periods are more likely to encroach on the WOCL, extend into the late
evening, or reduce the rest period between consecutive duty periods.
The Moebus Report (2008) recommends that under these conditions:
a) the ground break should be no less than 1/3 the length of the FDP
b) sleeping facilities should be provided during the break
c) the split duty period should start after 06:00 and end before 22:00
d) a minimum 10hr rest period is required between consecutive split duties
e) consecutive split duties with less than 10hr rest periods between should only be
attempted in crew who have received comprehensive fatigue risk training.
4.5.4 Rest During Layover
Little information is available on sleep quality during layover, whether the pilot sleeps in a
hotel, “crash pad”, or crew lounge. European business aviation pilots report that overall, they
receive 20 minutes less sleep in hotels than at home. While most report their sleep as being
“good” quality, 26% of pilots receive less than 6 hours of sleep (only 13% get this little sleep
at home), and 22% report their sleep during layovers as being “poor” or “very poor”, double
the number of pilots who report poor/very poor sleep at home (Alertness Solutions, 2011).
4.6 Standby
4.6.1 Standby at Base/Airport
There are differing approaches to how airport standby should be treated with respect to FDP
and duty time contributions. Moebus (2008) notes that there is no scientific evidence to
suggest that airport standby should be considered as any less fatiguing than flight duty and
that further research is needed in this area. It concludes that time spent in airport standby
should normally count 100% as flight duty when calculating the maximum FDP. It further
recommends that standby count as 50% FDP if adequate rest facilities are provided, and an
FRMS is in place. However, detailed scientific justifications are not provided in this report on
this issue and there is a general lack of scientific evidence about the impact of different
airport standby facilities.
The Principles and guidelines for duty and rest scheduling in Commercial Aviation ‘NASA
Study’ (Dinges et al., 1996) recommends that airport standby should be considered as duty
but does not provide a rationale for this.
This uncertainty is reflected in the range of European States’ national provisions covering
standby in Appendix 3.
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4.6.2 Standby at Home and Elsewhere
The nature of air taxi operations is that flights are available on an as needed, unscheduled
basis. This leads to a significant amount of standby for air taxi pilots (see Table 3.1). Long
periods of standby time can make it difficult for pilots to plan their sleep/rest appropriately. A
24 hour call window especially can make it challenging to decide when to sleep – does the
pilot stay up the night before and try to sleep during the day to prepare for an unlikely, but
possible night flight call? In the event of a day flight, the pilot would have truncated sleep. Or
does the pilot sleep at night and stay awake all day, which would benefit a day flight call, but
increase the probability that the pilot will be fatigued if called in for a night time flight?
Crew Factors in Flight Operations XI: A Survey of Fatigue Factors in Regional Airlines
Operations (Co, E., 1999) notes that the nature of flying on reserve means that
crewmembers must respond when called for duty, thus creating unpredictability in their
schedules. This unpredictability can lead to sleep loss. As evidence that sleep loss occurred,
crewmembers reported getting 5.6 h of sleep before duty on average - 2.3 h less than their
normal average sleep.
The majority of research into sleep and on-call issues has focused on the decrease in sleep
quantity and quality while on-call compared to non-call nights (e.g. in a hospital environment)
(Nicol and Botterill, 2004). One study investigated sleep quality in anticipation of being
woken in on-call ships’ engineers, which is more relevant to pilots on standby. This study
found that the anticipation of being called out for an emergency was enough on its own to
reduce sleep quantity and quality, increase heart rate, and increase sleepiness the following
day (Torsvall and Akerstedt, 1988).
The Principles and guidelines for duty and rest scheduling in Commercial Aviation ‘NASA
Study’ (Dinges et al., 1996) does not consider ‘on call reserve status’ as duty, but
recommends that ‘a …. 8 hour sleep opportunity’ should be protected from interruption by
assignment to a flight duty period. The Moebus Report (2008) acknowledges that not
enough is known about sleep while on standby to make a specific recommendation for how
to account for standby time in FDP limits and minimum rest period.
4.7 In-flight Rest and Flightdeck Napping
This section evaluates separately in-flight rest and controlled napping in the cockpit.
4.7.1 In-flight Rest
Some air taxi operations have aircraft capable of flying long, international flights. Augmented
crews allow pilots to use in-flight rest and obtain sleep in order to maintain alertness and
reduce fatigue. Numerous studies have shown that both objective physiological measures
and subjective ratings of alertness demonstrate improvement following an in-flight rest taken
during periods of sustained wakefulness, and that in-flight rest can also reduce or delay
expected performance decrements.
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A number of other studies have evaluated frequency and duration of in-flight sleep, and the
effectiveness of napping as a fatigue countermeasure. For example, a study of in-flight
napping during trans-Atlantic flights compared two and three-pilot crews. It found that sleep
duration was longer in augmented crews: 38 minutes in outbound flights, and 1 h 06 minutes
in homebound flights, compared to 26 min and 54 minutes respectively in non-augmented
crews. The difference in sleep amount was directly related to the time allowed for the pilots
to obtain in-flight rest. Shorter in-flight sleep was associated with lower performance at top-
of-descent for 2-pilot crews (Eriksen et al., 2006).
There is some debate on the quality of sleep obtained while on duty. Based on scientific
research, “sleep quality” ratings have been assigned to sleep in different facilities.
Depending on the aircraft, sleeping facilities could include
a) Class I: sleeping bunk/ fully reclining (lay-flat) first class seat
Sleeping in a bunk is thought to lead to the best sleep quality. Bunks are separate from the
main cabin and flight deck and include light, sound, and climate controls. Roach and
colleagues estimated that in-flight sleep in bunks provides pilots with 70% as much recovery
as duration-matched bed sleep (Roach et al., 2010). In a subsequent study, they evaluated
frequency of in-flight sleep. Their data showed that pilots obtained 1.8 hours of sleep (27%
of rest time) during duty periods with low fatigue likelihood and 3.7 hours of sleep (54% of
rest time) during duty periods with extreme fatigue likelihood. The results indicated that pilots
obtain more sleep during periods when fatigue is likely to be high (Roach et al., 2011). Other
studies support the finding that sleep efficiency will be best during a time that the pilot is
normally asleep (Simons et al., 1994; Valk and Simons, 1998; Pascoe et al. 1994). In well-
equipped aircraft, sleep of six hours or longer is possible under the right conditions (Signal et
al., 2003). A study of pilots flying Haj pilgrims to and from Indonesia and Saudi Arabia found
that 82% of pilots were able to sleep in a bunk. They obtained 1.2hrs of sleep with a sleep
quality of 4.52 (out of 7) (Spencer and Robertson, 2000).
There seems to be some controversy in how much of the time spent in the bunk is actually
sleep. For example, while the TNO report “Extension of flying duty period by in-flight relief”
(Simon, 2007) considers that 75% of the time spent in a bunk may be counted as actual
sleep, an FAA report (AC No: 120-100 Basics of Aviation Fatigue AFS-200, 2010) states that
flight crews who had a 7 hour sleep opportunity obtained, on average, only 3 hours 25
minutes of bunk sleep.
A fully reclining business class seat is expected to provide as much sleep quality as a bunk.
This is provided that the seat is separate from other business class travellers and can be
fully darkened (Simon, 2007).
b) Class II: a normal, semi-reclining business class seat
A normal business class seat that does not fully recline is expected to provide 75% of the
sleep quality possible in a bunk or lay-flat first class seat (Simon, 2007). In one study, sleep
was reduced 25% in a business class seat compared with sleep in a bunk (Spencer et al.,
2004). In a business class seat the pilot will be subject to noise and lights (unless they wear
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eye shades and earplugs). Pilots may only choose this option if they are completely
separated from other passengers by a curtain.
c) Class III: flight deck seat (40 degree angle)
Sleep in a flight deck seat is expected to provide 66% of the sleep quality possible in a bunk
(Simon, 2007). Seats in the back of the flight deck are separated from passengers and may
be quieter than business class seats in some circumstances. A study comparing sleep
quality in a horizontal bed, a “sleeperette” reclined to 49.5 degrees, a chair reclined to 37
degrees, and a chair that reclined to 17.5 degrees found that sleep could be obtained only in
chairs reclined to about 40 degrees (Nicholson and Stone, 1987). A study of pilots flying
pilgrims to the Haj found that 65% of pilots were able to sleep in a flight deck seat. They
obtained almost an hour of sleep, with a sleep quality of 5.41 (out of 7) (Spencer and
Robertson, 2000).
d) Class IV: economy class seat
Economy seats are the least recommended for good quality sleep. The TNO report (Simon,
2007) proposes to give no credit to rest in an economy seat, although no data are available
concerning onboard sleep in a normal economy class seat. However, based on laboratory
data and ergonomic considerations, sleep in an economy seat is considered to be degraded
to 0% of bunk because these seats do not recline to 40 degrees, have poor foot/leg room,
and are closely spaced to other passengers.
The TNO report “Extension of Flying Duty Period by In-Flight Relief” (Simon, 2007)
recommends allowing an extension of the FDP based on the duration of the rest period
available to the pilot and on the environment that is available for rest. The recommendations
assume the pilot is acclimatized to the local time zone (they suggest 3 days acclimatization
period). These conclusions are reflected by the Moebus Aviation report (2008).
a) Class I: Increase FDP length by 75% of the rest period (50% if not acclimatized)
b) Class II: Increase FDP length by 56% of the rest period (40% if not acclimatized)
c) Class III: Increase FDP length by 25% of the rest period (20% if not acclimatized)
d) Class IV: No extension of FDP
The TNO report (Simon, 2007) also recommends that if augmentation is only by one
additional pilot, the maximum FDP should be 16 hours.
4.7.2 Napping
Brief structured nap breaks during extended-hour work duties have been shown to be an
effective operational strategy. Timing and duration of naps can be designed for optimal
impact on alleviating fatigue. As with in-flight rest, napping will be most efficient when sleep
occurs during the WOCL. An important consideration in terms of scheduling is the duration
of the beneficial effects obtained. Studies suggest that a nap can maintain or improve
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subsequent performance and physiological alertness from 2 to 12 hours following the nap.
Experiments have examined naps of varying lengths, and there seems to be a dose-
dependent effect: more sleep is associated with greater beneficial effects.
However, some studies suggest that shorter naps can be just as or more effective than
longer ones; recommendations range from 20- to 60-minute duration. Shorter naps (10-20
minutes) are also less likely to be associated with the phenomenon of sleep inertia (a short
period of impaired alertness upon awakening). This is because in this amount of time, the
individual will usually remain in light sleep and would not reach deep sleep. It is easier to
wake up from light sleep and the individual will regain full alertness faster than waking up
from deep sleep. In the case of long naps, sleep periods of approximately 90 minutes allow
the completion of a full sleep cycle, and the individual wakes up from light sleep or REM
sleep, which minimizes sleep inertia. On the other hand, naps of 40-60 minutes would result
in the individual waking up from deep sleep, and that will result in more severe and long
lasting sleep inertia. Sleep inertia can be associated with a performance decrement lasting
for a few minutes to 35 minutes, though effects usually seem to dissipate in about 10 to 15
minutes (Robertson and Stone, 2002, Rosekind et al 1994).
A series of studies have proved the effectiveness of napping as a fatigue countermeasure in
the aviation industry, and ICAO has stated that controlled napping is a valuable mitigation
strategy that can temporarily relieve the symptoms of sleep loss (ICAO, 2011).
A joint study by the National Air and Space Administration (NASA) and the Federal Aviation
Administration (FAA) examined the effect of controlled napping during long-haul flights. Two
crews flying the same sequence of four scheduled flights were compared. One group was
allowed a 40-minute nap opportunity (one crew member at a time), whereas the other group
followed their normal activities. Pilots slept on 93% of the opportunities, falling asleep in 5.6
minutes on average and sleeping for 25.8 minutes on average. Crew assigned to the nap
group showed better performance and higher physiological alertness on objective measures
during the last 90 minutes of the flight (critical descent and landing phases of the flight) than
did the control group (Rosekind et al, 1994).
The FAA authorises in-flight rest for flight crews if there is an augmented crew, so that two
pilots are on the flight deck when the augmented crew is resting. The FAA does not
authorise naps in the cockpit, however, other carriers and authorities do.
4.8 Periodic Extended Rest
4.8.1 Rest After Multiple Consecutive Duty Shifts in the General Working Population
How much rest an individual needs between blocks of working days is related to the number,
timing, and length of consecutive shifts he or she has worked. Allowing more time off after
extended blocks of night shifts is important because night shifts are more fatiguing, and
sleep debt more prevalent, than with day shifts. There is agreement that a 24-h period
including one single night is usually not enough to fully recover from a series of consecutive
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work days, and that the number of consecutive days off should increase with consecutive
work days.
Several studies have found that two full nights of sleep are usually enough to recover from
sleep deprivation and return to baseline levels of sleep structure and waking performance
and alertness (Carskadon & Dement, 1979). Shiftwork researchers have shown that at least
two sleep episodes are needed to recover after a series of shifts and that at least 3 days,
including 3 overnight sleep episodes, are necessary to recover from 7 consecutive night
shifts (Knauth, 1997). Another study (Totterdell et al., 1995) showed that alertness and
performance were more impaired on the first three days back at work following a single rest
day, as compared to two or three rest days.
It is thus usually recommended that time off between blocks of work days should allow two
days with nocturnal sleep (Health and Safety Executive, 2006; Knauth, 1997). This is due to
the fact that night-time sleep occurs at the time when circadian rhythms are conducive to
sleep, and thus sleep episodes are longer and more restorative. An off-duty period of 36
hours after daytime shifts and 48 hours after night shifts are required to allow shiftworkers to
obtain these two nocturnal sleep episodes.
Folkard (2000) recommends that staff be able to have sufficient sleep to fully recover after
working two or three consecutive night shifts. This requires two full nights’ sleep after the
consecutive night shifts, without an early start after the second night. In order to ensure this
is achieved (and commuting time does not leave too short a period for rest), it is considered
optimum that 54 hours or more should elapse between the end of the consecutive night
shifts and the next shift.
4.8.2 Rest after Multiple Consecutive Duties in Aviation
Few studies have specifically investigated how much rest should be allowed after
consecutive FDPs in aviation.
One study examined sleep and alertness in a charter flight crew after a return flight from the
UK to the East coast of the United States. The layover period between legs lasted from 12
hours to three local nights. After returning to the UK, alertness levels took three recovery
nights to return to normal (Spencer and Montgomery, 1997). This study suggests that duty
periods involving time zone desynchronization may require more recovery time than multiple
consecutive duties within the same time zone (already addressed in section 4.3.4).
Despite a lack of specific research on rest periods in aviation, recommendations exist for
rest after consecutive duties. One potential mitigation strategy is additional rest after
consecutive night duties (Spencer, 1997). The Principles and guidelines for duty and rest
scheduling in Commercial Aviation ‘NASA Study’ (Dinges et al., 1996) recommends that if
two or more flight duty periods within a 7-day period encroach on all or any portion of the
WOCL, then the standard off-duty period (36 continuous hours within 7 days) be extended to
48 hours recovery.
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4.9 Travelling and Positioning
4.9.1 Overview
Travelling and positioning are two factors that may influence pilot fatigue. Travelling involves
commuting (by car, train, bus, or airplane) from the pilot’s domicile to their home base
airport. This is considered to be non-duty time. The average travel length for European
business aviation pilots is 1.5hr – suggesting a range of much higher travel times (Table
3.1). Positioning involves transporting the pilot from their home base (usually by air as a
passenger) to an airport further away for duty. Time spent flying while positioning is
considered duty, and is part of the FDP limits unless it occurs after flight duties are
completed. European business aviation pilots report that 65% of their companies use
positioning as part of their business (Table 3.1).
4.9.2 Travelling
Pilot travelling has become a source of controversy in aviation. Airlines report that pilots
might live hundreds of miles away from their home base and travel for duty via commercial
airline. The practice of travelling for hours before duty raised the issue of additional pilot
fatigue, since their time since awake could be extended by several hours. This issue was
brought to international attention after the crash of Colgan Air Flight 3407 to Buffalo NY,
killing all 49 passengers and crew. While the NTSB board reviewing the case did not agree
to list fatigue as a contributing factor, the Chairman Deborah Hersman issued a five page
report lamenting this exclusion, and argued the case that fatigue due to travel time was a
probable factor contributing to the crash.
Recently, the National Research Council (NRC) Committee published a special report on the
“Effects of Commuting on Pilot Fatigue” (2011) to investigate pilot travelling practices. The
NRC found that;
“…there are no comprehensive data on the frequency of pilot commuting, the lengths of
commutes, or such trip characteristics as the transportation modes used in commuting.
There are also no systematic data on the timing, duration, or quality of pilots’ sleep before or
during their commutes. Furthermore, changes in airports to which the pilots’ report for the
start of their duty (their domicile) may alter commuting patterns, but the committee was
unable to obtain any systematic information about how frequently individual pilots experience
domicile changes or how such changes affect pilot commuting behaviour.”
Based on the lack of objective data, the committee concluded that while travelling may
influence pilot fatigue and safety risk, there is no way to be certain. In the meantime, they
recommend that pilots should avoid planning any pre-duty activities, including travelling, that
will result in their being awake for 16 consecutive hrs by the end of the FDP. They also
suggest that pilots receive no less than 6hrs of sleep prior to duty, and consider how long
they have slept and been awake when they are deciding whether or not to fly.
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4.9.3 Positioning
As with travelling, no controlled experiments have examined the effect of positioning on pilot
fatigue. Positioning is considered duty and is already accounted for in determining FDP
limits when prior to a FDP. However, depending on when the positioning flight occurs, how
long it takes, and whether the pilot is able to sleep or not, in theory positioning flights can be
as disruptive as if the pilot was flying themselves. For example, if the positioning flight has
an early departure, all of the drawbacks of early departures apply. If the pilot has the ability
to nap during the positioning flights, some of the fatigue effects may be mitigated, but if not,
the potential exists for the pilot to begin their FDP already fatigued.
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5.0 Hazard Analysis
The following hazards from Table 3.2 are addressed in this section:
Duty Duration/ Time Awake
5.1 Hazard A1, duration of FDP too long leading to fatigue, (implicitly includes other
causes of overlong FDP, A2, A5, A6)
5.2 Hazard A3, extended FDP with augmented crew/ in-flight rest leads to fatigue
5.3 Hazard A4, on-ground break (split duty) used to excessively extend FDP leading to
fatigue
Time of Day Effects
5.4 Hazard B1, WOCL encroachment
5.5 Hazard B2, circadian disruption due to mixing night and day duties
5.6 Hazard B3, Time Zone desynchronisation
Cumulative
5.7 Hazard C1, cumulative effect of multiple consecutive FDPs
5.8 Home/ hotel standby – how the unpredictability of home/ hotel standby can contribute
to long periods awake, hazard A5, and how it could contribute to cumulative fatigue,
hazard C2
Rest and Sleep Off Duty
5.9 Hazard D1, lack of rest opportunity
Relaxation and Naps During Ground Breaks
5.10 Relaxation and napping relating to hazard E1, sleep inertia, and as a mitigation to
hazard A1
Others
5.11 Pilot in Command (PIC) discretion – hazard A2, PIC discretion leading to too long an
FDP
5.12 Positioning and travelling – hazards F1, F2 and F3 from Table 3.2 leading to
excessive time awake and/or cumulative fatigue.
For each of these hazards the safety, economic and social impacts associated with potential
FTL changes are analysed.
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5.1 Hazard A1, Duration of FDP Too Long Leading to Fatigue
5.1.1 Safety Impacts of Changes of FDP Duration and Extensions
The key issues associated with hazard A1 from Table 3.2 are considered to be:
i. Length of FDP and fatigue level
ii. Length of extended rest after a long duration or extended FDP
iii. Encroachment of WOCL (see section 5.4)
iv. Impact of number of sectors
v. Other potential mitigations.
5.1.1.1 Length of FDP and Fatigue Level
Literature Review and States’ Survey
The relationship between duty length and fatigue is complicated by circadian phase, time
awake, chronotype and the other factors discussed in Section 3.1. The literature in Section
4 from across industries indicates that shifts up to 12 hours are not necessarily higher risk
than 8 hour shifts if appropriate mitigations are put in place. From the airline industry there
is a range of proposed limits for daytime FDPs between 12-14 hours beyond which there is
likely to be increasing fatigue and risk. The number of sectors in an FDP and WOCL
encroachment will be important fatigue contributing factors.
For air taxi operations adherence to the maximum daily FDP requirements in Subpart Q
OPS 1.1105 are expected in Europe2. For single pilot operations see Appendix 3 – there are
specific national requirements for FDP limits, maximum daily blocks hours, maximum single
flight/ sector time and restrictions on extensions.
CAS modeling
FDPs in the range 11 to 20 hours have been considered with a two person crew. The
scenario specific assumptions are:
• Two sectors of 5 hours each, first flight starting 30 minutes after start of FDP and
second flight ending at end of FDP
• Pilots assumed to stay awake during break in 2 sectors
• No time-zone complications for this scenario
Three different finish times for the FDP have been selected, 0600 (worst case in terms of
alertness), 1300 and 2100. The graph below shows alertness at the end of the last flight for
these 3 different finish times with the different FDP durations.
Figure 5.1 indicates that:
2
CAP 371 applies for the UK
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• Alertness at the end of the last flight is heavily dependent on circadian time-of-day as
expected.
• For the finish time where alertness is highest (2100) there is a large variation in
alertness depending on FDP length between 11 hours (score of 76) and 20 hours
(score of 32). Above 13 hours FDP duration the alertness score starts to decrease
steadily.
• For the other two end times of 0600 and 1300 there is less variation with FDP
duration. In the case of 0600 the alertness is very low (<10 “bottomed out”) for all the
durations modeled. A combination of FDP greater than 11 hours flown with an
unaugmented crew and ending at 0600 will lead to low levels of alertness. Additional
mitigations may be applied by crew in such circumstances, such as controlled
napping when sanctioned. For 1300 the alertness varies from 38 to 27.
These findings seem broadly consistent with the literature in Section 4 indicating significant
increases in risk as FDP begins to exceed 12-14 hours. The combination of literature and
modeling shows that if extensions are granted beyond 13 hours, flight safety risks are likely
to increase.
Figure 5.1: Alertness at end of FDP depends on FDP length and time-of-day of FDP
end
With respect to single pilot operations it is to be expected that on average flightdeck
workload may increase relative to operations with two or more crew. The complexity of the
flightdeck and the nature of the operations will also influence the relative workloads and
hence it is difficult to determine how large the workload differences will be. To address this
preliminary CAS modeling was undertaken with the whole flight with a single pilot set at the
same workload as that used during take-off and landing for multi-crew operations. This
assumption models higher levels of fatigue over the course of each FDP and leads to lower
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alertness levels. Most of the States surveyed (see Appendix 3) have additional mitigations
in terms of maximum FDP and flying time limits for single pilot operations to counter this
potential for extra fatigue. These mitigations are summarized in Section 5.1.1.4 below.
5.1.1.2 Length of Extended Rest After an Extended FDP
One means of mitigating the effects of a long (extended) FDP, post-event, is to provide a
longer rest afterwards. Clearly this does not help during the long FDP, but it can mitigate
subsequent effects.
In terms of the scientific literature, The Principles and guidelines for duty and rest scheduling
in Commercial Aviation ‘NASA Study’ (Dinges et al., 1996) recommends that ‘the …..
required off-duty period should be extended by the same duration of the flight duty period
extension’. Other literature in Section 4 notes the importance of two nights sleep to recover
from peak fatigue.
5.1.1.3 Impact of Number of Sectors
The need to decrease the FDP if there are a significant number of sectors is confirmed by
many scientific studies (see Section 4.2.4). The Subpart Q requirement on maximum
allowable FDP is based on a 30-minute reduction after the second sector. Air Taxi (AT) and
single pilots can fly multiple sectors and it is reasonable to believe that this will have at least
a similar effect on them as for multi-crew scheduled and charter pilots. For single pilots the
impact may be greater as they have to conduct the turn-around alone.
5.1.1.4 Other Potential Mitigations
In addition to limits on FDP duration, extended rest and modifying maximum FDP depending
on the number of sectors, other potential mitigations for long duration FDPs could be
incorporated into the RIA options. These may include:
• Requiring full rest before the extended FDP (assumed in the modeling above)
• FRMS (general for all hazards)
• Ensuring that the most strict limits apply when extensions are used for mixed
operations (e.g. air taxi and AEMS)
• Limiting the frequency of extended FDPs
• Controlled napping and relaxation during any ground breaks between sectors
• Records to NAA of FDP extensions and NAA oversight measures.
• For single pilot operations specific requirements for FDP limits, maximum daily
block hours, maximum single flight/ sector time and restrictions on extensions (see
Appendix 3)
• Relief pilot for single pilot operations when an extension is invoked.
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5.1.2 Economic and Social Impacts of FTL Changes for FDP Duration and Extensions
Those economic and social impacts which are judged likely to be most significant following
proposed regulatory changes are tabulated below (Table 5.1).
Table 5.1: Economic and Social Impacts Associated with Potential Changes to FDP
Duration Provisions
Potential Reference situation in Identification of generic Factors which will
change Europe economic and social affect size of
impacts impacts
Harmonisation Air taxi operations If change effectively reduces Size of impact will
of basic max. already well maximum FDP this could depend on how close
FDP duration harmonized around impact service provision, e.g. to FDP limits single
and extensions Subpart Q. prevent a single pilot operation pilot operators
being able to provide the currently fly. If close
Maximum FDP for required combination of flights to the limits and limits
single pilot operations to a customer. This could change then could be
(SPLO) vary from 8 to have economic impacts and significant impacts.
11 depending on State, social impacts in terms of job
FDP start time and security.
number of sectors.
Hence impact analysis Changes could lead to
focusses on SPLO. requirement to switch from
single pilot to multi-crew
operations with associated
crew cost impacts.
Harmonisation Flight/ sector times for As above As above – depends
of flight time for single pilots are on how close
single sector for restricted to various operations are to
SPLO limitations including 5 harmonised flying
hours, 4 hours (with hours limits.
autopilot), and 2 hours
(without autopilot) in
different States.
Harmonisation One State restricts
of flying hours FDP block hours to
per FDP for less than 6 hours for
SPLO IFR operations or
operations at night for
single pilots.
An indication of the process for determining the economic impacts of proposed changes is
illustrated by the following example relating to daily block hours for single pilot operations:
• Assume that a regulatory change leads to a new daily block hours limit of X hours.
• Assume that a single pilot operator operates at greater than X flight hours for Y% of
FDPs.
• Assume that for these Y% of FDPs, two person operations need to be introduced.
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• From this extra crew numbers can be estimated and combined with estimates on the
percentage of operating costs due to crew costs (see Section 2.2).
5.2 Hazard A3, Extended FDP with Augmented Crew/ In-Flight Rest Leads to
Fatigue
5.2.1 Safety Impacts of Changes for Extended FDP due to Augmented Crew
The key issues associated with this hazard are:
i. Length of FDP and fatigue level
ii. Availability and quality of in-flight rest facilities and other potential mitigations.
5.2.1.1 Length of FDP and Fatigue Level
Literature Review and States’ Survey
Some issues with extended duration FDP’s can be avoided by augmenting the crew during
long flights with an additional crew member(s). Augmented crews allow pilots to take in-flight
rest and obtain sleep in order to maintain alertness and reduce fatigue.
Numerous studies have shown that both objective physiological measures and subjective
ratings of alertness demonstrate improvement following an in-flight rest taken during periods
of sustained wakefulness and that sleep can also reduce or delay expected performance
decrements (Simon, 2007). Timing and duration of rest/ sleep can be designed for optimal
impact on alleviating fatigue.
Appendix 3 summarises the national provisions regarding in-flight rest from the survey of
States. They show FDP extensions that are a function of the number of augmented crew,
the on-board rest facilities, minimum in-flight rest hours and the number of sectors. In France
the minimum rest at home base requirements can be changed for air taxi operations as
explained in Appendix 3. For the other States there are no air taxi specifics.
CAS modeling
FDPs in the range 11 to 20 hours have been considered with 3 person augmented crews.
The scenario specific assumptions are:
• Two sectors of 5 hours each, first flight starting 30 minutes after start of FDP and
second flight ending at end of FDP
• 90 minute sleeps as part of inflight rests were placed in the middle of each flight
• No time-zone complications for this scenario
As in section 5.1.1.1 three different finish times for the FDP have been selected, 0600 (worst
case in terms of alertness), 1300, and 2100. Figure 5.2 shows alertness at the end of the
last flight for these 3 different finish times for augmented and non-augmented crew.
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Figure 5.2: Impact of FDP duration on alertness at end of Augmented Crew FDP
The graph indicates that:
• For the end time where alertness is highest (2100) crew augmentation is effective in
maintaining alertness at the end of the second flight (compared to Figure 5.1 with
non-augmented crew).
• In the case of 0600 end time the alertness is low even with augmentation (although
augmentation does raise alertness to an equivalent level with a 1300 FDP end time
without augmentation) and at this finish time the alertness shows only weak
dependence with FDP duration.
• Alertness is at intermediate levels with an afternoon (1300) end time and
augmentation shows clear benefits.
5.2.1.2 Other Potential Mitigations
As well as providing limits to FDP extensions with in-flight rest other potential mitigations
could be incorporated into the RIA options. These may include:
• Technical criteria for in-flight rest facilities
• Minimum duration of rest period onboard required
• Setting minimum continuous duration for in-flight rest
• Limiting the number of sectors
• Limiting the FDP time over which a crew member can be Pilot Flying (PF)
• Specifying minimum rest durations at destination and at home
• Additional compensation time over and above the standard rest time (used in AEMS)
• Sleep opportunities at the airport after long missions
• Promote and pay for use of public transport after long missions which mitigates the
risk of car accidents for flight crew
• Limiting the frequency of such extended augmented FDPs.
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5.2.2 Economic and Social Impacts of FTL Changes for Augmented Crew Duty Duration
and Extensions
Those economic and social impacts which are judged likely to be most significant following
proposed regulatory changes are tabulated below (Table 5.2).
Table 5.2: Economic and Social Impacts Associated with Potential Changes to
Augmented Crew FDP Provisions
Potential Reference situation in Identification of generic Factors which will
change Europe economic and social affect size of
impacts impacts
Harmonising FDPs are a function of If a change requires 4 crew Size of impact will
FDP hours for the number of instead of 3 to fly an FDP of a depend on how close
augmented crew augmented crew, the certain number of hours this to FDP limits
and/ or on-board rest facilities, will clearly lead to increased operators currently fly.
requirements for minimum in-flight rest crew costs. If close to the limits
onboard rest hours and the number and limits change then
facilities of sectors. Up to 20 Alternatively operators may could be significant
hours in Switzerland choose to upgrade onboard need for more/ less
with 4 pilots, bunk beds rest facilities (if practical) to crew.
and 3 sectors. 18 achieve desired FDPs with
hours is the maximum available crew with
in other States. consequent capital costs.
Harmonising The required rest after Changes to the amount of rest The percentage of
extended rest an extended FDP can following an extended FDP FDPs that get
after an vary from = FDP up to may affect crew availability. If extended using
augmented 48 hours depending on a new requirement for augmented crew.
FDP State. extended rest following an
augmented FDP is introduced How much spare crew
then extra crew may need to capacity operators
be made available to cover currently have to
such an event. cover such events.
An indication of the process for determining the economic impacts of proposed changes is
illustrated by the following example relating to additional extended rests following extended
augmented FDPs:
• Assume that a regulatory change leads to an additional 12 hours rest being allotted
whenever an extended augmented FDP beyond X hours is flown.
• Assume that each crew member experiences an augmented FDP beyond X hours Y
times per year.
• The change will lead to an average of 12Y hours extra rest per year per crew
member.
• This can be used to assess the impact on crew costs and overall operating costs as
per the other illustrative example above.
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5.3 Hazard A4, On-Ground Break (Split Duty) used to Excessively Extend FDP
Leading to Fatigue
5.3.1 Safety Impacts of FTL Changes Relating to On-Ground Breaks (Split Duty)
5.3.1.1 Literature and States’ Survey
Table 3.1 indicates split duty is relatively common for ATXO. Folkard and Tucker (2003),
reviewed in Section 4.1.2.2, found that breaks in shifts reduced accident risks. Moebus
Aviation (2008) noted the lack of scientific studies on the impact of split duty on aircrew but
made a number of recommendations (see Section 4.5.4).
Related to this lack of clear scientific evidence there is a range of national provisions in place
in Europe on split duty. Seven out of the eight States surveyed have national provisions
covering split duty and Appendix 3 indicates that there is a significant degree of variation. In
six of the eight States there is a minimum period of 3 hours for a break before it can
influence FDP duration. In France and the UK the FDP can be extended by half of the break
minus 30 minutes. In other States there is a sliding scale where longer breaks can
contribute to proportionally longer FDP extensions. In Poland for example with a break
between 7 and 10 hours, the FDP can be extended by 1.5 times the break time provided the
break is between 20.00 and 08.00 local time. The national provisions in Appendix 3 have a
wide range of conditions and caveats associated with the possible extensions. These are
summarised below under Potential Mitigations.
In France there are specific provisions for Air Taxi related to taking a break inside the
aircraft. Conditions for taking the break inside the aircraft are the following:
• Minimal noise, temperature, light, ventilation conditions are included in the operations
manual
• Temperature and ventilation can be adjusted
• No passengers are on board
• No interference with on ground operations (catering, etc.) that might compromise the
rest during the break. Otherwise, the possible extension is decreased by half the
duration of said operations.
5.3.1.2 CAS Modeling
A number of scenarios have been modelled in CAS to investigate the influence of a ground
break on fatigue.
Day FDPs
Three scenarios have been modelled:
1. No ground break – 13 hour FDP starting at 07.00, with two six hour sectors
2. Ground break – 13 hour FDP starting at 07.00, with two 4 hour sectors at either end
of the FDP and a 5 hour ground break in between
3. Ground break and sleep – as for #2 but with a 90 minute sleep on the ground
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Fatigue/ Alertness Day FDP Scenario 1 Day FDP Scenario 2 Day FDP Scenario 3
Measures
3
Fatigue Score 6.8 6.7 5.7
Average Alertness 81.5 82.5 86.2
during FDP
Alertness at end of 78.2 80.4 86.7
FDP
These results indicate that for all these FDPs in isolation, fatigue is low and alertness high.
The unground break and afternoon sleep have little effect. If the break was used to extend
the FDP later than 20.00, time of day effects would become important combined with the
long duration FDP impacts illustrated in Figure 5.1.
Night FDPs
Three scenarios have again been modelled:
1. No ground break – 11 hour FDP starting at 20.00, with two five hour sectors
2. Ground break – 13 hour FDP starting at 20.00, with two sectors and a 4 hour ground
break in between
3. Ground break and sleep – as for #2 but with a 3 hour sleep on the ground
Fatigue/ Alertness Night FDP Scenario 1 Night FDP Scenario 2 Night FDP Scenario
Measures 3
Fatigue Score 46.4 48.5 23.0
Average Alertness 35.2 32.4 56.1
during FDP
Alertness at end of 9.7 21.6 74.8
FDP
For the night FDP, the ability to sleep during the ground break has a much larger effect on
reducing fatigue and increasing alertness. A break without a sleep does not show significant
benefits on average fatigue/ alertness across the FDP. Alertness at end of the FDP is also
affected by the different times of day at which the FDP ends.
Thus the degree to which an on-ground break can justify FDP extensions will be dependent
on a number of factors including time of day (which influences the ability to sleep and the
benefit of the break) and the rest facilities available to crew.
3
The fatigue score is calculated as a weighted sum of 11 individual factors including the average
alertness on duty, number of recovery breaks per week, hours on duty per week, number of time zone
crossings and others. It is based on a 0-100 scale, with 100 the most fatigued.
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5.3.1.3 Potential Mitigations
As well as specifying how the duration of the on-ground break contributes to FDP and
placing limits on the extension time and total FDP with split duty other potential mitigations
include:
• Establishing the minimum consecutive number of hours for break
• Specifying standards for the rest facilities/ accommodation during the break
(including aircraft facilities if break taken on-board)
• Establishing limits for the duration of FDP before and after the break
• Establishing limits for the numbers of landings/ sectors after the break
• Limiting numbers of breaks in one FDP
• Restriction on combining split duty with augmented crew rules or reduced rest
• Impact of travel time during break on FDP extension
• Time difference/ non-acclimatisation restrictions
• Frequency of extended FDPs due to split duties (e.g. in one week)
• Whether a crew member can be pilot flying after a certain FDP duration
• Taking account of split duty for subsequent rest calculation
• Pre-plan the break.
5.3.2 Economic and Social Impacts of FTL Changes Relating to On-Ground Breaks (Split
Duty)
The main economic and social impacts are judged to be associated with the following
potential changes:
• Harmonised rules for determining FDP extension based on break duration and
accommodation – this will effectively change FDP duration for some States and
hence the economic and social impacts will be as in Table 5.1 above.
• Harmonised rules for rest facilities/ accommodation – including on aircraft. This could
mean that some operators may not be able to take benefit for on-ground breaks in
terms of FDP durations or they have to spend money upgrading facilities. See Table
5.2 above for similar impacts.
5.4 Hazard B1, WOCL Encroachment
The traffic patterns for Business Aviation (BA) are different from the overall European traffic
picture in terms of hourly departures. EUROCONTROL (2010) shows the hourly pattern of
BA departures for Germany in the graph below (a similar pattern is also shown by
EUROCONROL for France). The busy hours for Business Aviation begin later and end
earlier than is the case for the rest of the traffic. There is a relatively low percentage of flights
beginning in the WOCL or soon after the WOCL.
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Figure 5.3: Hourly pattern of departures in Germany (from EUROCONTROL, 2010)
However, Business Aviation (and hence air taxi) flights do encroach the WOCL and hence
this source of fatigue requires consideration.
5.4.1 Safety Impacts of FTL Changes Relating to WOCL Encroachment
There is consensus within the scientific literature and from operational experience that the
length of the FDP should be reduced if sleep is restricted, e.g. if a crew member cannot
sleep during the WOCL and then finds it difficult to sleep at other times of the day. The CAS
modeling in Section 5.1.1.1 shows low alertness for FDPs ending at the end of the WOCL.
Subpart Q sets out requirements for reducing FDP for WOCL encroachment which is a
mitigation for transient effects.
Other potential mitigations aimed at cumulative fatigue include:
• Providing additional rest – e.g. if two or more FDPs encroach the WOCL during a
week, the weekly rest could be extended from 36 hours to 48 hours. This could
include other periods of extended rest not necessarily weekly.
• Limiting the frequency of such WOCL encroached FDPs.
Mitigations aimed at both transient and cumulative fatigue are:
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• Planning to optimize sleep opportunity (a Subpart Q provision) – this is hard to
guarantee for an on-demand service such as ATXO.
• Personnel trained to recognize fatigue and respond appropriately.
5.4.2 Economic and Social Impacts of FTL Changes Relating to WOCL Encroachment
The major potential impacts are judged to be any future rule changes affecting:
• Additional rest to compensate for WOCL encroachment – the economic impact will
be the equivalent of that described in Table 5.2 for Extended Rest after Extended
FDP and the illustrative calculation of impacts of extra rest time after Table 5.2.
• Changes in the manner that FDP is adjusted if WOCL is encroached – the economic
impact will be equivalent to changing the maximum FDP duration shown in Table 5.1.
5.5 Hazard B2, Circadian Disruption due to Mixing Day and Night FDPs
5.5.1 Safety Impacts of FTL Changes Relating to Day/ Night Transitions
As noted in Section 4.3.3 transitioning from day to night duties and vice versa can cause
problems. During the transition there is a misalignment of the circadian rhythms which leads
to malaise and increased fatigue. Research studies (Santhi et al., 2007) have studied the
transition from day to night shift without rest days in between and found that the first night
shift is most problematic with impairment in the ability to sustain focus, decrease in
subjective alertness and decrease in visual search sensitivity more pronounced than in
subsequent shifts.
Subpart Q notes that “Operators shall allocate duty patterns which avoid such undesirable
practices as alternating day/ night duties…”. The provision of rest in between these
transitions is an important mitigation for this cause of circadian disruption. Providing at least
one full local night between transitions provides some protection against a late night FDP
being followed by an early starting in the WOCL the following night. CAP 371 recommends
avoiding rest periods between 18 and 30 hours to avoid such disruption.
Limiting the frequency of such transitions may be difficult to achieve depending on
operational factors and crew resources.
5.5.2 Economic and Social Impacts of FTL Changes Relating to Day/ Night Transitions
Providing extended rest between transitions and minimizing their frequency may be more
difficult for smaller operators with less resource flexibility. However the economic impacts
would not be expected to be large given that these mitigations are good practice already
built into Subpart Q.
Minimising such disruption by applying adequate rest between transitions will have a positive
social impact in terms of promoting the wellbeing of crew.
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5.6 Hazard B3, Time Zone Desynchronisation
5.6.1 Safety Impacts of FTL Changes Relating to Time Zone Desynchronisation
5.6.1.1 Literature and States’ Survey
The literature reviewed in Section 4.3.4 indicates that it can take several days for people’s
body clock to align with the local time following long haul flights. The direction of travel and
the length of layovers will influence the impact as well as individual factors.
As noted in Table 3.1, crossings of several time zones are relatively common for ATXO. Six
out the eight States surveyed had specific national provisions concerning time zone
crossings. These are described in Appendix 3 and vary widely. In Switzerland for example,
for time zone differences of 3 hours or more the subsequent rest period must be increased
by 30 minutes for every hour of difference. In the UK, CAP 371 has a table for guidance
showing that the number of days for Minimum Base Turn Around (MBTR) is a function of
Return Sector Length, Duration of Trip and Time Zones Crossed; at the upper end, the
MBTR is 5 days for a return sector length of 14 hours +, a trip length of 96 - 216 hrs, and 7
plus hours time zone difference. In Germany after return to home base the rest in hours is
determined by multiplying the time zone difference by 8 up to a maximum of 12 time zones.
It should be noted that the provisions above are not specific for ATXO, but are general CAT
rules.
In France there are specific provisions for air taxi operations. Under general CAT rules
when returning to the home base, if the preceding FDP took the crew more than 3 time
bands away, then rest = 36h including 2 local nights. For air taxi operations, these
provisions may be changed as follows:
• Rest = maximum of either the preceding FDP or 10h + 1 additional hour for every
time zone crossed. Rest shall include at least one local night.
• If rest <36h or rest does not include 2 local nights, then the periodic rest referred to in
OPS 1.1110 §2.1 shall include 3 local nights and be granted at the home base.
• These changes may be implemented only under FRM.
The national provisions also cover rest provisions away from home base and rest between
Eastward-Westward and Westward-Eastward TZ transitions (see Appendix 3).
5.6.1.2 CAS Modeling
In order to understand this hazard better the following scenarios have been modeled with
CAS:
1. Flying East (flights during pilot’s subjective daytime): London, UK > Delhi, India >
Sydney, Australia > Tokyo, Japan > London, UK
2. As for #2 but flying during the pilot’s subjective night-time
3. Flying West: London, UK > New York City, USA > Miami, USA > Rio de Janeiro,
Brazil > London, UK
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For each of these three sequences augmented crews were assumed enabling in-flight rest of
either 90 minute sleeps (termed “normal” in graph below) or 3 hour sleeps (termed “extra
sleep” below).
Figure 5.4: Fatigue for Eastbound and Westbound Long Haul Air Taxi Flights
Effect of Extra Sleep on Fatigue for Eastbound and Westbound
Long-Haul Business Trips
50
45
40
35
Fatigue Score
30
25
20
15
10
5
0
Normal Extra Sleep Normal Extra Sleep Normal Extra Sleep
East (day) East (night) West
For the sequences creating increased fatigue, the extra in-flight rest shows benefits in terms
of reduced fatigue and increased alertness (see Appendix 4 for detailed alertness graphs). It
should be noted that while generally eastbound flights cause more problems (as noted in the
literature review), this particular westbound schedule involves erratic flight times relative to
the crew’s body clocks. The schedules above are considered realistic from the viewpoint of
long range air taxi flights, but clearly cannot represent the wide range that could actually be
encountered.
5.6.1.3 Potential Mitigations
In addition to trying to schedule flights to take account of TZ desynchronisation (difficult for
an on-demand service such as ATXO) and use of augmented crew to allow in-flight rest the
following mitigations are relevant:
• Duty restrictions and rest (home and away) based on number of time zones crossed
• Limit the maximum FDP according to day time and degree of acclimatization
• Set a minimum time before a crew would be considered time zone acclimatized
• FRMS of particular importance to take account of time zone specifics and specific
route patterns of a long range ATXO operator
• Limiting number of alternating east-west rotations per month and providing additional
rest when these happen.
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5.6.2 Economic and Social Impacts of FTL Changes Relating to Time Zone
Desynchronisation
The main economic and social impacts are judged to be associated with harmonised rest
provisions at home and away from home base following TZ crossings. Changes in these
provisions compared to a State’s current provisions could impact the availability of crew (see
Table 5.2). Whether this leads to additional crew being required will depend on how often a
pilot is required for an FDP soon after another FDP involving TZ crossings. In terms of
social impacts changes in rest provision after TZ crossings will affect crew’s ability to recover
and hence their overall feeling of wellbeing.
5.7 Hazard C1, Cumulative Fatigue due to Consecutive FDPs
Although AT pilots generally fly significantly fewer hours per year than scheduled airline
pilots, cumulative fatigue could still build up over shorter timeframes if workload is unevenly
spread. Single pilots, if flying scheduled operations (see Section 2.2.2.2), could accumulate
sleep debt in a similar manner to multi-crew scheduled and charter pilots.
5.7.1 Safety Impacts of FTL Changes Related to Cumulative Fatigue
5.7.1.1 Literature Review and States’ Survey
The scientific research on the links between fatigue and the subsequent risk of accident and
injuries over consecutive work days is reviewed in Section 4.4. The development of
cumulative fatigue tends to increase during consecutive periods of duty, especially for long
duties, early starts, late finishes and overnight duties, when the normal pattern of sleep is
disrupted (Spencer and Robertson 2000, Spencer and Robertson 2002).
How much rest an individual needs between blocks of working days is related to the number,
timing, and length of the consecutive days he or she works. Allowing more time off after
consecutive night FDPs is important because night flights are more fatiguing, and sleep debt
more prevalent, than with day flights. There is agreement in the literature that rest including
just one night’s sleep is usually not enough to fully recover from a series of consecutive work
days. Two consecutive days and nights rest (48hrs) with unlimited sleep opportunity is
usually enough to dissipate any cumulative sleep debt (see Section 4.8).
Monthly and annual limits are generally built up from weekly limits with rest days added in. It
is very difficult to relate cumulative fatigue to longer term limits either from scientific literature
or modeling.
Moebus Aviation’s report (Moebus, 2008) proposed additional limits to those in Subpart Q,
i.e. a duty hours limit over 14 consecutive days and a block hours limit per 12 consecutive
months. Limits on these (slightly modified from those proposed in the Moebus Aviation
report) are included in CRD 2010-14 although, as noted in NPA 2010-14 (EASA, 2010),
there is a lack of scientific evidence and the limits are rather based on judgments of what
appears “reasonable”. Operational experience with respect to ATXO and single pilot
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operations will be important to allow filling in the gaps from the scientific literature and
modeling on cumulative fatigue.
Based on the States’ survey, there are no special requirements for single pilot operations
and hence both Air Taxi and single pilot operators are assumed to adhere to Subpart Q
requirements for cumulative duty hours and block times.
5.7.1.2 CAS modeling
To investigate the potential buildup of cumulative fatigue over a week, the following
sequences of FDPs have been modeled with CAS:
Day FDPs – 5 consecutive days:
• FDPs starting at 0900 and ending 2200 with a 4 hour ground break, 2 sectors for
Days 1, 3 and 5 (“long” days) followed by travel, allowing just 6 hours sleep
• FDPs starting 0900 and ending 2000, 2 sectors for Days 2 and 4 (“short” days)
followed by travel allowing 8 hours sleep
This sequence has been considered with and without short sleeps during the on-ground
breaks in the long days.
Figure 5.5: Alertness over a 5 day sequence of Day FDPs
Effect of Reduced Rest on Alertness (all duty) over Five Days
90
85
Average Alertness
80
75
70
65
60
Long Short Long Short Long Long Short Long Short Long
Day FDP Day FDP +sleep
Even in the case of no on-ground afternoon sleeps, average alertness over the FDP remains
high through the 5 days with no sign of cumulative fatigue even with the reduced rest.
Adding the sleep does increase alertness, so it suggests that even though average alertness
scores are high, there is still some benefit of napping, particularly for the long days.
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A similar sequence of FDPs was also modeled for 5 consecutive nights. While average
alertness was lower than day FDPs (as expected) rather than show a deterioration over the
sequence of duties indicating cumulative fatigue, average alertness improves showing
adaptation to the sequence (see Appendix 4).
The modeling indicates that the Subpart Q limit on duty hours within a 7 day period appears
as an effective mitigation for shorter term cumulative fatigue. It should be noted that such
sequences of 5 consecutive day or night FDPs are unlikely to occur for on-demand air taxi
services.
5.7.1.3 Other Potential Mitigations
As well as limits on cumulative duty/ flying over weekly/ monthly and annual periods, other
potential mitigations could be incorporated into the options for managing cumulative fatigue.
These may include:
• Minimum number of days off per month – there is a lack of scientific evidence
regarding the impact of this measure on cumulative fatigue. The Working Time
Directive requires a minimum of 7 days off per month.
• Spread out duty as evenly as possible – good practice but difficult to apply in
ATXO.
• Rest period increased periodically – Subpart Q requires a weekly rest period of 36
hours including 2 local nights. National Authorities may decide that the second of
those local nights may start from 20.00 hours if the weekly rest period is at least 40
hours. The survey of eight States (Appendix 3) shows that about half of the National
Authorities do allow this.
• Cumulative fatigue mitigations related to WOCL encroachment and split duty –
see Table 3.2.
5.7.2 Economic and Social Impacts of FTL Changes Related to Cumulative Fatigue
Those economic and social impacts which are judged likely to be most significant following
proposed regulatory changes are tabulated below.
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Table 5.3: Economic and Social Impacts Associated with Potential Changes to
Cumulative Limits
Potential Reference situation Identification of generic Factors which will
change in Europe economic/ social impacts affect size of impacts
Changed Subpart Q cumulative New regulations on Depends on how
harmonised limits duty hours and block cumulative limits, if different current hours compare
on weekly, hours limits from current practices, will to whatever new limits
monthly, annual lead to crew reaching limits are proposed. For
duty/ block hours more quickly/ slowly and smaller operators with
impacting the productivity and less crew, effects are
costs of crew. likely to be
proportionally larger.
Harmonisation of Subpart Q OPS Existing flexibility in Subpart Q Percentage of
weekly extended 1.1110 para. 2.1 allows some operators to operator’s flights
rest allows for National begin operations at 06.00. currently based on
Authority acceptance Removing this flexibility could flexibility provided by
of changed hours for impact some of the services Subpart Q OPS 1.1110
second night rest that ATXOs currently provide para. 2.1.
with economic impacts.
5.8 Standby Related Hazards
The use of short call home standby is used by many European AT operators (see Section
3.2). Long call home standby (at least 10 hours before start of an assigned duty) is not
considered below as safety impacts are not considered so significant and is not so relevant
to AT on-demand operations.
5.8.1 Safety Impacts of FTL Changes Relating to Standby
The key issues associated with this hazard are:
i. Maximum duration of standby
ii. Taking account or not of standby time in FDP hours and duty hours and subsequent
rest calculations
iii. Other potential mitigations.
5.8.1.1 Maximum Duration of Standby
In terms of the scientific literature the Principles and guidelines for duty and rest scheduling
in Commercial Aviation ‘NASA Study’ (Dinges et al., 1996) does not consider ‘on call reserve
status’ as duty, but recommends that ‘a protected 8 hour sleep opportunity’ should be
protected from interruption by assignment to a flight duty period.
Crew Factors in Flight Operations XI: A Survey of Fatigue Factors in Regional Airlines
Operations (Co, E., 1999) notes that: ‘The nature of flying on reserve means that
crewmembers must respond when called for duty, thus creating unpredictability in their
schedules. This unpredictability can lead to sleep loss, for example, when a call for duty
occurs when a sleep period was planned. As evidence that sleep loss occurred,
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crewmembers reported getting 5.6 h of sleep before duty on average—2.3 h less than their
normal average sleep.’
The survey of national FTL provisions in Appendix 3 revealed maximum short call home
standby durations of 12 hours, 14 hours and 24 hours renewable. The degree to which crew
can obtain 8 hours sleep during a 24 hours standby is unclear.
If an operator is using different standby types it can be possible to use the crew on 24 hours
standby as a “last resort” and hence minimize the chance that their sleeps will be disturbed
(see below under “Other potential mitigations”). Hence the scale of safety significance and
the impact of changing maximum standby duration is uncertain.
Thus this is an issue where operational experience will have a large input in future RMT
discussions rather than the scientific literature or modeling. A key question is – does
operational experience (and any outputs from FRMSs) show that AT pilots and single pilots
on other services are able to get 7-8 hours sleep when on 24 hour standbys?
5.8.1.2 Taking Account of Standby Time in FDP Hours, Duty Hours and Subsequent Rest
Calculations
There is very little scientific research covering this topic. However, Torsvall and Akerstedt
(1988) showed that sleep quality is affected in ships’ engineers based on whether they are
on-call or not. Changes in sleep quality were noted before any alarms went off, suggesting
that sleep was disrupted in anticipation of being called out for duty.
The survey in Appendix 3 revealed wide variation in this issue. Clearly reducing the
allowable FDP length to allow for some/ all of the standby time before a callout will, on
average, reduce the chance of crew fatigue. However, it will also reduce the ability of the AT
operator to provide a service to their customers and/ or have economic impacts (see below).
CAS modeling
To investigate the potential impacts of home standby on subsequent FDPs if called out the
following scenario has been modeled:
FDP starting at 22.00 and finishing at 09.00 following a call out from home standby with the
following features of the home standby:
1. A good night’s sleep preceding the FDP (8 hours) and fatigue planning in terms of 2
naps mid-afternoon and prior to leaving for the FDP (termed “Planned – Good” in
graph below).
2. A poor night’s sleep preceding the FDP (6 hours) and fatigue planning in terms of 2
naps mid-afternoon and prior to leaving for the FDP (termed “Planned – Poor”
below).
3. A good night’s sleep preceding the FDP (8 hours) and no naps prior to leaving for the
FDP (termed “Unplanned – Good” below).
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4. A poor night’s sleep preceding the FDP (6 hours) and no naps prior to leaving for the
FDP (termed “Unplanned – Poor” below).
Figure 5.6: Alertness during a night FDP following home standby
Effect of Planned or Unplanned Sleep on Alertness (all duty)
Follow ing Standby
40
35
30
Average Alertness
25
20
15
10
5
0
Planned - Good Planned - Poor Unplanned - Good Unplanned - Poor
Sleep Planning/Quality
The graph indicates that the measures taken by crew during home standby and the
circumstances that could arise during home standby can have a significant impact on the
fatigue and alertness during a subsequent FDP. Awareness training and guidance to crew
as part of FRMS is clearly important (see below).
Accounting for home standby hours in duty hours (either in full or in part) would affect the
time it takes to reach cumulative limits with economic impacts, reviewed below. In terms of
safety the impacts are less easy to predict. In general AT crews fly less annual hours than
other types of pilots and cumulative fatigue is less of an issue than peak fatigue after long,
disrupted missions. New provisions that lead to extra rest requirements and fewer flights per
year might affect pilot competence and hence flight safety if crew hours drop too low. These
various safety impacts will need to be considered.
Thus this is an issue where operational experience will again have a large input in future
RMT discussions rather than the scientific literature or modeling. Key questions include –
does operational experience (and any outputs from FRMSs) show that AT and single pilots
are able to manage time at home so they do not arrive fatigued for FDPs, what fatigue
training and awareness do they receive concerning home standby and do they obtain
sufficient overall rest to manage cumulative fatigue? Fatigue training and awareness could
cover use and quality of pre-FDP naps, effect of meal and drinks, effects of home based
tasks on fatigue, etc.
The focus of the analysis above has been on home standby – however, the broad issues
also apply for hotel standby. For airport standby, Subpart Q requires this to count in full for
the purposes of cumulative duty. However, the issues of what relationship there should be
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between the time on airport standby and any subsequent FDP and what rest period should
follow an airport standby not leading to an FDP are applicable.
5.8.1.3 Other Potential Mitigations
Other potential mitigations include:
• FRMS and crew’s individual management of rest during standby – a FRMS can help
raise crew’s awareness of the importance of napping, avoiding heavy home working
tasks, etc.
• Establish different levels of readiness
• Management of standby so operator avoids placing crew on repeated 24 hr duration
standbys, and preferential use of persons on standby who should be better rested.
• Developing harmonized FTL requirements for standby other than at home, i.e. hotel,
airport and elsewhere.
5.8.2 Economic and Social Impacts of FTL Changes Relating to Standby
Those economic and social impacts which are judged likely to be most significant following
proposed regulatory changes are tabulated below.
Table 5.4: Economic and Social Impacts Associated with Potential Changes to
Standby Provisions
Potential Reference situation in Identification of generic Factors which will
change Europe economic/ social impacts affect size of
impacts
Harmonised Varied national If limit on standby duration is The extent will
limit on standby provisions up to a reduced (e.g. 24 hours to 12 depend on what
duration maximum of 24 hours hours) this is likely to increase standby patterns
(see Appendix 3). crew costs although this may operators are
vary depending on how the currently using and
standbys are organised. how much reliance is
being placed on
24 hour standby can have a longer home
negative social effect for crew standbys.
relative to 12 hour standby as it
does not allow relaxation time,
e.g. going out in the evening.
On the other hand having to
conduct 12 hour standbys twice
as often as 24 hour standbys
can also have social impacts
for crew.
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Potential Reference situation in Identification of generic Factors which will
change Europe economic/ social impacts affect size of
impacts
Harmonisation Varied national If available FDP duration is Frequency of
of the provisions for effectively changed by standbys.
contribution of contribution of home inclusion/ exclusion of a
standby to FDP, standby to FDP and contribution from home standby Duration of extra rest
duty hours and cumulative duty hours time this will have similar periods following
subsequent rest can vary from 100% to impacts to those potential FDP standby based on
calculations 0%, depending on changes set out in Table 5.1. proposed change.
State and associated
factors (see Appendix If home standby which does Degree of proposed
3). not lead to a duty is proposed contribution of
to be followed by a rest period standby hours to FDP
(e.g. in accordance with and duty hours.
ORO.FTL.235) and no rest has
been accorded before, there
will be a reduction in average
crew availability and a need for
higher crew costs to maintain
service level to customers.
Reaching cumulative duty hour
limits earlier or later due to
potential changes in the
manner in which standby hours
are counted in cumulative duty
time could also impact service
provision and/ or impact crew
costs.
An indication of the process for determining the economic impacts of proposed changes is
illustrated by the following example relating to additional rests following home standby that
does not lead to duty:
• Assume that a regulatory change leads to a new requirement for X hours rest
following a Y hour home standby.
• Assume an average of Z days home standby per crew member, with average of Y
hours per standby.
• New requirement would introduce Z × X hours of extra rest per year.
In addition operational data would be needed on how often a mission occurs immediately
after a standby period and hence whether the extra rest would necessitate an increase in the
operator’s crew numbers.
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5.9 Hazard D1, Lack of Sleep Opportunity
5.9.1 Safety Impacts of FTL Changes to Basic and Reduced Rest
5.9.1.1 Literature Review and States’ Survey
How much rest an individual needs between duties/ FDPs is reviewed in Section 4.5. A
single event of shortened sleep in a person who otherwise has been obtaining adequate
sleep can be tolerated without excessive fatigue risk. However, the number of days when
these short sleep episodes occur must be strictly limited because shortened sleep episodes
over consecutive days results in chronic sleep deprivation. Performance levels decrease and
the chance of errors and accidents increase as sleep reduces below 7-8 hours per night.
The minimum rest requirements in Subpart Q OPS 1.1110 (applicable to Air Taxi and single
pilot operations) for home and away from home base enable an 8 hour sleep opportunity.
Some States in the survey (see Appendix 3) allow reduced rest between duties with certain
mitigations in place. These mitigations include those listed in Section 5.9.1.3. The STARE
project (Air Transport Safety – Fatigue Risk) found that predictive models indicated that
fatigue risk levels for morning duties following a reduced rest varied widely from one
schedule to another. For rosters including a reduced rest, the STARE project (summarised in
EASA, 2010) found that the average sleepiness level during morning duties after a reduced
rest is close to that observed on the last flights of the day, prior to reduced rest, indicating
low recuperation during the rest. CAS modelling has been conducted to complement the
existing literature.
5.9.1.2 CAS Modeling
The sequence of FDPs used to investigate the potential for cumulative fatigue in section 5.7
(see Figure 5.5) included reduced rest between consecutive FDPs allowing only 6 hours
sleep. These did not lead to low alertness averaged across the FDPs nor the development
of cumulative fatigue as predicted by the modeling. However, scientific evaluation of
helicopter pilots working 7 consecutive days where sleep was dropping below 6 hours per
night did show clear signs of cumulative fatigue (Samel et al., 2004).
5.9.1.3 Other Potential Mitigations
In addition to setting minimum rest periods and limits on reduced rest, other potential
mitigations for lack of rest that could be considered are:
• Setting different minima for rest period at home base and out of base to cover
travelling time and protect sleep opportunity
• Augmentation of rest period following reduced rest
• Reduced maximum FDP following reduced rest
• Limiting the frequency of reduced rest occasions
• Limiting the length and number of sectors after reduced rest
• Ensuring reduced rest encompasses entire WOCL
• Specifying minimum accommodation requirements for reduced rest
• Not allowing rest reduction when FDP is extended by in-flight rest or when there is
crossing of multiple time zones
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• Special rules if reduced rest is combined with split duties (see French regulations in
Appendix 3)
• The identification via a FRMS of factors that can reduce the quality of sleep, e.g. a
noisy or uncomfortable hotel room, and resulting preventive actions.
5.9.2 Economic and Social Impacts of FTL Changes to Off-Duty Rest
Those economic impacts which are judged likely to be most significant following proposed
regulatory changes are tabulated below.
Table 5.5: Economic and Social Impacts Associated with Potential Changes to Off
Duty Rest Provisions
Potential Reference situation in Identification of generic Factors which will
change Europe impacts affect size of impacts
Removing Minimum reduced rest May need extra crew to Frequency with which
possibility for in different States varies provide services currently reduced rests are
reduced rest from: being provided by crew after currently taken.
reduced rest. Alternatively
• Sufficient to allow 10 service provision to customers
hours at may be reduced. Both have
accommodation potential economic impacts.
• 10 hours out of
home base, 12 hours
in base. Minimum of
9 hours at
accommodation
• Minimum of 10 hours
• 7.5 hours including 2
hours at least within
WOCL + mitigations
Harmonising As above. If the proposed regulatory As above.
minimum minimums are significantly
hours for different from current national
reduced rest rules, the impacts could be
similar to row above.
5.10 Relaxation and Naps During On Ground Breaks
5.10.1 Safety Impacts of FTL Changes to Relaxation and Naps during On Ground Breaks
Sections 4.6 and 4.7 review the literature related to napping between flights. If taken
between flights, a brief nap can benefit alertness and performance. The nap should be
limited to 15-20 minutes, or 90 minutes. Shorter naps (10-20 minutes) are less likely to be
associated with the phenomenon of sleep inertia (a short period of impaired alertness upon
awakening). This is because in this amount of time, the individual will usually remain in light
sleep and would not reach deep sleep. It is easier to wake up from light sleep and the
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individual will regain full alertness faster than waking up from deep sleep. In the case of long
naps, sleep periods of approximately 90 minutes allow the completion of a full sleep cycle,
and the individual wakes up from light sleep or REM sleep, which minimizes sleep inertia.
On the other hand, naps of 40-60 minutes would result in the individual waking up from deep
sleep, and that will result in more severe and long lasting sleep inertia. Sleep inertia can be
associated with a performance decrement lasting for a few minutes to 35 minutes, though
effects usually seem to dissipate in about 10 to 15 minutes (Robertson and Stone, 2002,
Rosekind et al 1994).
Another potentially negative consequence is that the nap can theoretically disrupt the
duration or quality of a later sleep period.
The CAS modeling in sections 5.3 and 5.7 above indicate that sleeps during on ground
breaks, especially during the night, can provide significant benefits in terms of managing
fatigue. In addition, providing fatigued employees with an opportunity for a nap before driving
home at the end of a long FDP will theoretically decrease the risk of accidents while driving
fatigued.
The main mitigation for the hazard of sleep inertia (E1 from Table 3.2) is awareness training
and the provision of guidance. There are no obvious FTL regulatory changes of relevance to
this hazard.
5.10.2 Economic and Social Impacts of FTL Changes to Relaxation and Naps during
Ground Breaks
The provision of awareness training and guidance as part of FRMS are not considered to
have significant economic or social impacts. If upgraded rest facilities are required to
facilitate napping between flights, this is addressed in section 5.3.2.
5.11 Hazard A2, Pilot in Command Discretion
5.11.1 Safety Impacts of FTL Changes to PIC Discretion
The facility for the PIC to extend an FDP is considered in the ranges of FDPs modeled in
Section 5.1. As well as providing maximum limits on this extension other potential
mitigations could be:
• A non-punitive process for a PIC to reduce a duty duration and/or increase rest in the
case of fatigue
• Training on fatigue to support PIC in the decision process (part of FRMS)
• Reporting to the NAA when the extension is above a certain threshold
• Guidance to the NAA on this subject.
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5.11.2 Economic and Social Impacts of FTL Changes to PIC Discretion
The main impact would be related to the duration of the extension period that is under the
PIC’s discretion. The impacts of changing extended FDP limits are considered already in
Section 5.1.
Other economic impacts will be related to the setting up and administration of any new or
updated processes related to training, reporting and guidance.
5.12 Positioning and Travelling Related Hazards
The relevant hazards are:
• Positioning before an FDP which could lead to excessive time awake towards the
end of a mission (F1, Table 3.2)
• Positioning immediately after an FDP which could lead to excessively long duty
periods with a cumulative effect (F2, Table 3.2)
• Excessive travelling time contributing to transient and cumulative fatigue (F3, Table
3.2)
5.12.1 Positioning
CAS modeling has been used to investigate positioning prior to a day FDP. The scenarios
involved an FDP from 07.00 to 20.00 with “No Positioning” prior to FDP, Positioning involving
a flight during the night with no sleep and Positioning during the night with some sleep. The
results in terms of average alertness during the FDP are shown below. Further details of the
scenario modeling are included in Appendix 4. The extra time awake caused by pre-FDP
positioning increases fatigue and this is only partially offset if sleep can be taken during the
night positioning.
Figure 5.7: Effect of Positioning on Alertness
Effect of Positioning On Alertness (all duty) During a
Daytim e FDP
90
80
Average Alertness
70
60
50
40
30
Positioning No Positioning Positioning +sleep
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The following mitigations from Subpart Q (applicable for air taxi and also applied for single
pilot operations based on the survey in Appendix 3) are relevant for positioning:
• Counting position duties as FDP when immediately prior to FDP (supported by
results above)
• Rest being based on the duty hours which counts positioning in full.
5.12.2 Travelling
The potential for excessive traveling times contributing to fatigue is relevant to AT as for
other operations. As noted in section 4 there is a lack of literature and knowledge about the
impact of travel on fatigue risk. Long travel durations prior to an FDP could lead to
excessive times awake by the end of the FDP. In section 5.7 where sequences of day FDPs
are modeled it is noticeable that the alertness during the travel home is noticeably lower for
the “long days” (see Figure 5.8 below). Figure 5.8 shows that the alertness during the travel
home can be low as long travel times push this into the late evening hours and extend the
time awake. Providing facilities for crew to nap after long FDPs can reduce road accident
risk.
Figure 5.8: Alertness during Travel Home After FDPs in Section 5.7.1
Effect of Sleep on Alertness During Travel Hom e after Day FDP
80
70
60
Average Alertness
50
40
30
20
10
0
Long Short Long Short Long Long Short Long Short Long
Day FDP Day FDP +sleep
The following mitigations are likely to be relevant in terms of flight safety:
• Nomination of a home base for each crew member (part of Subpart Q)
• Ensuring a protected 8 hour sleep opportunity (part of Subpart Q)
• Counting travel time in excess of a limit (e.g. 60 minutes) as duty time (or positioning)
• Napping during ground breaks to reduce fatigue at the end of long days created by
long duration FDPs and travel.
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The EBAA survey data (see Table 3.1) on crew travel times from home to home base
showed a mean time of 1.5 hours based on almost 750 responses. Thus introducing a limit
such as 60 minutes over which travel counts as duty time or positioning could have
significant economic impacts. If this causes movement of crew closer to bases there could
also be social impacts. Further data collection and analysis would appear worthwhile on this
topic.
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6.0 Conclusions
Air Taxi operations (ATXO) have certain characteristics that can potentially create
challenges to managing fatigue hazards. These characteristic include:
• On demand operations with the majority at short notice;
• Large amount of standby at home with a relatively low chance on average of being
called out;
• Frequent change of schedule/routing; this can include duty start times being put back
or brought forward;
• Many of the flights (especially on the small and light jet segments) leave in the
morning and come back in the evening. In between, pilots are often waiting in crew
rest facilities or on the aircraft on split duty;
• Passenger requirements can lead to planned on-ground breaks being curtailed or
alternatively ad-hoc split duties being needed;
• Considerable use is made of positioning of crew and aircraft relative to scheduled
flights; and
• Significant time zone (TZ) crossings occur for long range ATXO.
A survey of eight European States has showed that there is a range of national provisions
for addressing split duty, additional rest for TZ crossings, reduced rest, in-flight rest and
standby at the airport and elsewhere.
Single Pilot operations (SPLO) occur in the Air Taxi, scheduled airline and AEMS sectors.
They have the potential for leading to additional workload relative to multiple crew and hence
could impact fatigue. Thus long duration flights/ FDPs are addressed in some national
provisions in a variety of ways.
Given the range of national FTL provisions for ATXO and SPLO, European harmonisation of
these FTL provisions is likely to have safety, economic and social impacts. These are
investigated at a preliminary level in this report.
This report provides information and preliminary analysis to be considered for the RIA
development for RMT. 0429 on FTL for Air Taxi and Single Pilot operations with a view to
assist in an overall balanced assessment of safety, social and economic impacts.
Reference to part of this report which may lead to misinterpretation is not permissible
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8.0 Acronyms/ Abbreviations
Term Description
AAIB Aircraft Accident Investigation Board
ADREP (ICAO’s) Accident Data Reporting system
AEMS Aeroplane Emergency Medical Services
API American Petroleum Institute
ATXO Air Taxi Operations
BA Business Aviation
CAA Civil Aviation Authority
CAP Civil Aviation Publication
CAS Circadian Alertness Simulator
CAT Commercial Air Transport
CM Crew Member
CRD Comment Response Document
CS Certification Specification
CVR Cockpit Voice Recorder
d/yr Days per year
DNV Det Norske Veritas
EASA European Aviation Safety Agency
EBAA European Business Aviation Association
EEG Electro-encephalography
EMS Emergency Medical Services
ETSC European Transport Safety Council
EU OPS European Union (Safety Regulations) Commercial Air Transportation Operations
FAA Federal Aviation Administration
FDP Flight Duty Period
FDT Flight Duty Time
FMCSA Federal Motor Carrier Safety Administration
FRM(S) Fatigue Risk Management System
FTL Flight Time Limitations
GA General Aviation
GDP Gross Domestic Product
GVA Gross Value Added
h or hrs hours
ICAO International Civil Aviation Organisation
IFR Instrument Flight Rules
IR Implementing Rules
JAR OPS Joint Aviation Requirements on Commercial Air Transportation Operations
MSLT Multiple Sleep Latency Test
MWT Maintenance of Wakefulness Test
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Term Description
NAA National Aviation Authority
N/A Not Applicable
NASA National Air and Space Administration
NM Nautical Miles
NPA Notice of Proposed Amendment
N/R Not Relevant
NTSB National Transportation Safety Board
PF Pilot Flying
PIC Pilot In Command
REM Rapid Eye Movement
RIA Regulatory Impact Assessment
RMG Rule Making Group
RMT Rule Making Task
SPLO Single Pilot Operations
SRG Safety Regulation Group
TNO Nederlandse Organisatie voor Toegepast Natuurwetenschappelijk Onderzoek (Netherlands
Organisation for Applied Scientific Research)
TZ Time Zone
ULR Ultra Long Range
VFR Visual Flight Rules
VMC Visual Meteorological Conditions
WOCL Window Of Circadian Low
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Appendix 1 – Air Taxi and Single Pilot Safety Data with Fatigue as a Causal
Factor
1. Data from EASA’s Safety Analysis Section
EASA’s Safety Analysis Section conducted a search of the EASA copy of the ICAO ADREP
data base. The EASA copy of IACO ADREP data base contains 215 air taxi operations
occurrences between March 2, 1998 and March 21, 2012. Only one accident (in the US)
could be associated to pilot fatigue, meaning that in 0.5% of air taxi operations occurrences
pilot fatigue was involved.
With regards to aeroplane single pilot operations EASA’s copy of ICAO ADREP data base
contains 32046 occurrences registered until March 21, 2012. Pilot fatigue is indicated as a
contributory factor of an occurrence in 139 events. Expressed as a percentage, 0.4% of
single pilot aeroplane operations occurrences can be related to pilot fatigue. EASA’s Safety
Analysis Section have supplied narratives to 13 European occurrences; in 5 cases the
narratives specify useful information about the circumstances leading to fatigue and are
reproduced below.
Single Pilot – 5 occurrences
Occurrence 1 – 1986, UK, Britten – Norman – BN – 2A MK3 Trislander, CAT, 0 fatalities
THE PILOT TOOK OFF AT 0030 HRS FOR A NIGHT FLIGHT TO AMSTERDAM, WHICH
WAS COMPLETED WITHOUT INCIDENT. HE THEN HAD 2 HRS SLEEP AND DEPARTED
AT 0500 HRS FOR A VFR FLIGHT TO STANSTED AT 1000 FT. WHILE OVER THE SEA,
HE BRIEFLY FELL ASLEEP, DESPITE FEELING WELL RESTED. HE FELL ASLEEP
AGAIN AND THE A/C HIT THE SEA SUSTAINING SUBSTANTIAL DAMAGE TO ITS
LANDING GEAR, INCLUDING COMPLETE LOSS OF THE RIGHT GEAR. THE A/C
BECAME AIRBORNE AGAIN AND THE PILOT NOTED THAT ALL THREE ENGINES
WERE DELIVERING REDUCED POWER DUE TO CARBURETTOR ICING. THE FLIGHT
WAS CONTINUED AND THE PILOT LANDED WITH LITTLE ADDITIONAL DAMAGE TO
THE A/C. >THE CAA HAVE INSTRUCTED THAT TWO PILOTS ARE TO BE EMPLOYED
ON ALL NIGHT FLIGHTS UNDERTAKEN BY THE OPERATOR.
Occurrence 2 – 2004, France, Piper – PA – 31T Cheyenne, GA Pleasure, 3 fatalities
The pilot was on a flight from Ben Gurion Airport (Israel) to Toussus-le-Noble (France) with a
stopover at the airport in Kerkyra Corfu (Greece). He filed an IFR flight plan with a scheduled
departure at 5 am for an estimated 3hr 50min flight to Corfu. After refuelling, it took off again
from Corfu at 10.41 on an IFR flight to Toussus-le-Noble. During the VOR-DME approach to
runway 07L at Toussus-le-Noble at around 15.25, the pilot lost control and the aircraft fell in
the middle of a forest along a nearly vertical trajectory.
Probable Causes
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The loss of control probably resulted from significant airframe icing inadequately or belatedly
addressed by the pilot. The possible contributing factors to the accident were:
1) Pilot fatigue caused by 8h 30min flying single pilot operations and being faced with quick
icing phenomenon while the workload required by the approach was already high.
2) A desire to reach the destination field approach so that the pilot was excessively focused
on his objective and encouraged to continue the approach without taking sufficient account
of external phenomena.
Occurrence 3 – 2004, France, Gulfstream Aerospace – G V, GA Business, 0 fatalities
At 18:31:57, the pilot of a private business flight from New-York - La Guardia (KLGA) to
Geneva, was handed over by Marseille Control to Geneva and called on the ARRIVAL
sector control frequency. The aircraft was in the region of La Tour-du-Pin (LTP/VOR), at
flight level FL 160. The pilot was cleared by the radar controller direct to point INDIS for a
straight-in approach on runway 05, at flight level FL 160. The pilot asked the ARRIVAL radar
controller to repeat the point to which he was cleared, without reading back the flight level.
The ARRIVAL radar controller then gave him a heading of 025 degrees and the pilot read
back this clearance.
At 18:32:07, the pilot of a scheduled flight between Lyon-St-Exupéry and Rome called the
Geneva Initial South control sector (INS). The pilot was cleared by the radar controller to
change to flight level FL 150 on the route PENAR - RISOR. The pilot informed him of traffic
just above him. This was the GA business flight. The routes followed by the two aircraft
intersected perpendicularly in the region of the La-Tour-du-Pin VOR.
According to his statements, the pilot of the GA business flight thought he was cleared to
descend to flight level FL 130 and began his descent. He repeated the clearance to maintain
flight level 160. At 18:32:27, the ARRIVAL radar controller issued essential traffic
information to the pilot of the business flight, who replied that he had contact with the traffic.
The pilot received the confirmation to maintain flight level FL 160. He then asked for
confirmation that he was in fact to maintain flight level FL 160 and the radar controller again
confirmed this clearance.
Despite these urgent instructions and during their transmission, the pilot of the business
flight began a descent to flight level FL 130, to which the pilot, according to his statements,
believed he was cleared. When the two aircraft were at a lateral separation of 4.7 NM and
an altitude difference of 700ft, on converging headings, the Short Term Conflict Alert (STCA)
was activated on the controller's radar screen. According to the radar plot, the private flight
was at flight level 156. The INS radar controller immediately issued essential traffic
information to the pilot of the scheduled operator, who replied that he was following his
TCAS. Less than ten seconds later, when the routes of the two aircraft were still converging
and the separation reducing, the ARRIVAL radar controller instructed the pilot of the private
business flight to climb immediately to flight level FL 160, issuing him with further essential
traffic information. The ARRIVAL radar controller asked the pilot of the private business
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flight if he had the traffic in sight. The pilot replied that he was at flight level FL 160, adding
that he was obeying a TCAS resolution advisory.
The private flight then carried out a steep climb, passed flight level FL 160 for which he was
cleared and continued to climb to flight level FL 171.
CAUSE
The incident is due to the fact that the pilot of the private business flight left the flight level
cleared by ATC. The crew stated as the reason of this error the effect of the circadian
cycle (time difference) and fatigue.
Occurrence 4 – 2005, Scotland, Britten-Norman Islander, AEMS, 2 fatalities (also
appears in D2 report for EMS)
http://www.aaib.gov.uk/cms_resources.cfm?file=/Summary%20%20AAR%202-
2006%20Pilatus%20Britten-Norman%20BN2B-26%20Islander,%20G-BOMG.pdf
On 15 March 2005, a Britten-Norman Islander aircraft crashed into the sea while descending
toward Campbeltown Airport in western Scotland. The aircraft was operating an air
ambulance flight on behalf of the Scottish Ambulance Service. The pilot and paramedic both
died in the crash. Given the relevance of this accident to the current study quotes are taken
from the UK AAIB report below.
AAIB Report No: 2/2006 Report on the accident to Pilatus Britten-Norman BN2B-26 Islander,
G-BOMG, West-north-west of Campbeltown Airport, Scotland, on 15 March 2005
Abstract/ Summary
“The Glasgow based Islander aircraft was engaged on an air ambulance task for the
Scottish Ambulance Service when the accident occurred. The pilot allocated to the flight
had not flown for 32 days; he was therefore required to complete a short flight at Glasgow to
regain currency before landing to collect a paramedic for the flight to Campbeltown Airport
on the Kintyre Peninsula.
Poor weather at Campbeltown Airport necessitated an instrument approach. There was
neither radar nor Air Traffic Control Service at the airport, so the pilot was receiving a Flight
Information Service from a Flight Information Service Officer in accordance with authorised
procedures. After arriving overhead Campbeltown Airport, the aircraft flew outbound on the
approach procedure for Runway 11 and began a descent. The pilot next transmitted that he
had completed the ‘base turn’, indicating that he was inbound to the airport and commencing
an approach.
Nothing more was seen or heard of the aircraft and further attempts at radio contact were
unsuccessful. The emergency services were alerted and an extensive search operation was
mounted in an area based on the pilot’s last transmission. The aircraft wreckage was
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subsequently located on the sea bed 7.7 nm west-north-west of the airport; there were no
survivors.
The investigation identified the following causal factors:
1. The pilot allowed the aircraft to descend below the minimum altitude for the aircraft’s
position on the approach procedure, and this descent probably continued unchecked until
the aircraft flew into the sea.
2. A combination of fatigue, workload and lack of recent flying practice probably contributed
to the pilot’s reduced performance.
3. The pilot may have been subject to an undetermined influence such as disorientation,
distraction or a subtle incapacitation, which affected his ability to safely control the aircraft’s
flightpath.”
AAIB Section on Pilot rest
“The pilot was rostered for a night standby duty on 14 March 2005, to be conducted from
home and commencing at 2300 hrs. He had finished a two week leave period on 12 March,
and had been rostered for a day off on the 13 March. During his leave he had gone on
holiday to Italy with his family, returning to the UK on 9 March and travelling home on 12
March. He spent the remainder of the weekend at home with his family. On the evening of
13 March he had retired at about 2245 hrs and had an uninterrupted night’s sleep. On the
day of the 14 March the pilot awoke at about 0645 hrs and spent the day attending to
domestic tasks. He was called at 2136 hrs by the operations officer and notified of the
intended flight. He dressed and drove to work, arriving at about 2220 hrs. There was no
indication that the pilot attempted or achieved any sleep during the day or early evening.”
The aircraft took off about 23.30 after a short currency flight. The crash happened 15 March
2005 at 0018 hrs.
AAIB Section on Pilot fatigue
“The pilot was well rested prior to the day of the accident flight, and had achieved a normal
sleep pattern for the 72 hours prior to the accident. He reportedly achieved about seven
hours 45 minutes of sleep during the night and was not known to have suffered from any
sleep disorders that may have reduced the quality of his sleep. The average human adult
physiologically requires about eight hours of sleep for optimal performance and alertness, so
the pilot was probably close to maximum ‘sleep credit’ at the start of the day.
Although he had been rostered a night standby duty, the pilot was called only infrequently on
such duties and did not normally aim to achieve any sleep during the day. Such seems to be
the case on the day of the accident. The difficulty of achieving sleep during the day
preceding an initial night duty is well recognised, and for many individuals the best that can
be achieved is a period of rest.
How long an individual remains awake is a physiological factor that can affect performance
and alertness. Generally, performance and alertness can be maintained up to 12 hours of
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wakefulness, after which some reduction in performance occurs. Sixteen to 17 hours of
continuous wakefulness can be associated with significantly reduced performance and
alertness. At the time of the accident the pilot had been awake for 17 hours 15 minutes and
is therefore likely to have been suffering from fatigue to some extent.”
Occurrence 5 – 2005, UK, Reims – F172, GA Pleasure, 1 fatality
The pilot and aircraft had been involved in two consecutive days of banner-towing
operations. The accident occurred on a positioning flight towards the end of the second day.
Shortly after takeoff the aircraft was seen to turn left, with an increasing angle of bank, until it
stalled and impacted the ground after turning through approximately 310º. Although the
banner hook installation showed evidence of interference with the rudder, it was considered
that this was not a factor in the accident. The most likely cause was a stall following the turn
to the left with an increasing bank angle. This may have resulted from an attempt to maintain
visual contact with a point on the ground, and would have been exacerbated by an
increasing tailwind. It was also considered that the pilot may have been affected by fatigue
after the two intensive days of banner-towing. Recommendations have been made
relating to the banner hook installation and on fatigue associated with banner-towing
operations.
2. Data from Sources Other than EASA
Air Taxi
Report on the accident to Bombardier CL600-2B16 Series 604, N90AG at Birmingham
International Airport, 4 January 2002
www.aaib.gov.uk_cms_resources.cfm_file=_5-2004 N90AG.pdf
This accident on take-off caused five fatalities, two crew, two passengers and one non-flying
observer. The investigation identified the following causal factors:
1. The crew did not ensure that N90AG’s wings were clear of frost prior to take-off.
2. Reduction of the wing stall angle of attack, due to the surface roughness associated with
frost contamination, to below that at which the stall protection system was effective.
3. Possible impairment of crew performance by the combined effects of a non-prescription
drug, jet-lag and fatigue.
Flight Details and Fatigue Related Timings
N90AG was based at Dekalb Peachtree Airport (PDK), Atlanta, Georgia, USA. On 3 January
2002, the crew came on duty at 0900 hrs (0400 hrs local time in Atlanta) at PDK in
preparation for a planned flight to the UK. The aircraft and crew departed PDK at 1015 hrs
for a flight to Fort Myers Airport (FMY) in Florida to pick up a passenger. After landing at
FMY at 1135 hrs, N90AG departed at 1200 hrs for a flight to West Palm Beach Airport (PBI)
to pick up a second passenger. The aircraft landed at PBI at 1230 hrs and departed at 1259
hrs.
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After an uneventful flight, N90AG arrived at Birmingham Airport at 2039 hrs.
The aircraft was parked on the Western Apron while at Birmingham. There was no
precipitation while the aircraft was on the ground at Birmingham. Over the night of 3/4
January 2002 the air temperature remained below zero, with a minimum temperature of
minus 9°C at 0550 hrs.
The two pilots and the observer spent the night in a local hotel. Records indicated that they
checked in at approximately 2115 hrs and had a meal and some alcohol between 2144 hrs
and 2315 hrs, before retiring to bed. The handling pilot for the return to the USA made a
phone call home at 0200 hrs.
The next morning, the handling pilot and the observer arrived at the aircraft together at
approximately 1040 hrs. Aircraft refuelling commenced at about 1105 hrs and the aircraft
fuel tanks were reported full at about 1140 hrs. Then, following the arrival of the two
passengers, the aircraft doors were closed. The occupants were the same as on the arrival
flight. During the morning, various witnesses had seen frost/ice on the wing surfaces of
N90AG. Other aircraft had been de-iced during the morning, with associated reports of
severe to moderate ice accumulation. Evidence from the Cockpit Voice Recorder (CVR)
indicated that the operating pilots discussed the presence of frost on the leading edge prior
to engine start. However, neither requested deicing and N90AG was not de-iced.
Following ATC clearance, engine start was at 1156 hrs and N90AG was cleared to taxi at
1201 hrs. At 1207 hrs, N90AG was cleared for takeoff and the crash occurred shortly after.
Single Pilot Events from the USA
USA Event 1, 2004
Reference: National Transportation Safety Board. 2006. Special Investigation Report on
Emergency Medical Services Operations. Special Investigation Report NTSB/SIR-06/01.
Washington, DC.
Dodge City, Kansas
On February 17, 2004, about 0256 central standard time, a Beech BE-B90 twin engine
airplane, N777KU, operated by Ballard Aviation, Inc., was destroyed when it impacted terrain
about 5 nautical miles (nm) northwest of Dodge City Regional Airport (DDC), Dodge City,
Kansas. The single pilot, flight nurse, and flight paramedic were killed. The 14 CFR Part 91
positioning flight departed Wichita Mid-Continental Airport (ITC), Wichita, Kansas, about
0210 and was en route to DDC. Night VMC prevailed. The flight was on an IFR flight plan,
but the pilot cancelled the IFR flight plan about 37 miles east of DDC and proceeded under
VFR.
The Safety Board’s investigation revealed that the pilot had been awake for as long as 21
hours at the time of the accident. Additionally, the accident occurred 14.5 hours after his duty
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day began. Recorded radar data indicate that the airplane initiated a gradual, straight-line
descent toward the airport but flew past the airport before descending into the ground. No
communications from the airplane were made during this descent, which suggests that the
pilot was fatigued.
The Safety Board determined that the probable cause of this accident was the pilot’s failure
to maintain clearance with terrain due to pilot fatigue (lack of sleep).
USA Event 2, 2010
NTSB Identification: CEN10MA367
Nonscheduled 14 CFR Part 135: Air Taxi & Commuter operating as air ambulance
Accident occurred Sunday, July 04, 2010 in Alpine, TX
Aircraft: CESSNA 421B
Injuries: 5 Fatal.
The airplane impacted terrain shortly after takeoff. The extended landing gear and flaps
degraded the climb performance of the airplane. The single pilot held an airline transport
pilot certificate and had recent night flight experience. According to family members, the pilot
normally slept from 2230 or 2300 to 0700; the accident occurred at 0015. Although the
investigation was unable to determine how long the pilot had been awake before the
accident or his sleep schedule in the three days prior to the accident, it is possible that the
pilot was fatigued, as the accident occurred at a time when the pilot was normally asleep.
The company did not have, and was not required to have guidance or a policy addressing
fatigue management.
The National Transportation Safety Board determines the probable cause(s) of this accident
as follows: The degraded performance of the airplane due to the pilot not properly setting the
flaps and retracting the landing gear after takeoff. Contributing to the accident was the pilot’s
fatigue.
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Appendix 2 – CAS Modeling Description
Introduction
Circadian Technologies, Inc. has developed a Circadian Alertness Simulation (CAS) model
that allows the assessment of fatigue risk based on sleep-wake patterns. Since the model
includes an algorithm that predicts the most likely sleep pattern given a specific work pattern,
it allows the evaluation of duty patterns for fatigue-related risk.
The impact of duty patterns on the alertness level and the resulting fatigue risks of an
individual pilot are relatively uncertain and difficult to calculate analytically, especially if the
individual sleep characteristics of the employee are not known. Here, the application of a
simulation tool is particularly useful. Simulation models help us to understand when
situations of extreme fatigue risk occur and why.
CAS – Model Concept
The CAS concept is based on the Three-Process Model of sleep regulation. A homeostatic
component, a circadian component, and a sleep inertia component are combined to
calculate an alertness curve. Figure 1 through 3 show the steps in the process between
activity data (horizontal bars), the alertness calculation and the results output. Alertness at
any specified point in time is entirely a function of all preceding data points. It therefore
includes the effects of acute and cumulative fatigue.
Figure 1: Duty-Rest data without sleep
Based on the calculation of alertness, CAS5 predicts a sleep/wake pattern by triggering
sleep when alertness reaches a certain lower threshold. The algorithm assumes sleep and
calculates the subsequent data points assuming sleep until an upper wake-up threshold or
an activity block (e.g., work, commuting) is reached. This capability was used for the model
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validation and it allows the analysis of data where there is no information about the person’s
actual sleep pattern (e.g. duty logs, time and attendance data, proposed work schedules).
Figure 2: Duty-Rest data with sleep (black blocks)
After CAS5 has added sleep into the duty pattern, the model can now calculate an alertness
value based on the three processes mentioned before:
• Alertness decreases during duty and non-sleep and increases during sleep
(homeostatic component)
• Alertness fluctuates throughout the day (circadian component)
• Alertness is temporarily lowered after sleep depending on length of sleep and level of
alertness on wake-up (sleep inertia component).
Figure 3: Alertness curve based on Sleep-Wake-Duty pattern
The CAS5 model can adjust various parameters of the model to reflect individual sleep
profile properties (morning vs, evening type, long sleeper vs. short sleeper, habitual wake-up
time, napping propensity, etc.). These adjustments affect the alertness calculation. However,
at a planning stage there cannot be an individual profile since it is not known which specific
person will work any of the simulated patterns.
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The calculated alertness can then be used to analyze specific moments or periods in time,
i.e. alertness at the end of a duty period, alertness during a scheduled flight/sector.
Figure 4: Sleepiness During a Specified Duty Pattern
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Appendix 3 – Survey of National FTL Provisions
Air Taxi
The survey of the eight states focused on the Article 8.4 issues. These are preceded by a
table of the definitions used in different states for “Air Taxi”.
Definitions of Air Taxi (if different from EASA proposal)
UK
Air Taxi/Sole Use Charter - in the context of CAP 371, Annex B which
addresses Air Taxi/ Sole Use Charter, this term is applicable when the
operator utilises an aircraft which contains 19 or less passenger seats,
and:
a) flights are confined to an area within which the local time does not
vary by more than 2 hours, and
b) the application of in-flight relief to extend an FDP is not used.
Switzerland No information received
Spain The Spanish national regulation neither provides a definition of Air Taxi
Operations nor specific requirements for them.
Germany There is no legal definition.
France The French FTL regulation does not refer to “air taxi operations”, but
implements specific requirements for operators using :
- aircraft with a MCTOM of less than 10t or
- aircraft with MOPSC of 19 seats or less
The “non-scheduled” or “on demand” criteria are not used.
Norway EASA proposed definition used. No specific rules for Air Taxi though.
Poland EASA proposed definition used.
Czech Republic The legislative framework for the operation of aircraft in the Czech
Republic does not specify Air Taxi category. This type of operation is not
conducted under any special requirements and operators hold a
certificate for commercial air transport only. Requirements for CAT
(Aeroplanes) operators are defined in Subpart Q of Annex III to
Regulation (EEC) No 3922/91. There are no additional national
provisions.
Split Duty
UK CAP 371 applies to all air taxi operations (Section B, Para 16)
When an FDP consists of two or more sectors - one of which can be a
positioning journey counted as a sector - but separated by less than a
minimum rest period, then the FDP may be extended by the amounts
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Split Duty
indicated below.
Consecutive Hours Rest Max. FDP Extension
Less than 3 hours NIL
3-10 hours A period equal to half the rest taken
The rest period shall not include the time allowed for immediate post
flight and preflight duties, a minimum total of 30 minutes. When the rest
period is 6 hours or less it will suffice if a quiet and comfortable place,
not open to the public, is available. Rest may be taken in the aircraft on
the ground only when the crew has adequate control of the temperature
and ventilation within the aircraft, and the passengers are not on board.
If the rest period is more than 6 consecutive hours, then suitable
accommodation will be provided.
Switzerland Below is a standardized sample for the application of a split duty model
as accepted by the Swiss NAA:
A split duty must be defined and announced to the crew before the
beginning of the FDP.
Consecutive hours break Increase in FDP
0-3 hours NIL
3-7 hours ½ length of break
7-10 hours 2/3 length of break or full length if 7
hours of the break fall between 2000-0800 local time
• Parts of the FDP before and after the break may not be longer
than 10 hours.
• The total length of the increased FDP must not be more than 20
hours including the break.
• Only one break may be used for applying split duty rules.
• Split duty rules may not be combined with augmented flight crew
rules.
• Suitable accommodation must be provided if planned break is 6
hours or more or when the break is covering 3 hours or more of
the period 2200-0600. Otherwise adequate facilities must be
provided.
• If during a break for split duty the traveling time in both
directions between place of rest and airport exceeds 1 hour, any
travelling time in excess of 1 hour shall be deducted from the
break for the purposes of calculating increase in FDP.
• The time difference between where the duty starts and where it
ends shall not exceed two hours.
• No reduced rest period shall be applied immediately prior to or
after a split duty.
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Split Duty
Spain Extended FDP due to split duty = + 50% of the rest time in suitable
accommodation if,
-Minimum rest 3 hours
-Max FDP increase due to split duty of 4 hours or 50% of the time in the
rest facility, whichever is most restricted, is allowed
- Number of extended FDP due to split duty is limited to 3 times in 7 days
- Further extension not allowed; e.g. by in flight rest.
For more information, see article 5 Real Decreto 1952/2009.
Germany 1. DvLuftBO, §11 Split flight duty time
If the flight time in OPS 1.1105 or § 10 schedule is interrupted by a pause
of at least three hours and a secluded room with sleeping
accommodation is available for the member of the crew during a break in
the immediate vicinity of the airfield the related service period could be
extended up to 18 hours. Extra conditions associated with this extension
include:
• Not being PF after 10 hours
• No more than two landings planned after the break
• No more than 2 split duties within 7 consecutive days
• No more than 2 extensions within 7 consecutive days arising
from split duties + in-flight rest
France Same as for CAT operations, i.e:
a. Minimum consecutive number of hours for the break : 3h ≤ break ≤
10h
b. Maximum Flight Duty Period (FDP) based on the length of the break :
FDP< FDPmax +0.5 (break-30min)
c. Suitable accommodation for the break:
- Break <6h : comfortable and quiet place with no public access
+…(minimum conditions to be included OPS manual)
- Break ≥6h : suitable accommodation
d. Take account of non acclimitisation: crew must have spent at least 48h
in the time zone where the split duty begins, if a preceding duty was
more than 3 time zones away from home base.
For Air Taxi operations, it is of utmost importance to maintain the
possibility to take the break inside the aircraft (accommodation may not
be available for all destinations). Conditions for taking the break inside
the aircraft are the following :
- Minimal noise, temperature, light, ventilation conditions are
included in the ops manual
- Temperature and ventilation can be adjusted
- No pax is on board
- No interference with on ground operations (catering…) that
might compromise the rest during the break. Otherwise, the possible
extension is decreased by half the duration of said operations.
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Split Duty
See provisions concerning combination of split duty and reduced rest
below.
Norway The following is valid for all operators that are using Subpart Q.
Provisions for split duty are 1) break on ground counts 50%towards max
FDP provided a rest facility with bed is available 2) if break is planned to
be >4hrs then time is = 0 towards max FDP.
Poland Regulation of the Minister of Infrastructure, 2002 - Journal of Laws,
§ 13
1. If the working time is divided by a planned ground break which is
included in the timetable, the time for carrying out aviation activities,
shall be extended as follows:
1) a break of 3-6 hours and 59 minutes – extending by ½ of the
break time;
2) a break of 7-9 hours and 59 minutes – extending by 2/3 of the
break time or 1 ½ of the break time, provided that the break was
between 20:00 and 8:00 local time
2. Extending the time of carrying out aviation activities, referred to in
par. 1, before and after the break, shall not exceed 8 hours, and the
working time extended in this way shall be no longer than 18 hours.
3.Only one break is allowed in the course of one period of carrying out
aviation activities.
4.Provisions of par. 1-3 shall not apply to working time in an augmented
aircraft crew.
Czech Republic No additional national provisions to Subpart Q.
Additional Rest due to Time Zone Differences
UK Although Annex B of CAP 371 assumes time zone differences less than 2
hours, Annex E of CAP371 contains a table on rest used as guidance for
all operations. The number of days for Minimum Base Turn Around
(MBTR) is a function of Return Sector Length, Duration of Trip and Time
Zones Crossed and is given for flight crew and cabin crew separately. At
the upper end the MBTR is 5 days for a return sector length of 14 hours
+, a trip length of 96 - 216 hrs, and 7 plus hours time zone difference.
Switzerland For time difference of 4hours or more - the subsequent rest period must
be increased by 30 min. for every hour of time difference.
Spain SubpartQ-OPS 1.1110 + Article 6, Real Decree to 1952/2009;
Rotation; FDPs starting and finishing at home base, or in a place where
time difference is no more than one hour compared to the home base,
and including at least one flight crossing 4 or more time zones .
Additional rest will be achieved following the rotation and at home base
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Additional Rest due to Time Zone Differences
or in a place with time difference no more than one hour compared to
the base.
Additional rest + basic minimum rest (due to previous duty) will include 2
local nights and will be as follows:
a)When time elapsed between departure and arrival to the home base is
less or equal to 60 hours= max (36, 4 time the time difference between
the home base and the location with the greatest local time difference).
b) When time elapsed between departure and arrival to the home base is
greater than 60 hours= max (36, 6 time the time difference between the
home base and the location with the greatest local time difference).
c)With FDP extension by in flight rest, the rest defined in a) and b) will
not be in any case less than 48 hours.
Before a FDP crossing 4 or more time zones a minimum 14 hours rest
shall be respected.
Rest according to a), b) and c) could be reduced (respecting OPS 1.1110)
when: prior FDP finishing at home base a rest including 3 local night had
been provided and subsequent flight duty less than 11 hours and its
following rest includes 3 local nights as well.
Period rest between Eastward-Westward and Westward-Eastward time
zone transitions, or vice-versa, shall be at least 3 local nights. This rest
could be reduced to 2 local nights if the rest following both rotations
includes 4 local nights.
Article 12,Circular del Director General de aviación Civil, 17/12/2010;
In the computation of time differences, seasonal time corrections will not
be taken into account.
The number of rotations in 28 consecutive days or in one month is
limited to 5 for each crew member being not applicable split duty.
Germany 1. DvLuftBO, § 12 Taking into consideration resting periods between
time zone differences
If there exists between the place of commencement of the air service
and the location of the termination of air service a time zone difference
of four or more time zones, the minimum rest period is increased to 14
hours.
After return to home base, the rest in hours is determined by multiplying
the time zone difference by 8 up to a maximum of 12 time zones.
France For CAT operations :
a) Away from home base : if the preceding FDP takes the crew more than
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Additional Rest due to Time Zone Differences
3 time bands away for the time zone of departure, then rest = max
(FDP,14h)
b) At home base: if the preceding FDP took the crew more than 3 time
bands away, when returning home base, rest = 36h including 2 local
nights.
For air taxi operations, provisions in b) may be changed :
•rest _1 = max (preceding FDP;10h+time zone crossing). Rest shall
include one local night.
• if rest_1 <36h or rest_1 does not include 2 local nights, then
periodic rest referred to in OPS 1.1110 §2.1 shall include 3 local
nights and be granted at the home base.
• These changes may be implemented only under FRM.
Norway No national provisions stated.
Poland Regulation of the Minister of Infrastructure, 2002 - Journal of Laws,
§ 19. Member of the flying staff who carries out the flight in the changed
time zone may start work outside home port, provided that the rest
period uninterrupted with any duties was at least as long as the time of
aviation activities, however no less than 14 hours – when the time
difference was at least 4 hours, and no less than 16 hours – when the
time difference was at least 6 hours.
Czech Republic No additional national provisions to Subpart Q.
Basic (Reduced) Rest
UK CAP 371 Annex B Air Taxi, section 17
An aircraft commander may, at his discretion, and after taking note of
the circumstances of other members of the crew, if carried, reduce a rest
period, but only insofar as the accommodation allocated to the crew
member must be available for occupation for a minimum of 10 hours.
The exercise of such discretion, must be considered exceptional and
must not be used to reduce successive rest periods. If the preceding FDP
was extended, the rest period may be reduced, provided that the
subsequent allowable FDP is also reduced by the same amount. In no
circumstances may a commander exercise discretion to reduce a rest
period below 10 hours at accommodation.
When away from base and where an individual crew member separates
from the crew, or the crew as a whole splits up, then any use of
discretion to reduce rest becomes a decision for an individual crew
member. The decision to continue with the next flight and the
submission of an associated discretion report is the responsibility of the
relevant commander after the crew member, and operator if in a
position to do so, has informed the commander that a reduced rest
period has been taken.
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Basic (Reduced) Rest
Switzerland Rest may not be reduced below basic rest of 10 hours or as long as
previous duty whichever longer.
Spain OPS 1.1110 and Article 7, Real Decreto 1952/2009;
Rest reduction limited to 3 hours.
Minimum duration of reduced rest = 10 hours out of home base or 12
hours in base.
Minimum of 9 hours at the suitable accommodation.
Subsequent rest shall be augmented by the shortfall.
FDP following reduced rest shall be reduced by the shortfall.
Number of reduced rest occasions is limited to 3 times scheduled in 90
days.
Reduction not allowed when: pre or post-FDP is extended by in flight rest
and/or time zone crossing at the previous or next FDP.
Germany 1. DvLuftBO, §13 Shortened rest periods in special cases (OPS 1.1110
Nr.1.4.1 and 2.1)
The supervisory authority may, upon written request grant deviations
from the requirements of § 12 and in accordance with OPS 1.1110 permit
No. 1.4.1, if there are important reasons for shortening the rest period.
The minimum rest periods may be shortened by no more than two
hours. A minimum rest period of ten hours must not be reduced.
France There are French national provisions for reduced rest under CAT
operations (see Figure 1 below).
All these provisions can also be used under so called Air Taxi operations.
Yet, there are some possible variations :
- Combination of split duty and reduced rest
• if break <6h, reduced rest = max [10h; FDP-0.5*break duration]
E.g. for a 4 sectors FDP not encroaching the WOCL and a 5h30 break,
max FDP =13h-1h+1/2*(5h30 –0h30) = 14h30
If planned FDP = 13h45, then minimum rest = 13h45-0.5*5h30=11h
• if break >6h, reduced rest = max [10h; FDP-3h-0.75*(break
duration-6h)]
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Basic (Reduced) Rest
- Max 2 reduced rest between two periodic rests as per OPS 1.1110 §2.1
- If shortfall = nominal rest – reduced rest, then subsequent rest (or
alternatively , next periodic rest as per OPS 1.1110 §2.1) = minimum rest
+ shortfall
E.g. with same example as above : let us assume reduced rest = 11h15,
then shortfall = 13h45-11h15=1h30
Then the rest after the reduced rest should be = normal rest+1h30
(alternatively 36h+1h30) as a minimum
Norway No national provisions stated.
Poland Regulation of the Minister of Infrastructure, 2002 - Journal of Laws, § 17.
§ 16. If members of the flying staff comprising aircraft crew start their
work:
1) outside their home port – the employer shall provide them with
rest time which is at least as long as the previous working time, or
amounting to 10 hours, depending on which of the two is longer;
2) in their home port - the employer shall provide them with rest
time specified in point 1, however:
a) after work with a break – rest time should be at least as long as
the previous working time including break.
b) After a flight in a changed time zone – rest time should be at
least 48 hours starting from 24:00 local time on the arrival day.
§ 17.1 Rest time specified in par.16.1 may be reduced by a maximum of
3 hours, provided that rest is no shorter than 10 hours and:
1) Previous rest time was at least as long as rest time specified in
par. 16.1.
2) Number of hours by which rest was reduced is added to the next
rest time which cannot be shortened;
3) Rest time may not be reduced before or after work with a
break.
2.Rest time specified in par.16.1. a) should be increased to:
1) 36 hours – over the next 7 days, or
2) 60 hours – over the next 10 days.
3. member of the flying staff be entitled to:
1) as many days free from duties in the home port, as there are days off
in the adopted settlement period, including at least 1 free day each
month falling on a Sunday or holiday; these days can include rest
periods;
2) the allocated days off shall be notified at least 24 hours in advance and
shall be planned to make sure that they can be used in home port.
4. if over 7 subsequent days one of at least three planned work
timetables falls between 01:00 – 06:00 local time and time difference
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Basic (Reduced) Rest
between two rest locations is less than 4 hours, than the rest period of
36 hours referred to in par. 2.1. shall be extended to 48 hours.
Czech Republic No additional national provisions to Subpart Q.
Figure 1 – French Provisions for Reduced Rest and Combining with Split Duty
Weekly Rest – Adjusted Second Night Allowed (OPS 1.1110 para. 2.1)
UK No – a single day off shall include 2 local nights and be at least 34 hours
long. (CAP371, Section B, Para 20.2)
Switzerland
No information received
Spain Yes.
Germany Yes.
France Weekly rest : no difference with CAT operations except for extended FDP
due to in-flight rest.
The possibility to start the second local night as per OPS 1.1110 §2.1
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Weekly Rest – Adjusted Second Night Allowed (OPS 1.1110 para. 2.1)
exists for air taxi operations.
Norway No provision on this.
Poland No provision on this.
Czech Republic No additional national provisions to Subpart Q.
Duty Extensions due to In-Flight Rest
UK CAP371 – Minimum 3 hours, 50% of time in bunk can be added to FDP
(maximum FDP permissible shall be 18 hours for flight crew) or 33% of time in
suitable seat (40 degree recline, leg and foot support, screened from pax and
crew) can be added to FDP up to maximum of 15 hours for flight crew. (Section
B, Para 15)
Switzerland Standard limit 3 landings:
with C.Bunk:
3 Pilot: 18 hrs FDP
4 Pilot: 20 hrs
With Rest seat:
3 Pilot: 16 hrs
4 Pilot: 18 hrs
With 4 landings. Values must be reduced by 2 hrs.
No more than 4 landings allowed with augmented crew rules.
Spain Article 9 and 10, Real Decree to 1952/2009
Flight Crew;
≥ 70º pitch seats, augmented → +5h, max 16h30min
≥ 70º, double crew→ +7h, max 18h30min
≥ 45º, augmented→ +4h30min, max 16h15min
≥ 45º, double crew→ +6h30min, max 18h
‹ 45º, augmented, additional rest requirements→ +4h, max 16h
‹ 45º, double crew, additional rest requirements→ +5h30min, max 17h30min
Passenger Cabin Crew;
33% in flight-rest, max 18h30min
25% in flight-rest, max 16h30min
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Duty Extensions due to In-Flight Rest
1h in flight-rest, max 15h
Germany 1. DvLuftBO, §13
NAA may grant FDP extensions up to 18hrs max twice within 7 consecutive
days - providing crew is augmented and there is suitable sleeping arrangement
in-flight. Cannot be pilot flying if served over 12 hours.
Attachment to 1. DvLuftBO “Design, Equipment and Installation Criteria for
Flight Crew Sleeping Quarters” (includes definition of facilities)
The maximum FDP may be extended:
With one additional flight crew member:
(i) up to 15 hours with class 3 rest facilities;
(ii) up to 16 hours with class 2 rest facilities;
(iii) up to 17 hours with class 1 rest facilities;
(iv) up to 18 hours with class 1 rest facilities, if a bunk is installed;
The FDP shall be limited to 2 sectors, where 1 sector shall be over 9 hours
continuous flight time.
The minimum in-flight rest period shall be a consecutive 90-minute period for
each crew member and two consecutive hours for those crew members at
control during landing.
The cruise phase of the flight above FL 200 shall be used to maximise the
inflight rest period of those crew members at control during landing.
The whole period of time spent in the rest facility shall be counted as FDP.
The minimum rest at destination shall be at least as long as the preceding duty
period, or 14 hours, whichever is the greater.
All flight crew members shall commence their FDP at the same reporting place
if they are part of an augmented crew. No single crew member may start a
positioning sector to then augment a crew on the same flight.
France Same as for commercial air transport
a. Flight crew :
- 1 additional pilot :
• bunks (90°): FDP up to 18h
• reclinable seat (not precisely defined) : FDP up to 16h
• minimum consecutive rest of 90 minutes
b. Cabin crew (no additional cabin crew member required):
• bunks (90°): FDP up to 18h
• reclinable seat : FDP up to 16h ( near bunks for the NPA)
• minimum rest of 90 minutes
c. Sectors requirements : 4 max (-30 minutes/sector from the third) for FDP of
16h or less and 2 sectors max for FDP of more than 16h (which need bunks)
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Duty Extensions due to In-Flight Rest
d. Minimum rest at home base following extended FDP is 48h with 2 local
nights
Requirement d. above may be changed for air taxi operations :
• rest _1 = max (preceding FDP;10h+time zone crossing; 14h). Rest shall
include one local night.
• if rest_1 <48h or rest_1 does not include 2 local nights, then periodic
rest referred to in OPS 1.1110 §2.1 shall be at least 60h, include 3 local
nights and be granted at the home base.
These changes may be implemented under FRM
Norway No national provisions stated.
Poland Regulation of the Minister of Infrastructure, 2002 - Journal of Laws, § 15
§ 15.1. If the composition of multi-person aircraft crew is enlarged with
another complete crew which comprises members of the flying staff the time
of carrying out aviation activities may be extended to 18 hours, and the
uninterrupted flying time to 15 hours.
2.If the aircraft crew is enlarged with one pilot who is authorized to perform
the role of aircraft commander in a given aircraft type, the name of carrying
out aviation activities shall not exceed 15 hours, and the uninterrupted flying
time shall not exceed 12 hours.
3.the enlarged aircraft crew shall not carry out more than 2 landings in the
event referred to in par. 1 and 2.
4.if the planned time for carrying out aviation activities by members of the
flying staff comprising a multi-person aircraft crew referred to in par.1 and 2, in
enlarged crew:
1) does not exceed 16 hours – the crew which temporarily does not carry out
any activities should be provided with a reclining chair separated from crew
cabin and the passengers;
2) is 16 or more hours – the crew which temporarily does not carry out any
activities should be provided with berth separated from crew cabin and the
passengers.
Czech Republic No additional national provisions to Subpart Q.
Airport Standby & Standby Elsewhere
Airport Standby Time Standby Elsewhere
UK4 100% of Airport Standby counted Home standby and contactable duties.
towards the FDP, FDP calculated from Max duration 12 hours.
report time of the standby. (CAP 371
4
CAP 371 has variations from Subpart Q involving the maximum FDPs as a function of duty start
times and sectors (see tables below)
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Airport Standby & Standby Elsewhere
Airport Standby Time Standby Elsewhere
Section B, Para12) Up to 6 hours on home standby any
time spent on standby beyond 6 hours
Minimum rest period of 12 hours if reduces the allowable FDP by the
not called out (Section B, Para 12) same amount.
100% towards cumulative duty when
on immediate readiness during the
day and 50% between 2200 – 0800 or
if the notice period from call to report
is 3 hours or more (long call pre-
notified).
Contactable – 10 hours’ notice to
report, does not count towards
cumulative duty but contactable
periods must be notified in advance
and not be longer than 2 ½ hours in
one day.
Hotel standby follows home standby
rules.
(CAP 371,Section B, Para 12 and Para
22.3)
Switzerland
Standby at Hotel or home does not
count as duty.
Spain5 SubpartQ-OPS 1.1125 + Artículo 9, Hotel Standby;
Circular del Director General de Subpart Q-OPS 1.1125+Article 1a),
aviación Civil, 17/12/2010; Real Decreto 1952/2009;
When a FDP is immediately followed Hotel standby; is defined as the
by a standby and during this standby standby performed in the hotel
a new flight duty begins, the previous designated by the operator, providing
FDP as well as the standby will be part a suitable accommodation to the crew
of the last FDP. for adequate resting
However, when a rest period is Article 9, Circular del Director General
followed by standby and during this de aviación Civil, 17/12/2010;
standby a new FDP begins, the FDP When a FDP is immediately followed
counts from the reporting time. by a standby and during this standby
a new flight duty begins, the previous
Article 2, Real Decreto 1952/2009; FDP as well as the standby will be part
Standby shall be provided in a of the last FDP.
5
Spain’s regulations have variations from Subpart Q involving the maximum FDPs as a function of
duty start times and sectors (see tables below)
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Airport Standby & Standby Elsewhere
Airport Standby Time Standby Elsewhere
suitable accommodation ("suitable
accommodation" is defined in the Article 11.3, Real Decreto 1952/2009;
article 3 Real Decreto 1952/2009) Hotel standby period is limited to 12
hours
Article 11.3 Real Decreto 1952/2009;
Airport standby period is limited to 12 Article 11.4, Real Decreto 1952/2009;
hours % of Hotel standby vs FDP (and DP);
0% < 6 hrs, 0% FDP > 6 h, 100% DP > 6
Article 11.8 Real Decreto 1952/2009; h
When standby period goes over 8
hours and is not followed by flight Article 11.5, Real Decreto 1952/2009;
duty a minimum rest period shall be The rest period following a hotel
provided according to OPS 1.1110. standby with FDP shall be increased by
the time elapsed between the sixth
standby hour and the beginning of the
FDP
Article 11.8 Real Decreto 1952/2009;
When standby period goes over 8
hours and is not followed by flight
duty a minimum rest period shall be
provided according to OPS 1.1110
Home Standby;
OPS 1.1125+ Article 1b), Real Decreto
1952/2009;
Home standby; standby other than
airport and hotel standby
Article 9, Circular del Director General
de aviación Civil, 17/12/2010;
When a FDP is immediately followed
by a standby and during this standby
a new flight duty begins, the previous
FDP as well as the standby will be part
of the last FDP
Article 11.3, Real Decreto 1952/2009;
Home standby period is limited to 24
hours
Article 11.6, Real Decreto 1952/2009;
% of Home standby vs FDP (and DP);
0% < 12 hours, 0% FDP > 12 h, 50%
DP > 12 h
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Airport Standby & Standby Elsewhere
Airport Standby Time Standby Elsewhere
Article 11.7, Real Decreto 1952/2009;
When standby begins at home and
then changes to hotel or airport, or
vice-versa, 50% of the home standby
time will contribute as hotel or airport
standby, depending on the place
where the previous or subsequent
standby takes place.
Article 11.8 Real Decreto 1952/2009;
When standby period goes over 8
hours and is not followed by flight
duty a minimum rest period shall be
provided according to OPS 1.1110
Germany As per Subpart Q-OPS 1.1125. (3) Standby time following a rest
1. DvLuftBO §15 Standby period in which the crew member is in
1) Standby time shall be counted as their own home or an appropriate
flight duty time if flight duty time not accommodation at a particular place
separated by a rest period in where he may have the opportunity to
accordance with OPS 1.1110 sleep shall be counted as rest time.
and either The same applies to a corresponding
1. the crew member during the standby time before a rest period.
standby time has no secluded space
with sleeping accommodation No maximum duration.
available,
2. or the crew member during the
standby time has a secluded room
with sleeping accommodation
available, but the standby time is less
than two hours, unless the standby
time is spent following a rest period.
(2) If a secluded room with sleeping
accommodation is available to the
crew member, the Standby time will
be counted as a break.
France Same as for CAT operations : Same as for CAT operations:
- No impact on Duty and FDP (max FDP
At airport (or at a place required by fully available whatever the time
the operator): when crew members are called out)
- Standby is considered as duty - Limit on standby duration : 24h
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Airport Standby & Standby Elsewhere
Airport Standby Time Standby Elsewhere
- Reduction of the subsequent FDP renewable
corresponding to the standby period
spent beyond 6 hours
- Limit on Standby duration : 12h
- Minimum rest after standby with no
FDP : 11h
Norway Subpart Q - OPS 1.1125 applies. In Subpart Q applies & maximum
addition: 1) if standby is immediately standby duration shall not >14hrs.
followed by a FDP then 100% of (Valid for all operators that are using
previous standby time counts towards subpart Q) FOR 2008- 02-21 § 11.
max daily FDP & 2) if standby period is Norway.
not followed by duty period then 1) All activities shall be planned ahead
minimum rest in accordance with OPS and/or the crew shall be informed
1.110 applies. beforehand.
2) The time of start and end of the
standby period shall be defined and
the crew informed beforehand.
3) The standby time must not exceed
14 hours.
4) The flight crew shall have access to
rest in a bed during the standby
period. 5) Not counting the exceptions
below, the standby time outside the
airport shall count as 50% towards
cumulative duty hours (OPS 1.1100
1.1) and daily FDP.
6) If the standby period is preceded by
a rest period, the first 4 hours of the
standby period shall not count
towards cumulative duty hours (OPS
1.1100 1.1) and daily FDP. If called for
flight duty, item 8) below is still valid.
7) If there is no call for flight duty
between 22.00 and 06.00, the time in
this period shall not count towards
cumulative duty hours (OPS 1.1100
1.1) and daily FDP.
8) By the time being called for flight
duty, 50% of the time from the call
until start of the flight duty will count
towards cumulative duty hours (OPS
1.1100 1.1) and daily FDP.
9) If being called in the time period
06.00-22.00 with early enough
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Airport Standby & Standby Elsewhere
Airport Standby Time Standby Elsewhere
warning that the time between the
call and reporting time for flight duty
is at least 5 hours, the time between
the call and reporting shall not count
towards cumulative duty hours (OPS
1.1100 1.1) and daily FDP.
Poland Subpart Q-OPS 1.1125 - 1.2. Airport Regulation of the Minister of
standby will count in full for the Infrastructure, 2002 - Journal of Laws,
purposes of cumulative duty hours. § 21.1. Standby can be executed at the
1.4. Where the airport standby does home port, in a different local
not lead to assignment on a flight determined by the employer or by
duty, it shall be followed at least by a phone. Member of the aircraft crew
rest period as regulated by the should be capable of taking up work.
Authority. 2.Duty time limits have been specified
1.5. While on airport standby the in table No. 4:
operator will provide to the crew
member a quiet and comfortable
place not open to the public. Notification time Maximum
standby time
Regulations are being prepared by the Up to 5 hours 59 12 hours
Ministry of Transport, Construction minutes
and Maritime Economy. from 6 hours and 18 hours
more
§ 22 - 1. If duty is carried out outside
the mother port, when it exceeds 6
hours or when more than 4 hours fall
between 22:00 – 06:00 local time, the
employer shall provide respective
accommodation conditions.
2. If duty is carried out at the airport,
the employer shall provide respective
conditions for carrying out duty.
3. Time of telephone duty shall be
included in working time as 50 % of
the duty time, excluding the first 4
hours.
4. If the flight is delayed, the time
between the planned take-off hour
and the new take-off hour shall be
included in the time of carrying out
duty.
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Airport Standby & Standby Elsewhere
Airport Standby Time Standby Elsewhere
Also regulations are being prepared by
the Ministry of Transport,
Construction and Maritime Economy.
Czech Republic No additional national provisions to Subpart Q.
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Special Single Pilot Provisions
Single Pilot Provisions
UK See FDP tables – single pilot FDPs less than two flight crew.
CAP371 Section B, Para 13, Table C
Local Number of Sectors
time of
start 4 5 6 7 8+
0600- 10 9:15 8:30 8 8
0650
0700 - 11 10:15 9:30 8:45 8
1259
1300 - 10 9:15 8:30 8 8
1759
1800 - 9 8:15 8 8 8
2159
2200 - 8 8 8 8 8
0559
Otherwise provisions same as tables above.
Switzerland
No information received
Spain Article 4.2 , Circular operativa 16B;
Maximum interrupted flight time (single pilot) = 5h (+ 10% to complete stage)
Maximum FDP function of report time and number of sectors worked in
passenger operations = Table n1 in Article 5.3.1.1, Circular Operativa 16B (see
below)
Maximum FDP function of report time and number of sectors worked in cargo
operations = Table n1 in Article 5.3.1.2, Circular Operativa 16B (see below)
Article 3, Circular Operativa 16B;
Position duties shall be counted as FDP when immediately prior to an FDP
Article 5 Circular del Director General de Aviación Civil, 17/12/2010;
After 18 hours of duty (FDP+Post-FDP positioning) crew members will be able
to choose if they want to proceed to positioning or take minimum rest.
Other provisions the same as for multi-pilot crew in tables above.
Germany For single pilot (VFR) ops, maximum basic daily FDP is 10 hours and extensions
according to 2.1 to 2.7 of OPS 1.105 are not applicable.
Otherwise all provisions are same as multi-pilot crew.
France Same as for CAT operations described above except for the following:
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Single Pilot Provisions
For IFR operations or operations at night, total block hours of each FDP shall be
less than 6h
Maximum block hours for each sector shall be :
- 4h or less if the aeroplane is equipped with a full autopilot
- 2h in all other cases
Norway Max. FDP for single pilot operations is reduced by 3 hours related to ops 1.1105
1.3
Max. FDP is reduced by 30 mins. per sector from the third sector.
No other special provisions.
Poland Regulation of the Minister of Infrastructure, 2002 Journal of Laws, - §9 time for
carrying out aviation services by an aircraft single-person crew
Maximum amount of landings and time of carrying out
aviation activities
Time of 1-4 5 landings 6 landings 7 landings and
reporting for landings more
flight (time of
local Take-off
port)
0600-0659 9 hours 8 ¼ hours 8 hours 8 hours
0700-1359 10 hours 9 ¼ hours 8 ¼ hours 8 hours
1400-1759 9 hours 8 ¼ hours 8 hours 8 hours
1800-2159 8 ½ hours 8 hours 8 hours 8 hours
2200-0559 8 hours 8 hours 8 hours 8 hours
Otherwise same as for multi-pilot crew.
Czech Republic No additional provisions to Subpart Q.
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Spain
Table n1 in Artice 5.3.1.1, Circular Operativa 16B – Single Pilot, Passenger Operations
Table n1 in Artice 5.3.1.2, Circular Operativa 16B – Single Pilot, Cargo Operations
Cabin Crew Provisions if different for Air Taxi
Cabin Crew Provisions
UK No special provisions. If cabin crew are required to be carried they must comply
with all the regulations. Where they are not required by the regulations but are
carried then the Operator is encouraged to comply with all safety training
requirements.
Switzerland
No information received
Spain No special provisions for cabin crew involved in air taxi operations.
Germany No data provided.
France Provisions for cabin crew are the same as for pilots.
Norway No information received
Poland No information received
Czech Republic No additional national provisions to Subpart Q.
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Appendix 4 – CAS Model Scenarios
Colour code:
Black = sleep
White = awake
Light blue = ascent/descent
Dark blue = cruising
Teal = ground duty
Green = positioning OR travelling (depending on context)
Additional notes on CAS graphs:
Red arrow = WOCL
Time of Day = Pilot BODY time, not LOCAL time
Main report Section 5.6 - Time Zone Desynchronisation
Assuming a 3 pilot augmented crew for flights >8hr, pilots can take 90min or 3 hour in-flight
sleeps.
Flying East (flights during pilot subjective daytime): London, England > Delhi, India >
Sydney, Australia > Tokyo, Japan > London, England, Fatigue Score: 31.60
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EASA DNV & Circadian
Flying East with mitigations (extra sleep on first day, longer in-flight sleep). Fatigue score:
31.09
Effect of Extra Sleep on Alertness during an Eastbound
Long-haul Route (flights during pilots subjective day)
100
95
90
Average Alertness
85
80
Normal
75
Extra Sleep
70
65
60
55
50
Flight1 Flight2 Flight3 Flight4
Flight# of Sequence
Average alertness while flying four flights on an Eastbound business trip is improved by
obtaining extra in-flight sleep. Average alertness during flights 1-4 with a short (90 minute)
in-flight sleep (blue bars), versus a long (3 hour) nap plus extra sleep pre-trip (mauve bars).
Flight 1: London, England > Delhi, India, Flight 2: Delhi, India > Sydney, Australia, Flight 3:
Sydney, Australia > Tokyo, Japan, Flight 4 (return) Tokyo, Japan > London, England. All
flights occur during the pilot’s subjective day.
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EASA DNV & Circadian
Flying East (flights during pilot subjective night-time): London, England > Delhi, India >
Sydney, Australia > Tokyo, Japan > London, England, Fatigue Score: 43.85
Flying East (night) with mitigations (longer in-flight sleep), Fatigue Score: 30.68
Reference to part of this report which may lead to misinterpretation is not permissible
28 September 2012
Preliminary Analysis of Potential Regulatory Impacts – Air Taxi and Single Pilot Page 130
EASA DNV & Circadian
Effect of Extra Sleep on Alertness during an Eastbound
Long-haul Route (flights during pilots subjective night)
100
95
90
Average Alertness
85
80
Normal
75
Extra Sleep
70
65
60
55
50
Flight1 Flight2 Flight3 Flight4
Flight# of Sequence
Average alertness while flying four flights on an Eastbound business trip is improved by
obtaining extra in-flight sleep. Average alertness during flights 1-4 with a short (90 minute)
in-flight sleep (blue bars), versus a long (3 hour) in-flight sleep plus extra sleep pre-trip
(mauve bars). Flight 1: London, England > Delhi, India, Flight 2: Delhi, India > Sydney,
Australia, Flight 3: Sydney, Australia > Tokyo, Japan, Flight 4 (return) Tokyo, Japan >
London, England. Flights occur during some portion of the pilot’s subjective night.
Flying West: London, England > New York City, USA > Miami, USA > Rio de Janeiro, Brazil
> London, England, Fatigue Score: 42.25
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Preliminary Analysis of Potential Regulatory Impacts – Air Taxi and Single Pilot Page 131
EASA DNV & Circadian
Flying West with mitigations (extra sleep first day, longer in-flight sleep), Fatigue Score:
31.66
Effect of Extra Sleep on Alertness during a Westbound
Long-haul Route
100
95
90
Average Alertness
85
80
Normal
75
Extra Sleep
70
65
60
55
50
Flight1 Flight2 Flight3 Flight4
Flight# of Sequence
Average alertness while flying four flights on a Westbound business trip is improved by
obtaining extra in-flight sleep. Average alertness during flights 1-4 with a short (90 minute)
in-flight sleep (blue bars), versus a long (3 hour) in-flight sleep plus extra sleep pre-trip
(mauve bars). Flight 1: London, England > New York City, USA, Flight 2: New York City,
USA > Miami, USA, Flight 3: Miami, USA > Rio de Janeiro, Brazil, Flight 4 (return): Rio de
Janeiro, Brazil > London, England.
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28 September 2012
Preliminary Analysis of Potential Regulatory Impacts – Air Taxi and Single Pilot Page 132
EASA DNV & Circadian
Main report Section 5.7 - Modelling of Cumulative Fatigue, Rest and Reduced Rest
Scenario: Pilots sometimes have to fly on reduced rest, due to long FDP (13hr), long
commutes (1.5hr each way), and early starts. These scenarios are intended to compare
nights with reduced rest to those with reasonable amounts of rest.
Daytime FDP, 3 late nights (6hr sleep), 2 earlier nights (8hr sleep), Fatigue Score: 26.09
Daytime FDP, plus naps, 3 late nights (6hr sleep), 2 earlier nights (8hr sleep), Fatigue Score:
24.37
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28 September 2012
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EASA DNV & Circadian
Night-time FDP, 3 late nights, 2 earlier nights, Fatigue Score: 62.04
Night-time FDP, plus naps, 3 late nights, 2 earlier nights: Fatigue Score: 44.13
Reference to part of this report which may lead to misinterpretation is not permissible
28 September 2012
Preliminary Analysis of Potential Regulatory Impacts – Air Taxi and Single Pilot Page 134
EASA DNV & Circadian
Effect of Reduced Rest on Alertness (all duty) over Five Days
60
55
Average Alertness
50
45
40
35
30
Long Short Long Short Long Long Short Long Short Long
Night FDP Night FDP +sleep
Reduced rest does not obviously alter alertness following a long vs. short night-time FDP.
Average alertness increases over time between “Long” days (13hr FDP, 2000-0900 – 9hr
flight time) and “Short” days (11hr FDP, 2000-0700 – 9hr flight time). A 90 minute nap during
ground break improves alertness on both Long days and Short days.
Effect of Sleep on Alertness During Travel Hom e after Night FDP
80
70
60
Average Alertness
50
40
30
20
10
0
Long Short Long Short Long Long Short Long Short Long
Night FDP Night FDP +sleep
Reduced rest alters alertness during a 90 minute travel home for long and short night-time
FDP. Average alertness is reduced during travel home on “Long” days (13hr FDP, 2000-
0900 –9hr flight time) and Short days (11hr FDP, 2000-0700 –9hr flight time) and is
improved by a 90 minute nap during ground break.
Summary: Overall Fatigue Score and alertness improved with naps included for long
nights/reduced rest. When looking at travel home, naps dramatically improve alertness on
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Preliminary Analysis of Potential Regulatory Impacts – Air Taxi and Single Pilot Page 135
EASA DNV & Circadian
both short and long days. No sign of cumulative fatigue, in fact the pilots appear to adapt to
the schedule and alertness improves over the five days
Main report Section 5.12 - Positioning
Scenario: Pilots sometimes have to be positioned to an airport before they can begin their
FDP. This scenario examines how positioning could affect fatigue levels, depending on
whether the pilot is able to sleep or not during the positioning flight.
Day FDP, no sleep during positioning, Fatigue Score: 21.76
Comparison, no positioning, Fatigue Score: 7.3
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EASA DNV & Circadian
Day FDP, sleep during positioning, Fatigue Score: 14.61
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Preliminary Analysis of Potential Regulatory Impacts – Air Taxi and Single Pilot Page 137
EASA DNV & Circadian
Page Intentionally Left Blank
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DNV
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a different approach for a new reality:
EBAA/ECA Study of Fatigue in
Air Taxi, Emergency Medical
Service Commercial Air
Operations
Presentation to EASA
Cologne, 27th October 2015
Barbara Stone
and Mick Spencer
FRMSc Limited
PO Box 631, Farnham, Surrey, GU10 4RL
[email protected] +44 7879 887489
© Copyright Fatigue Risk Management Science Limited 2015
Contents
1. Introduction
2. Study objectives and methodology
3. Results – Objective data
4. Results – Subjective data
5. Conclusions
© Copyright Fatigue Risk Management Science Limited 2015
1.0 INTRODUCTION
© Copyright Fatigue Risk Management Science Limited 2015
Background
Purpose:
a. Study work-rest patterns and levels of
fatigue
– Air Taxi (AT) and Emergency Medical
Services (EMS)(fixed wing only)
– Single pilot operations originally
included in the ITT but not part of the
study
b. Assist in the development of Flight
Time Limitation and rest requirements
being considered by the European
Aviation Safety Agency (EASA)
Sponsor: European Business Aviation
Association (EBAA) in collaboration with the
European Cockpit Association (ECA)
© Copyright Fatigue Risk Management Science Limited 2015
Specific problems identified linked to FTL
Implementing rule
1. Air Taxi pilots fly fewer hours and
have fewer duty days than their
commercial equivalents (less
than 30 hours flying and around
10 duty days per month)
2. Non-scheduled operations
require more flexibility
3. Last minute changes occur at
short notice making planning
difficult
© Copyright Fatigue Risk Management Science Limited 2015
Specific problems identified linked to FTL
Implementing rule
4. Reduction in maximum daily FDP
poses a problem for the 3rd
sector as three sectors are
common in Air Taxi (one of three
is often a positioning flight)
5. Definition of acclimatised is an
issue, as application and
calculation is difficult when
planning at short notice
6. Rest time after TZ crossing,
combined with days of inactivity
7. Standby is said to be more
relaxed than airline standby
© Copyright Fatigue Risk Management Science Limited 2015
2.0 STUDY OBJECTIVES AND
METHODOLOGY
© Copyright Fatigue Risk Management Science Limited 2015
2.1 Tender requirements
Tender requirements for The European
Business Aviation Association (EBAA)/
European Cockpit Association (ECA)
study :
2. 1.1 To research a dataset of the
fatigue/alertness changes and levels of
pilots on real world flight duties in the
context of real world schedules in
business aviation.
© Copyright Fatigue Risk Management Science Limited 2015
2.1 Tender requirements
2.1.2. Separately:
a. To analyse this dataset to determine the
effects of the different aspects of
unscheduled duties and rostering
(unscheduled flights are typical for business
operations) on pilot fatigue/alertness
b. To propose scientifically based mitigation
measures to prevent fatigue from reducing
alertness to unsafe levels or adversely
affecting the health of aircrew.
c. Compare the dataset with a commercially
available fatigue model
© Copyright Fatigue Risk Management Science Limited 2015
2.2 FRMSc Approach
Objective 1
• Fatigue and sleep patterns were measured
in volunteer pilots from EBAA members
during one month of duties.
• Volunteers were recruited from both Air
Taxi and Emergency Medical Service
operations.
• Air Taxi operations included some pilots
operating across more than three time
zones in order to measure the effect of
transient, cumulative and circadian fatigue
• Measurement methods included
actiwatch recordings that are validated
against EEG measures
© Copyright Fatigue Risk Management Science Limited 2015
2.2 FRMSc Approach
Objective 2
• Sleep patterns were measured
subjectively (diary) and objectively
(actigraphy)
• Circadian rhythms were measured
by assessment of sleep adaptation
following time zone changes
• Comparison of the data with a bio
mathematical model (SAFE) has
been made
© Copyright Fatigue Risk Management Science Limited 2015
2.2 FRMSc Approach
Objective 3
The fatigue and alertness levels
experienced by pilots carrying out their
operations was measured using diaries.
© Copyright Fatigue Risk Management Science Limited 2015
2.2 FRMSc Approach
Objective 4
The differences between the impact of Business Aviation and CAT
operations on alertness levels, transient and cumulative fatigue have been
identified.
© Copyright Fatigue Risk Management Science Limited 2015
2.2 FRMSc Approach
Objective 5
The major fatigue risks affecting
Business Aviation operations have
been identified and scientifically based
mitigation measures have been
proposed.
© Copyright Fatigue Risk Management Science Limited 2015
2.3 Volunteers
Eligibility
• Home base in Europe
• Operate an aircraft with a MOPSC
of 19 or less
• Not a management pilot
• Pilots from non-commercial
Operators were eligible, provided
the Operator follows the EU-Ops
(Subpart Q) Regulations or similar
National FTL rules
• Volunteers included those from
large and small operators and no
more than 10 pilots from one
company to provide objective data
• iPad owner or have daily access for
a month
– Paper diaries introduced in order to
increase number of volunteers
© Copyright Fatigue Risk Management Science Limited 2015
2.3 Volunteers
Recruitment
• Recruitment by invitation from
EBAA and ECA to its members
• Members responded & FRMSc
followed up to determine numbers
• EBAA validated suitable volunteer
organisations
• Equipment and instructions sent
out by FRMSc
© Copyright Fatigue Risk Management Science Limited 2015
2.4 Data collection tools
Subjective
Electronic diary (iPad ‘app’)
• Self-rate level of fatigue,
workload, timing of duty
(including standby), flights, and
sleep
• Complete for one month
Questionnaire (on-line)
• Optional questions about health
• Monitor any changes in relation
to work-rest patterns/levels of
fatigue
– Complete at start, middle &
end of study
© Copyright Fatigue Risk Management Science Limited 2015
2.4 Data collection tools
Objective: Sleep
Actiwatch
• Tri-axial accelerometer measures activity and
estimates sleep duration
• Wear for one month
© Copyright Fatigue Risk Management Science Limited 2015
2.4 Data collection tools
Objective: Performance
Psychomotor Vigilance Task
A rectangle
• Measures reaction time using an iPad is displayed
on the iPAD
app
• 3 minute task The stimulus
• Practice before study appears in the
rectangle
– Three occasions
• During the study
Responding
– On report to the
stimulus by
– Before top of descent of each pressing the
screen will
sector change the
rectangle
colour from
red to yellow
© Copyright Fatigue Risk Management Science Limited 2015
2.5 Circadian adaptation to time zone changes
Monitor the internal ‘body clock’
after time zone changes of more than
3 hours
• Planned to measure melatonin
levels in urine
– Insufficient volunteers
• Revised to an assessment of the
adaptation of sleep patterns
– Paper diary survey of sleep on
returning home after >3 h
time zone change & until the
next flight
© Copyright Fatigue Risk Management Science Limited 2015
2.6 Considerations
Anonymity
– Ensures that data cannot be
traced back to an individual
– Increase the quality and quantity
of data collected
© Copyright Fatigue Risk Management Science Limited 2015
3.0 RESULTS – OBJECTIVE DATA
© Copyright Fatigue Risk Management Science Limited 2015
3.1 Sleep
Actiwatches were provided to 57 pilots, of these, 35 pilots (14 EMS) submitted usable
watch & diary data (with 619 sleep periods recorded in both the watch & diary)
• Sleep period time (SPT) was over-estimated in the diary by 17 minutes on average,
compared with actigraphy (mean diary SPT of 7.27 h; mean watch SPT of 6.99 h)
• Overall, there was a good linear fit (R2 = 0.865) between the two sources of data
© Copyright Fatigue Risk Management Science Limited 2015
3.2 Performance
34 pilots (17 EMS) with usable diary data also volunteered to carry out the PVT
• Only 14 pilots (6 EMS) completed at least one PVT in-flight
• There were insufficient data to analyse as the proportion of PVTs completed in-
flight was less than one third of the total number of flights operated by these pilots
Several logistical issues affected PVT usability and contributed to the lack of data
• Some pilots considered that the PVT was not compatible with piloting an aircraft,
particularly when operating multiple, short-duration flights
• Pilots found the PVT App cumbersome e.g. input of the username and password
each time the task was carried out
• Data were not readily transmitted when in range of an internet connection
Recent research suggests that the PVT is not a sensitive measure of aircrew
performance, contrary to previous publications, as pilots maintain a fast response
speed even after sleep loss (Gander et al, J Sleep Res, 2015; 24(1):110-119)
© Copyright Fatigue Risk Management Science Limited 2015
4.0 RESULTS – SUBJECTIVE DATA
© Copyright Fatigue Risk Management Science Limited 2015
4.1 FATIGUE AND HEALTH SURVEY
© Copyright Fatigue Risk Management Science Limited 2015
Demographics
Questionnaire completed by 78 pilots, of which, 71 completed a diary
• Approx. one third were EMS pilots
• The majority (94%) were male Number of
• 73 males (24 EMS pilots) pilots
• 5 females (1 EMS pilot) 25
EMS
• Age 40.4 years on average
ATXO
• Half of AT pilots >40 years 20
• One third of EMS >40 years All pilots
15
Mean Range
N (years) (years) 10
EMS 25 38.8 25 – 59
5
Air taxi 53 41.1 24 – 58
All 78 40.4 24 – 59 0
≤25 30 35 40 45 50 55 60
pilots
Age (years)
© Copyright Fatigue Risk Management Science Limited 2015
Home bases of the pilots
Pilots were based across 38 airports in 13 European countries
• Majority (87.2%) based in CET time zone (68 pilots; 24 EMS)
• Others in UTC (10 pilots; 1 EMS)
Number of pilots
18
EMS
16
14 ATXO
12 All pilots
10
8
6
4
2
0
© Copyright Fatigue Risk Management Science Limited 2015
Experience in pilot role
AT pilots reported being more
experienced in the pilot role Number of
• 20% reported > 20 years’ pilots
experience 30
25
EMS
Mean Range ATXO
20
N (years) (years) All pilots
EMS 23 8.8 0 – 18 15
Air taxi 50 13.2 0 – 38 10
All 73 11.8 0 – 38
pilots 5
Data source 0
• Diary data from 73 pilots 0 1-5 6 - 10 11 - 15 16 - 20 21 - 25 26 - 30 31 - 35 36 -40
• Three of these pilots did not provide Experience (years) in pilot role
any work/rest data
© Copyright Fatigue Risk Management Science Limited 2015
Commuting time
Typical commute to home base
• ≤ 30 minutes for ~80% of EMS
• ≤ 1 hour for ~75% of AT Number of
pilots
• Long commutes (6 to 7 hours)
40
for two EMS pilots, who
EMS
stayed on base 35
ATXO
30 All pilots
Mean Range 25
N (hours) (hours)
20
EMS 23 0.9 0–7
15
Air taxi 50 0.9 0.1–3
10
All 73 0.9 0– 7
5
Data source
• Diary data from 73 pilots 0
• Three of these pilots did not provide 0.5 1 1.5 2 3 4 5 6 7
any work/rest data Commuting time (hours)
© Copyright Fatigue Risk Management Science Limited 2015
Total duty hours – last two weeks
> 30 and < 70 duty hours in the last two weeks
• 55% of the EMS and half of the AT samples
> 70 hours duty hours in the last two weeks
• 15% of the EMS and 22% of the AT samples
Proportion of responses (%)
20%
EMS
ATXO
15%
10%
5%
0%
10 20 30 40 50 60 70 80 90 100 110 120
Total duty hours in the last two weeks
© Copyright Fatigue Risk Management Science Limited 2015
Maximum hours on duty at any one time
The maximum single duty period (excluding Standby) in the last two weeks
• >10 and <20 hours in 75.5% and 72.8% of the EMS and AT samples, respectively
• The longest single duty period was 28.25 hours, which involved positioning flights
Proportion of responses
(%)
40%
EMS
35%
ATXO
30%
25%
20%
15%
10%
5%
0%
8 10 12 14 16 18 20 22 24 26 28 30
Maximum single duty period (hours)
© Copyright Fatigue Risk Management Science Limited 2015
Duties starting before 07:00 (local time)
• Early starts were reported by 56.6% of EMS and 60.2% of AT samples
• Approx. half of the total sample reported one to three such duties in the last two
weeks
Proportion of responses (%)
50%
EMS
40%
ATXO
30%
20%
10%
0%
0 1 2 3 4 5 6
Number of occasions duty started before 07:00 (last two weeks)
© Copyright Fatigue Risk Management Science Limited 2015
Duties finishing after 23:00 (local)
Late finishes were reported in around half of the questionnaires
• 43.4% of the EMS and 46.3% of the AT samples reported one to three such duties in
the last two weeks
Proportion of responses (%)
50%
EMS
40%
ATXO
30%
20%
10%
0%
0 1 2 3 4 5 6 7
Number of occasions duty finished after 23:00 (last two weeks)
© Copyright Fatigue Risk Management Science Limited 2015
Number of overnight flights
• No overnight flights* were reported by approximately half of EMS and nearly two
thirds of AT samples
Proportion of responses (%)
70%
60% EMS
50% ATXO
40%
30%
20%
10%
0%
0 1 2 3 4 5 6 10
Number of overnight flights (last 2 weeks)
* Any duty partially or fully overlapping the hours 02:00 – 05:59
© Copyright Fatigue Risk Management Science Limited 2015
Nights away from home base
• More than one third of the EMS sample were never away from home base
overnight
• Two thirds of the AT sample were away from home base for 5 – 14 nights
Proportion of responses (%)
40%
30%
EMS
ATXO
20%
10%
0%
0 1 2 3 4 5 6 7 8 9 10 - 14
Number of nights away from home base (last two weeks)
© Copyright Fatigue Risk Management Science Limited 2015
Maximum time zone change
• 1 to 3 hour TZ change reported in approx. 20% of EMS and 40% of AT samples
• > 4 hour TZ change reported approx. three times more frequently in AT than EMS
(12% of AT westward and 19.4% of AT eastward)
Proportion of responses (%)
Westward Eastward
80%
70%
60%
EMS
50%
ATXO
40%
30%
20%
10%
0%
-11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 0 1 2 3 4 5 6 7 8 9 10
Maximum time zone change (hours)
© Copyright Fatigue Risk Management Science Limited 2015
Number of days feeling ‘jet-lagged’
• Around one fifth reported feeling ‘jet-lagged’ for 1 – 4 days in the last two
weeks
• A longer period of ‘jet-lag’ (5 to 13 days) was reported by 7.4% of the AT
sample
Proportion of responses (%)
80%
70%
EMS
60%
ATXO
50%
40%
30%
20%
10%
0%
0 1 2 3 4 5 6 7 8 13
Number of days feeling 'jet-lagged' (last two weeks)
© Copyright Fatigue Risk Management Science Limited 2015
Minimum notice of duty from Standby at home
Standby was reported in approx. one third of the total sample
• ≤ 0.5 hours’ notice in nearly a quarter of EMS (N=25 responses from 12 pilots)
• These pilots either stayed on base or lived within a 15 minute commute to base
• ≤ 0.5 hours’ notice in one fifth of the AT (N = 37 responses from 25 pilots)
• Three of the six pilots were ≤ 0.5 hour commute to base
Proportion of responses (%)
25%
EMS
20%
ATXO
15%
10%
5%
0%
0.5 1 1.5 2 3 4 8 12 16 24 48 72 168
Minimum notice of duty (hours) from Standby at home (last two weeks)
© Copyright Fatigue Risk Management Science Limited 2015
Standby hours – not called out
• ≤ 48 hours in approx. one third of EMS and nearly two thirds of the AT samples
• Next most frequently reported period of time spent on Standby in previous 2 weeks
• EMS pilots: 120 and 192 hours (20% of the sample)
• AT pilots: ≥ 48 and ≤ 96 hours (~25%); 120 to 192 hours (~20%)
Proportion of responses (%)
25%
20%
EMS
ATXO
15%
10%
5%
0%
0 12 24 36 48 60 72 84 96 108 120 132 144 156 168 180 192
Total Standby hours (not called out) in the last two weeks
© Copyright Fatigue Risk Management Science Limited 2015
Performance affected by fatigue
• 60% of EMS and ~40% of the AT considered performance was affected by fatigue
• More than half reported this occurred once and approx. 40% reported that it
happened several times
Was performance affected Frequency performance was
Proportion of by fatigue? Proportion of
responses (%) responses (%) affected by fatigue
60% 60%
EMS EMS
50% 50%
ATXO ATXO
40% 40%
30% 30%
20% 20%
10% 10%
0% 0%
Not applicable (no duties) No Yes Once Several times Fairly often
© Copyright Fatigue Risk Management Science Limited 2015
Factors contributing to fatigue
In both EMS & Air Taxi
• Long duty hours were cited most
frequently (~15%)
• 2nd was poor sleep (~10%)
• Within the five most reported factors, EMS
were night duty and high workload
Only EMS pilots reported
• Early starts and the number of
sectors/multiple landings among the
top five factors
Only AT pilots cited
• Time zone changes among the top five
factors
The latter two findings reflect the Air Taxi
different nature of the two operations
© Copyright Fatigue Risk Management Science Limited 2015
Health questionnaire
• Medication to assist sleep was taken by a small proportion (8.2%) of the sample
(170 questionnaires received from respondents willing to answer this question)
• Two types of medication were cited
• Sleep promoting
• zolpidem (prescription drug); melatonin (synthetic hormone);
diphenhydramine and doxylamine (antihistamines)
• Pain relief
• paracetamol and ibuprofen
• Pilots agreed to answer questions about their health on the majority (93%) of
occasions (of 175 questionnaires received)
• However, two thirds did not follow the instructions to review all of the
symptoms/conditions listed and indicate whether any applied
• It was therefore not possible to assess any changes to these symptoms/conditions
during the study to explore whether they were affected by the pattern of duty
© Copyright Fatigue Risk Management Science Limited 2015
Health questionnaire – symptoms reported
• The symptoms/conditions were reviewed by 31 pilots (8 EMS); 4 had no symptoms
• The five most frequently reported symptoms/conditions were
• Musculo-skeletal conditions, colds/’flu, headaches/migraines, problems with
early awakening and problems falling asleep
© Copyright Fatigue Risk Management Science Limited 2015
4.2 CIRCADIAN RHYTHM
© Copyright Fatigue Risk Management Science Limited 2015
Jet-lag questionnaire
There were insufficient long-range flights to carry out a meaningful analysis
• The descriptive results from the usable data (14 questionnaires from 9 pilots), show
the typical pattern of a more rapid adaptation of sleep after the westward return
• Westward return (6-7 hours) after 5.5 days away (range 1-11 days)
• Eastward return (6-7 hours after 4.1 days away (range 2-11 days )
Westward (6 to 7 hours) Eastward (6 to 7 hours)
© Copyright Fatigue Risk Management Science Limited 2015
4.3 ANALYSIS OF THE SUBJECTIVE DIARY
DATA
© Copyright Fatigue Risk Management Science Limited 2015
The sample
• Data were collected from 87 pilots, from the
following three main groups:
– Emergency Medical Services (EMS) – 33 pilots
– Air Taxi – 43 pilots
– Air Taxi (non-commercial) – 11 pilots
• 79 pilots completed the app, and 8 (3 Air Taxi and 5
EMS) returned a paper diary
• The analysis has been based on all three groups
combined, except where there were significant or
substantial differences between the individual
groups.
© Copyright Fatigue Risk Management Science Limited 2015
Numbers of days and FDPs covered
• Information was obtained from 837 flight duty
periods (FDPs) during a total of 2610 elapsed days.
• The breakdown among the three groups was as
follows:
EMS Air Taxi Air Taxi (nc)
FDPs 280 443 114
Days 714 1448 448
© Copyright Fatigue Risk Management Science Limited 2015
Total FDP and other duty hours
EMS Air Taxi Air Taxi (nc) Total
Total FDP hours 2820 3621 920 7361
Standby unspecified 919 435 213 1567
Standby hotel 34 1506* 26 1566
Standby home 366 866 23 1255
Other activity 460 266 418 1144
Commuting 204 669 128 1001
Check in 34 154 54 242
Standby at airport 200 27 0 227
Simulator Training 31 163 22 217
Positioning 4 118 2 123
Waiting 3 25 0 28
Check out 1 10 1 12
Total 5076 7860 1807 14744
*including 1206 hours away from base
© Copyright Fatigue Risk Management Science Limited 2015
Rates of working
• Based on the elapsed number of days in the data set, the
overall average number of flying hours per day was 1.4, in
FDPs averaging 2.8 hours, with 1.8 hours of standby:
Hours per day EMS Air Taxi Air Taxi (nc)
Flying 2.04 1.15 1.09
FDPs 3.95 2.50 2.05
Standby 2.13 1.96 0.58
• The equivalent rates per year were as follows:
Hours per year EMS Air Taxi Air Taxi (nc)
Flying hours 743 419 399
FDP hours 1443 913 750
Standby 777 715 213
© Copyright Fatigue Risk Management Science Limited 2015
Average hours per FDP
EMS Air Taxi Air Taxi (nc) Combined
Flights 5.19 3.75 4.29 4.30
Check in 0.63 0.83 0.96 0.78
Waiting 0.39 0.58 0.71 0.53
Check out 0.14 0.33 0.42 0.28
Other activity 0.30 0.13 0.55 0.24
Standby unspecified 0.60 0.09 0.00 0.24
Standby at airport 0.39 0.08 0.00 0.17
Positioning Type A 0.02 0.34 0.00 0.19
Positioning Type B 0.06 0.09 0.01 0.07
Standby home 0.34 0.01 0.00 0.12
Standby hotel 0.05 0.02 0.00 0.03
Unspecified hours 1.96 1.92 1.23 1.84
Total 10.07 8.18 8.17 8.80
© Copyright Fatigue Risk Management Science Limited 2015
Sleep during the FDP
• Naps were recorded during 58 (7%) of the 839 FDPs,
of which 29 were in-flight.
• In-flight naps were mostly on Air Taxi (17) or non-
commercial (nine) operations.
• In-flight nap duration 50%
was 74 minutes on 40%
average. 30%
• The duration of the 20%
flights on which naps 10%
occurred was 7.6 0%
hours on average. Bunk Business class Flight deck / Other
economy
© Copyright Fatigue Risk Management Science Limited 2015
Distribution of FDPs over the 24-hour day
© Copyright Fatigue Risk Management Science Limited 2015
Multiple sector duties
• Approximately 35% of all
FDPs were single sector, and
approximately 34% two
sector.
• Six per cent were more than
four sector.
• EMS operations had a
relatively small proportion of
single-sector duties (17%). 14
12
• Mean duty hours increased 10
mean fdp
duration
from six (single-sector) to 12
hours
8 mean flying hours
(four or more sectors). 6
4
• Mean total flying hours 2
varied between four and six. 0
1 2 3 4 5 6
no of flights
© Copyright Fatigue Risk Management Science Limited 2015
Sequences of consecutive FDPs
• 44% of all sequences
consisted of a single
FDP.
• Single FDPs were
slightly less common in
EMS operations.
• Four or more
consecutive duties
accounted for 17% of
all sequences.
© Copyright Fatigue Risk Management Science Limited 2015
Sequences of consecutive rest days
• One rest day defined as 30 hours off, including two local nights.
© Copyright Fatigue Risk Management Science Limited 2015
Number of schedules with time-zone crossings
Maximum time-zone No. of schedules • There was a wide variety in
change (hours) East West the types of schedule:
3 7 3 – direction (east / west)
4 4 2 – number of time zones crossed
5 2 3 – time of day of the flights
6 3 3 – the length of time away from
7 1 5 base
8 3 0 – the total number of flights
9 0 0 undertaken
10 1 0 • Hence the data are
11 0 1
insufficient to draw clear
Total No. of schedules 21 17
conclusions
© Copyright Fatigue Risk Management Science Limited 2015
Recovery (app only)
• Pilots were asked, at the start of each FDP, to assess the
extent they had recovered from the previous duty or
sequence of duties.
• Responses were on a 10-point scale, where ‘one’ represented
fully recovered.
• The table shows the replies as percentages within each group.
• A large majority in every group (particularly Air Taxi) reported
being fully recovered.
Extent of recovery Proportion (%) of responses
(‘1’ = Fully recovered) EMS Air Taxi Air Taxi (nc) Combined
1 73.9 83.2 92.8 81.4
2 to 4 19.3 11.2 2.9 12.8
>4 6.8 5.6 4.3 5.8
© Copyright Fatigue Risk Management Science Limited 2015
Workload (app only)
• Pilots were asked to assess the workload of each activity they
carried out.
• Responses were on a 100-point scale, where ‘one’
represented the lowest workload, and the default value was
50.
• The table shows the replies as percentages within each group
for the workload of each flight.
Workload Proportion (%) of responses
‘1’ (low) to ‘100’ (high) EMS Air Taxi Air Taxi (nc) Combined
<50 6.6 2.5 0.0 3.8
50 70.3 69.5 93.7 73.4
51 to 69 11.1 12.1 3.4 10.4
≥70 12.0 15.9 2.9 12.4
© Copyright Fatigue Risk Management Science Limited 2015
Hassle factors
• Pilots were asked whether there were any significant hassle factors
associated with a particular duty.
• The percentage of flights associated with individual hassle factors are
shown in the table.
Proportion (%) of flights
Hassle factor
EMS Air Taxi Air Taxi (nc) Combined
Weather 24.7 12.3 1.9 16.1
Time pressure 6.8 11.6 2.9 8.5
Terrain 13.4 3.2 0.0 7.0
Air Traffic Control 6.5 5.1 1.4 5.2
Aircraft or Equipment 5.3 6.2 1.4 5.2
Delay 3.6 7.3 0.0 4.8
Visibility 7.4 1.4 0.0 3.7
Human factors 2.3 4.5 1.9 3.3
Team factors 2.0 3.3 0.5 2.4
Air Traffic congestion 2.1 2.6 0.5 2.1
Inexperience 1.5 1.4 0.0 1.3
Other 3.8 5.3 1.0 4.1
© Copyright Fatigue Risk Management Science Limited 2015
Fatigue
• At the start and end of every activity, pilots were
asked to assess their level of fatigue on a the seven-
point Samn-Perelli (SP) fatigue scale, from 1: fully
alert, wide awake, to 7: completely exhausted,
unable to function effectively.
• This scale has been used extensively on aircrew
fatigue studies.
• In the internet application, the default value was set
to 1.
© Copyright Fatigue Risk Management Science Limited 2015
Fatigue at the start and end of an FDP
• Mean values at the start were similar across the three groups
(2.09, 2.13, 2.20 for EMS, AT and ATnc respectively.
• Mean values at the end were 3.52, 3.37 and 2.96 respectively.
© Copyright Fatigue Risk Management Science Limited 2015
Fatigue related to duty length and number of
flights
5 5.0
4.5 4.5
4 4.0
fatigue
fatigue
3.5 3.5
3 3.0
2.5 2.5
2 2.0
less than between 4 between 6 between 8 between greater 1 2 3 4 5 6 7
4 and 6 and 8 and 10 10 and 12 than 12
number of flights
duration of FDP (hours)
• There was a rising trend in fatigue related to the length of
duty and (less clearly) to the number of individual flights.
• These are raw means, uncorrected for other factors (e.g.
for each other or for time of day).
© Copyright Fatigue Risk Management Science Limited 2015
Derivation of a model for fatigue at the end of a
duty period
• Statistical modelling of the data was carried out in order to:
– determine the effect of individual factors, corrected for the effects of
all other significant factors,
– enable comparisons to be made with models for other types of
operation.
• The models used were mixed model analysis of variance /
regression, with pilot as the single random factor.
• Other factors investigated included length of duty, number of
flights, duration of other activities (standby, waiting, etc.),
duties on consecutive days, and type of operation (EMS / Air
Taxi / Air Taxi nc).
© Copyright Fatigue Risk Management Science Limited 2015
Effects of different types of activity on fatigue
• Fatigue at the end of an Positioning (A)
FDP depended on the Positioning (B)
amount of different types Flight (stick time)
of activity that had been
carried out. Waiting
• The most rapid increases Airport Standby
were associated with Check Out
positioning (but standard Unspecified time
errors were large due to
the small amounts of these Check In
types of activity). Other Activity
• The activity with the most Other Standby
significant effect was flying. -0.10 0.00 0.10 0.20 0.30 0.40 0.50
Increase in fatigue per hour
© Copyright Fatigue Risk Management Science Limited 2015
Simplified model based on activity
• Based on the initial calculations,
0.30
a simplified model for the effect
of activity was constructed.
0.25
• Activities were classed as
Increase in fatigue per hour
‘Positioning (types A and B), 0.20
‘Flight (stick time)’ and ‘Other
Activity (everything else). 0.15
• On average, every hour of
positioning contributed 0.25 to 0.10
the fatigue score, every hour of
flying 0.13, and every hour of 0.05
other activity approximately
0.00
0.06.
Positioning Flight (stick Other
• There were no significant time) Activity
differences with type of
operation.
© Copyright Fatigue Risk Management Science Limited 2015
Time of day
• The variation in fatigue with
time of day was similar to 4.5
that in many other aircrew
studies. 4.0
fatigue
• After correcting for the 3.5
amount of activity, mean
levels of fatigue at the end 3.0
of an FDP are shown 2.5
alongside. 00-06 06-12 12-15 15-18 18-21 21-00 00-06
• A sinusoidal fit has an time of day
amplitude of 0.54 (1.07 from
peak to trough), and an
acrophase of 05:45.
© Copyright Fatigue Risk Management Science Limited 2015
Number of flights and number of consecutive
duties
• Number of flights: 5.0
– the no. of flights had no 4.5
significant effect on fatigue 4.0
fatigue
after correcting for the amount 3.5
of activity 3.0
– this is despite a slight increase 2.5
after more than three sectors 2.0
• Number of consecutive 1 2 3 4
number of flights
5-7
duties: 5.0
– the no. of consecutive duties 4.5
had no significant effect on 4.0
fatigue
fatigue
3.5
– mean levels were somewhat
3.0
higher after four or more
consecutive duties 2.5
2.0
1 2 3 4 5-7
number of consecutive duties
© Copyright Fatigue Risk Management Science Limited 2015
Summary
• Fatigue at the end of an FDP contains three main
components:
1. a time of day effect, with peak fatigue in the middle of the night,
2. the total duration of the FDP,
3. the proportion of the duty taken up by flying or travelling /
positioning. 100
• Typically, time during a duty 90
80
percentage of duties
period was roughly equally 70
divided between flying and 60
50
non-flying. 40
•
30
Fewer than 8% of duties had a 20
ratio of more than 4:1 flying to 10
0
non-flying. 0.0 0.2 0.4 0.6 0.8 1.0
proportion of flying time
© Copyright Fatigue Risk Management Science Limited 2015
Differences between the types of operation
• The EMS crews tended to have a higher work-rate
– they did more flying
– they had longer FDPs
– they worked more in the late evening and overnight than
the Air Taxi crews
• However, there was no significant difference
between roles in the number or strength of the
factors contributing to fatigue
– i.e. the same model applied across all operations
© Copyright Fatigue Risk Management Science Limited 2015
Comparison with the SAFE model
• This figure shows a comparison
between the fit derived from this 6
data set and the prediction of the best fit (50% flying)
SAFE model: 5
SAFE prediction
– based on a duty period starting at
FDP,
4
– the fit assumes 50% flying,
fatigue
– the SAFE prediction, is based on a
single-sector two-crew operation. 3
• There is good agreement, allowing
for a normal margin of error. 2
• SAFE predicts higher fatigue on very
long duties, but these are beyond the 1
1 3 5 7 9 11 13 15 17 19
range of most of the data.
time on duty (h)
© Copyright Fatigue Risk Management Science Limited 2015
Comparison of a high workload with the SAFE
model
• This comparison is based 6
on the same duty times, best fit (80% flying)
with a higher level of 5
SAFE prediction
workload:
– the fit assumes an 80% 4
fatigue
workload,
3
– the SAFE model is based on
a four-sector duty.
2
• The two predictions are
very close between 14 1
1 3 5 7 9 11 13 15 17 19
and 16 hours. time on duty (h)
© Copyright Fatigue Risk Management Science Limited 2015
5.0 CONCLUSIONS
© Copyright Fatigue Risk Management Science Limited 2015
Conclusions (1)
• As in normal commercial operations, the build-up in fatigue
during an FDP is determined mainly by the time of day and
the duration of duty.
• However, the amount of flying is also an important influence,
rather than the number of sectors.
• Although EMS pilots have longer duty hours, the factors
contributing to fatigue are the same as for Air Taxi operations.
• There are insufficient data to determine the effects on fatigue
of trans-meridian flights in these operations
• Positioning / commuting during an FDP is especially fatiguing
© Copyright Fatigue Risk Management Science Limited 2015
Conclusions (2)
• The work in EMS/AT operations is relatively low in terms of
– cumulative flying hours
– total days free of duty
– consecutive days of duty
• Little significant increase in fatigue with number of sectors
(when controlling for flying time).
• Based on these considerations, and after controlling for
workload and flying time, it is possible to envisage a modified
approach to controlling fatigue in these operations, for
example:
– by relaxing the link between max FDP and number of sectors,
– by permitting 1h extensions outside the WOCL as standard,
– by relaxing the link between minimum rest and the duration of the
previous duty (but only when the rest is overnight).
© Copyright Fatigue Risk Management Science Limited 2015
Questions
© Copyright Fatigue Risk Management Science Limited 2015
European Aviation Safety Agency
Notice of Proposed Amendment 2017-17
Development of FTL for commercial air transport operations of emergency
medical services by aeroplanes and helicopters
and
Update and harmonisation of FTL for commercial air transport by aeroplane
for air taxi operations and single-pilot operations taking into account
operational experience and recent scientific evidence
RMT.0492 & RMT.0493
EXECUTIVE SUMMARY
The objective of this NPA is to develop a harmonised set of flight time limitation (FTL) rules for each of the following types
of operation:
— air taxi operations (ATXO) and emergency medical service operations with aeroplanes (AEMS),
— single-pilot operations (scheduled as well as on demand), and
— emergency medical operations with helicopters (HEMS).
This NPA proposes amendments to Subpart FTL of Part-ORO by extending its scope to the aforementioned types of
operation. Notably, references to new certification specifications have been introduced to enable the description of
detailed safety objectives and prescriptive elements for each type of operation.
For ATXO, the proposed amendments are expected to improve safety, especially during night duties, increase efficiency
and at the same time ensure harmonisation across the European Union (EU).
From an FTL perspective, AEMS is a subset of ATXO. Therefore, a transition between air taxi operation and emergency
medical operation would be possible within the same duty period. The proposed amendments are mainly expected to
improve safety during night duties.
Duties, flight time and rest periods in HEMS operations are currently regulated at national level. Overall, the proposed
changes are expected to improve safety where scientific principles have not been used so far and ensure harmonisation
across the EU.
All proposed amendments are fully aligned with the ICAO Standards and Recommended Practices (SARPs).
The proposed amendments affect:
— EASA, because the scope of Subpart FTL is extended to cover additional types of operations, thus leading to (1) a
potential increase in the number of evaluations of individual flight time specification schemes the EASA is
mandated to carry out and (2) extending the scope of the implementation support provided to Member States;
— Competent authorities as they will have to bear the implementation effort;
— Operators (ATXO, AEMS and HEMS) who will have to bear the implementation effort, but will reap efficiency gains
and benefit from a level playing field and improved safety;
— Aircrew members who will benefit from improved harmonisation, safety and efficiency.
Action area: Operators other than airlines
Affected rules: Regulation (EU) No 965/2012; Part-ORO; AMC/GM to Part-ORO; CS-FTL.1; CS-FTL.2 (new); CS-FTL.3 (new)
Affected stakeholders: HEMS operators; CAT aeroplane operators of air taxi and AEMS operations; aircrew members;
competent authorities; EASA
Driver: Level playing field Rulemaking group: Yes
Impact assessment: Full Rulemaking Procedure: Standard
21.8.2012 27.10.2017 2018/Q1 2018/Q3 2018/Q3
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Table of contents
Table of contents
1. About this NPA ..................................................................................................................................... 3
1.1. How this NPA was developed ...................................................................................................................3
1.2. How to comment on this NPA...................................................................................................................3
1.3. The next steps ...........................................................................................................................................4
2. In summary — why and what ............................................................................................................... 5
2.1. Why we need to change the rules — issue/rationale...............................................................................5
2.2. What we want to achieve — objectives ...................................................................................................6
2.3. How we want to achieve it — overview of the proposals ........................................................................6
2.4. What are the expected benefits and drawbacks of the proposals ...........................................................7
3. Proposed amendments and rationale in detail ...................................................................................... 8
3.1. Draft cover regulation (Draft EASA opinion) .............................................................................................8
3.2. Draft certification specifications (Draft EASA Decision) .........................................................................18
3.3. Draft acceptable means of compliance and guidance material (Draft EASA Decision) ..........................42
4. Impact assessment (IA) ....................................................................................................................... 47
4.1. What is the issue .....................................................................................................................................47
4.1.1. EMS operations in EASA Member States .........................................................................................47
4.1.2. Air taxi operations in EASA Member States ....................................................................................49
4.1.3. AEMS ................................................................................................................................................51
4.1.4. Safety risk assessment .....................................................................................................................52
4.1.5. Who is affected ................................................................................................................................53
4.1.6. How could the issue/problem evolve ..............................................................................................53
4.4. What are the impacts..............................................................................................................................58
4.4.1. Safety impact ...................................................................................................................................58
4.4.2. Environmental impact .....................................................................................................................59
4.4.3. Social impact ....................................................................................................................................59
4.4.4. Economic impact..............................................................................................................................61
4.4.5. General Aviation and proportionality issues ...................................................................................67
4.5. Conclusion ...............................................................................................................................................67
4.5.1. Comparison of options ....................................................................................................................67
4.6. Monitoring and evaluation .....................................................................................................................68
5. Proposed actions to support implementation...................................................................................... 69
6. References ......................................................................................................................................... 70
6.1. Affected regulations................................................................................................................................70
6.2. Affected decisions ...................................................................................................................................70
6.3. Other reference documents ...................................................................................................................70
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1. About this NPA
1. About this NPA
1.1. How this NPA was developed
The European Aviation Safety Agency (EASA) developed this NPA in line with Regulation (EC) No 216/20081
(hereinafter referred to as the ‘Basic Regulation’) and the Rulemaking Procedure2. This rulemaking activity is
included in the EASA 5-year Rulemaking Programme3 under rulemaking tasks RMT.0492 and RMT.0493. The
text of this NPA has been developed by EASA based on the input of the rulemaking groups (RMG) RMT.0492
and RMT.0493, which included representatives from competent authorities and industry. Notably, industry
experts provided valuable input for the development of the certification specifications depending on the type
of operation such as air taxi (ATXO), aeroplane emergency medical services (AEMS) and helicopter emergency
medical services (HEMS). Other sources of data include:
— a ‘Data Collection and Comparative Assessment of Existing National FTL Provisions for EMS’,
commissioned by EASA4;
— a ‘Preliminary Analysis of Impacts from Future Potential FTL Regulatory Changes for EMS’ commissioned
by EASA5;
— a Preliminary Analysis of Impacts from Future Potential FTL Regulatory Changes for Air Taxi and Single
Pilot Operations6;
— a scientific study commissioned by EBAA and ECA7; and
— a report on the Assessment of proposed FTL tables for Air Taxi and Emergency Medical Services
Operations8.
This NPA is hereby submitted to all interested parties9 for consultation.
1.2. How to comment on this NPA
Please submit your comments using the automated Comment-Response Tool (CRT) available at
http://hub.easa.europa.eu/crt/10.
The deadline for submission of comments is 31 January 2018.
1
Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of
civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC)
No 1592/2002 and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1) (http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=
1467719701894&uri=CELEX:32008R0216).
2
EASA is bound to follow a structured rulemaking process as required by Article 52(1) of Regulation (EC) No 216/2008. Such a
process has been adopted by the EASA Management Board (MB) and is referred to as the ‘Rulemaking Procedure’. See MB Decision
No 18-2015 of 15 December 2015 replacing Decision 01/2012 concerning the procedure to be applied by EASA for the issuing of
opinions, certification specifications and guidance material (http://www.easa.europa.eu/the-agency/management-board/
decisions/easa-mb-decision-18-2015-rulemaking-procedure).
3
http://easa.europa.eu/rulemaking/annual-programme-and-planning.php
4
Attachment I to this NPA.
5
Attachment II to this NPA.
6
Attachment III to this NPA.
7
Attachment IV to this NPA.
8
Attachment V to this NPA.
9
In accordance with Article 52 of Regulation (EC) No 216/2008, and Articles 6(3) and 7 of the Rulemaking Procedure.
10
In case of technical problems, please contact the CRT webmaster (
[email protected]).
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1. About this NPA
1.3. The next steps
Following the closing of the public commenting period, EASA will review all comments.
Based on the comments received, EASA will develop an opinion containing the proposed amendments to
Regulation (EU) No 965/201211. The opinion will be submitted to the European Commission, which will use it
as a technical basis in order to prepare an EU regulation.
Following the adoption of the regulation, EASA will issue a decision containing the related certification
specifications (CSs)/acceptable means of compliance (AMC)/guidance material (GM).
The comments received and the EASA responses thereto will be reflected in a comment-response document
(CRD). The CRD will be annexed to the opinion.
11
Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures
related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 296,
25.10.2012, p. 1) (http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32012R0965&rid=1).
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2. In summary — why and what
2. In summary — why and what
2.1. Why we need to change the rules — issue/rationale
The FTL requirements laid down in Subpart Q of EU-OPS were, before the adoption of Subpart FTL of
Regulation (EU) No 965/2012, applicable to CAT operations by aeroplanes, including scheduled and
charter operations, ATXO, single-pilot and emergency medical services.
The European Parliament and the Council, when adopting Regulation (EC) No 1899/2006, specifically
requested EASA to conduct a scientific and medical evaluation of Subpart Q [ref. Regulation
(EC) No 3922/91 new Article 8(a)] and assist the Commission in the preparation of regulatory
proposals.
‘By 16 January 2009, the European Aviation Safety Agency shall conclude a scientific and medical
evaluation of the provisions of Subpart Q and, where relevant, of Subpart O of Annex III. Without
prejudice to Article 7 of Regulation (EC) No 1592/2002 of the European Parliament and of the Council
of 15 July 2002 on common rules in the field of civil aviation and establishing a European Aviation
Safety Agency, the European Aviation Safety Agency shall assist the Commission in the preparation of
proposals for the modification of the applicable technical provisions of Subpart O and Subpart Q of
Annex III.’
The Subpart Q requirements have been reviewed and updated with rulemaking task OPS.055. During
the initial phase of rulemaking, taking into account the wide diversity of operations concerned, it was
decided to prioritise scheduled and charter operations, and to address ATXO, single-pilot operations by
aeroplane and emergency medical service operations at a later stage to allow for collecting scientific
evidence of the factors affecting fatigue in those operations.
Subpart FTL implementing rules, certification specifications and acceptable means of compliance are
applicable as of 18 February 2016 to CAT scheduled and charter operations by aeroplane.
Still today, Subpart Q requirements apply to a varying extent to ATXO, single-pilot operations by
aeroplane and emergency medical service operations by aeroplane. An exception in this respect is the
maximum daily flight duty period in single-pilot and emergency medical service operations. Instead,
national rules apply. The maximum daily flight duty period constitutes a major element of FTL.
ATXO are on-demand operations, the majority at short notice; they are characterised by frequent
standby duties at home, frequent change of schedule, long break periods between duties and time
zone crossings. Air taxi pilots on average fly significantly fewer hours per year than scheduled or
charter airline pilots. Considerable use is made of positioning of crew and aircraft relative to scheduled
flights.
There are two types of EMS: helicopters (HEMS) and aeroplanes (AEMS). Helicopters are used for
short-haul, often trauma-related emergency flights, when time is of the essence. Aeroplanes are
typically used for medical air transport of patients who need extensive or urgent medical assistance or
for the fast transport of live organs.
AEMS pilots are subject to rapid response, often unpredictable, round-the-clock missions, multiple
sectors and time-zone crossings. Various studies suggest, however, that block hours and duty time
could be relatively low compared to that of airline pilots of typical scheduled and charter CAT
operations, who have more days free of duty. In addition, positioning before and after duties appears
to be much more common than in typical CAT operations.
There are a lot of similarities in the patterns of work between ATXO and AEMS.
HEMS are also on-demand operations with very short notice, long breaks at the HEMS base, multiple
(very) short missions (could be as many as 20 short flights in a few hours), mostly visual flight rules
(VFR) operations often in unpredictable operational conditions to unknown landing sites.
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2. In summary — why and what
Single-pilot operations by aeroplane (SPLO) relate to domestic or intra-European flights, generally
shorter than multi-pilot CAT operations, but more challenging than multi-pilot operations. Single pilots
often operate under high workload conditions, since the pilot assumes multiple roles. This can make
single pilots more vulnerable to fatigue.
In the context of FTL, there are significant differences between ATXO, AEMS, HEMS and SPLO on the
one hand, and typical CAT operations on the other. Still, ATXO, AEMS and SPLO are regulated on the
basis of duty and flight time limits, and rest requirements of Subpart Q that have been designed for
scheduled multi-crew airline operations.
In comparison to flight times and duty periods that apply in CAT, ATXO and AEMS require much more
flexibility and ability to accommodate often very demanding duties while managing fatigue to
acceptable levels. Today, Subpart Q does not to provide that flexibility or the necessary levels of
control and mitigation.
Flight times and rest periods in HEMS are today regulated at Member States’ level. This often leads in
some States to extremely long duty hours — e.g. daily FDPs with extension of over 15–16 hours, as well
as to reduced rest times from 6 to 11 hours. There is variability in cumulative duty and block hours, as
well as in the way States regulate airport (base) and other standby.
2.2. What we want to achieve — objectives
The objectives of the EASA system are defined in Article 2 of the Basic Regulation. This proposal will in
particular contribute to the high uniform level of civil aviation safety, provide a level playing field for all
actors in the common European aviation market, and facilitate the free movement of goods, persons
and services.
The specific objective of this proposal is to establish an improved and proportionate Europe-wide basis
for regulating flight and duty times and rest periods for HEMS, based on scientific knowledge and
established best practices.
The attainment of the objective will be measured through the monitoring indicators, mentioned in
Section 4.6.
2.3. How we want to achieve it — overview of the proposals
The proposal seeks to adapt, where possible, existing implementing rules (IRs) in Subpart FTL to the
specificities of ATXO, SPLO, AEMS and HEMS operations, and to include new operation specific
requirements.
To that end, in addition to the scientific studies and analysis mentioned under point 1.1, this proposal
builds on the following:
— Member States’ national FTL provisions on the maximum daily flight duty period in SPLO and EMS
operations, by aeroplanes, as Subpart Q, OPS 1.1105 does not apply;
— Member States’ national FTL provisions applicable to ATXO and SPLO, by aeroplane, derogating
from those specified in Subpart Q by virtue of Article 8(3) of Regulation (EEC) 3922/1991;
— Member States’ national FTL provisions applicable to ATXO and SPLO, by aeroplane, adopted or
maintained under Article 8(4) of Regulation (EEC) 3922/1991;
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— the Regulatory Impact Assessment (RIA) of NPA 2010-1412 as relevant to ATXO, SPLO and AEMS,
as well as the European Commission’s impact assessment to Opinion 04/201213;
— safety improvements introduced by Commission Regulation (EU) No 83/201414;
— Member States’ national FTL provisions and best practices in the field of HEMS operations;
— the (H)EMS philosophy as described in GM1 SPA.HEMS.100(a)15;
— the particular nature of on-demand operations.
2.4. What are the expected benefits and drawbacks of the proposals
The expected benefits and drawbacks of the proposal are summarised below in Chapter 3.1. For the
full impact assessment of alternative options, please refer to Chapter 4.
12
NPA 2010-14 ‘Implementing Rules on Flight and Duty Time Limitations and rest requirements for commercial air transport (CAT)
with aeroplanes’.
13
http://ec.europa.eu/smart-regulation/impact/ia_carried_out/docs/ia_2014/swd_2014_0024_en.pdf
14
Commission Regulation (EU) No 83/2014 of 29 January 2014 amending Regulation (EU) No 965/2012 laying down
technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008
of the European Parliament and of the Council (OJ L 28, 31.1.2014, p. 17) (http://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2014:028:0017:0029:EN:PDF).
15
Annex to ED Decision 2012/019/R ‘AMC & GM to Part-SPA’
(https://www.easa.europa.eu/system/files/dfu/Annex%20to%20ED%20Decision%202012-019-R.pdf).
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3. Proposed amendments and rationale in detail
The text of the amendment is arranged to show deleted text, new or amended text as shown below:
— deleted text is struck through;
— new or amended text is highlighted in grey;
— an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.
3.1. Draft cover regulation (Draft EASA opinion)
Article XX
The Agency shall conduct a continuous review of the effectiveness of the provisions concerning flight
and duty time limitations and rest requirements contained in Annex III to Regulation (EU)
No 965/2012.
That review shall involve scientific expertise, where relevant, and be based, as a minimum, on the
following operational data collected by the Member States and submitted to the Agency not less than
once a year after the date of application of this Regulation:
— Number of fatigue reports;
— Impact of disruptive schedules on fatigue;
— Impact of time-zone crossing on fatigue;
— Impact of positioning on fatigue;
— Frequency of exceedances of rostered FDPs compared to actual FDPs;
— Use of commander discretion to extend the FDP or to reduce the rest period;
— Adequacy of sleep opportunities prior to safety related duties;
— Adequacy of recovery periods;
— Adequacy of requirements to control sleep disruption due to:
alternating day/night duties;
alternating eastward-westward or westward-eastward time zone transitions;
— Adequacy of procedures to control awake time.
No later than in 2025 EASA shall produce a first report on the results of this review.
Article YY
Regulation (EU) No 965/2012 is amended as follows:
Article 8 is replaced by the following:
‘Article 8 Flight time limitations
1. CAT operations with aeroplanes, including air taxi, single-pilot operations and emergency medical
services, as well as CAT operations with helicopters for the purpose of emergency medical services,
shall be subject to the requirements of Subpart FTL of Annex III. Excluded are emergency medical
service operations with helicopters conducted exclusively in an operating area, where alternative
ground emergency medical services are not possible or are ineffective, as defined by the Member
State.
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2. By way of derogation from paragraph 1, air taxi, emergency medical service and single pilot CAT
operations by aeroplanes shall be subject to the provisions of national law referred to in Article 8(4) of
Regulation (EEC) No 3922/91 and of Subpart Q of Annex III to that Regulation.
2 3. By way of derogation from paragraph 1, CAT operations with helicopters, other than emergency
medical services, and CAT operations with sailplanes shall comply with the applicable requirements of
the national law of the Member State in which the operator has its principal place of business.
3. Non-commercial operations, including non-commercial specialised operations, with complex motor-
powered aeroplanes and helicopters, as well as commercial specialised operations with aeroplanes,
helicopters and sailplanes with regard to flight time limitations shall comply with the applicable
requirements of the national law of the Member State in which the operator has its principal place of
business, or, where the operator has no principal place of business, the place where the operator is
established or resides.’
Article ZZ
Subpart FTL of Annex III to Regulation (EU) No 965/2012 is amended as follows:
‘SUBPART FTL
FLIGHT AND DUTY TIME LIMITATIONS AND REST REQUIREMENTS
SECTION 1
General
ORO.FTL.100 Scope
This Subpart establishes the requirements to be met by an operator and its flight, cabin and HEMS
crew members with regard to flight and duty time limitations and rest requirements for crew
members.
ORO.FTL.105 Definitions
For the purpose of this Subpart, the following definitions shall apply:
[…]
(5) ‘augmented flight crew’ means a flight crew which comprises more than the minimum
number required to operate the aircraft, allowing each flight crew member to leave the
assigned post, for the purpose of in-flight rest, and to be replaced by another appropriately
qualified flight crew member, or, in the case of on-board rest in air taxi and AEMS
operations, allowing each flight crew member to leave the assigned post for the purpose of
on-board rest also when the aircraft is on the ground;
(6) ‘break’ means a period of time within an flight duty period, shorter than a rest period,
counting as duty and during which a crew member is free of all tasks;
[…]
(13) ‘flight time’ means, for aeroplanes and touring motor gliders, the time between an aircraft
first moving moves from its parking place for the purpose of taking off until it comes to rest
on the designated parking position and all engines or propellers are shut down, and for
helicopters, the time from the moment a helicopter’s rotor blades start turning until the
moment the helicopter finally comes to rest at the end of the flight, and the rotor blades are
stopped.;
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[…]
(24) ‘sector’ means the segment of an FDP between an aircraft aeroplane first moving for the
purpose of taking off until it comes to rest after landing on the designated parking position.
[…]
(29) ‘EMS flight’ means a flight with an aeroplane (AEMS) or helicopter (HEMS) carrying out
emergency medical service operations, the purpose of which is to facilitate emergency
medical assistance, where immediate and rapid transportation is essential, by carrying at
least one of the following:
(a) medical personnel;
(b) medical supplies (equipment, blood, organs, drugs);
(c) ill or injured persons and other persons directly involved.
A sector flown to position an aircraft to the operating base before or after an EMS flight is
considered part of that flight.
(30) ‘single-pilot operation’ means, in the case of aeroplanes, an operation with one pilot or, in
the case of HEMS, an operation with one pilot and one HEMS crew member.
ORO.FTL.110 Operator responsibilities
An operator shall:
[…]
(j) except for EMS operations, change a schedule or crew arrangements, if the actual operation
exceeds the maximum flight duty period on more than 33 % of the flight duties in that schedule
during a scheduled seasonal period;
(k) in EMS operations, change a schedule or adapt crew arrangements, if the actual operation
exceeds the maximum FDP on any EMS operating base on more than 10 % of the FDPs in any
3 months.
[…]
ORO.FTL.120 Fatigue risk management (FRM)
[…]
(b) The FRM established, implemented and maintained shall provide for a continuous improvement
to the overall performance of the FRM and shall include:
[…]
SECTION 2
Commercial Air Transport Operators
[…]
ORO.FTL.205 Flight duty period (FDP)
(a) The operator shall:
(1) establish maximum daily FDP for crew members taking into account the type of
operation and relevant certification specifications.
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(2)(1) define reporting times appropriate to each individual operation taking into account
ORO.FTL.110(c);
(3)(2) establish procedures specifying how the commander shall, in case of special
circumstances which could lead to severe fatigue, and after consultation with the crew
members concerned, reduce the actual FDP and/or increase the rest period in order to
eliminate any detrimental effect on flight safety.
(b) Basic maximum daily FDP without the use of extensions.
(1) The maximum daily FDP without the use of extensions for acclimatised crew members
conducting two-pilot operation other than HEMS shall be in accordance with the
following table:
Table2
Maximum daily FDP — Acclimatised crew members — two-pilot operation other than HEMS
[…]
(2) The maximum daily FDP for two-pilot operation other than HEMS when crew members
are in an unknown state of acclimatisation shall be in accordance with the following
table:
Table 3
Maximum daily FDP — Crew members in an unknown state of acclimatisation — two-pilot
operation other than HEMS
[…]
Table 4
Maximum daily FDP — Crew members in an unknown state of acclimatisation under FRM
— two-pilot operation other than HEMS
[…]
(4) The maximum daily FDP for acclimatised crew members conducting single-pilot
operations, other than HEMS shall be in accordance with the following table:
Table 5
Maximum daily FDP* in hours — Acclimatised crew members — single-pilot operation other than
HEMS
Starting time Number of Sectors
of FDP Up to 4 5 6 7 8 9 10 or more
0600–0659 10:00 09:15 08:45 08:15 08:00 08:00 08:00
0700–0759 10:30 09:45 09:15 08:45 08:15 08:00 08:00
0800–1259 11:00 10:15 09:45 09:15 08:45 08:15 08:00
1300–1429 10:30 09:45 09:15 08:45 08:15 08:00 08:00
1430–1659 10:00 09:15 08:45 08:15 08:00 08:00 08:00
1700–2159 09:00 08:15 08:00 08:00 08:00 08:00 08:00
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2200–0359 08:00 08:00 08:00 08:00 08:00 08:00 08:00
0400–0559 09:00 08:15 08:00 08:00 08:00 08:00 08:00
* The flight time for each sector shall be limited to 4 hours with autopilot and to 2 hours without
autopilot.
(5) The maximum daily FDP for crew members in an unknown state of acclimatisation
conducting single-pilot operations other than HEMS shall be 8 hours.
(6) By derogation from (b)(1), flight time specification schemes in air taxi and AEMS
operations may specify the maximum daily FDP without the use of extensions for
acclimatised crew members in accordance with the certification specification
applicable to those operations.
(7) Flight time specification schemes in HEMS operations shall specify the maximum daily
FDP without the use of extensions for acclimatised crew members in accordance with
the certification specification applicable to those operations.
[…]
(d) Maximum daily FDP for acclimatised crew members in two-pilot scheduled and charter
operations with the use of extensions without in-flight rest.
[…]
(d1) Maximum daily FDP for acclimatised crew members in two-pilot air taxi and AEMS operations
with the use of extensions without on-board rest
(1) The maximum daily FDP may be extended by up to 1 hour not more than twice in any
7 consecutive days. In that case, the post-flight rest period shall be at least as long as
the preceding duty period plus 4 hours or the subsequent extended recovery rest
period shall be increased to 60 hours including 3 local nights.
(2) The use of the extension shall be planned in advance, and shall be limited to a
maximum of:
(i) 4 sectors; or
(ii) 3 sectors, when the WOCL is encroached by more than 2 hours.
(3) Extension of the maximum basic daily FDP without on-board rest shall not be
combined with extensions due to on-board rest or split duty in the same duty period.
(4) Flight time specification schemes shall specify the limits for extensions of the
maximum basic daily FDP in accordance with the certification specifications applicable
to this type of operation, taking into account:
(i) the number of sectors flown; and
(ii) WOCL encroachment.
(e) Maximum daily FDP with the use of extensions due to in-flight or, in the case of AEMS or air
taxi operations, on-board rest.
Flight time specification schemes shall specify the conditions for extensions of the maximum
basic daily FDP with in-flight rest or, in the case of AEMS or air taxi operations, on-board rest
in accordance with the certification specifications applicable to the type of operation, taking
into account:
(i) the number of sectors flown;
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(ii) the minimum in-flight or on-board rest allocated to each crew member;
(iii) the type of in-flight or on-board rest facilities; and
(iv) the augmentation of the basic flight crew.
(f) Unforeseen circumstances in flight operations — commander’s discretion
(1) The conditions to modify the limits on flight duty, duty and rest periods by the
commander in the case of unforeseen circumstances in flight operations other than
EMS, which start occur at or after the reporting time, shall comply with the following:
[…]
(7) The conditions to modify the limits on flight duty, duty and rest periods by the
commander in the case of unforeseen circumstances in EMS operations, which occur
at or after the reporting time, shall be established on the basis of the relevant
certification specifications.
[…]
ORO.FTL.210 Flight times and duty periods
(a) The total duty periods to which an individual crew member may be assigned in scheduled
and charter operations and in air taxi and AEMS operations shall not exceed either of the
following limits:
(1) 60 duty hours in any 7 consecutive days;
(2) 110 duty hours in any 14 consecutive days; and
(3) 190 duty hours in any 28 consecutive days, spread as evenly as practicable
throughout that period.
(b) The total duty periods to which an individual crew member may be assigned in HEMS
operations is established:
(1) in accordance with (a); or
(2) in accordance with the limits specified in the certification specifications applicable to
HEMS operations.
(c)(b) The total flight time of the sectors on which an individual crew member is may be assigned
as an operating crew member, except for HEMS or mixed AEMS/HEMS, shall not exceed
either of the following limits:
(1) 100 hours of flight time in any 28 consecutive days;
(2) 900 hours of flight time in any calendar year; and
(3) 1 000 hours of flight time in any 12 consecutive calendar months.
(d) The total flight time to which an individual crew member may be assigned as an operating
crew member in HEMS or mixed AEMS/HEMS operations shall not exceed either of the
following limits:
(1) 35 hours in any 7 consecutive days;
(2) 90 hours in any 28 consecutive days;
(3) 800 hours in any 12 consecutive calendar months.
(e) The total flight time to which an individual crew member may be assigned in air taxi and
AEMS operations is established:
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(1) in accordance with (c). In such case, table 1 in ORO.FTL.205(b)(1) shall apply; or
(2) in accordance with the limits specified in the certification specifications applicable to
air taxi operations. In such case, CS FTL.2.205 for air taxi shall apply.
(f)(c) Post-flight duty shall count as duty period. The operator shall specify in its operations
manual the minimum time period for post-flight duties.
ORO.FTL.215 Positioning
If an operator positions a crew member, the following shall apply:
(a) positioning after reporting but prior to operating shall be counted as FDP but shall not
count as a sector;
(b) all time spent on positioning shall count as duty period. ;
(c) flight time specification schemes established in accordance with the certification
specifications applicable to air taxi operations shall specify the impact on the maximum FDP
of:
(1) the duration of positioning; and
(2) the mode of transportation.
ORO.FTL.220 Split duty
The conditions for extending the basic maximum daily FDP due to a break on the ground shall be in
accordance with the following:
(a) flight time specification schemes shall specify the following elements for split duty in
accordance with the certification specifications applicable to the type of operation:
(1) the minimum duration of a break on the ground; and
(2) the possibility to extend the maximum basic daily FDP prescribed under point
ORO.FTL.205(b) taking into account the duration of the break or, in the case of air
taxi and EMS operations, breaks on the ground, the facilities provided to the crew
member to rest and other relevant factors;
(b) the break(s) on the ground shall count in full as FDP;
(c) split duty shall not follow a reduced rest.
ORO.FTL.225 Standby and duties at the airport or at the HEMS operating base
If an operator assigns crew members to standby or to any duty at the airport or at the HEMS
operating base, the following shall apply in accordance with the certification specifications applicable
to the type of operation:
(a) standby and any duty at the airport or at the HEMS operating base, as applicable, shall be in
the roster and the start and end time of standby shall be defined and notified in advance to
the crew members concerned to provide them with the opportunity to plan adequate rest;
(b) a crew member is considered on airport standby or on standby at the HEMS operating base
from reporting at the reporting point until the end of the notified standby period;
(c) airport standby shall count in full as duty period for the purpose of points ORO.FTL.210 (a)
and (b) and ORO.FTL.235;
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(d) any duty at the airport or at the HEMS operating base, as applicable, shall count in full as
duty period and the FDP shall count in full from the airport duty reporting time;
(e) the operator shall provide accommodation to the crew member on airport standby or on
standby at the HEMS operating base.
(f) flight time specification schemes established in accordance with the certification
specifications applicable to the type of operations shall specify the following elements:
(1) the maximum duration of any standby;
(2) the impact of the time spent on standby on the maximum FDP that may be assigned,
taking into account facilities provided to the crew member to rest, and other relevant
factors such as:
– the need for immediate readiness of the crew member,
– the interference of standby with sleep, and
– sufficient notification to protect a sleep opportunity between the call for duty
and the assigned FDP;
(3) the minimum rest period following standby which does not lead to assignment of an
FDP;
(4) how time spent on standby other than airport standby shall be counted for the
purpose of cumulative duty periods.
[…]
ORO.FTL.235 Rest periods
[…]
(c1) Reduced rest for air taxi operations
By way of derogation from point (a) or (b) flight time specification schemes established in
accordance with the certification specifications applicable to air taxi operations may reduce
the minimum rest periods at home base or away from home base considering all of the
following:
(1) the minimum reduced rest period;
(2) the state of acclimatisation;
(3) the number of local nights included in the rest period;
(4) the time zone crossing;
(5) the combination of flight time and positioning immediately prior to the reduced rest
period; and
(6) the flight time in the previous 7 consecutive days prior to rest period.
[…]’
Rationale for the implementing rules
Article 8 ‘Flight time limitations’ of Regulation (EU) No 965/2012 is extended to now include air taxi,
single-pilot and emergency medical service operations, with aeroplanes, as well as CAT operations with
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helicopters for the purpose of emergency medical services. It, however, excludes from the scope
certain HEMS conducted exclusively in areas where an alternative ground transportation is not possible
or is ineffective, to be defined by the competent authority of a Member State. This will allow a number
of socially important operations to continue to exist, as any reduction in the duty and flight hours will
further reduce the anyway low number of missions. Those impacts are expected to have a detrimental
effect on pilots’ proficiency, costs for new recruitment and pilot training.
This extension of the scope makes the following amendments to Subpart FTL necessary:
1. ORO.FTL.100 is amended to also include HEMS crew members. HEMS operations, especially daily
missions, are typically operated by mixed crews consisting of a pilot and a HEMS crew member
who assists the PIC. This justifies the application of the same FTL regime to both.
2. ORO.FTL.105 — the definition of (5) ‘augmented flight crew’ has been extended to also
incorporate the concept of on-board rest in air taxi and AEMS operations, when the aircraft is on
the ground and the flight crew has been augmented, in addition to in-flight rest.
3. ORO.FTL.105 — the definitions of (13) ‘flight time’ and (24) ‘sector’ have been adapted to include
both operations with aeroplanes and helicopters.
4. ORO.FTL.105 — a new definition (29) ‘EMS flight’ is included in analogy to the definition of ‘HEMS
flight’ in Annex I to Regulation (EU) No 965/2012. Thus, the HEMS concept16 becomes applicable to
flight and duty times and rest periods in any EMS operation.
5. ORO.FTL.105 — a new definition (30) ‘single-pilot operation’ is included to avoid potential
misinterpretation, especially as regards daily HEMS operations where a HEMS crew member is
needed to assist the pilot.
6. ORO.FTL.110 — a change to point (j) and inclusion of new point (k) to include a responsibility for
any EMS operator to adapt scheduling when the planned FDP is exceeded too frequently, to better
reflect the nature of EMS operations.
7. ORO.FTL.120(b) — an editorial correction is made to improve readability of the text.
8. ORO.FTL.205(a) — a new point (1) has been included to clarify that operators are now required to
establish maximum daily FDP limits for crew members taking into account the type of operation
and relevant certification specification. Existing points are renumbered to (2) and (3), respectively.
9. ORO.FTL.205(b) — many adaptations have been introduced to cater for the specificities of the FDP
in all types of operations that have been included in the scope of Subpart FTL:
— the scope of (b) is clarified as it only relates to FDPs without the use of extensions;
— points (1) and (2) as well as the titles of Table 2, 3 and 4 are amended to reflect the type of
operation they relate to, i.e. two-pilot operations other than HEMS;
— a new point (4) is inserted to introduce a new Table 5 containing FDP values for
acclimatised crew members in single-pilot operations with aeroplanes;
— a new point (5) is inserted containing the maximum FDP value for crew members in an
unknown state of acclimatisation in single-pilot operations with aeroplanes;
16
The HEMS philosophy is described in GM1 SPA.HEMS.100(a) Helicopter emergency medical service (HEMS) operations.
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— a new point (6) gives air taxi and AEMS operators the option to establish flight time
specification schemes in which the maximum daily FDP limits for acclimatised crew
members, without the use of extensions, are in accordance with certification specifications
specific for on-demand operations;
— a new point (7) gives HEMS operators the option to establish flight time specification
schemes in which the maximum daily FDP limits for acclimatised crew members, without
the use of extensions, are in accordance with certification specifications specific for this
type of operation;
10. ORO.FTL.205(d) — clarification that this point applies only to two-pilot scheduled and charter
operations.
— A new point ORO.FTL.205(d1) is inserted to allow FDP extensions in air taxi and AEMS
operations without on-board rest based on a number of conditions such as an increase of
the post-flight rest or of the extended recovery rest.
11. ORO.FTL.205(e) — adapted to also include extensions due to on-board rest in AEMS and air taxi
operations.
12. ORO.FTL.205(f)(1) — clarification that this point does not apply to EMS operations.
13. A new point ORO.FTL.205(f)(7) gives EMS operators the flexibility to establish flight time
specification schemes in which the use of commander’s discretion is in accordance with
certification specifications specific for this type of operation.
14. ORO.FTL.210 — several adaptations have been introduced to cater for the cumulative duty and
flight time limits according to the specificities of each type of operation:
— The scope of point (a) is limited to scheduled and charter operations as well as air taxi and
AEMS;
— Point (b) is replaced by new text providing HEMS operators with the flexibility to choose
either the cumulative duty limits of scheduled and charter operations or those that are
more adapted to the nature of HEMS operations. The cumulative duty periods in HEMS are
governed by Member States’ national law, this flexibility will allow the continuation of
national practices that are deemed to be safe;
— Current point (b) becomes point (c) and its scope is limited to scheduled and charter
operations;
— A new point (d) is inserted to introduce cumulative flight time limits for crew members in
HEMS or mixed AEMS/HEMS operations;
— A new point (e) is inserted to allow air taxi operators the choice of either applying the
cumulative flight time limits for scheduled and charter operations with a set of more
restrictive daily limits or a set of more restrictive cumulative flight time limits in
combination with less constraining maximum daily FDP limits. If choosing the first option,
the operator must include in its flight time specification scheme the widely known and
tested limits that have been applicable in scheduled and charter operations by aeroplanes
for many years (under Subpart Q). In view of the nature of scheduled and charter flights,
where the workload is usually evenly distributed and cumulative fatigue builds for longer
periods, periodic cumulative limits are higher and come in combination with lower daily
limits. Air taxi operations might need more flexible daily FDP limits. Therefore, as an
alternative to the limits in CS-FTL.1, the operator may define more restrictive cumulative
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flight time limits in its specification scheme. These must remain within the margin of
CS-FTL.2. The additional flexibility is based on the findings presented in Attachment IV;
— Current point (c) becomes point (f).
15. ORO.FTL.215 — a new point (c) is added requiring the operator to specify, in its flight time
specification scheme, the impact of positioning on the maximum FDP depending on the duration
of positioning and the mode of transport. As described in Attachment IV to this document, the
duration of positioning and the mode of transport seem to have a higher impact on fatigue in air
taxi compared to scheduled and charter operations.
16. ORO.FTL.220 — several editorial changes to allow for more than one break during the maximum
basic daily FDP in case of split duties in air taxi and EMS operations.
17. ORO.FTL.225 — several editorial changes are prompted by the extension of the scope of Subpart
FTL to cover also HEMS operations. HEMS operating bases17 are not always located at airports. The
rules for airport standby shall, however, also be applicable at the HEMS operating base.
18. ORO.FTL.235 — a new point (c1) is added to allow the certification specification applicable to air
taxi operations to establish reduced rest requirements at home base or away from home base
adapted to that type of operation.
3.2. Draft certification specifications (Draft EASA Decision)
CERTIFICATION SPECIFICATIONS
AND GUIDANCE MATERIAL
FOR COMMERCIAL AIR TRANSPORT BY AEROPLANE
SCHEDULED AND CHARTER OPERATIONS
BOOK 2
[…]
GM1 CS FTL.1.200 Home base
TRAVELLING TIME
Crew members should consider making arrangements for temporary accommodation closer to their
home base if the travelling time from their residence to their home base usually exceeds 90 minutes.
[…]
GM1 CS FTL.1.225 Standby
MINIMUM REST AND STANDBY
17
See definition (62) in Annex I to Regulation (EU) 965/2012.
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(a) If airport or other standby initially assigned is reduced by the operator during standby that does not
lead to an assignment to a flight duty period, the minimum rest requirements specified in ORO.FTL.235
should apply.
(b) If a minimum rest period as specified in ORO.FTL.235 is provided before reporting for the duty
assigned during the standby, this time period should not count as standby duty.
(c) Standby other than airport standby counts (partly) as duty for the purpose of ORO.FTL.210 only. If a
crew member receives an assignment during standby other than airport standby, the actual reporting
time at the designated reporting point should be used for the purpose of ORO.FTL.235.
GM1 CS FTL.1.225 (b) Standby
STANDBY OTHER THAN AIRPORT STANDBY NOTIFICATION
Operator procedures for the notification of assigned duties during standby other than airport standby
should avoid interference with sleeping patterns if possible.
GM1 CS FTL.1.225(b)(2) Standby
AWAKE TIME
Scientific research shows that continuous awake in excess of 18 hours can reduce the alertness and
should be avoided.
[…]
GM1 CS FTL.1.230 Reserve
RESERVE NOTIFICATION
Operator procedures for the notification of assigned duties during reserve should avoid interference
with sleeping patterns if possible.
GM2 CS FTL.1.230 Reserve
NOTIFICATION IN ADVANCE
The minimum 'at least 10 hours' between the notification of an assignment for any duty and reporting
for that duty during reserve may include the period of 8 hours during which a crew member on reserve
is not contacted by the operator.
GM1 CS FTL.1.230(c) Reserve
RECURRENT EXTENDED RECOVERY REST
ORO.FTL.235 (d) applies to a crew member on reserve.
[…]
GM1 CS FTL.1.235 (b)(3) Rest periods
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TIME ELAPSED SINCE REPORTING
The time elapsed since reporting for a rotation involving at least a 4-hour time difference to the
reference time stops counting when the crew member returns to his/her home base for a rest period
during which the operator is no longer responsible for the accommodation of the crew member. ‘
Rationale for CS-FTL.1
18. The above GM to CS-FTL.1 has been considered as relevant for all types of operations and moved,
therefore, to its corresponding IR.
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CERTIFICATION SPECIFICATIONS
AND GUIDANCE MATERIAL
FOR COMMERCIAL AIR TRANSPORT BY AEROPLANE
AIR TAXI OPERATIONS AND AEMS OPERATIONS
CS-FTL.2
CS FTL.2.100 Applicability
The following certification specifications are applicable to commercial air transport operations by
aeroplanes for the purpose of air taxi and AEMS operations.
GM1 CS FTL.2.100 Applicability
To ensure regulatory continuity for the full duration of an AEMS flight, an AEMS flight may include
positioning the aeroplane after the patient is unloaded from the aeroplane to enable it to return to a
suitable location for the next AEMS flight.
CS FTL.2.200 Home base — air taxi and AEMS
(a) The home base is a single airport location assigned with a high degree of permanence.
(b) In the case of a change of home base, the recurrent extended recovery rest period prior to
starting duty at the new home base is increased once to 72 hours, including 3 local nights.
Travelling time between the former home base and the new home base is positioning.
CS FTL.2.205 Flight duty period (FDP) — air taxi and AEMS
Night duties in air taxi and AEMS operations under ORO.FTL.205(b)(6) and (d1)
Night duties in air taxi and AEMS operations comply with the following:
(1) When establishing the maximum FDP for consecutive night duties, the number of sectors
is limited to 4 sectors per duty.
(2) The operator applies appropriate fatigue risk management to actively manage the
fatiguing effect of night duties of more than 10 hours in relation to the surrounding duties
and rest periods.
CS FTL.2.205 Flight duty period (FDP) — air taxi and AEMS
Maximum daily FDP without extensions under ORO.FTL.205(b)(6)
The maximum daily FDP without the use of extensions for acclimatised crew members in two-pilot air
taxi and AEMS operations is limited to the values specified in the table below:
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Table 1
Maximum daily FDP in hours — Acclimatised crew members in two-pilot air taxi and AEMS operations
Start of FDP
at 1–3 4 5 6 7 8 9 10
reference Sectors Sectors Sectors Sectors Sectors Sectors Sectors Sectors
time
0600–0814 13:00 12:30 11:30 11:00 10:30 10:00 09:30 09:00
0815–0829 13:15 12:45 11:45 11:00 10:30 10:00 09:30 09:00
0830–0844 13:30 12:30 12:00 11:00 10:30 10:00 09:30 09:00
0845–0859 13:45 13:15 12:15 11:00 10:30 10:00 09:30 09:00
0900–1159 14:00 13:30 12:30 11:00 10:30 10:00 09:30 09:00
1200–1229 13:30 13:30 12:30 11:00 10:30 10:00 09:30 09:00
1230–1259 13:00 13:00 12:30 11:00 10:30 10:00 09:30 09:00
1300–1329 13:00 12:30 12:30 11:00 10:30 10:00 09:30 09:00
1330–1359 12:45 12:15 11:15 10:45 10:15 09:45 09:15 09:00
1400–1429 12:30 12:00 11:00 10:30 10:00 09:30 09:00 09:00
1430–1459 12:15 11:45 10:45 10:15 09:45 09:15 09:00 09:00
1500–1529 12:00 11:30 10:30 10:00 09:30 09:00 09:00 09:00
1530–1559 11:45 11:15 10:15 09:45 09:15 09:00 09:00 09:00
1600–1629 11:30 11:00 10:00 09:30 09:00 09:00 09:00 09:00
1630–1659 11:15 10:45 09:45 09:15 09:00 09:00 09:00 09:00
1700–0459 11:00 10:30 09:30 09:00 09:00 09:00 09:00 09:00
0500–0514 12:00 11:30 10:30 10:00 09:30 09:00 09:00 09:00
0515–0529 12:15 11:45 10:45 10:15 09:45 09:15 09:00 09:00
0530–0544 12:30 12:00 11:00 10:30 10:00 09:30 09:00 09:00
0545–0559 12:45 12:15 11:15 10:45 10:15 09:45 09:15 09:00
CS FTL.2.205 Flight duty period — air taxi and AEMS
Maximum daily FDP with extensions without on-board rest under ORO.FTL.205(d1)(4)
The maximum daily FDP with extensions without on-board rest for acclimatised crew members in two-
pilot air taxi and AEMS operations is limited to the values specified in the table below:
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Table 2
Maximum daily FDP in hours — Acclimatised crew members in two-pilot air taxi and AEMS operations
with extensions without on-board rest
Start of FDP at
1–3 Sectors 4 Sectors
reference time
0615–0629 13:15 12:45
0630–0644 13:30 13:00
0645–0659 13:45 13:15
0700–1329 14:00 13:30
1330–1359 13:45 13:15
1400–1429 13:30 13:00
1430–1459 13:15 12:45
1500–1529 13:00 12:30
1530–1559 12:45 Not allowed
1600–1629 12:30 Not allowed
1630–1659 12:15 Not allowed
1700–1729 12:00 Not allowed
1730–1759 11:45 Not allowed
1800–1829 11:30 Not allowed
1830–1859 11:15 Not allowed
1900–0614 Not allowed Not allowed
CS FTL.2.205 Flight duty period — air taxi and AEMS
Extension of the maximum basic daily FDP due to on-board rest under ORO.FTL.205(e)
The maximum basic daily FDP in air taxi or AEMS operations may be extended due to on-board rest for
flight crew:
(i) with one additional flight crew member:
(A) up to 15 hours with class B rest facilities; or
(B) up to 16 hours with class A rest facilities;
(ii) with two additional flight crew members:
(A) up to 16 hours with class B rest facilities; or
(B) up to 17 hours with class A rest facilities,
provided all the following conditions are met:
(1) the FDP is limited to 3 sectors;
(2) the minimum on-board rest period is a consecutive 90-minute period for each crew
member and 2 consecutive hours for those flight crew members at control during the
last landing.
(3) The on-board rest facilities comply with one of the following descriptions:
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a. ‘Class A rest facility’ means a bunk or other surface that allows for a flat or
near flat sleeping position. It reclines to at least 80° back angle to the vertical.
b. ‘Class B rest facility’ means a seat in an aircraft cabin that reclines at least 45°
back angle to the vertical, has a seat width of at least 20 inches (50 cm) and
provides leg and foot support.
(4) The operator describes means to provide darkness and noise mitigation in the
operations manual and ensures that these means are available to all crew members
during on-board rest. The operator establishes a procedure in the operations manual to
ensure that crew members are not disturbed during on-board rest.
(5) The minimum on-board rest in Class A or B on-board rest facility for each cabin crew
member is:
Maximum extended FDP (in hours) Minimum on-board rest (in hours)
up to 14:30 1:30
14:31–15:00 1:45
15:01–15:30 2:00
15:31–16:00 2:15
16:01–16:30 2:45
16:31–17:00 3:15
17:01–17:30 3:45
17:31–18:00 4:15
(6) The limits for pilots may be increased by 1 hour, if the FDP includes a consecutive 150-
minute on-board rest period for each flight crew member.
(7) All time spent in the rest facility is counted as FDP.
(8) The minimum rest at destination is at least as long as the preceding duty period, or
14 hours, whichever is greater.
(9) The first sector of an FDP requiring an augmented flight crew may be accomplished with
two flight crew members, if that sector does not exceed 01h30.
CS FTL.2.205 Flight duty period (FDP) — AEMS
Unforeseen circumstances in AEMS operations — commander’s discretion
The conditions to modify the limits on flight duty, duty and rest periods by the commander in AEMS
operations in the case of unforeseen circumstances that occur at or after the reporting time, or at the
end of the FDP, comply with the following:
(a) The maximum basic daily FDP may be increased for AEMS by up to 1 hour unless the flight crew
has been augmented, in which case the maximum FDP may be increased by up to 2 hours;
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(b) If on the final sector within the FDP the allowed increase of up to 1 hour or up to 2 hours as
applicable is further exceeded because of unforeseen circumstances after take-off, the flight
may continue to the planned destination or alternate aerodrome. If unforeseen circumstances
occur just before take-off for the final sector, the allowed increase may only be exceeded to
transport the patient.
(c) The rest period following the FDP may be reduced away from base but can never be less than 10
hours.
CS FTL.2.205 Flight duty period (FDP) — air taxi and AEMS
Unforeseen circumstances in air taxi and AEMS — delayed reporting
(a) The operator may delay the reporting time in the event of unforeseen circumstances, if
procedures for delayed reporting are established in the operations manual.
(b) The operator keeps records of delayed reporting.
(c) Delayed reporting procedures establish a notification time allowing a crew member to remain in
his/her suitable accommodation when the delayed reporting procedure is activated.
(d) If the crew member is informed of the delayed reporting time, the FDP is calculated as follows:
(1) one notification of a delay leads to the calculation of the maximum FDP according to (c) or
(d);
(2) if the reporting time is further amended, the FDP commences 1 hour after the second
notification or at the original delayed reporting time if this is earlier;
(3) when the delay is less than 4 hours, the maximum FDP is calculated based on the original
reporting time and the FDP starts counting at the delayed reporting time;
(4) when the delay is 4 hours or more, the maximum FDP is calculated based on the more
limiting of the original or the delayed reporting time and the FDP starts counting at the
delayed reporting time;
(5) As an exception to (a) and (b), when the operator informs the crew member of a delay of
10 hours or more in reporting time and the crew member is not further disturbed by the
operator, such delay of 10 hours or more counts as a rest period.
CS FTL.2.210 Flight times and duty periods — air taxi operations
The total flight time of the sectors on which an individual crew member in air taxi operations is
assigned as an operating crew member under ORO.FTL.210(e) shall not exceed:
(1) 80 hours of flight time in any 28 consecutive days;
(2) 210 hours of flight in any 84 consecutive days; and
(3) 625 hours of flight time in any 12 consecutive calendar months.
CS FTL.2.215 Positioning — air taxi operations
(a) If the positioning time is more than 1 hour or includes more than one transport mode, the
maximum FDP is reduced by 30 minutes;
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(b) If self-driving in a motor vehicle is chosen as a method to position crew members, the maximum
daily FDP is reduced for those crew members by:
(i) 30 min, if the driving time is between 30 min and 60 min; and
(ii) twice the duration of the self-driving time in excess of 60 minutes.
CS FTL.2.220 Split duty — air taxi operations and AEMS
The following applies in the case of split duty with one or more breaks on the ground in air taxi and
AEMS operations:
(a) one break on the ground has a minimum duration of 3 consecutive hours;
(b) any additional break on the ground has a minimum duration of at least 2 consecutive hours;
(c) the time allowed for post- and pre-flight duties and travelling is excluded from each break; the
minimum total time for post- and pre-flight duties and travelling is 30 minutes; the operator
shall specify the actual times in its operations manual;
(d) accommodation or a Class A facility is provided;
(e) for any break of 6 hours or more or for a break that encroaches the window of circadian low
(WOCL), suitable accommodation is provided;
(f) an extension of the maximum basic daily FDP due to split duty is not combined with an extension
due to on-board rest;
(g) an operator may extend the basic maximum daily FDP specified in CS FTL.2.205 by up to 50 % of
the combined duration of all breaks on the ground, with the exception of the time exceeding 6
hours or encroaching the WOCL, if spent in other than suitable accommodation.
GM CS FTL.2.220(c) Split duty — air taxi operations and AEMS
Post-, pre-flight duty and travelling times
The operator should specify post- and pre-flight duty and travelling times taking into account the
aircraft type, the type of operation and airport conditions.
CS FTL.2.225 Standby — air taxi operations and AEMS
The limits on flight duty, duty and rest periods in air taxi operations or AEMS are modified in
accordance with the following:
(a) Airport standby
(1) When an airport standby does not lead to the assignment of a FDP, airport standby is
followed by a rest period as specified in ORO.FTL.235.
(2) If an assigned FDP starts during airport standby, the following applies:
(i) the FDP counts from the start of the FDP. The maximum FDP is reduced by any time
spent on standby in excess of 4 hours;
(ii) the maximum combined duration of airport standby and assigned FDP as specified in
ORO.FTL.205(b) and (d1) is 16 hours, unless split duty applies.
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(b) Standby other than airport standby:
(1) The maximum duration of standby other than airport standby is 16 hours. This limit may be
extended by the number of hours between 23:00 and 07:00 or between 13:00 to 17:00
during which the crew member is undisturbed and is able to remain at his/her place of rest
at the local time where the crew member is acclimatised, if the standby encompasses that
period;
(2) the operator’s standby procedures are designed to avoid that the combination of standby
and FDP leads to more than 18 consecutive hours awake time;
(3) Time spent on standby duty counts as duty time for the purpose of CS.FTL.2.210(a), as
follows:
(i) 25 % for standby duty with a response time of 90 minutes or more;
(ii) 50 % for standby duty with a response time between 89 and 60 minutes;
(iii) 100 % for standby duty with a response time of less than 60 minutes.
(4) standby is followed by not less than 10 hours rest period;
(5) standby ceases when the crew member reports at the designated reporting point;
(6) if standby ceases within the first 6 hours, the maximum FDP counts from reporting;
(7) if standby ceases after the first 6 hours, the maximum FDP is reduced by the amount of
standby time exceeding 6 hours;
(8) if the FDP is extended due to on-board rest according to CS FTL.2.205(e) or split duty
according to CS FTL.2.220, the 6 hours of points (6) and (7) are extended to 8 hours;
(9) if standby starts between 23:00 and 07:00 at the local time where the crew member is
acclimatised, the time between 23:00 and 07:00 does not count towards the reduction of
the FDP under points (7) and (8) until the crew member is contacted by the operator;
(10) if a crew member is undisturbed and is able to remain at his/her place of rest between
13:00 and 17:00 at the local time where the crew member is acclimatised, the time spent
before 13:00 does not reduce the maximum FDP. In such case, the maximum FDP is only
reduced by the amount of standby after 17:00 in excess of 6 hours (or 8 hours for
augmented crew or split duty);
(11) the response time established by the operator allows the crew member to arrive from
his/her place of rest to the designated reporting point within a reasonable time.
(c) The response time is the time between the communication of a duty assignment and the
reporting time and is reflected in the operator’s flight time specification scheme.
CS FTL.2.230 Reserve — air taxi operations
The operator assigns duties to a crew member on reserve under the provisions of ORO.FTL.230
complying with the following:
(a) An assigned FDP after reserve counts from the reporting time.
(b) Reserve times do not count as duty period for the purpose of ORO.FTL.210 and ORO.FTL.235.
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(c) The operator specifies a number of consecutive reserve days within the limits of ORO.FTL.235(d).
(d) To protect an 8-hour sleep opportunity, the operator rosters a period of 8 hours, taking into
account fatigue management principles, for each reserve day during which a crew member on
reserve is not contacted by the operator.
(e) Minimum notification time for any duty is 10 hours that may include the 8-hour sleep
opportunity under (d).
(f) Reserve time does not count as recurrent extended recovery rest.
GM1 CS.FTL.2.230(d)
Fatigue management principles mean in the context of a rostered 8-hour sleep opportunity that crew
members should be able to maintain a consistent sleep pattern with surrounding days.
CS FTL.2.235 Rest periods — air taxi and AEMS
(a) Disruptive schedules
(1) If a transition at home base is planned from a late finish/night duty to an early start,
(i) the rest period between the 2 FDPs includes 1 local night, or
(ii) the second FDP is limited to 11 hours and the rest period after the second FDP
includes 1 local night.
(2) For a crew member performing 4 or more night duties, early starts or late finishes
between 2 extended recovery rest periods as defined in ORO.FTL.235(d) the extended
recovery rest period following the disruptive schedules is extended to 60 hours.
(b) Time zone differences
(1) For the purpose of ORO.FTL.235(e)(1), ‘rotation’ means a duty or a series of duties,
including at least one flight duty, and rest periods out of home base, starting at home
base and ending when returning to home base for a rest period where the operator is no
longer responsible for the accommodation of the crew member.
(2) Time zone differences are compensated by additional rest, as follows:
(i) At home base, if a rotation involves a 4-hour time difference or more, the
minimum rest is as specified in the following table:
Minimum consecutive local nights of rest at initial reference time of the first FDP involving at
least a 4-hour time difference to the reference time to compensate for time zone differences
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Maximum time difference
(h) between reference Time elapsed (h) between reporting for the first duty period involving at
time and local time where least 4-hour time difference to the reference time and return to the initial
a crew member rests reference time in a rotation
during a rotation
< 48 48–71:59 72–95:59 ≥ 96
≤6 2 2 3 3
≤9 2 3 3 4
≤ 12 2 3 4 5
(ii) Away from home base, if an FDP involves a 4-hour time difference or more, the
minimum rest between this FDP and the following FDP is at least as long as the
preceding duty period, or 14 hours, whichever is greater. By way of derogation
from point (b)(2)(i) and only once between 2 recurrent extended recovery rest
periods as specified in ORO.FTL.235(d), the minimum rest provided under this point
(b)(2)(ii) may also apply to home base if the operator provides suitable
accommodation to the crew member.
(3) For eastward-westward or westward-eastward transitions, covering 6 or more time zones
in one direction followed by four or more time zones in the opposite direction, at least 3
local nights of rest at home base are provided between alternating rotations.
(4) The monitoring of combinations of rotations is conducted under the operator’s
management system provisions.
(c) Reduced rest
(1) The minimum reduced rest periods under reduced rest arrangements are 12 hours at
home base and 10 hours out of base.
(2) the crew member is acclimatised;
(3) the rest period includes a local night;
(4) the rest period takes place at a location no further than 3 time zones away from the place
of departure;
(5) the flight time in the FDP prior to the rest period is no more than 8 hours;
(6) the FDP prior to the rest is limited to 4 sectors and
(7) the total flight time in the previous 7 consecutive days prior to rest period is no more than
24 hours.’
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Rationale for CS-FTL.2
20. The extension of scope of Subpart FTL makes it necessary for EASA to issue certification specifications
that also address air taxi and EMS. Therefore, This NPA proposes a new set of certification
specifications, CS-FTL.2, to cover air taxi and EMS operations.
It should be noted that not all flights performed for medical reasons are considered EMS flights. A
flight is considered AEMS flight, if its purpose is immediate and rapid transportation to facilitate
emergency medical assistance or life organs for transplant. That means that a flight with a patient
where such purpose is not evident is considered an air taxi operation (e.g. an injury such as a simple
bone fracture that has already been treated and where the patient prefers to spend the convalescence
in his/her home country).
It is possible that the same crew member operates consecutively air taxi and AEMS flights during the
same FDP. Furthermore, a mission that has started as a normal CAT flight may suddenly turn into an
EMS flight, because e.g. the condition of the patient has in the meantime deteriorated and an urgent
transportation becomes necessary. This specificity calls for a full compatibility between the FTL regime
for air taxi operations and that for AEMS operations. It would be impracticable to apply different sets
of FTL limits to the same individual crew member unless all measures intended to mitigate cumulative
fatigue, such as e.g. cumulative duty and flight time limits, were the same. It should therefore be
possible to manage all limits for a combined air taxi and AEMS operation under one regime whilst
allowing the flexibility needed because of the urgency of the AEMS flight.
Transient fatigue, resulting mainly from extended awake times and the window of circadian low, may
be controlled by having enough rest. A rest period must be long enough to allow a crew member to
obtain a high quality sleep to report fully rested for duty. Limiting the duration of the FDP depending
on its starting time is intended to mitigate excessive awake times for those FDPs that take place at
night. An effective system to control crew member fatigue may only be achieved by the appropriate
combination of the following elements:
— minimum requirements for the duration of rest periods;
— limits on the duration of the FDP depending on the time of the day it takes place considering the
circadian rhythm; and
— measures to control cumulative fatigue resulting from previous duties.
21. CS FTL.2.100 defines the scope of the new set of certification specifications addressed to air taxi and
AEMS operations. Despite many similarities between air taxi and AEMS operations and the need to
apply compatible FTL regimes within a single FDP, still some CS are only applicable to air taxi and some
others to AEMS.
22. GM1 CS FTL.2.100 explains that for the sake of regulatory continuity, positioning of the aeroplane after
the patient is offloaded should still be considered an AEMS operation.
23. CS FTL.2.200 — same requirements as regards ‘home base’ apply to air taxi and AEMS.
24. CS FTL.2.205:
— to ORO.FTL.205(b)(6) and (d1) — no change as regards night duties in air taxi and AEMS
operations compared to CS-FTL.1;
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— to ORO.FTL.205(b)(6) — a new Table 1 introduces specific values of the maximum daily FDP
without extensions for acclimatised crew members in two-pilot air taxi and AEMS operations.
ORO.FTL.205(b)(6) allows air taxi and AEMS operators to specify in their flight specification
schemes FDP limits within the limits of CS FTL.2.205. These limits are presented in Table 1 under
CS FTL.2.205. The maximum pre-planned FDP is set to 14 hours in a 3-sector FDP at the most
favourable time of the day. For on-demand operations the workload is measured in a number of
sectors; thus the FDP reduction due to workload starts at the fourth sector and not as in
CS-FTL.1 at the third sector. Table 1 is based on the recommendations of Attachment IV and has
been scientifically assessed as presented in Attachment V. Due to the nature of on-demand air
taxi and AEMS operations, pre-planning is not always practicable.
— to ORO.FTL.205(d1)(4) — a new Table 2 introduces specific values of the pre-planned maximum
daily FDP with extensions without on-board rest for acclimatised crew members in two-pilot air
taxi and AEMS operations. The values in this table are based on the table in CS FTL.1.205(b). It
must also follow the conditions contained in ORO.FTL.205(d1).
— to ORO.FTL.205(e) — now includes the concept of on-board rest specific for FDPs in air taxi and
AEMS where the basic flight crew may be augmented by one or two additional flight crew
members. As opposed to the concept of in-flight rest, here the time that the aeroplane is on the
ground is also available as relief period for fatigue mitigation. The time that the aeroplane is on
the ground may, however, only be counted as on-board rest if certain conditions, as stipulated
in CS FTL.2.205, are met. Notably, the operator must establish a procedure to ensure that crew
members are not disturbed during on-board rest. In CS-FTL.1 rest facilities located separately
from the flight crew compartment and from the passenger cabin are deemed to achieve the
maximum extension of the FDP. This separation is, however, not possible in smaller aeroplane
types that are often used for air taxi and AEMS operations. Therefore, the definitions of in-flight
rest facilities in CS-FTL.1 have been adapted to the size of aeroplanes normally used for air taxi
and AEMS operations. The lack of separation is compensated by requiring:
means to provide darkness and noise mitigation; and
a procedure that ensures that resting crew members are not disturbed.
The values of minimum on-board rest for cabin crew in air taxi and AEMS operations are
adapted to the specificities described above. They are based on the provisions in CS-FTL.1.
— to ORO.FTL.205(f) — is only applicable to AEMS operations; it includes the possibility to develop
specific conditions to modify the limits on flight duty, duty, and rest periods by the commander
in the case of unforeseen circumstances, which occur at or after the reporting time based on
CS FTL.2.205. In AEMS operations it should be possible to exceed the maximum allowed FDP
based on the commander’s discretion in order to be able to continue a flight to its destination or
alternate aerodrome after take-off also if unforeseen circumstances occur just before take-off
for the final sector. This is, however, only allowed if a patient is on board.
— to ORO.FTL.205(g) — delayed reporting in the event of unforeseen circumstances in air taxi and
AEMS — no change compared to CS-FTL.1.
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25. CS FTL.2.210 sets more restrictive cumulative limits in case the operator has chosen, under
ORO.FTL.210(e), to apply more flexible daily FDP limits in its air taxi operations.
26. CS FTL.2.215 — based on the findings contained in Attachment IV, ORO.FTL.215 requires operators to
specify in their flight time specification schemes the impact of positioning and the mode of transport
on the maximum FDP in air taxi operations. Therefore, CS FTL.2.215 stipulates that:
— the maximum daily FDP is reduced by 30 minutes, if the positioning time is over 1 hour.
— the maximum daily FDP is reduced by 30 min, if the self-driving driving time is between 30 min
and 60 min, and by twice the duration of the self-driving time in excess of 60 minutes.
27. CS FTL.2.220 — applies to both air taxi operations and AEMS. As explained here above, it is possible to
start an FDP as an air taxi operation and continue and finalise it as an AEMS. Therefore, certain
elements are common for both air taxi operations and AEMS. That is the case for split duty.
CS FTL.2.220 is based on CS-FTL.1. However, the specific nature of air taxi and AEMS operations make
the following adaptions of split duty requirements necessary:
— flexibility in the number of breaks: it is possible to apply more than one break on the ground
during one split duty, provided one break has a minimum duration of 3 consecutive hours and
any additional break on the ground has a minimum duration of at least 2 hours. This is without
reducing the possibility and time available to sleep during the break e.g. excluded from each
break is the time for disembarking passengers before the break and embarking passengers after
the break and other duties on the ground;
— flexibility in rest facilities: either in the accommodation on the ground or in a Class A facility on
board of the aeroplane as long as each crew member has one rest facility available during the
entire break. This additional flexibility is necessary to allow for operations to distant airports
that do not have accommodation in the vicinity.
28. CS FTL.2.225 — applies to standby in both air taxi operations and AEMS to allow operators to carry out
both types of operations. Typically, crew members in these types of operations spend more time on
standby other than airport-standby than crew members in scheduled and charter operations.
Therefore, CS FTL.2.225 introduces certain flexibility, based on operational experience and best
practices, without compromising the level of safety:
— In air taxi and AEMS operations the likelihood to be called out of standby with short notice for a
departure in the early morning hours (e.g. before 07:00) is rather low. Crew members are
supposed to remain within their day-night rhythm in the time zone where they are acclimatised.
In these types of operations and due to the high number of standby days, it is paramount for
crew members to manage their sleeping behaviour in order to prepare themselves for duty calls.
In this context, fatigue management training is crucial to explain which are the most appropriate
sleeping and napping strategies for the specific type of operation in line with sleep science. The
maximum duration of standby remains 16 hours as in CS-FTL.1. It may be extended by the
number of hours between 23:00 and 07:00 or between 13:00 and 17:00, if crew members are
undisturbed and able to remain at their place of rest, if the standby encompasses that period.
— Following that same logic, a reduction of the FDP does not apply if crew members are
undisturbed and able to remain at their place of rest during the time intervals mentioned in the
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paragraph above. In all other cases the FDP must be reduced by any time spent on standby in
excess of 6 hours (8 hours for augmented crew operations or split duty).
— It is difficult to quantify the effect on cumulative fatigue of standby. It may be reasonably
assumed that the shorter the response time is, the higher the impact is on the crew members’
ability to manage their rest. Therefore, 100 % of time spent on standby with a response time of
less than 60 minutes shall count as cumulative duty time for the purpose of CS FTL.2.210(a). For
response times between 60 and 89 minutes 50 % shall count and 25 % for response times of
90 minutes or more. These values have been agreed by consensus in the rulemaking group.
A new point (c) defines the meaning of response time and requires operators to establish a response
and reflect it in their flight time specifications scheme.
29. CS FTL.2.230 — only applies to air taxi operations. It is based on CS-FTL.1, but, for clarity, it includes
some elements from the definition and the GM. GM1 CS FTL.2.230(d) is new and explains what fatigue
management principles means in the context rostering sleep opportunities when crew members are
on reserve.
30. CS FTL.2.235 — applies to air taxi and AEMS operations. It is based on CS-FTL.1, but adapted to the
specific operational context, as follows:
— to mitigate disruptive schedules, an additional option is offered to mitigate transitions at home
base from a late finish to an early start. Operators may choose to:
offer 1 local night of rest between the 2 FDPs as known from CS-FTL.1; or
limit the second FDP to 11 hours and defer the rest period including 1 local night after it.
— the requirements to compensate for time zone crossing are the same as in CS-FTL.1. Only
editorial improvements have been made to the text.
— specific reduced rest provisions allow rest periods no shorter than 10 hours out of base and 12
hours at home base, provided:
the crew member is acclimatised;
the rest period includes a local night;
the rest period takes place at a location no further than 3 time zones away from the place
of departure;
the flight time in the FDP prior to the rest period does not exceed 8 hours;
the FDP prior to the rest is limited to 4 sectors; and
the total flight time in the previous 7 consecutive days prior to rest period is no more than
24 hours.
These provisions are based on the findings presented in Attachment IV.
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CERTIFICATION SPECIFICATIONS
AND GUIDANCE MATERIAL
FOR COMMERCIAL AIR TRANSPORT BY HELICOPTER
— EMERGENCY MEDICAL SERVICE OPERATIONS BY HELICOPTERS (HEMS)
CS-FTL.3
CS FTL.3.100 Applicability
The following certification specifications are applicable to emergency medical service operations by
helicopters (HEMS).
GM1 CS FTL.3.100 Applicability
To ensure regulatory continuity for the full duration of a HEMS flight, a HEMS flight may include
positioning the helicopter after the patient is unloaded from the helicopter to enable it to return to the
HEMS operating base for the next HEMS flight.
CS FTL.3.200 Home base — HEMS
(a) The home base is assigned to each crew member with a high degree of permanence and may
either be:
(1) a single HEMS operating base; or
(2) multiple HEMS operating bases if the travelling time between any of these HEMS
operating bases does not exceed 60 minutes under usual conditions.
(b) In the case of a change of home base, the recurrent extended recovery rest period prior to
starting duty at the new home base is increased once to 72 hours, including 3 local nights.
Travelling time between the former home base and the new home base is positioning or flight
duty period.
CS FTL.3.205 Flight duty period (FDP) — HEMS
Maximum basic daily FDP in HEMS operations under ORO.FTL.205(b)(7)
The maximum basic daily FDP without the use of extensions for acclimatised crew members in HEMS
operations is established as follows:
(a) For two-pilot HEMS operations, the basic maximum daily FDP and the maximum flight time
within that FDP are established in accordance with Table 1 and comply with the following
conditions:
(1) For FDPs of over 12 hours, the operator ensures at least one break of minimum 60
consecutive minutes or more within each FDP at the HEMS operating base at times that
ensure likelihood of sleep and provides suitable accommodation for the purpose of
breaks at the HEMS operating base;
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(2) The time for breaks constitutes 50 % of the time over 12 hours and excludes the
necessary time for post- and pre-flight duties; and
(3) The operator specifies in the operations manual a minimum of 30 minutes for the first
pre-flight duties performed at the beginning of the FDP and a minimum of 15 minutes for
post-flight duties for every flight returning to the HEMS operating base.
Table 1
Maximum basic daily FDP in hours — Acclimatised crew members in two-pilot HEMS operations
Two-pilot Maximum FT Maximum FT
Start of FDP maximum basic daily FDP with autopilot without autopilot
at reference time at HEMS base
0630-0659 12:30 7:30 5:30
0700-0729 13:00 8:00 6:00
0730-0959 14:00 9:00 7:00
1000-1059 13:30 8:30 6:30
1100-1159 13:00 8:00 6:00
1200-1359 12:30 7:30 5:30
1400-0629 12:00 7:00 5:00
(b) For single-pilot HEMS operations, the basic maximum daily FDP and the maximum FT within that
FDP are limited in accordance with Table 2, and comply with all the following conditions:
(1) Continuous FT is limited in all cases to 4 hours with autopilot and to 2 hours without
autopilot;
(2) For FDPs of over 10 hours, the operator ensures at least one break of minimum 60
consecutive minutes within each FDP at the HEMS operating base at times that ensure
likelihood of sleep and provides suitable accommodation for the purpose of breaks at the
HEMS operating base;
(3) The time for breaks constitutes 50 % of the time over 10 hours and excludes the
necessary time for post- and pre-flight duties;
(4) The operator specifies in the operations manual, a minimum of 30 minutes for the first
pre-flight duties performed at the beginning of the FDP and a minimum of 15 minutes for
post-flight duties for every flight returning to the HEMS operating base.
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Table 2
Maximum basic daily FDP in hours — Acclimatised crew members in single-pilot HEMS operations
Single-pilot Maximum FT Maximum FT
Start of FDP Maximum basic daily with autopilot without autopilot
at reference time FDP at HEMS base
0630–0659 12:30 05:30 03:30
0700–0729 13:00 06:00 04:00
0730–0959 14:00 07:00 05:00
1000–1059 13:30 06:30 04:30
1100–1159 13:00 06:00 04:00
1200–1359 12:30 05:30 03:30
1400–0629 12:00 05:00 03:00
(c) If the rest period before reporting for the FDP is taken at the HEMS operating base, the limits of
Table 1 for reporting times between 0730-0959 also apply for reporting times between 0630–
0729.
(d) The operator may assign a block of up to 4 consecutive FDPs of more than 12 hours, but less
than 14 hours, if the following conditions are met:
(1) the rest period preceding the first FDP is at least 36 hours including 2 local nights; and
(2) the rest period provided after completion of the series of consecutive FDPs is at least 60
hours including 3 local nights.
CS FTL.3.205 Flight duty period (FDP) — HEMS
Unforeseen circumstances in flight operations — commander’s discretion in HEMS under
ORO.FTL.205(f)
The conditions to modify the limits on flight duty, duty and rest periods by the commander in the case
of unforeseen circumstances in HEMS flight operations which occur at or after the reporting time, or at
the end of the FDP, comply with the following:
(a) The maximum basic daily FDP may be increased for HEMS by up to 1 hour for single-pilot
operation or by up to 2 hours for two-pilot operation.
(b) If on the final sector within the FDP the allowed increase under (a) is further exceeded because
of unforeseen circumstances after take-off, the flight may continue to the planned destination
or alternate aerodrome. If unforeseen circumstances occur just before take-off on the final
sector, the allowed increase may only be exceeded to transport the patient.
(c) If commander discretion is used in any HEMS operating base more than 10 % of the total FDP
over a 3-month period, the schedule and crew resources of the HEMS operating base are
reviewed and adapted.
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CS FTL.3.210 Flight times and duty periods — HEMS
Duty periods in HEMS operations under ORO.FTL.210(b)
The total duty periods to which an individual crew member in HEMS operations may be assigned under
ORO.FTL.210(b) does not exceed either of the following limits:
(1) 110 duty hours in any 14 consecutive days, on the condition that:
i. the maximum daily FDP specified in CS FTL.3.205(a) or (b) does not exceed 14 hours;
ii. the operator ensures at least one break of minimum 60 consecutive minutes within
each FDP at the HEMS operating base at times that ensure likelihood of sleep;
iii. for each FDP of more than 12 hours, the total break time constitutes 50 % of the time
above 12 hours;
iv. the time for breaks excludes the necessary time for post- and pre-flight duties;
v. the operator provides suitable accommodation for crew members at the HEMS
operating base for the purpose of breaks;
vi. the minimum recurrent extended recovery rest period required under
ORO.FTL.235(d) shall be increased to include 4 local nights.
(2) 190 duty hours in any 28 consecutive days, spread as evenly as practicable throughout
that period.
CS FTL.3.220 Split duty — HEMS
The following applies in the case of split duty with one or more breaks on the ground in HEMS
operations:
(a) A break on the ground at the HEMS operating base is at least 60 consecutive minutes, if taken in
a suitable accommodation, or at least 2 consecutive hours, if taken in accommodation.
(b) If not taken at the HEMS operating base, the break on the ground has a minimum duration of
3 consecutive hours.
(c) For any break of 6 hours or more or for a break that encroaches the window of circadian low
(WOCL), suitable accommodation is provided;
(d) Time allowed for post- and pre-flight duties and travelling is excluded from each break; the
minimum total time for post- and pre-flight duties and travelling is 30 minutes or 15 minutes if
at a HEMS operating base; the operator shall specify the actual times in its operations manual;
(e) An operator may extend the basic maximum daily FDP specified in CS FTL.3.205 by up to 50 % of
the combined duration of all breaks on the ground, with the exception of the time exceeding
6 hours or encroaching the WOCL if spent in other than suitable accommodation.
GM1 CS FTL.3.220(b) Split duty — HEMS
Post-, pre-flight duty and travelling times
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The operator should specify post- and pre-flight duty and travelling times taking into account the
aircraft type, the type of operation and the conditions of the airport, landing site or HEMS operating
base, as applicable.
CS FTL.3.225 Standby and duties at the HEMS operating base
The limits on flight duty, duty and rest periods in HEMS operations may be modified in accordance with
the following:
(a) The maximum duration of standby duty is 16 hours.
(b) Standby is followed by a rest period in accordance with ORO.FTL.235. In case of consecutive
standby duties not leading to an assignment of FDP, the applicable minimum rest period may be
reduced to 8 hours, if the response time specified by the operator is 60 minutes or more.
(c) Standby ceases when the crew member reports at the designated reporting point.
(d) If standby ceases within the first 6 hours of standby, the maximum FDP counts from reporting;
(e) If standby ceases after the first 6 hours, the maximum FDP is reduced by the amount of standby
time exceeding 6 hours except in case of split duty; or
(f) Time on standby duty is not counted for the reduction of the maximum allowable FDP in the
following cases:
(1) if the standby starts between 23:00 and 07:00 and the crew member is not contacted by
the operator during that period;
(2) if the assigned FDP includes a break on the ground; and
(3) the response time established by the operator allows the crew member to arrive from
his/her place of rest to the designated reporting point within a reasonable time.
(g) The response time is the time between the communication of a duty assignment and the
reporting time and is reflected in the operator’s flight time specification scheme.
CS FTL.3.230 Reserve — HEMS
The operator, when assigning duties to a crew member on reserve as provided for by ORO.FTL.230,
complies with the following:
(a) A crew member may be assigned to a maximum of 21 days on reserve per calendar year.
(b) Any FDP or standby duty, assigned after the reserve, counts from the reporting time.
(c) Reserve times do not count as duty period for the purpose of ORO.FTL.210(a) or (b) and
ORO.FTL.235.
(d) The operator specifies a number of consecutive reserve days within the limits of
ORO.FTL.235(d).
(e) To protect an 8-hour sleep opportunity in accordance with fatigue management principles, the
operator rosters/pre-notifies for each reserve day a period of 8 hours during which a crew
member on reserve cannot be contacted by the operator.
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(f) Minimum notification time for any duty is 10 hours that may include the 8-hour sleep
opportunity under (e).
(g) Reserve time does not count as recurrent extended recovery rest.
GM1 CS.FTL.3.230(d)
Fatigue management principles means, in the context of a rostered 8-hour sleep opportunity, that
crew members should be able to maintain a consistent sleep pattern with surrounding days.
CS FTL.3.235 Rest periods — HEMS
(a) Reduced rest in HEMS operations complies with the following:
(1) The minimum rest period may be reduced to 10 hours, only if taken at the HEMS
operating base with a suitable accommodation provided by the operator.
(2) Reduced rest is used under FRM.
(3) The recurrent extended recovery rest following a reduced rest period is increased to
include 4 local nights.
(b) Disruptive schedules
(1) When a transition from a late finish/night duty to an early start is planned at home base,
the rest period between the 2 FDPs, includes 1 local night.
(2) For a crew member performing 4 or more night duties, early starts or late finishes
between 2 extended recovery rest periods as defined by ORO.FTL.235(d), the second
extended recovery rest period is extended to include 3 local nights.’
Rationale for CS-FTL.3
31. The inclusion of HEMS FTL rules in Subpart FTL makes the development of specific certification
specifications for HEMS necessary. HEMS operations, from an FTL perspective, are currently not at all
harmonised at EU level contrary to HEMS from an air operations perspective. Subpart J of Annex V
(Part-SPA) to Regulation (EU) No 965/2012 is entirely dedicated to HEMS and reflects the philosophy
of HEMS flights. This NPA proposes a new set of certification specifications that are in line with the
HEMS philosophy, CS-FTL.3, to cover HEMS operations. The CS-FTL.3 requirements are developed on
the basis of input from the rulemaking group and data presented in Attachments I and II.
32. FTL.3.100 sets the scope of CS-FTL.3. GM1 CS FTL.3.100 explains that, for the purpose of regulatory
continuity, positioning of the helicopter after the patient is offloaded should still be considered HEMS
operation if the flight was started as HEMS flight.
33. CS FTL.3.200 refers to HEMS operating base instead of airport, because HEMS helicopters are often not
based at an airport. ‘HEMS operating base’ is defined in Annex I to Regulation (EU) No 965/2012. It is
possible to assign multiple HEMS operating bases to one crew member as home base, provided the
travelling time between any of these HEMS operating bases does not exceed 60 minutes under usual
conditions. This proposal is based on a consensus amongst rulemaking group members.
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34. CS FTL.3.205:
— to ORO.FTL.205(b)(7) — currently, duty period limits in HEMS operations across EU Member
States vary considerably. The data collection and preliminary impact assessment commissioned in
2012 by EASA (see Attachments I and II) showed that there was a wide range of national practices.
The majority of rulemaking group members therefore agreed, for the purpose of defining
common FDP limits for HEMS, to build on those national practices that include scientific principles
and are based on extensive operational experience. They aim at ensuring an appropriate balance
between wake and sleep times in a 24-hour cycle in combination with the minimum rest
requirements. A block of consecutive duty days must be followed by an off-duty period that is
long enough to fully dissipate cumulative fatigue from the duty days before.
CS FTL.3.205 establishes FDP limits in tables for two-pilot and single-pilot HEMS operations. The
FDP limits range from:
12 hours when the FDP encroaches the night hours; and
up to 14 hours when the FDP starts at the most favourable time of the day.
Basic maximum daily FDPs of more than 12 hours are possible only if crew members can benefit
from at least one break of at least 60 consecutive minutes. Fatigue due to workload is controlled
by limiting the flight time during the FDP depending on the time of the day and on whether the
helicopter is equipped with an auto pilot. A similar approach is proposed for maximum basic FDP
for single-pilot HEMS operations. The maximum flight time for the maximum daytime FDP is
limited to 7 hours with autopilot and 5 hours without autopilot. During the least favourable hours
of the circadian rhythm the maximum flight time is limited to 5 hours with autopilot and 3 hours
without autopilot.
For FDPs following a rest period that has been taken at the HEMS base, the maximum FDP for a
start of the FDP between 0730 and 0959 may be applied 1 hour earlier. This will not have an
impact on the crew members’ ability to sleep because crew members will not spend any time on
travelling from their place of rest to the HEMS base.
It is possible to roster a block of up to 4 consecutive FDPs of more than 12 but less than 14 hours,
only if the block is surrounded by extended recovery rest periods: 36 hours including 2 local nights
before and 60 hours including 3 local nights after, to ensure that there is enough time to dissipate
potential cumulative fatigue. Thus, a current operational practice in some Member States may
continue under the common rules allowing 4 consecutive 14-hour FDPs with rest periods at the
HEMS base of 10 hours, on the condition that each FDP of more than 12 hours includes at least
120 minutes break time of which 60 minutes are consecutive.
— to ORO.FTL.205(f) — commander’s discretion in the case of unforeseen circumstances after
reporting may be applied to extend flight duty and duty periods in HEMS, on the condition that it
is limited to 1 hour for single-pilot operations and 2 hours for two-pilot operation. Where
unforeseen circumstances occur after take-off on the final sector, the flight may continue to the
planned destination or alternate aerodrome. If unforeseen circumstances occur just before take-
off on the final sector, the allowed increase may only be exceeded to transport the patient. The
use of commander’s discretion must be monitored per HEMS operating base. Crew resources and
schedule of a HEMS operating base must be reviewed, if commander’s discretion is applied in
more than 10 % of the FDPs operated at one HEMS operating base in a 3-month period.
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35. CS FTL.3.210 allows for 110 duty hours in 14 consecutive days under certain conditions as an
alternative to the 60 hours of duty in 7 consecutive days required under ORO.FTL.210. This is
necessary to enable the continuation of an existing safe working model consisting of a block of 5
12-hour FDPs followed by 5 rest periods of 12 hours at the HEMS operating base, including a buffer for
commander’s discretion. Otherwise, the 7-day limit of 60 hours would be exhausted already on the
fourth day, considering the need of certain buffers for unplanned extensions during the first 4 days.
This is, however, only possible if the following mitigation is applied: the operator ensures at least one
break per FDP of minimum 60 consecutive minutes at the HEMS operating base, provides suitable
accommodation and increases the extended recovery rest period to include 4 local nights.
36. CS FTL.3.220 sets the conditions for split duty (break on the ground) in any other case, irrespective of
the length of the FDP or cumulative duty period. It is an adaptation of the CS-FTL.1 split duty
provisions to the HEMS operating environment
37. CS FTL.3.225 is an adaptation of the CS-FTL.1 airport standby provisions to the HEMS operating
environment. The FDP assigned when a crew member is on standby will in most cases be reduced
except when:
— the standby has started between 23:00 and 07:00 and the crew member is not contacted by the
operator during that period of 8 hour sleep opportunity;
— the assigned FDP includes a break on the ground; and
— the response time established by the operator allows the crew member to arrive from his/her
place of rest to the designated reporting point within a reasonable time.
These conditions are intended to ensure that the time on standby does not increase the awake time
before the start of the FDP. A new point (g) defines the meaning of response time and requires
operators to establish a response time and reflect it in their flight time specifications scheme.
38. CS FTL.3.230 is an adaptation of the CS-FTL.1 Reserve provisions, but for clarity includes some
elements from the definition and the GM. The prescriptive limit of 21 days of reserve per crew
member and per calendar year is based on the comparison of existing practices and the consensus of
the rulemaking group. In the HEMS operating environment it is often found that crew members have
considerable commuting distances between their residence and the HEMS operating base. Therefore,
an excessive number of reserve days could negatively impact on the cumulative fatigue resulting from
commuting between the residence of the crew member and the HEMS operating base.
GM1 CS FTL.3.230(d) is new and explains what fatigue management principles means in the context
rostering sleep opportunities when crew members are on reserve.
39. CS FTL.3.235 establishes reduced rest provisions that are tailored to the HEMS environment. The
reduced rest periods in HEMS operations are provided on the HEMS operating base. That means, crew
members do not spend any time on travelling between the HEMS operating base and the place of rest.
Therefore, the minimum rest period at the HEMS operating base is set to 10 hours. This allows for an
8-hour sleep opportunity. The FDP following a reduced rest period does need to be reduced because
the workload in HEMS is limited by limiting the number of flight hours per FDP and by prescribing a
protected break(s) during the FDP.
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3.3. Draft acceptable means of compliance and guidance material (Draft EASA Decision)
‘SUBPART FTL
FLIGHT AND DUTY TIME LIMITATIONS AND REST REQUIREMENTS
SECTION 1
General
GM1 ORO.FTL.105(1) Definitions
ACCLIMATISED
(a) A crew member remains acclimatised to the local time of his/her reference time during 47 hours
59 minutes after reporting no matter how many time zones he/she has crossed.
(b) The maximum daily FDP for acclimatised crew members is determined by using the appropriate
tables 1 of ORO.FTL.205(b)(1) or of the certification specifications applicable to the type of
operation with the reference time of the point of departure. As soon as 48 hours have elapsed,
the state of acclimatisation is derived from the time elapsed since reporting at reference time
and the number of time zones crossed.
[…]
GM1 ORO.FTL.105(10) Definitions
ELEMENTS OF STANDBY FOR DUTY
ORO.FTL.225(c) and (d) and CS FTL.1.225 (b)(2) the certification specifications applicable to the type of
operation determine which elements of standby count as duty.
[…]
GM1 ORO.FTL.105(17) Definitions
OPERATING CREW MEMBER
A person on board an aircraft is either a crew member or a passenger. If a crew member is not a
passenger on board an aircraft he/she should be considered as ‘carrying out duties’. The crew member
remains an operating crew member during in-flight rest or on-board rest, as applicable. In-flight rest or
on-board rest, as applicable, counts in full as FDP, and for the purpose of ORO.FTL.210.
[…]
AMC1 ORO.FTL.110(a) Operator responsibilities
PUBLICATION OF ROSTERS IN CAT SCHEDULED AND CHARTER OPERATIONS
Rosters should be published at least 14 days in advance in CAT scheduled and charter operations.
AMC2 ORO.FTL.110(a) Operator responsibilities
PUBLICATION OF ROSTERED REST PERIODS IN AIR TAXI, AEMS AND HEMS OPERATIONS
Rostered extended recovery rest periods should be published at least 7 days in advance.
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AMC3 ORO.FTL.120(b)(4) Fatigue risk management (FRM)
HEMS OPERATORS IDENTIFICATION OF HAZARDS
In addition to AMC1 ORO.FTL.120(b)(4), HEMS operators should also take into account hazards specific
to HEMS operations, such as the following:
(a) The mission rate of the HEMS operating base;
(b) Any particular conditions of the HEMS operating site or HEMS operating base;
(c) The workload and stress levels of single-pilot operations;
(d) The permanent hands-on flying on aircraft not equipped with autopilot;
(e) Operations to unsurveilled landing sites or unknown destinations; and
(f) Particular environmental circumstances such as extreme temperatures, smells, noises, air
dryness, humidity, as well as vibrations, absence of lavatories, and wearing a helmet/survival
suit.
[…]
AMC1 ORO.FTL.120(b)(7) Fatigue risk management (FRM)
CAT OPERATORS FRM PROMOTION PROCESS
FRM promotion processes should support the on-going development of FRM, the continuous
improvement of its overall performance, and attainment of optimum safety levels.
The following should be established and implemented by the operator as part of its FRM:
(a) training programmes to ensure competency commensurate with the roles and responsibilities of
management, flight crew, and cabin crew, technical crew and all other involved personnel under
the planned FRM; and
(b) an effective FRM communication plan that:
(1) explains FRM policies, procedures and responsibilities to all relevant stakeholders; and
(2) describes communication channels used to gather and disseminate FRM-related
information.
[…]
AMC1 ORO.FTL.125(a) Flight time specification schemes
SINGLEPILOT OPERATIONS BY AEROPLANE
(a) The flight time specification scheme for single-pilot scheduled and charter operations by
aeroplane should be established on the basis of the certification specifications of CS-FTL.1.
(b) The flight time specification scheme for single-pilot air taxi or AEMS operations by aeroplane
should be established in accordance with the certification specifications of CS-FTL.2.
[…]
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SECTION 2
Commercial Air Transport Operators
GM1 ORO.FTL.200 Home base
TRAVELLING TIME
Crew members should consider making arrangements for temporary accommodation closer to their
home base, if the travelling time from their residence to their home base usually exceeds 90 minutes.
GM1 ORO.FTL.205(a)(1) Flight Duty Period (FDP)
REPORTING TIMES
The operator should specify reporting times taking into account the type of operation, the size and
type of aircraft and the reporting airport conditions of the reporting airport or HEMS operating base as
applicable.
[…]
AMC1 ORO.FTL.210(c)(f) Flight times and duty periods
POST-FLIGHT DUTIES
The operator should specify post-flight duty times taking into account the type of operation, the size
and type of aircraft and the airport conditions of the airport or the HEMS operating base, as
applicable.
[...]
AMC1 ORO.FTL.225 Standby
MINIMUM REST AND STANDBY
(a) If airport or other standby initially assigned is reduced by the operator during standby that does
not lead to an assignment to an FDP, the minimum rest requirements specified in ORO.FTL.235
should apply.
(b) If a minimum rest period as specified in ORO.FTL.235 is provided before reporting for the duty
assigned during the standby, this time period should not count as standby duty.
(c) Standby other than airport standby counts (partly) as duty for the purpose of ORO.FTL.210(a) or
(b) only. If a crew member receives an assignment during standby other than airport standby,
the actual reporting time at the designated reporting point should be used for the purpose of
ORO.FTL.235.
GM1 ORO.FTL.225 Standby
STANDBY OTHER THAN AIRPORT STANDBY NOTIFICATION
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Operator procedures for the notification of assigned duties during standby other than airport standby
should avoid interference with sleeping patterns if possible.
GM1 ORO.FTL.225 Standby
AWAKE TIME
Scientific research shows that continuous awake time in excess of 18 hours can reduce the alertness
and should be avoided.
GM1 ORO.FTL.230 Reserve
RESERVE NOTIFICATION
Operator procedures for the notification of assigned duties during reserve should avoid interference
with sleeping patterns if possible.
GM2 ORO.FTL.230 Reserve
NOTIFICATION IN ADVANCE
The minimum 'at least 10 hours' between the notification of an assignment for any duty and reporting
for that duty during reserve may include the period of 8 hours during which a crew member on
reserve is not contacted by the operator.
GM1 ORO.FTL.230 Reserve
RECURRENT EXTENDED RECOVERY REST
ORO.FTL.235(d) applies to a crew member on reserve.
[…]
GM1 ORO.FTL.235 Rest periods
TIME ELAPSED SINCE REPORTING
The time elapsed since reporting for a rotation involving at least a 4-hour time difference to the
reference time stops counting when the crew member returns to his/her home base for a rest period
during which the operator is no longer responsible for the accommodation of the crew member.’
Rationale for the acceptable means of compliance and guidance material
40. GM1 ORO.FTL.105(1) ‘ACCLIMATISED’ is complemented with references to the FDP tables under
ORO.FTL.205(b) and the certification specifications applicable to specific types of operations in view of
the expanded scope. It explains how the maximum FDP is determined in operations that entail
crossing more than two times zones.
41. GM1 ORO.FTL.105(10) ‘ELEMENTS OF STANDBY FOR DUTY’ is complemented with a reference to the
certification specifications applicable to the type of operation.
42. GM1 ORO.FTL.105(17) ‘OPERATING CREW MEMBER’ is amended to refer also to on-board rest in the
case of air taxi and AEMS operations.
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43. AMC1 ORO. FTL.110(a) ‘PUBLICATION OF ROSTERS IN CAT SCHEDULED AND CHARTER OPERATIONS’ is
not appropriate for the specific on-demand nature of air taxi and EMS operations. The title is therefore
complemented to specify that it only refers to scheduled and charter operations. On-demand
operations do normally allow to pre-plan FDPs.
44. AMC2 ORO.FTL.110(a) ‘PUBLICATION OF ROSTERED REST PERIODS IN AIR TAXI, AEMS AND HEMS
OPERATIONS’ — a new AMC that requires pre-planning and publishing of extended recovery rest
periods 7 days in advance. The 7-day advance is based on the consensus of the rulemaking group. The
purpose of pre-planning is to allow crew members to manage their sleep periods and allow for an
appropriate work-life balance, referring in particular to being able to plan visits to administration,
doctors, dentists etc.
45. AMC3 ORO.FTL.120(b)(4) ‘HEMS OPERATORS IDENTIFICATION OF HAZARDS’ — a new AMC
specifically addressed to HEMS operators in view of the specific fatigue hazards in HEMS operations.
A non-exhaustive list of elements that should be taken into account when assessing fatigue in HEMS
operations gives examples of these specificities.
46. AMC1 ORO.FTL.120(b)(7) ‘CAT OPERATORS FRM PROMOTION PROCESS’ is complemented with a
reference to HEMS crew members in view of the extended scope of the regulation to HEMS
operations.
47. AMC1 ORO.FTL.125(a) ‘SINGLE-PILOT OPERATIONS BY AEROPLANE’ clarifies which set of certification
specifications apply to single-pilot operations with aeroplanes depending on how those operations are
taking place — as scheduled, charter or as on-demand (air taxi or AEMS).
48. GM1 ORO.FTL.200 ‘TRAVELLING TIME’ is moved from GM1 CS FTL.1.200 to the implementing rules as
it is considered relevant for all types of operations. It recommends crew members to make
arrangements to avoid commuting times of more than 90 minutes (travelling from their residence to
their home base).
49. GM1 ORO.FTL.205(a)(1) ‘REPORTING TIMES’ is complemented with a reference to the HEMS
operating base as crew members in HEMS operations usually report for and finish their duties at HEMS
operating bases.
50. AMC1 ORO.FTL.210(f) ‘POST-FLIGHT DUTIES’ now includes a reference to the HEMS operating base.
This AMC previously addressed ORO.FTL.210(c).
51. Moved from CS-FTL.1 to the implementing rules as they are considered relevant for all types of
operations are the following AMC/GM:
— AMC1 ORO.FTL.225 ‘MINIMUM REST AND STANDBY’ (previously GM1 CS FTL.1.225);
— GM1 ORO.FTL.225 ‘STANDBY OTHER THAN AIRPORT STANDBY NOTIFICATION’ (previously
GM1 CS FTL.1.225 (b));
— GM1 ORO.FTL.225 ‘AWAKE TIME’ (previously GM1 CS FTL.1.225(b)(2));
— GM1 ORO.FTL.230 ‘RESERVE NOTIFICATION’ (previously GM1 CS FTL.1.230);
— GM2 ORO.FTL.230 ‘NOTIFICATION IN ADVANCE’ (previously GM2 CS FTL.1.230);
— GM1 ORO.FTL.230 ‘RECURRENT EXTENDED RECOVERY REST’ (previously GM1 CS FTL.1.230(c));
— GM1 ORO.FTL.235 ‘TIME ELAPSED SINCE REPORTING’ (previously GM1 CS FTL.1.235(b)(3)).
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4. Impact assessment (IA)
4.1. What is the issue
4.1.1. EMS operations in EASA Member States
Overall Scale of EMS Activity
Based on the data that could be collated, approximately 200 000 HEMS and AEMS missions are flown annually
in Europe. HEMS represent 90 % of these operations. There are over 360 HEMS helicopter bases in Europe
with additional fixed-wing air ambulance bases chiefly providing cross-border or intercontinental services such
as medical repatriation (http://www.ehac.eu/index.html).
Extra details about activity levels were sought from the eight States surveyed are presented in Attachment I.
This data was supplemented by data available on public websites. The number of annual missions per State
are summarised in Table 2.1 below. Not all the surveyed States were able to provide data. The values in Table
2.1 account for about 75 % of the estimated 200 000 missions per year in Europe.
Table 1: Annual Missions By State (partial picture only) — Year 2012
MEMBER STATE HEMS AEMS TOTAL COMMENTS
MISSIONS MISSIONS MISSIONS
FRANCE 15000 private Minimum estimate for HEMS, AEMS
+11800 public data difficult to obtain
GERMANY 84671 1020 85691 Based on data from 3 operators
NETHERLANDS 4200 Data based on only 1 operator.
Assuming 2 flights = 1 mission.
NORWAY 10663 8988 19651 Data based on 1 operator and
military missions. Another operator
probably contributes about half as
much again in Norway.
POLAND 4417 327 4743 Assuming 2 flights = 1 mission.
SWITZERLAND 10797 1052 11849 Data based on 1 operator.
2 other operators in State.
UK 17500 1500 19000 Minimum value for AEMS
TOTAL 157000 13000 170000
(ROUNDED)
Source: DNV Study for EASA18 — Deliverable 2
Cross-border services
Table 2: Examples of operators with cross-border services
MEMBER OPERATOR ADDITIONAL NUMBER OF CROSSBORDER SERVICES WITH
STATE MEMBER HEMS BASES
STATE *
GERMANY HSD 3 Poland, Czechia, Austria, Switzerland,
Luftrettung Netherlands
gemeinnützige
18
Attachment I to this NPA.
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GmbH
GERMANY ADAC Austria 3 Belgium France Austria Netherlands
ITALY INAER 31 Austria
Aviation Italia
(Rotor Wing
Department)
LUXEMBURG Luxemburg Air 3 Germany, Belgium, France
Ambulance
S.A.
NORWAY Lufttransport 3 Sweden, Finland
NORWAY Norsk Denmark 8 Sweden
Luftambulanse
SWEDEN Norrlandsflyg 1 Norway, Denmark
Ambulans
SWEDEN Scandinavian Finland, Total:10 Norway
MediCopter Denmark SE: 6, FI: 3, DK:
1
SWITZERLAND Air-Glaciers SA 2 France, Italy
SWITZERLAND Base 1 France
hélicoptère
des HUG
SWITZERLAND HUG 1 France
SWITZERLAND REGA 12 Germany, France
Source: EHA, year 2015
*Additional Member State is the place where the operator has additional bases outside the teritory of the
Member State where the operator has its principle place of business.
Business models
The following was extracted from Attachment I.
‘There are many different EMS operators in Europe, as indicated in the DNV Appendix 3. These operators have
a variety of business models which affect their costs. The different EMS business models in Europe include the
following options, sometimes in combinations:
Government funded (via Civil and Military), examples include:
o Scottish Ambulance Service is the UK’s only government funded air ambulance service.
o Poland’s LPR is funded by the government through the Ministry of Health but run
independently.
o Helicopters operated by the Ministry of the Interior in Germany are staffed by German Police
pilots performing emergency responses when required.
o Royal Norwegian Air Force provides an air ambulance service.
o Norwegian Luftambulanse is funded primarily by grants from four regional health authorities.
Donation/ Charity based, e.g.:
o The air ambulance service in England and Wales is funded by charities organized into regions.
o REGA in Switzerland is non-profit receiving no government subsidies and obtains funds from
patrons and donations as well as fees for service from insurance companies and liable parties.
o The DRF’s AEMS and HEMS operations in Germany are not completely covered by public health
insurance and also need the support of sponsoring members and donations.
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Fee based – in this model operators charge fees for their EMS services. These fees can be covered by
travel or health insurance companies, liable parties or public health services. Some organisations mix
this model with additional donations as noted above.
Independently supported – a business or outside organization can fund the EMS service. An example of
this is ADAC, Germany’s largest automobile club, which funds the operation of many air ambulances.
Shared cost model – some EMS operators share aircraft, pilots and facilities with other organisations.
Examples include the UK’s Wiltshire and Sussex Air Ambulance services which part share their
helicopter operations with the Police.
As well as the different business models there are other factors that will affect operating costs around Europe
and between different operators:
Different types of mission in different States (e.g. aiding a ski injury as compared to a road traffic
accident);
Different utilisation of crews – for example, in some locations close to areas with high population
density and dense road infrastructure pilots may fly more missions than a pilot based in a remote
location;
Whether medical staff are included within the overall personnel costs of an EMS operator or whether
they are outside funded within health care services;
Whether crew and facilities are shared with other operators (e.g. police) and whether crew are leased
or are full time personnel.’
Estimated relative share of crew costs versus the total operating costs
Considering Attachment I (Table 2.2: Estimates of Crew Costs As Percentage of Overall Operating Costs) the
share of crew costs19 in comparison to the total operating costs varies from 11 to 32 %. There were only a
limited number of answers from the contacted Member States and operators.
4.1.2. Air taxi operations in EASA Member States
Air taxi flights in EASA Member States
Source: Attachment III section 2.2.2.1
‘There were 654,514 movements of Business Aviation (BA) in 2011 in Europe based on EUROCONTROL data.
45 %20 of BA traffic was found to be “non-scheduled commercial” and all this traffic involved aircraft with 19 or
less passenger seats. Commission Regulation (EU) No 965/2012 defines Air taxi operation as “Non-scheduled,
on demand commercial operations with an aeroplane with a passenger seating configuration of 19 or less.”
Thus, it is estimated that in 2011 there were 654,514 x 0.45 = 295,000 air taxi movements in Europe. It is
estimated that this represents approximately 3% of all movements in the EASA Member States; BA traffic in
total represents just over 7% of all movements (EBAA, 2012).’
19
Crew costs cover salary and non-salary such as pensions.
20
EUROCONTROL’s analysis of 2009 BA data (EUROCONTROL, 2010).
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General operational data from some Member States
Table 3: Air Taxi Operational Data from States
Source: Table 2.1, Attachment III
Size of Operators
‘The EBAA commissioned Alertness Solutions to examine fatigue factors in European Business Aviation
Operations (Alertness Solutions, 2011). As part of that study a survey of several hundred Business Aviation
pilots was conducted. One of the background questions asked was how many pilots are employed by your
company. The responses are shown below which provide an indication of the distribution of operator sizes in
Europe.’
Table 4: Distribution of Pilot Numbers for Business Aviation Operators
Single-Pilot Operation with Air Taxi
EBAA has no specific data on single pilot operations within air taxi or BA operations. It was considered a
marginal activity by EBAA within their membership.
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Table 5: Operational Data on SPLO for Air Taxi
Source: Attachment III, Table 2.3: Operational Data on SPLO for Air Taxi
‘In Poland about half the aircraft and pilots involved in air taxi are involved in single pilot operations. In Spain
there are no current air taxi single pilot operations. In the UK, about 25 % of air taxi operators have aircraft
capable of single pilot operations. Thus, based on the limited received data the picture is varied in different
European States. Further data collection on single pilot operations would be desirable.’
Scheduled Operations
Source: Attachment III, Section 2.2.2.2
‘In France, single pilots are involved in some scheduled operations. Examples include:
— Finist’air an airline providing scheduled passenger flights between Brest and Ouessant as well as air taxi
operations and freight transport. The airline operates Cessna 208 Caravans.
— St. Barth Commuter an airline based in the Caribbean operating Cessna 208 Caravans and Britten-
Norman Islanders.
In the UK single pilot operations apply to scheduled services around the Highlands and Islands (e.g. Loganair
and Hebridean Air Services) and the Channel Islands.
No other data on scheduled single pilot operations were obtained during the survey of NAAs and relevant
associations.’
4.1.3. AEMS
Source: Attachment III, Section 2.2.2.3
‘During the preparation of report D2 on EMS [Attachment II], data were received from France and UK that
single pilot AEMS operations take place in those States and that relevant FTL provisions are in place. Poland
stated that single pilot AEMS operations did not occur in that State. No other specific information on single
pilot operations in AEMS was obtained during the EMS survey.’
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4.1.4. Safety risk assessment
4.1.4.1 EMS Safety risk assessment (DNV assessment)
Attachment II Section 7, page 90
‘EMS operations have certain higher risk characteristics relative to other aircraft operations such as time
pressures to reach and transport patients and flights made at short notice with potentially challenging
topographical features and weather conditions. In addition there are aspects of flight time limitations and rest
provisions that could lead to fatigue and increased risk, e.g. requirements to extend a duty period to respond to
an emergency.’
Attachment II, page 4
‘Two European EMS accidents reports which refer to fatigue (or the possibility of fatigue) are described in
Appendix 1 from public domain sources. In addition EASA’s Safety Analysis Section conducted a search of the
EASA copy of the ICAO ADREP data base. This uncovered one further European accident and 2 non-European
EMS occurrences where fatigue appears to have been a factor. [Over the period 1971 – 12 January 2012]
These 5 events equate to 1.3% of the 395 EMS occurrences in the data base. Four of these five events were
fatal accidents. 28% of the 395 EMS occurrences in the data base were fatal accidents. Thus fatigue appears
to be a contributory cause in 3.6% of fatal EMS accidents. These relatively low percentages for the contribution
of fatigue to overall occurrence and accident rates should be treated with some caution for the reasons noted
above; in particular reports may not identify fatigue even though it could have been a factor to some degree.
One event from 2005 in the UK (described in Appendix I) reveals the potential difficulty of pilots on home
standby managing their rest so that they do not become excessively fatigued when they are called out,
particularly at night. Another occurrence was also related to a pilot remaining awake all day before a
helicopter nighttime shift.
Even with the caveats about under-reporting of fatigue as a causal factor it would appear from the occurrence
data that the controls that have been in place to manage fatigue in European EMS have generally been
effective. Compared to the social benefits from EMS operations in terms of patient safety and health (see
below), the overall safety balance (flight safety v patient safety) is very positive.’
In the period between 1 March 2012 and 31 August 2017, 59 accidents and 12 serious incidents in EMS
operations are recorded in the EASA ADREP Database. Of these, 13 accidents and 5 serious Incidents occurred
in the EASA Member States. In the entire dataset, 49 helicopters and 24 fixed-wing aircraft were involved in
these occurrences. In two of these accidents, both fatal, fatigue was identified as a possible contributory
factor.
— F-GXES, French Antilles, 2012-05-05, fatal accident, 4 fatalities, aircraft crashed in sea shortly after take-
off: ‘The causes of the accident cannot be determined with any certainty. However, the almost
permanent standby status used in single-pilot operations and the underlying risk of fatigue can be
considered a contributing factor.’
— EC-IBA, Spain, 2012-08-02, fatal accident, 2 fatalities, aircraft crashed on approach in heavy fog
condition: ‘The ultimate cause of the accident could not be determined. […] The contributing factors
were: […] the fatigue built up over the course of working at a time when they should have been sleeping
after an unplanned duty period.’
4.1.4.2 Air Taxi safety risk assessment
The EASA ADREP database contains 100 accidents and 22 serious incidents in air taxi operations in the period
between 1 March 2012–31 August 2017. Of these, 66 involved fixed-wing aircraft while 56 involved
helicopters.
12 accidents and 9 serious incidents occurred in the EASA Member States. None of these occurrences were
found to contain any information as to whether fatigue was a factor in the occurrence.
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4.1.5. Who is affected
— Operators of single-pilot operations with aeroplanes,
— Air taxi operators,
— AEMS operators,
— HEMS operators,
— Air taxi and AEMS crew members,
— HEMS crew members,
— NAAs,
— EASA.
4.1.6. How could the issue/problem evolve
HEMS
Currently, there are few HEMS bases in additional States and limited cross-border services. Furthermore, there
is no indication of specific urgent safety issues. Nonetheless, due to the differences in FTL HEMS in the
different Member States (detailed information in Attachment I, 3.2), it is difficult to estimate how effective
national fatigue mitigations would be under operational circumstances specific for another MS (i.e. number
and length of missions, service obligations such as response time, on the ground facilities for rest and other
national legislation that has an impact on crew member fatigue). Therefore, the current situation would
remain acceptable, if HEMS operations were conducted predominantly in the Member State that issued the
AOC. However, HEMS flights have only recently been harmonised at EU level from an air operations regulation
perspective. It can reasonably be expected that the situation will change in the near future in terms of number
of HEMS bases to be established across Europe and the number of services to be available cross-border. Since
purely national FTL provisions are often a result of social negotiation and adapted to the specific operational
circumstances of the Member States, discrepancies between national FTL regimes might make it difficult for
operators to conduct HEMS outside their principal home base.
Air Taxi
As specified in Section 4.1.4.2Error! Reference source not found., scheduled and charter CAT operations with
eroplanes and air taxi operations are very similar in terms of safety risks resulting from crew members’ fatigue.
Therefore, the reader is invited to refer to NPA 2010-14.
4.2. What we want to achieve — objectives
Please refer to Section 2.2.
4.3. How it could be achieved — options
The following options only focus on the HEMS operations.
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Table 6: Selected policy options HEMS
Option No Short title Description
0 No policy change No change in the existing situation; HEMS continue to be regulated
under MS national rules
1 Flexible approach Prescriptive EU rules combined with performance-based options, to
allow for flexibility, subsidiarity and proportionality (please refer to
rationale for CS-FTL.3)
2 Fully prescriptive Prescriptive EU rules for HEMS operators
approach
It has to be noted that the scope of the HEMS rules exclude the remote bases that are open on a 24-hour
basis. This decision has been taken after an analysis of the potential high negative economic impacts which
could, as a side effect, reduce the availability of such remote bases and limit the availability of emergency
medical services. For the future more research needs to be done in order to assess the fatigue risks in remote
basis.
The analysis shows that the impact of the new HEMS rules would be highly negative on certain remote bases:
1) If additional pilots are not recruited this would lead to higher workload for the pilots. In addition, if this
is not compensated by a corresponding increase in salary, this could lead to social tensions or pilots
finding a more lucrative job elsewhere (e.g. offshore in Norway).
2) If additional pilots are recruited this would lead to fewer flights per pilot. Consequently, this would lead
to a loss of practical experience due to the limited number of HEMS flights per pilot. This loss could be
compensated by additional training hours. However, this has not the same value as real HEMS flights.
3) If additional pilots are not recruited this would lead to less service for the public
The following table provides the justifications with an estimate of the impacts.
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Case Study — Remote bases open 24/24 (e.g. case in Norway)
Items for calculations Current situation Project situation* : Max duty period = 9 to 14h per day EASA draft rules
Solution 1: Change in pilot workload Solution 2: Change in crew members
Comment Impact Change Comment Impact Change Comment
(%) (%)
For one crew member (1
crew = 1 pilot + 1 HEMS
crew member)
Mandatory maximum duty 2000 2000 2000
hours per year
Hour buffer for training 200 200 200
Max target duty hours 1800 1800 1800
Number of days of work 7 7 0% 7 0%
per week
Number of hours per day 14 14 hours/day plus 10 12 -14% Day and night shifts are introduced to 12 -14% Day and night shifts are introduced
hours rest, all spent cope with EASA rules to cope with EASA rules
at the base, over 7
consecutive days
Number of work weeks 15 1 work week/2 week 21 40 % Increase of 40 % of work weeks: there are 15 0%
off - 1ww/3wo 2 possibilities:
1) HEMS pilots may go for CAT helicopter
offshore operations where they would
get a higher salary relevant for the higher
work weeks in offshore
2) HEMS pilots may request higher salary
to compensate the increased working
weeks
Note: risk of social conflicts with HEMS
crew member which could request higher
salary
Number of crew member 1 1 1.4 40 % Increase of 40 % of crew member:
the consequence is a decrease of
flight hours per crew as the number
of missions will remain the same
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Additional training hours 70 35% Increase of 35% of training hours
to compensate decrease of
mission flight hours per
crew member
Additional staff to not Additional training hours means
compensate additional quantifi that more crew shall be recruited to
training ed compensate the staff on training. A
here, total impact is calculated for
see Norway in the table below.
comme
nts
Total number of hours per 1470 1764 20 % 1470 0%
year
Items for calculations Current situation Project situation* : Max duty period = 9 to 14h per day EASA draft rules 30.10.2013
Solution 1: Change in pilot workload Solution 2: Change in crew members
Comm Impact Change Comment Impact Chang Comment
ent (%) e (%)
Global impact on crews
in Norway
Total number of 13 including 1 new
helicopters (only 1 base
with 2 helicopters)
Average crew per 3.5
helicopter
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Items for calculations Current situation Project situation* : Max duty period = 9 to 14h per day EASA draft rules 30.10.2013
Solution 1: Change in pilot workload Solution 2: Change in crew members
Comm Impact Change Comment Impact Chang Comment
ent (%) e (%)
Total number of crews 45.5 There are also Increase of 40 % of work weeks: 64 19.5 additional
additional senior staff there are 2 possibilities: crews
to support the crews: 1) HEMS pilots may go for
instructors, chief offshore operations where they
pilots, … would get a higher salary
relevant for the higher work
weeks in offshore
2) HEMS pilots may request
higher salary to compensate the
increased working weeks
Note: risk of social conflicts with
HEMS crew member which
could request higher salary
Additional impacts: travel time 2 2 additional crews
and living arrangements due to to compensate
day/night shifts: not additional training
monetarised for the moment
Total number of crews 66 21.5 additional
crews
More information is contained in Attachment VI.
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Table 7: Selected policy options air taxi and AEMS
Option No Short title Description
0 No policy change No change in the existing situation; air taxi and AEMS continue to be
regulated under Subpart Q plus national rules
1 Flexible approach Prescriptive EU rules combined with performance-based options, to
allow for flexibility, subsidiarity and proportionality (please refer to
rationale for CS-FTL.2)
2 Fully prescriptive Prescriptive EU rules for air taxi and AEMS operators
approach
4.4. What are the impacts
4.4.1. Safety impact
4.4.1.1 HEMS
Option 0 — No policy change (HEMS)
As specified in the Section 4.1.3, ‘Even with the caveats about under-reporting of fatigue as a causal factor, it
would appear from the occurrence data that the controls that have been in place to manage fatigue in
European EMS have generally been effective.’
Options 1 & 2 (HEMS)
In the absence of evidence of specific safety risks requiring an urgent action or a new approach to manage
potential high risks, it can only be considered that Options 1 or 2 could provide some positive low benefits.
Safety risks could, however, arise if there are changes to the current situation where operations remain
predominantly in the Member State that issues the AOC.
A general positive impact is to be expected from the introduction of scientific principles to managing long
duties and reduced rest, operators’ responsibilities to monitor and manage fatigue and to implement
mandatory fatigue management training for their crew members, rostering staff and managerial staff involved
in the operation.
Summary table for HEMS
HEMS Options Safety impact
Option 0 — No policy change Neutral, if operations remain predominantly in the MS that issues the
AOC
Option 1 — Flexible approach Positive low benefits
Option 2 — Fully prescriptive approach Positive low benefits
4.4.1.1 Air taxi and AEMS
Option 0 — No policy change
The Regulatory Impact Assessment (RIA) of NPA 2014-14 highlighted areas where safety improvements were
recommended for CAT operations with aeroplanes in scheduled and charter operations. Notably, it was
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recommended to remove the possibility to allow extensions of the FDP to 11:45 during the most unfavourable
time of the day. That means, Option 0 has the potential of not addressing known safety concerns. Please refer
to the RIA of NPA 2010-14 for further details on safety improvements for those elements of FTL that were not
harmonised under Subpart Q.
Options 1 & 2
A positive safety impact is to be expected from the reduction of fatigue for operations taking place at the most
unfavourable time of the circadian rhythm. With regard to the proposed harmonisation of the provisions for
standby, split duty and the measures to control the fatigue related risks resulting from time zone crossing, a
positive impact is to be expected in those Member States that currently apply less stringent measures. A
further positive impact is to be expected from the strengthened operator responsibilities and the introduction
of mandatory fatigue management training for crew members, rostering staff and managers, and measures to
compensate the fatigue resulting from disruptive schedules. Please refer to NPA 2010-14 for more detailed
information.
Summary table for air taxi and AEMS
Air taxi & AEMS Options Safety impact
Option 0 — No policy change Minor negative
Option 1 — Flexible approach Positive low benefits
Option 2 — Fully prescriptive approach Positive low benefits
4.4.2. Environmental impact
Not relevant.
4.4.3. Social impact
4.4.3.1 HEMS
Option 0 — No policy change
There is no negative impact in terms of employment or working conditions because Option 0 does not
introduce new rules.
Option 1 — Flexible approach
Overall, a neutral impact in terms of employment or working conditions because Option 1 allows
implementing an individual flight time scheme for each operator that may or may not remain within the
specified limits. The social impact could vary from negative to positive depending on the FTL scheme of the
operator.
It is expected that some HEMS operators will continue with their specific operations, including consecutive,
15-16 hours FDPs, combined with reduced rest periods at HEMS operating base, if proven safe. In those cases
no social impact is expected.
Some operators will have to improve their working conditions, while others will have to recruit new pilots. If
additional pilots are recruited, this is likely to result in fewer flights per pilot. This may in turn lead to a loss of
practical experience. This loss could be compensated by additional training hours in a simulator. However, this
has not the same value as real HEMS flights.
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Option 2 — Fully prescriptive approach
Despite that the rules are developed to provide better working conditions for the pilots by reducing the risk of
fatigue, the impact would be negative:
1) If additional pilots are not recruited this would lead to higher workload. In addition, if this is not
compensated by a corresponding increase in salary, this could lead to social tensions or pilots finding
elsewhere more lucrative jobs (e.g. offshore in Norway).
2) If additional pilots are recruited this would lead to fewer flights per pilot. Consequently this would lead to
a loss of practical experience due to the reduced number of HEMS flights per pilot. This loss could be
compensated by additional training hours in a simulator. However this has not the same value as real
HEMS flights.
3) If no additional pilots are recruited this would lead to less service for the public.
Summary table for HEMS
HEMS Options Social impact
Option 0 — No policy change Neutral
Option 1 — Flexible approach Neutral
Option 2 — Fully prescriptive approach Highly negative
4.4.3.2 Air taxi and AEMS
Option 0 — No policy change
A negative social impact is to be expected. Crew members cannot easily change from air taxi/AEMS operations
to scheduled and charter operations due to the rolling 1 000-flight-hours-per-12-consecutive-calendar-months
limit.
Option 1 — Flexible Approach
A positive social impact is to be expected for crew members due to the harmonisation of standby, rest
requirements to compensate for time zone crossing and disruptive schedules.
Option 2 — Fully prescriptive approach
A positive social impact is to be expected for crew members due to the harmonisation of standby, rest
requirements to compensate for time zone crossing and disruptive schedules.
Summary table for air taxi and AEMS
Air taxi and AEMS Options Social impact
Option 0 — No policy change Negative
Option 1 — Flexible approach Positive
Option 2 — Fully prescriptive approach Positive
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4.4.4. Economic impact
This section is broken down per type of stakeholder: HEMS operators, air taxi and AEMS operators, and EASA.
4.4.4.1 HEMS
Option 0 — No policy change
There is no negative economic impact because Option 0 does not introduce new rules. For operators
performing HEMS outside certifying State there might be a slight negative impact as those operators have to
deal with different FTL regimes which would lead to additional costs and would prevent free movement of
persons and services in EU.
Option 1 — Flexible approach
Option 1 allows for implementing an individual flight time specification scheme. The individual scheme may
deviate from or remain within the certification specifications. It may reasonably be assumed that for HEMS
operators it will also take approximately 2 000 working hours to develop and document an individual scheme
that deviates from the certification specifications as has been reported by CAT aeroplane scheduled and
charter operators. However, these are one-off costs.
The economic impact of Option 1 on HEMS operators is unclear due to the lack of data on the economic
performance of these operators and their diversity in EASA Member States. Under the obligations of their
management system, operators have been collecting data on their economic and safety performance,
including their FTL schemes, since the implementation of Regulation (EU) No 965/2012 in October 2014.
The HEMS operators are invited use the following link to provide feedback on cost estimates for Option 1 and
other general information: https://ec.europa.eu/eusurvey/runner/NPAFTLHEMS.
Option 2 — Fully prescriptive approach
There are 2 main types of negative economic impacts which have been identified and estimated:
1) Impacts only for HEMS operators. They would address the impacts by either:
a) recruiting additional pilots;
b) increasing the working time of pilots;
c) increase of service cost, or
2) in order to continue their current way of operations, the number of derogation would increase which
would require an additional work for operators, competent authorities, DG MOVE and EASA.
No economic benefits have been identified.
A case study for HEMS base with day operations has been performed to quantitatively estimate the impacts.
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Case Study — Base with day operations (e.g. Germany)
Items for Current situation example Bremen Projected situation : Max duty period = 9 to 14h per day
calculations
Change in workload and crew
Pilots in average average Sum Sum per Impact Pilots in average average Sum Change Sum Change Comment
schedule work work per base schedule work work per (%) per (%)
days hours pilot days hours pilot base
per day per
day*
Mandatory
maximum hours 2000 2000
per year
Max target hours 2000 198 2000 290
January 3 10 9 91 274 3 10 9 91 0% 274 0%
February 3 12 11 124 373 3 12 11 124 0% 373 0%
March 3 15 12 180 539 3 15 12 180 0% 539 0%
calculated 2h
April 3 14 14 198 593 4 18 16 145 -27 % 677 14%
overlapping
for handing over,
May 3 12 15 176 527 4 16 17 134 -23 % 597 13%
servicing
and waiting for
June 3 10 16 155 465 4 15 18 131 -15 % 525 13%
helicopter
July 3 13 16 197 591 4 17 18 151 -23 % 667 13 % dto
August 3 10 15 151 452 4 16 17 129 -14 % 516 14 % dto
September 3 12 13 165 496 3 12 13 165 0% 496 0%
October 3 15 11 168 504 3 15 11 168 0% 504 0%
November 3 10 9 95 284 3 10 9 95 0% 284 0%
December 3 10 8 86 258 3 10 8 86 0% 258 0%
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Items for Current situation example Bremen Projected situation : Max duty period = 9 to 14h per day
calculations
Change in workload and crew
Pilots in average average Sum Sum per Impact Pilots in average average Sum Change Sum Change Comment
schedule work work per base schedule work work per (%) per (%)
days hours pilot days hours pilot base
per day per
day*
Number of work
143 13 1785 5355 166 9 1427 -20% 5709 7%
days/Pilot/year
Number of work
1785 1427 -20%
hours/Pilot/year
Total number of
hours per year per 231 173 -25%
pilot
Global impact on
crews in Germany
Total number of
bases with that 32 32
routine
Average pilots per
3 4
base
Total number of
96 128
Pilots
*The average working hours per day in the table include the FDP and post-flight duties, where some overlap between the shifts is calculated.
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Summary table for HEMS
HEMS Options Economic impact
Option 0 — No policy change Neutral
Option 1 — Flexible approach Medium negative
Option 2 — Fully prescriptive approach Highly negative
4.4.4.2 Air taxi and AEMS
Option 0 — No policy change
Option 0 does not introduce changes to the FTL regulatory framework. As a consequence, ATXO and AEMS
operations would continue to be less efficient compared to Option 1, which will allow for more effective
operations at certain times of the day due to the flexible approach in Option 1.
As such there is no economic change if Option 0 remains the baseline, however, there is an economic situation
which is less cost-effective in comparison with Option 1.
Option 1 — Flexible approach
Option 1 allows for implementing an individual flight time specification scheme. The individual scheme may
deviate from or remain within the certification specifications.
A positive impact is to be expected from the additional flexibility in FDP limits for air taxi operations.
Furthermore, proven safe practices may continue under individual flight time specifications schemes.
It may reasonably be assumed that for air taxi and AEMS operators, it will also take approximately 2 000
working hours to develop and document an individual flight time specification scheme that deviates from the
certification specifications as has been reported by CAT aeroplane scheduled and charter operators. However,
these are one-off costs.
The two types of impacts may compensate each other, it is estimated that this would provide a minor positive
impact overall.
Option 2 — Fully prescriptive approach
A negative impact is to be expected for some operators. This option is a ‘one-size-fits-all’ approach. The
additional flexibility in FDP limits is not available. Therefore, operators cannot reap the positive impact from
efficiency gains for certain FDPs.
Summary table for air taxi and AEMS
Air taxi and AEMS Options Economic impact
Option 0 — No policy change Neutral
Option 1 — Flexible approach Minor positive
Option 2 — Fully prescriptive approach Negative
4.4.4.3 Economic impact for EASA with HEMS, Air taxi and AEMS options
Option 0 — No policy change
The economic impact is neutral for EASA.
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Option 1 — Flexible approach
EASA has experience with implementation of the FTL rules for CAT scheduled and charter operations. Since
October 2014 until now 14 individual flight time specification schemes deviating from the certification
specifications or derogating from the implementing rules have been evaluated. The Commission is involved
only when a scheme derogates from the implementing rules. Under the flexible approach, requirements that
could trigger a need for an individual scheme are placed in the certification specifications.
It is expected that several operators will apply for schemes that deviate from the certification specifications, as
was the case for scheduled and charter operations.
In order to assess the future workload for EASA, the experience gained with assessing derogations/deviations
with scheduled and charter operations needs to be considered. Thus, the potential workload with HEMS,
AEMS and air taxi derogations/deviations is estimated for the 3 first years starting from 2019 (the first year of
implementation).
EASA assessment for a derogation/deviation from the current FTL rules:
— Workload between 50 and 800 hours, depending on the complexity of the case
— Number of evaluations: in average 5 per year for the past 3 years
— Average workload per evaluation: 100 hours
— EASA implementation support: 200 hours in 2017
— Ex post evaluation of the current FTL rules: 300 hours for 2017, same for 2018
EASA assessment for a deviation from future HEMS and air taxi FTL rules
— number of evaluations per year:
during the first year: 8 for HEMS, 3 for air taxi
during the second year: 5 for HEMS, 2 for air taxi
during the third year: 3 for HEMS, 1 for air taxi
— EASA implementation support from 2019
during the first year: 800 hours
during the second year: 400 hours
during the third and following years: 100 hours
— Ex post Evaluation of the current HEMS FTL rules: 300 hours in 2021, same in 2022
Note: The impact on the workload of the Commission and the Member States is not estimated here due to
lack of data.
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Table 8: Overall workload impact for EASA
Cost items Unit 2015 2016 2017 2018 2019 2020 2021 2022
CAT FTL
Number of derogations Number 5 5 5 5 5 5 5 5
average workload hours 150 150 150 150 150 150 150 150
Total derogation workload hours 750 750 750 750 750 750 750 750
Implementation support workload hours 800 600 200
Ex post evaluation of the current CAT
hours 300 300 300 300 300 300
FTL rules
Total workload hours 1 550 1 350 1 250 1 050 1 050 1 050 1 050 1 050
Additional workload with HEMS and Air Taxi FTL
HEMS FTL
Number of derogations Number 8 5 3 3
average workload hours 150 150 150 150
Total derogation workload hours 1 200 750 450 450
Air Taxi FTL
Number of derogations Number 3 2 1 1
average workload hours 150 150 150 150
Total derogation workload hours 450 300 150 150
Total derogation workload for HEMS
hours 1 650 1 050 600 600
and Air Taxi
HEMS and Air Taxi FTL support
Rulemaking activity hours 300 200 100 100
Implementation support workload hours 800 400 100 100
Ex post evaluation for HEMS/Air Taxi & hours 300
AEMS FTL rules
Total additional workload HEMS and
hours 300 200 100 100 2 450 1 450 700 1 000
Air Taxi
Equivalent FTEs FTEs 0.2 0.1 0.1 0.1 1.5 0.9 0.4 0.6
All FTL activities
Total workload hours 1 850 1 550 1 350 1 150 3 500 2 500 1 750 2 050
Equivalent FTEs FTEs 1.2 1.0 0.8 0.7 2.2 1.6 1.1 1.3
The implementation of Option 1 would require 1.5 additional FTEs in 201921 and between 0.4 and 0.9
additional FTEs in the following years.
Option 2 — Fully prescriptive approach
Option 2 is considered to have a stronger negative impact for EASA workload than the Option 1 impact.
Experience shows that processing a request for derogation from FTL implementing rules is more time-
consuming than the assessment of a deviation from certification specifications due to additional
administrative work.
21
3.6 FTEs in the last line of the table above minus 1 current FTE in EASA.
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Summary table for EASA
Options Economic impact for EASA
Option 0 — No policy change Neutral
Option 1 — Flexible approach Medium negative
Option 2 — Fully prescriptive approach Highly negative
4.4.4.4 Overall conclusion for the economic impacts per type of options and stakeholders
Options HEMS Air taxi & AEMS EASA
Option 0 — No policy change Neutral Neutral Neutral
Option 1 — Flexible approach Medium negative Minor positive Medium negative
Option 2 — Fully prescriptive Highly negative Negative Highly negative
approach
Question to stakeholders on economic impacts:
Stakeholders are invited to provide quantified justification elements on the possible economic impacts of the
options proposed, or alternatively to propose another justified solution to the issue.
4.4.5. General Aviation and proportionality issues
Not relevant.
4.5. Conclusion
4.5.1. Comparison of options
Summary of impacts for all criteria and options:
Options Safety impact Social impact Economic impact
HEMS
Option 0 — No policy change Neutral Neutral Neutral (minor
negative)
Option 1 — Flexible approach Positive low benefits Neutral Medium negative
Option 2 — Fully prescriptive Positive low benefits Highly negative Highly negative
approach
Air Taxi & AEMS
Option 0 — No policy change Minor negative Negative Neutral
Option 1 — Flexible approach Positive Low benefits Positive Minor positive
Option 2 — Fully prescriptive Positive Low benefits Positive Negative
approach
In addition, the implementation of Option 1 would require for EASA 1.5 additional FTEs in 2019 and between
0.4 and 0.9 additional FTEs in the following years.
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4. Impact assessment (IA)
The impact of Option 1 on the Members States has not been assessed due to lack of data. Any feedback
Member States can provide would improve the quality of this impact assessment and will allow for adequate
conclusions to be drawn regarding future FTL requirements.
Following this assessment, Option 1 would be the preferred option. However, it is expected that the RIA will
be updated if the stakeholders’ comments on this NPA, and especially the survey indicated in Section 0
(economic impacts), require this.
Question to stakeholders
Stakeholders are also invited to provide any other quantitative information they may find necessary to bring
to the attention of EASA.
As a result, the relevant parts of the RIA might be adjusted on a case-by-case basis at the Opinion stage.
4.6. Monitoring and evaluation
EASA, with the support of the competent authorities and industry, shall conduct a continuous monitoring of
the provisions concerning flight and duty time limitations and rest requirements.
The monitoring shall encompass different aspects of the rules implementation, however as minimum criteria:
— Number of fatigue reports;
— Impact of disruptive schedules on fatigue;
— Impact of time zone crossing on fatigue
— Impact of positioning on fatigue;
— Frequency of exceedances of rostered FDPs compared to actual FDPs;
— Use of CD to extend the FDP and to reduce the rest period;
— Adequacy of sleep opportunities prior to safety related duties;
— Adequacy of recovery periods;
— Adequacy of requirements to control sleep disruption due to:
alternating day/night duties
alternating eastward-westward or westward-eastward time zone transitions;
— Adequacy of procedures to control awake time.
The industry is expected to collect data on the above criteria, analyse them and share the results with the
competent authority. The operators are invited to add more criteria, depending on the specificity of their
work.
The data shall be further aggregated by the competent authorities and transmitted, not less than once a year,
to EASA which will use it to assess the level of implementation of the rules.
In particular EASA will assess how well the adopted rules function, taking account of the overall objectives and
earlier predictions made in impact assessment. Based on this assessment EASA will provide an evidence-based
judgement of the extent to which the proposal has been relevant, given the needs and its objectives, effective
and efficient, coherent and has achieved EU added-value.
A first evaluation will be done 5 years after the rules apply. The evaluation report will justify whether the rules
should be modified, simplified or repealed.
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5. Proposed actions to support implementation
5. Proposed actions to support implementation
EASA proposes the following actions as implementation support:
— A dedicated workshop with stakeholders in Cologne after the consultation of the NPA when all
comments have been processed.
— Providing supporting clarifications through electronic communication tools to the competent
authorities.
— Thematic workshops with stakeholders organised during a potential transition period.
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6. References
6. References
6.1. Affected regulations
— COMMISSION REGULATION (EU) No 965/2012 of 5 October 2012 laying down technical
requirements and administrative procedures related to air operations pursuant to Regulation
(EC) No 216/2008 of the European Parliament and of the Council (OJ L 296, 25.10.2012, p. 1)
6.2. Affected decisions
— Executive Director Decision 2014/017/R of 24 April 2014 ‘AMC and GM to Part-ORO’
6.3. Other reference documents
— The Regulatory Impact Assessment (RIA) of NPA 2010-14
— European Commission’s impact assessment to Opinion 04/2012
— ‘Data Collection and Comparative Assessment of Existing National FTL Provisions for EMS’,
commissioned by EASA (Attachment 1)
— ‘Preliminary Analysis of Impacts from Future Potential FTL Regulatory Changes for EMS’
commissioned by EASA (Attachment 2)
— Preliminary Analysis of Impacts from Future Potential FTL Regulatory Changes for Air Taxi and
Single Pilot Operations (Attachment 3)
— Scientific study commissioned by EBAA and ECA (Attachment 4)
— Report on the Assessment of proposed FTL tables for Air Taxi and Emergency Medical Services
Operations (Attachment 5)
— ICAO Annex 6, Part I
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Det Norske Veritas
Data Collection and
Comparative Assessment of
Existing National FTL
Provisions for EMS
Report for EASA
Report D1 No: 3
10 May 2012
10 May 2012
Data Collection of EMS FTL provisions
EASA DNV & Circadian
DET NORSKE VERITAS LTD.
Data Collection and Comparative Assessment of Palace House
Existing National FTL provisions for EMS 3 Cathedral Street
for SE19DE London
Tel: +44 (0)20 7357 6080
EASA
Fax: +44 (0)20 7357 6048
Registered in England
Company No. 1503799
Report No.: D1, version 3
Indexing terms: Flight Time Limitations (FTL), Fatigue Risk, Emergency Medical Services (EMS)
Summary: This report is final Deliverable D1.
Prepared by: Suk Rathore
Senior Consultant, DNV
Steve Goodwin
Director, Circadian
Verified by: Edward Smith
Principal Consultant, DNV
Approved by: Edward Smith
Principal Consultant, DNV
Date of issue: 10th May 2012
DNV Project No: PP027950 EASA Project No: EASA.2010.FC06-SC001
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Contents
1.0 Introduction .................................................................................................... 1
1.1 Background ...................................................................................................... 1
1.2 Objectives of Project......................................................................................... 1
1.3 Scope of Activities ............................................................................................ 1
1.4 Scope and Structure of this Report - Deliverable D1 ........................................ 3
2.0 Overview of States’ Regulations ................................................................... 4
2.1 Approach to Identifying FTL Provisions ............................................................ 4
2.2 Czech Republic ................................................................................................ 6
2.3 France .............................................................................................................. 6
2.4 Germany........................................................................................................... 7
2.5 Norway ............................................................................................................. 7
2.6 Poland .............................................................................................................. 8
2.7 Spain ................................................................................................................ 8
2.8 Switzerland ....................................................................................................... 9
2.9 United Kingdom ................................................................................................ 9
2.10 Summary of EMS FTL Scope for Surveyed States ........................................ 10
3.0 Key EMS Issues ............................................................................................ 11
3.1 Aeroplanes (AEMS) ........................................................................................ 11
3.2 Helicopters (HEMS) ........................................................................................ 25
4.0 Comparison to CRD Sections 1 and 2 ........................................................ 35
5.0 Main Findings ............................................................................................... 40
5.1 Aeroplanes (AEMS) ........................................................................................ 40
5.2 Helicopters (HEMS) ........................................................................................ 41
6.0 References .................................................................................................... 43
7.0 Acronyms/ Abbreviations ............................................................................ 44
Appendix 1 Questionnaire to States
Appendix 2 Collation of States’ FTL Data
Appendix 3 Supporting FDP Tables
Appendix 4 Example HEMS Shift Patterns
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1.0 Introduction
1.1 Background
In December 2010 the European Aviation Safety Agency (EASA) published the Notice of
Proposed Amendment (NPA) No. 2010-14A [1] on ‘Implementing Rules on Flight and Duty
Time Limitations and Rest Requirements for Commercial Air Transport (CAT) with Aeroplanes’.
Following extensive consultation the Comment Response Document (CRD) to NPA 2010-14A
was published in January 2012 [2]. Within the CRD is a Draft Opinion of EASA, Annex III,
PART-ORO (ORGANISATION REQUIREMENTS) covering Subpart — Flight and duty time
limitations and rest requirements. Section 1 of this contains General FTL requirements and
Section 2 is for Commercial Air Transport Operators. Also within the CRD is a Certification
Specification (CS) for Commercial Air Transport by Aeroplane — Scheduled and Charter
Operations, designated FTL 1.
The CRD has placeholders for Certification Specifications FTL 2, 3 and 4 covering Emergency
Medical Services (EMS) by aeroplane and by helicopter, Air Taxi by aeroplane (including
Single Pilot Operations) and other CAT operations by helicopters respectively.
A rulemaking task will start beginning of 2012 for the development of FTL for EMS. The
rulemaking task for Air Taxi will begin third quarter of 2012 and the one for other CAT
operations by Helicopters is to follow in 2013.
To support the development of these rules EASA requires the preparation of Regulatory Impact
Assessments (RIAs) similar to the one which appears in NPA 2010-14A.
Under framework agreement EASA.2010.FC06 EASA has requested that DNV/Circadian
assist in the preparation of the RIAs supported by a data collection exercise as described
below in Section 1.3.
1.2 Objectives of Project
The main objectives of the project are to:
Ensure that the rule development for FTL provisions for EMS, Air Taxi and Helicopters
is based on an objective and impartial assessment of current regulations and informed
by RIAs complying with the established EASA process.
Compare the CRD’s flight and duty time limitations and rest requirements (Sections 1
and 2) to the currently applicable national FTL provisions to identify any significant
difference or conflict.
1.3 Scope of Activities
The scope of the work is to cover different types of operation and aircraft under three separate
tasks as follows:
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Task 1: EMERGENCY MEDICAL SERVICES (EMS) BY AEROPLANES (A) & EMERGENCY
MEDICAL SERVICES (EMS) BY HELICOPTERS (H)1
a. Data collection and comparative assessment of existing national FTL provisions
covering at least 8 EASA Member States including FR, DE,UK,SP,CH, one
Scandinavian country and 2 others as more relevant to the concerned operations.
b. Comparison of the results of a. with the provisions (Implementing rules in Sections
1 and 2 only) of the CRD to NPA 2010-14 which was published in January 2012;
c. Preparation of the elements necessary for the Regulatory Impact Assessment
(RIA).
Task 2: AIR TAXI AND SINGLE PILOT OPERATIONS (AEROPLANES)
a. Data collection and comparative assessment of existing national FTL provisions
covering at least 8 EASA Member States including FR, DE,UK,SP,CH, one
Scandinavian country and 2 others as more relevant to the concerned operations.
b. Preparation of the elements necessary for the Regulatory Impact Assessment
(RIA).
For Air Taxi, EU-OPS Subpart Q applies and it is assumed there are no FTL provisions
different from Subpart Q. Therefore there is no requirement for data collection and comparative
assessment of existing national provisions on FTL. Single Pilot operations have been excluded
from EU-OPS 1.1105. It will therefore be necessary for these operations to include data
collection and comparative assessment of the related existing national FTL provisions.
Task 3: COMMERCIAL AIR TRANSPORT OPERATIONS BY HELICOPTERS
a. Data collection and comparative assessment of existing national FTL provisions
covering at least 8 EASA Member States including FR, DE,UK,SP,CH, one
Scandinavian country and 2 others as more relevant to the concerned operations.
b. Preparation of the elements necessary for the Regulatory Impact Assessment
(RIA).
For each of the three tasks:
The preparation of the related RIA necessitates collection of data as relevant for each
of the elements to be assessed (e.g. FTL provisions and accident/incident data for
safety aspects; number of operators concerned, level of activity and crew numbers for
the economic and/or social aspects); and
The finalisation of the RIA, in particular point 7 ‘Conclusions and preferred options’, and
the related decision to be made, will be the task of the concerned rulemaking group.
1
Hereafter referred to as AEMS when by aeroplane and as HEMS when operated by helicopter
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1.4 Scope and Structure of this Report - Deliverable D1
This report is deliverable D1 under this project and covers Tasks 1a and 1b from the task list
above. Deliverable D2 will be the RIA for EMS operations, Task 1c.
The rest of this report is structured as follows:
Section 2 provides an overview of the EMS FTL data collected from the 8 States. In
addition to the 5 States specified above, we also contacted Poland, Norway and the Czech
Republic. The detailed responses from the 8 States are included in Appendix 2 of this
report.
Section 3 identifies and analyses key EMS issues from the States’ data.
Section 4 compares the FTL requirements from the CRD, Sections 1 and 2, to the States’
data to identify any significant differences or inconsistencies.
Section 5 contains the main findings to be fed forward to the RIA.
The Appendices contain supporting data namely:
o Appendix 1 – questionnaire sent to the States
o Appendix 2 – detailed responses from the States
o Appendix 3 – supporting FDP tables from States where these vary from Subpart
Q values
o Appendix 4 – example HEMS working patterns.
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2.0 Overview of States’ Provisions
This section provides an overview of the applicable provisions governing FTL requirements in
eight European States. Specifically, it outlines which provisions apply to Emergency Medical
Services (EMS) operations by aeroplane and helicopter. The eight European States were
chosen with the following criteria in mind:
To provide a representation across the EU regions;
To cover a mix of geographies and environments, namely mountainous and non-
mountainous and extreme northerly environments;
To collect information on both HEMS and AEMS; and
To ensure that the levels of EMS activities in the chosen States were a significant
proportion of total European EMS operations.
In terms of the overall scale of EMS, there are over 360 HEMS bases in Europe with additional
fixed wing ambulance bases chiefly providing cross-border or inter-continental services such
as medical repatriation. Approximately 200,000 HEMS and fixed wing air ambulance missions
are flown annually in Europe [17]. The chosen States account for well over 50% of European
EMS operations.
The scope of what is covered by EMS varies between countries. There is a general consensus
that EMS provisions apply when rapid and immediate transportation of patients (with or without
family members), medical staff and supplies is required. Six of the eight member States apply
EMS provisions also to transport of stabilised patients between medical facilities and to rescue
missions. Spain and the UK exclude these latter two categories from the scope of EMS.
France Germany, Norway and the UK have definitions of EMS scope within regulations and
these are provided in the State sections below. The other four States do not have formal
definitions but have clarified the scope and this is summarised in a table in section 2.10.
A brief explanation is provided below on how information relating to the national FTL provisions
has been gathered.
2.1 Approach to Identifying FTL Provisions
In order to focus on key fatigue contributory elements and to ensure a consistent level of
responses for identifying what FTL provisions are in place amongst different States, a
structured questionnaire was developed (see Appendix 1). The key areas covered under this
questionnaire are based on the categories listed in the Hazard/Mitigation Table ref. 2.2.2 within
the NPA 2010-14A document [1] and also with reference to the NPA draft implementing rules.
The areas are:
1. Duty hours
2. Cumulative duty
3. Cumulative block times
4. Basic maximum Flight Duty Period (FDP)
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5. Night, early and late duties
6. Duty extensions
7. Positioning
8. Travelling
9. Split duty
10. Pilot discretion
11. Airport standby and standby elsewhere
12. Basic minimum rest
13. Basic reduced rest
14. Extended and recovery rest
15. Time zone crossing
16. Nutrition
17. Records for flight duty and rest periods
18. Other elements including FRMS
States were asked to populate the questionnaire under each of these headings providing
relevant information on applicable FTL provisions for EMS using Aeroplanes and Helicopters.
Some States also provided supporting documents on applicable national legislative
requirements, referenced via the questionnaire. Where further clarifications were required, this
was subsequently requested via separate email and telephone correspondences.
Subpart Q of EU OPS 1 (in Annex III of EC regulation 3922/91) provides Flight and Duty Time
Limitations and Rest Requirements for Commercial Air Transportation by Aeroplane. Subject
to the provisions of Article 8 of EC regulation 3922/91, Authorities may grant variations to the
requirements in Subpart Q in accordance with applicable laws and procedures within the
States concerned and in consultation with interested parties. Each operator has to
demonstrate to the relevant Authority that its request for a variation produces an equivalent
level of safety (with suitable mitigation measures where appropriate).
In the States’ responses extensive reference is made to Subpart Q for AEMS. There is no
equivalent baseline for HEMS operations and hence there is reliance on national provisions.
This is described further below; each sub-section provides an overview of the eight States’ FTL
provisions for EMS.
The details of the States responses are provided in Appendix 2. Key EMS issues are
compared and analysed in Section 3.
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2.2 Czech Republic
2.2.1 Aeroplanes
The FTL provisions for AEMS operators are as specified in EU OPS Subpart Q. The fixed-wing
operators in the Czech Republic conduct only secondary medical services such as transport
and repatriation flights and for this reason these are subject to the requirements for commercial
air operations for aeroplanes.
2.2.2 Helicopters
Specific FTL requirements for HEMS operators are regulated under the national Decree (No.
466/2006 Coll [3]). This Decree sets out the rules for HEMS operators which determine the
following areas:
Maximum duty period and flight duty periods
Flight time
Minimum rest requirements.
2.3 France
2.3.1 Aeroplanes
Subpart Q is applicable for AEMS. In addition, there are specific national provisions in place for
areas including split duty, reduced rest, standby, extension for in-flight rest and time zone
crossing. There are, however, some rules [4] which deviate from the normal CAT operations in
the event of an actual emergency and are applicable if an operator is operating with a minimum
of two flight crew members and under Fatigue Risk Management’ (FRM) provisions. In such
cases, the deviation allows for extended FDP, up to a maximum of 18 hours.
Operator and crew responsibilities as stated within Subpart Q are applicable for French AEMS
operations.
2.3.2 Helicopters
FTL provisions for helicopter EMS operations are specified in a national safety regulation [5] as
part of social requirements regulating duty periods for these activities. The French DGAC has
highlighted within this regulation the most important aspects with relation to EMS operations
with helicopters. These are detailed in Appendix 2.
Within this regulation there is a definition of what is covered by EMS:
“Civil emergency air operation means any operation, regardless of the qualification of flight by
regulations, including a flight or series of flights, including an emergency that makes scheduling
impossible, carried out to:
1. Provide transportation directly related to:
a) seriously ill or injured persons, accompanied or not by relatives or medical staff, to a
place where the means required for urgent treatment can be provided to them;
b) medical personnel required;
c) medical supplies such as equipment, blood, organs and necessary drugs;
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2. Ensure a public safety mission, assist a person in danger, safeguarding persons and
property, including mountain rescue or at sea, firefighting or fire watch;”
2.4 Germany
2.4.1 Aeroplanes
In Germany, AEMS operations are covered by Subpart Q supplemented by the national FTL
provisions as laid out within the internal document ‘DVLuftBO1’ [6] under articles §8-15.
2.4.2 Helicopters
FTL provisions for helicopters are regulated under German Subpart Q (referred to as JAR-OPS
3) and DVLuftBO2 [7] under articles §7-22. In particular, articles §21 and §22 of DVLuftBO2
specifically relate to provisions on limiting flight time and rest periods in helicopter rescue
services.
In terms of definitions, Germany refers to the HEMS definition from Appendix 1 to JAR-OPS
3.005(d), i.e.
“Helicopter Emergency Medical Service (HEMS) flight. A flight by a helicopter operating under
a HEMS approval, the purpose of which is to facilitate emergency medical assistance, where
immediate and rapid transportation is essential, by carrying:
i. Medical personnel; or
ii. Medical supplies (equipment, blood, organs, drugs); or
iii. Ill or injured persons and other persons directly involved. “
2.5 Norway
2.5.1 Aeroplanes
There are very few regulations directly related to EMS operations. However, there is local
legislation covering CAT (aeroplanes) operations which is also relevant to some areas of fixed-
wing EMS activities with specific references made to air ambulance and emergency service at
the airport and elsewhere (standby). These are covered under references [8] and [9].
In cases where there are no national FTL provisions relevant parts of Subpart Q are applicable.
An ambulance flight in the Norwegian regulations means a flight where the purpose is to
perform transportation directly connected with:
a) Seriously ill or injured persons, their families, and medical staff, to a place where
appropriate treatment can take place.
b) Medical staff required to perform necessary tasks.
c) Vital medical supplies, including equipment, blood, organs and medicines.
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d) Necessary transportation of persons or medical supplies in connection with a), b) or c)
above.
2.5.2 Helicopters
For helicopters, the FTL requirements are determined by agreement between the operator and
their air crew. These agreements are required to stipulate provisions regarding duty and rest
requirements and a roster for at least four weeks is produced and released at least two weeks
in advance.
2.6 Poland
2.6.1 Aeroplanes
FTL provisions for AEMS operations are covered by an internal regulation referenced as
‘Regulation of the Minister of Infrastructure’ (dated 13th December 2002) [10] which outlines
national legislation on the working times and rest time of aircraft crew members and air traffic
controllers. Chapter 5 of this regulation specifically covers aviation medical rescue service and
medical transportation. In Poland these activities are considered under the scope of EMS
operations.
In accordance with the Polish Act of Aviation Law (PRAWO LOTNICZE) a new regulation is to
come into force but until this happens Chapter 5 of the existing regulation remains valid for
EMS operations.
In addition to the internal regulation, relevant parts of Subpart Q are applicable for areas such
as block time, standby and basic minimum rest requirements.
2.6.2 Helicopters
Article 103a of the Act of Aviation Law (PRAWO LOTNICZE) [10] has been written for
helicopters. Specific allowances have been made for operations involving emergency medical
services and provisions laid out on the limitations on working times for crew members.
Relevant parts of Chapter 5 of the ‘Regulation of the Minister of Infrastructure’ as used for
AEMS operations are also applicable for HEMS operations.
2.7 Spain
2.7.1 Aeroplanes
FTL provisions related to EMS operations are essentially governed by 3 national regulations.
These are:
1. Circular del Director General de Aviación Civil (dated 17th December 2010) [12]
2. Real Decreto 1952/2009 (dated 18th December 2010) – national law which adopts
requirements related to flight time limits and crew rest as per CAT operations [13]
3. Circular Operativa 16B – sets out limits on flight time, maximum aviation activity and
minimum periods of rest for flight crew [14].
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In some cases, provisions include a combination of national regulations and Subpart Q.
Spanish EMS airborne activities are restricted to transport of those in urgent need of medical
care to appropriate facilities and transport of organs or blood for transplant operations.
Transport of stabilised patients between medical facilities or rescue activities are not
considered under national EMS provisions.
2.7.2 Helicopters
Applicable FTL regulations for helicopters are also covered by relevant articles within the
above mentioned references. See Appendix 2 for more details.
2.8 Switzerland
2.8.1 Aeroplanes
Switzerland has only one AEMS operator and currently there are no special national provisions
in place for EMS aeroplane operations. However in most cases accepted procedures in line
with Subpart Q are applicable. The single operator is in the process of implementing FRMS.
Further details are provided in Appendix 2.
2.8.2 Helicopters
Switzerland’s EMS operators, REGA, Air Zermatt and Air Glacier have, between them, over 40
years of search and rescue experience.
The provisions relating to HEMS operations have been addressed within an internal document
referenced as ‘Duty Time Requirements for HEMS OPS’ [15]. These are not regulations but
are requirements and policies regarding HEMS operations based on historical practices.
2.9 United Kingdom
2.9.1 Aeroplanes
FTL provisions are principally covered under the UK CAA’s Safety Regulation Group (SRG)
CAP 371 document on ‘The Avoidance of Fatigue in Aircrews’ [16]. CAP 371 defines a
framework for the duty hours of flight crew and cabin crew. FTL requirements as well as
guidance data on applicable limitations and restrictions are provided for operators to follow
when developing their flight crew working shift patterns. Although CAP 371 has general
provisions under fixed-wing (aeroplanes) it makes specific allowances for EMS operations
under its ‘Air Ambulance Supplement’ provisions. This Supplement defines the allowable FDP
increases for air ambulance flights and states the conditions that need to be met for required
FDP extensions.
In the UK (as with Spain), the scope for EMS airborne activities only consider those flights for
which the sole reason is to transport an ill or injured person to a recognized medical facility or
the carriage of a human organ/ blood necessary for transplant operation. Transport of
stabilised patients between medical facilities or rescue activities are not considered under
national EMS provisions. Air ambulance flights are defined as “When the sole reason for the
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flight is to carry an ill or injured person to a recognized medical facility, or the carriage of a
human organ necessary for a transplant operation.”
2.9.2 Helicopters
As with fixed-wing above, helicopters are also covered under the detailed FTL provisions within
CAP 371. Within this document, specific provisions and guidance are provided for HEMS for
operators under the Annex D on ‘Air Ambulance Supplement – Helicopter’. CAP 371 provides
explicit guidance for limits on cumulative duty and flying hours, maximum FDP allowances and
other areas where there are clear differences in limitations between helicopter and fixed-wing
operations.
The scope of UK HEMS activities are the same as described above for aeroplanes.
2.10 Summary of EMS FTL Scope for Surveyed States
State Transport of Transport of Transport of Search and Comments
acute cases organs/ stabilised rescue
blood for patients (S&R)
transplant
Czech
Republic
France
Germany
HEMS HEMS AEMS HEMS
Norway
Poland
Spain
Switzerland
UK Has separate
S&R
requirements
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3.0 Key EMS Issues
3.1 Aeroplanes (AEMS)
The key EMS issues identified are:
EMS related extension: Some of the States allow extensions beyond the basic maximum
FDPs to deal with EMS events. France, Norway, Poland and the UK allow extensions beyond
the 1 hour extension referred to in Subpart Q. These are summarised in Table 3.2 below,
together with the additional mitigating measures (e.g. extended rest) adopted to manage the
increased risks associated with these extensions.
Basic maximum daily FDPs: In order to fully understand the total daily FDPs that can be
possible after EMS extension, Table 3.1 below sets out the relevant basic maximum daily
FDPs for each State. Although derived in different ways a daily extended FDP of 18 hours for
a two person EMS crew is possible for France and the UK with various mitigating measures in
place. Commander’s discretion can further extend this value.
Basic Minimum Rest/ Reduced Rest: Basic minimum rest is generally compliant with
Subpart Q (see Table 3.3). In addition to this following an EMS extended FDP, France and UK
have extended rest requirements (see Table 3.2). For reduced rest, the only EMS specific
issue is the way in which an EMS extended FDP can be combined with reduced rest in France
– the mitigating measures on this are set out in Table 3.3.
Cumulative Duty Hours and Block Hours: The States have values complying with Subpart Q
and some have additional annual limits on duty hours (see Table 3.4) at least one dating from
before EU OPS. The UK has an additional provision concerning duty hours within a 14
consecutive day period.
In Flight Rest/ Augmented Crew: Germany, UK and Switzerland make use of augmented
crews to extend EMS FDPs to 18 hours and above (see Table 3.5).
Airport and Other Standby: Given that EMS are on-demand services, the manner in which
standby is treated is important. Section 11 within Appendix 2 presents the data provided by
States on standby provisions. For airport standby there is a wide range of provisions
concerning how the standby time is treated when immediately followed by flight duty. The UK
treats airport standby in full for daily FDP calculations if a callout occurs, France requires a
reduction in the subsequent FDP corresponding to the standby period spent beyond 6 hours
whereas Germany and Spain do not count the standby time if suitable accommodation is
provided. In terms of counting towards cumulative duty hours there is consistency with
Subpart Q. With respect to other forms of standby, there is again a wide range of provisions
concerning how the standby time is treated when immediately followed by flight duty. In some
cases it contributes 100% to FDP (e.g. UK under certain situations), sometimes 0% (e.g. Spain
in hotel standby) plus intermediate provisions (e.g. Norway where standby time outside the
airport contributes 50% to daily FDP as well as cumulative duty hours). These ranges are not
EMS specific but reflect more general national provisions on standby and are consistent with
the ranges of options considered in NPA 2010-14.
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Table 3.1: Basic Maximum Daily FDP – Aeroplane
Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
Basic Refer to Tables As per Subpart Refer to Tables Maximum FDP Maximum As per Subpart As per Subpart As per Subpart
maximum FDP in Circular Q OPS 1.1105, A-C (see is 18 hours for working hours Q OPS 1.1105. Q OPS 1.1105. Q OPS 1.1105.
without Operativa 16B i.e. Appendix 3) EMS with two for aviation Basic maximum
extensions Articles 5.3.1.1 maximum FDP showing pilots and with activities in daily FDP is 13 See below
and 5.3.1.2 (see is 13 hours with two or more FRMS EMS is 12 hours. (Table 3.5) for
Appendix 3) 30 minute- flight crew, implemented. hours within 24 FDP provisions
showing reductions per acclimatised consecutive This can be for augmented
passenger and sector (starting and non- FDP provisions hours. increased by 2 flight crew
cargo from 3rd sector) acclimatised, are modified by hours for air allowing
operations, and reductions and single flight implementing ambulance. extended EMS
single and for WOCL crew. sector reduction operations.
multiple pilots. encroachment. rule as minus Hence up to 15
Maximum FDP 30 minutes per hours is
For 2 or more If EMS involves permitted for sector starting possible.
pilots in single pilot, two or more from the 4th
passenger ops. max. FDP is acclimatised sector with a
the max. FDP is reduced to 10 pilots, is 14 maximum
14 hours. hours and hours. reduction of 2
extension hours. WOCL
Maximum FDP provisions from Maximum FDP encroachment
derived as a OPS 1.1105 are derived as a also factored in.
function of daily not allowed. function of daily
start times & start times & 1 hour
number of number of extension from
sectors flown. sectors flown. OPS 1.1105
allowed
Organs/ blood providing 18
would be hour cap not
considered as exceeded.
‘Cargo’. Medical
patient would be
considered as
‘Passenger’.
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Table 3.2: Extensions in Maximum Allowable FDP due to EMS Scenario – Aeroplane
Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
Limitations on No special No provisions. Air ambulance Maximum FDP Upon approval FDP extension As above: Extensions
FDP extension provisions for FDP can be up to 18 hours of aircraft of 1 hour is 13hours + beyond 13 + 1
due to EMS extending due extended from is allowed (see commander, permitted – as 2hours for EMS. hours (Subpart
scenario to EMS values in Tables Table 3.1 FDP can be in Subpart Q. Q) would
scenario. A-C (Appendix above). extended as involve
3) by up to 4 follows: No special EMS augmented
hours subject to 1 hour ‐ For extension crew as
conditions (see extension on participation in provisions described below
rows below). FDP is allowed rescue action stated. in Table 3.5.
as in Subpart Q - by 2 hours.
Therefore up to 18 hour ‐ Flight with ill
maximum FDP cap. or wounded
permitted is 18 patient to
hours for 2 pilot Although in medical care
crew if daily special cases, or to deliver
start time and under Pilot blood or
number of discretion, a 2- human organs
sectors allow. hour maximum for transplants
(whatever the - by 3 hours.
In exceptional circumstances)
circumstances, extension is Maximum duty
FDP may be allowed taking time shall not
extended total FDP to 20 exceed 15
beyond 4 hour hours. hours 30
extension – minutes in 24
mitigating hours.
measures on
this are also
described
below.
Conditions on N/A N/A FDP extension FDP extension Flying time can N/A This is only See Table 3.5.
EMS related of up to 4 hours (up to 18 hours also be valid for the
FDP extension is subject to : total) permitted extended by 2 ambulance
a) qualified without prior hours up to mission itself.
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Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
medical staff on authorization maximum of 10 As this is not a
flight providing it is an hours. “planned
emergency and extension”,
b) only operates with at there are no
immediate least 2-pilots special rules for
family/next of and FRMS is the rest
kin allowed in implemented. afterwards,
addition to other than
patient & normal subpart
medical staff Q rest
requirements.
c) crew must
have had full
rest entitlement
prior to duty.
Conditions on N/A N/A Single Pilot: In special N/A N/A With Pilot In case of
Exceptional/ FDP cases, under discretion a unforeseen
Discretionary extension>4hrs Pilot discretion, maximum of 17 circumstances,
Extensions permitted a 2-hour hours FDP is the flight may
related to EMS providing maximum permitted. This be continued to
additional relief (whatever the rule is only valid destination or
Pilot carried circumstances) for air alternate. No
until organ/ extension is ambulance other PIC
patient is allowed taking missions and discretion.
disembarked. total FDP up to normal Subpart
20 hours. Q rules apply
Two-Pilot: for all other
Commander operations
may use
discretion to
extend
FDP>4hrs only
to offload/
deliver patient/
organ to
destination.
Rest N/A N/A The crew must If FDP is greater Minimum rest N/A As above - so if N/A
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Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
requirements have had the than 14 hours, requirements in FDP is
preceding & full entitlement subsequent rest Subpart Q OPS extended to 17
post of rest relating must be at least 1.1110. hours upon pilot
extensions due to the preceding 24 hours discretion then
to EMS duty including a local rest will be 17
scenario prior to starting night except if hours minimum.
an air reduced rest
ambulance provisions are
flying duty. applied.
Following an Air
Ambulance FDP
the appropriate
full rest period
must be taken.
At least 48
hours must
elapse between
the end of one
extended Air
Ambulance
FDP and the
start of another
Air Ambulance
FDP (an
exception to this
rule is described
in CAP 371).
Restriction on N/A N/A A pilot can only Two FDP Not stated. N/A Not stated. N/A
number of fly 3 air extensions in 7
consecutive ambulance consecutive
FDP extended FDPs days (from
extensions in any 28 Subpart Q OPS
related to EMS consecutive 1.1105).
days.
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Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
Prohibition on N/A N/A For air Not stated. Not stated. N/A The 2 hour air N/A
Combining ambulance, if ambulance
FDP extension FDP is No specificity extension can
with ‘split duty’ increased by 4 under split duty be combined
hours (as for EMS with split duty
above) then use operations. extensions.
of split duty to
further extend
FDP is not
permitted.
However, if this
extension for
dedicated air
ambulance has
not already
been applied
then FDP
extension using
split duty and
Pilot discretion
is allowed.
Combining Not stated. Not stated. Combined None stated. Regulation Not stated. Not stated. No.
operational public transport separates
regime (e.g. and air ‘aviation Single Swiss
EMS with air ambulance medical rescue’ EMS operator.
taxi) operations are missions from
permitted. ‘medical
transport’ but
In this case, same FTL
FDP extension provisions are
using split duty applied.
and pilot
discretion is FDP extensions
permitted. The differ depending
extension upon whether
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Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
permitted for rescue mission
dedicated air or carrying
ambulance patient/organ.
does not apply
in this case.
Related N/A N/A Commanders’ Not stated. Not stated. N/A Not stated. N/A
Records discretion
reports relating
to extensions
must be
submitted to the
CAA.
Relevant duty
records must
show
adherence to
Air Ambulance
supplement of
CAP 371.
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Table 3.3: Basic Minimum Rest and Reduced Rest – Aeroplane
Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
Minimum Rest At home: max. As per Subpart Minimum rest If FDP is within As in Subpart As in Subpart As in Subpart Q As in Subpart
Limits of 12 hours or Q-OPS 1.1110. period before limits set out in Q. Q. OPS 1.1110 Q.
length of the undertaking an Subpart Q, then paragraph 2.1
preceding duty FDP shall be: rest provisions
period a) at least as in Subpart Q
long as apply.
Away from preceding FDP
home base or If FDP> 14
(flight crew): b) 12hrs hours, then
max. of 10.5 whichever is consecutive rest
hours or length greater. is 24h including
of the preceding a local night
duty period with If away from except in case
8 hour sleep home and of reduced rest.
opportunity. providing there
is suitable
accommodation
then rest period
may be reduced
by 1 hour.
Limit on Minimum Minimum No reduced rest Maximum 2 None stated. None stated. None stated. None stated.
Reduced-Rest duration of duration of provisions but reduced rest
Hours reduced rest = reduced rest = Pilot may periods in a
10 hours away 10 hours reduce rest to week providing
from home base set minimums FRMS
or 12 hours in i.e. 12hrs at implemented.
home base. home & 10hrs
for away from If the FDP
Minimum of 9 home. before or the
hours at the FDP after the
suitable reduced rest
accommodation. lasts more than
14h, then :
a. reduced rest
is 10h or
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Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
more (even
in the case
of use of
captain's
discretion).
b. The reduced
rest shall
normally
include 2
hours at
least of the
WOCL.
Impact on FDP FDP following None stated. Only in If the FDP None stated. None stated. None stated. None stated.
allowance and reduced rest exceptional before or the
subsequent shall be reduced circumstances FDP after the
rests by by the shortfall. and under Pilot reduced rest
Reduced-Rest discretion is lasts more than
Reduced rest FDP extension 14h, then:
not allowed for permitted - The
when pre or following subsequent
post-FDP is reduced rest. FDP shall be
extended by in reduced by the
flight rest and/or time difference
time zone between the
crossing at the basic minimum
previous or next rest and the
FDP. reduced rest
(called shortfall)
and the number
of sectors of
the subsequent
FDP is 4 or less
‐ The
subsequent
rest period
shall be
extended by
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Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
the time
difference
between the
basic minimum
rest and the
reduced rest. It
shall include
one local night
and not be
less than 24h.
‐ An alternative
consists in
extending the
weekly rest
period (OPS
1.1110 §2.1) of
all shortfalls
generated
during the
week
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Table 3.4: Cumulative Duty Hours and Block Hours – Aeroplane
Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
Limits on duty Subpart Q-OPS Subpart Q-OPS Maximum Subpart Q-OPS Subpart Q-OPS Subpart Q-OPS Subpart Q-OPS Subpart Q-OPS
hours over 1.1100: 60 duty 1.1100 cumulative duty 1.1100 1.1100 1.1100 1.1100. 1.1100
consecutive hours in 7 hours shall not although some
periods consecutive + 2000 hours exceed: 55 flights are ad- A general rule
days & annual limit hours in any 7 hoc. of a yearly
190 duty hours spread as consec. days maximum 2000
in 28 evenly as (but can be duty hours,
consecutive possible. increased to 60 including
days spread as hours when a standby hours
evenly as rostered duty converted to
possible. schedule is duty hours
subject to apply (based on
+ unforeseen Council
1800 duty hours delays). Directive
(+200 extra 2000/79/EC for
hours for 95 hours in any mobile
transport other 14 consec. days workers).
than passenger) & 190 hours in
in calendar year any 28 consec.
days.
Limits on Subpart Q-OPS Subpart Q-OPS Subpart Q-OPS Subpart Q OPS Subpart Q OPS Subpart Q OPS Subpart Q OPS Subpart Q-OPS
allowable 1.1100: 900 1.1100 1.1100 1.1100 1.1100 1.1100 1.1100 1.1100
Block Hours block hours in a
calendar year
and 100 block
hours in 28
consecutive
days.
+
945 block hours
in 12
consecutive
months
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Table 3.5: In Flight Rest/ Augmented Crew Requirements – Aeroplane
Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
Limits on FDP Not specific to Extensions up to A further 2 hours may be In practice, the None None stated None Maximum FDP
extension with EMS 18 hours possible added to the 4 hours EMS national stated stated allowed is up to
augmented with augmented extension already allowable provisions for 34 hours with
crew crew. subject to the extension due to four flight crew
additional conditions below in flight rest are and 6 or less
being met. not relevant as 18 landings on
hours FDP max is special
allowed under missions.
EMS provisions
with 2 flight crew With three flight
members as crew maximum
described above. FDP limitations
for augmented
operations are:
for 3 sectors =
20hours, 5
sectors = 16
hours, 8 sectors
= 10 hours.
Conditions N/A Cannot be pilot a) A third Captain qualified N/A N/A N/A N/A Compensation
associated flying if served crew member must be on in days free of
with extension over 12 hours. board. duty will follow
b) A stretcher or these ops.
NAA may grant 2 comfortable reclining seat
FDP extensions must be available for the
to 18hrs max resting crew member.
within 7 c) Maximum duty will be 18
consecutive days hours or as per Table A
providing crew is (Appendix 3) above plus 6
augmented and hours whichever is the
there is suitable lesser.
sleeping d) The air ambulance
arrangement in- operation will terminate
flight. when the patient or organ
has been offloaded
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Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
and full rest entitlement
must be taken at that point.
e) An additional 'day off'
(minimum 34 hours which
includes 2 local nights)
must be taken on
completion of the full rest
entitlement.
f) All 'heavy crew' duty days
carried out must be notified
to the CAA.
Cumulative N/A Not more than a) Only 2 'heavy crew' duty N/A N/A N/A N/A None stated.
limitations on once every 7 days will be permitted in
use of days. any 28 consecutive days.
augmented b) In any 28 day period
crew containing a 'heavy crew'
duty day:
i) A minimum of 10 days off
will be achieved.
ii) Maximum duty hours
must not exceed 160 hours.
iii) Maximum flying hours
shall be limited to 75 hours.
iv) A maximum of 60 hours
flying averaged over 3 such
28 consecutive day
periods.
v) If one or more such
periods contain 'heavy
crew' duty days then the
allowable flying hours for
the 12 month period must
be reduced to 700 hours.
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The other issues surveyed with the States did not show up significant differences in EMS
provisions. They are briefly summarised below, with the details provided in Appendix 2.
Duty Hours: Generally the way in which flight duties are combined with ground duties and
definitions of relevant terms are consistent with Subpart Q (see Section 1 of Appendix 2).
While some States have daily limits on duty hours, fatigue is generally being controlled through
the specification of rest requirements rather than limiting daily duty times in line with Subpart Q.
Night, Early and Late Duties: Only the UK responded with provisions (see Section 5 of
Appendix 2). France clarified that the provisions it applies to scheduled and chartered
operations are not applied to EMS. The importance of this issue in the context of EMS is
currently unclear. It is thus treated as an open issue to be further considered in the RIA.
Positioning and Travelling: Several States indicate that Subpart Q: OPS 1.1105 point 5 on
“Positioning” is followed (see Sections 7 and 8 of Appendix 2).
Extension by On-Ground Break/ Split Duty: Section 9 of Appendix 2 presents the States’
responses on split duty. No specific EMS provisions were provided by States other than the
UK‘s restriction on combining split duty extensions with EMS related extensions (described in
Table 3.2 above). This is an Article 8 issue under Subpart Q.
Pilot in Command Discretion: PIC discretion extensions are included above under Table 3.2
in the context of EMS events. More generally there is consistency with Subpart Q-OPS 1.1120
(see Section 10 of Appendix 2).
Extended and Recovery Rest: Subpart Q OPS 1.1110 paragraph 2 generally applies (see
Section 14 of Appendix 2).
Time Zone Crossing: Section 15 of Appendix 2 presents the States’ responses on time zone
crossing. One State noted that flights across time zones were more likely to be Medevac rather
than emergencies and hence controlled by standard CAT regulations (relates to scope of EMS,
see Section 2 above) . A mixture of FTL regulations were presented by States. This is an
Article 8 issue under Subpart Q OPS 1.1110 paragraph 1.3.
Nutrition: Most States follow Subpart Q: OPS 1.1130 (see Section 16 of Appendix 2).
Record Keeping: Commander discretion reports and duty records relating to EMS extensions
are covered in Table 3.2. Otherwise Subpart Q OPS 1.1135 is used by most States (see
Section 17 of Appendix 2).
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3.2 Helicopters (HEMS)
The key EMS issues identified are:
EMS related extensions: Combining the basic maximum FDPs (see Table 3.6) with the
permitted extensions leads some of the States to daily FDPs after extension of 15-16 hours
maximum. The mitigating measures associated with these extensions are shown in Table 3.6
below.
Basic Minimum Rest/ Reduced Rest/ Extended Recovery Rest: There is some variability in
basic minimum rest times from 8.5 hours to 12 hours. Generally where rest time is less than 10
hours there are conditions associated with this, e.g. limitation on number of days for which this
can happen. Other mitigating measures are listed in Table 3.7 below. There is a mixture of
provisions for reducing rest periods below these basic minimums and for extended/ recovery
rest (see Table 3.7).
Cumulative Duty Hours and Block Hours: Some States have duty hour limits similar to those
for aeroplanes in Subpart Q but there is variability in these and in cumulative block hours.
Some States also have additional limits on daily flying time for helicopters (see Table 3.8).
Airport and Other Standby: Given that HEMS are on-demand services, the manner in which
standby is treated is important. Section 11 within Appendix 2 presents the data provided by
States on standby provisions. With respect to how airport standby time is treated the UK (as
for aeroplane) treats airport standby in full for daily FDP calculations if a callout occurs
whereas in Spain for example the FDP counts from the reporting time. In Germany if a
secluded room is available with sleeping accommodation the standby time would be counted
as a break if it was more than 2 hours uninterrupted. In Switzerland any time between two
assignments exceeding one hour is counted as a break and duty is interrupted. In terms of
counting towards cumulative duty hours the UK counts airport standby in full, whereas in the
Czech Republic it is counted as 50%. With respect to other forms of standby, there is again a
wide range of provisions. In some cases it contributes 100% to daily FDP (e.g. UK under
certain situations) and cumulative duty, whereas in some States 0% (e.g. Switzerland and
Germany at home or suitable accommodation).
In addition to these issues some HEMS operators work with duty hours restricted shifts.
Examples of shift patterns and airport stand-by cycles are provided in Appendix 4 from
Switzerland and France which were the States who provided this information. In the case of
France these cycles are set out in the regulations [5] as prescriptive options; in Switzerland the
operators proposed the different schedules described in Appendix 4 based on numbers and
type of missions and these were approved by the NAA.
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Table 3.6: Basic Maximum FDP / Duty Time and Extensions - Helicopter
Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
Basic Maximum FDP between 2 Maximum FDP is 12 Maximum duty Maximum FDP Max FDP for No Maximum duty
maximum FDP FDP is limited rest periods is hours (with two pilots duration is (carrying out multi-pilot maximum time is
for EMS to 12 hours. 10hours (max). and when FDP starts 12hours. aviation helicopter FDP limit determined by
(without between 08:00-13:59) activities) is 12 crew is: a) defined. number of
extensions) Maximum in a single day. hours within 12hrs for consecutive
2
FDPs are 24 hours). VFR pikett days.
based on See Table ‘D’ operations
Circular (Appendix 3) for FDP b) 10hrs for If pikett period is
Operativa 16B for other start times, IFR. 5 consecutive
as specified in limits on maximum Note: FTL days then duty
Tables 5.3.1.1 flying times and single requirements time = 9.5
A, B & C (see pilot provisions. for EMS hours and if
Appendix 3) helicopters pikett period is 2
values minus are consecutive
1 hour. determined days then duty
by time =
agreement 13hours.
between the
operator and
their aircrew.
Limitations on No EMS Up to 2 hours Air ambulance FDP can No special EMS Upon approval Total duty N/A FDP can be
FDP (max) specific FDP extension be extended from provisions are of aircraft must not extended up to
extension due provisions for allowed. values in Tables D by stated for duty commander, exceed 15hours
to EMS extending. up to 4 hours subject extension on the FDP can be 15hrs during maximum upon
scenario FDP could Therefore a to conditions (below). basic 12 hours. extended as 24hr PIC discretion –
only be maximum FDP of follows: consecutive see below.
extended by 12 hours is Therefore maximum However, there is ‐ For hrs.
split duty and permitted. FDP permitted is 16 a possibility of a participation
PIC hours for 2 pilot crew if 2-hour extension in rescue
discretion. FDP + Standby daily start time allows. through the use of action - by 2
2
Pikett is effectively a period of standby other than at the airport. A pikett day is a period of 24 hours including all pikett time, airport standby time, flight
duty period, post flight duty time and block time.
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Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
time (between captain’s hours.
two rest periods) In exceptional discretion. ‐ Flight with ill
must not be circumstances, FDP or wounded
more than 15 may be extended patient to
hours 30 beyond 4 hour medical care
minutes. extension – mitigating or to deliver
measures on this are blood or
described below. human
organs for
If the 4 hour extension transplants -
is granted under the by 3 hours.
following conditions
then the use of spilt
duty to further extend
the FDP is not
permitted.
Conditions on N/A See Rest FDP extension of up to See above. Flying time can Air N/A Yes under PIC
EMS related condition below. 4 hours is subject to : also be emergency discretion – see
FDP a) qualified extended by 2 services below.
extensions medical staff on flight hours up to flight duty
b) only immediate maximum of can be
family/next of kin 10 hours. extended, if
allowed in addition to during duty a
patient & medical helicopter
staff receives
c) crew must have had request for
full rest entitlement HEMS flight,
prior to duty. by the time
necessary to
Also for two-pilot crew, perform
a pilot can only fly 3 air such flight.
ambulance extended
FDPs in any 28
consecutive days.
Conditions on N/A Decision to Single Pilot: FDP See above. N/A N/A N/A At Pilot's
Exceptional/ extend FDP up extension>4hrs discretion the
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Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
Discretionary to 2 hours shall permitted providing following may
Extensions be made by the additional relief Pilot apply:
(PIC) related to helicopter pilot. carried until organ/ 1) FDP may be
EMS patient is disembarked. extended to
max of 15hrs
Two-Pilot: Commander (excl. 30mins of
may use discretion to post flight duties
extend FDP>4hrs only at end of FDP &
to offload/deliver 2) if on final
patient/organ to sector within
destination. FDP, additional
unforeseen
circumstances
occur after take-
off, resulting in
permitting hours
being exceeded
then flight may
continue to
planned
destination or
alternate.
3) if life is in
danger then
Pilot may
extend Duty
Time after
consultation
with crew
members.
Rest N/A After an The crew must have Not stated. Minimum rest Minimum Not stated. HEMS FDP
requirements extended FDP of had the full entitlement post FDP is 8 rest pre FDP Regulation
preceding & more than 11 of rest relating to the hours 30 must be 11 Addendum ref.
post hours, a rest preceding duty minutes. hours (with extreme
extensions period of at least prior to starting an air at least example:
due to EMS 12 hours must be ambulance flying duty. 8hours in a implies a 6
scenario given. bed). hours rest is
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Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
Following an Air allowed
Ambulance FDP the following a full
appropriate full rest duty/ standby
period must be taken. day plus 3
hours additional
At least 48 hours must flight duty.
elapse between the
end of one extended
Air Ambulance
FDP and the start of
another Air Ambulance
FDP.
Provisions for Not stated. Not stated. Yes - maximum FDP Not stated. Yes - Yes - for Not stated. Not stated.
Single Pilot allowable is 10 hours. Regulation single pilot
Table No.8: helicopter
Maximum FDP crew FDP
= 10hours. maximum is
10hrs.
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Table 3.7: Basic Minimum Rest, Reduced Rest and Extended Recovery Rest - Helicopter
Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
Minimum Rest Basic minimum Minimum daily Minimum rest period Minimum daily Minimum rest Minimum rest Not stated. Nothing beyond
Limits rest is rest period is before undertaking an rest period is is 8hours, of 11 hours. the 6 hours
10.5hours or as 10hours. FDP shall be: 10hours. 30mins. described
long as a) at least as long as Used rarely, below under
preceding FDP preceding FDP or this value may reduced rest.
whichever is b) 12hrs whichever is soon be
greater. greater. reviewed/
discussed with
stakeholders.
Conditions on At least 8 hours Duty period Exceptionally at home If duty period Standby Within the N/A N/A
rest limits must be in which include base, rest can be (including flight) period which 11hour
accommodation. rest time < reduced by up to 1 encroaches by include rest minimum rest
10hours within hour but only to 2hours or more time < there should be
subsequent minimum of the 22.00 – 6.00 10hours within possibility of at
24hours must 12hours. window then subsequent least 8hours in
not exceed 4 crew will have 10 24hours must a bed).
days. consecutive not exceed 4
hours rest. days.
Limit on Rest reduction Minimum rest If away from home Rest period may Not stated. Basic rest of N/A 6hours has
reduced rest limited to may be reduced and providing there is be reduced to 11hours may been set as the
3hours. to 8hours suitable 8hours. be reduced to minimum time
30minutes accommodation then 9hours to get “enough”
The duration of within 24 hours. rest period may be Also if an provided sleep before the
this reduced This is permitted reduced by 1 hour. operation following next flight
rest is limited to up to 3 times encroaches the conditions are during a 48
10hours and an within 4 planned rest met: hour shift. This
FDP following a consecutive period, the rest -HEMS also applies for
reduced rest days. period may be operations are a 5 day pikett
shall be reduced reduced by during daytime period. This
by the shortfall 2hours but not only value is under
(difference less than 8hours. -There is review by the
between Subsequent rest suitable NAA.
planned rest period is accommodation
and actual rest). augmented by for crew during
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Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
the shortfall basic rest
(=difference period at home
between planned base.
and actual rest).
Extended Rest Not stated. A rest period of Additional (recovery) Cycle 1 : two A rest period HEMS operator Not stated. Before and after
between Duty 48hours is rest requirements for consecutive days of 24hours shall extend the each pikett
Periods / allowed after aircrew are: rest after 5 minimum must basic rest period, a
Recovery Rest each period of ‐ Not work more than consecutive days be taken period as minimum of
service. 7 consecutive days of planned on before each follows: 12hours rest
‐ Have 2 consecutive site standbys duty period. ‐ To 36hours , period must be
days off following a including 2 ensured.
period of 7 Cycle 2 : 6 Also, duty local nights
consecutive days consecutive days period which with 7 In addition, rest
duty rest after 12 includes rest consecutive requirements
‐ Have 2 consecutive consecutive days time of less days stated are:
days off in any of onsite standby than 10hours ‐ To 60hours -within 10
consecutive 14 days within including 3 consecutive
and have at least 3 Cycle 3 : 7 subsequent local nights days, pilot shall
days off in any consecutive days 24hours shall with 10 receive at least
consecutive 14 days rest after 7 not exceed consecutive one 48hour rest
and consecutive days 4days. days period.
‐ Have a minimum of of onsite standby In addition, the - within each
7days off in any HEMS operator calendar month,
consecutive 4 weeks shall specify pilot shall
and days off in the receive at least
‐ Have an average of pilot roster as 8 local days
at least 8 days off in follows: free of duty and
each consecutive 4 ‐ 7 days in a pikett.
week period calendar - within each
averaged over 3 month, into calendar year,
such periods. which the pilot shall
basic rest receive at least
period can be 96 local days
included free of duty and
‐ 24 days in a pikett.
calendar
quarter, into Also for rest
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Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
which the period between
basic rest pikett periods
period can be the following
included. limits apply:
‐ for up to 3
pikett days,
minimum of 1
(24hours) rest
day
‐ for up to 5
pikett days,
minimum of 2
(48hours) rest
days.
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Table 3.8: Cumulative Duty Hours and Block Hours - Helicopter
Parameter/ Czech
Spain Germany UK France Poland Norway Switzerland
Issue Republic
Limits on duty 2000 duty 210 hours within Maximum duty hours Cumulative duty 190hrs in any Total duty Annual 2000hours work
hours over hours per 30 consecutive shall not exceed period over a 28 consec hours must not working per year.
consecutive year. days and 60hours in any 7 week is limited to days spread exceed: hours shall
periods 1800hrs within consecutive days & maximum of as evenly as 200hrs in any not exceed
12 consecutive 200 hours in any 28 44hours. possible, 28 consec 2000hours.
months. consecutive days. 60hrs in any days, 60hrs in
2000 duty hours consec 7 any 7 consec
per year. days days &
1800hrs in any
12 consec
months.
Limits on Total duty Block times for In a single day, Maximum duration Flight time for HEMS Maximum of Maximum block
allowable periods shall aircrew for EMS maximum flying of flight duty hours helicopter operator shall 900hours time per day is
Block Hours not exceed (rescue service) hours = 8hrs (2- in single day = EMS shall not limit flight time per calendar 7hours.
900 block shall not exceed pilots) & 7hrs (single 8hours. exceed: as follows: year.
(flying) hours 600hours within pilot). -80hours ‐ 7hours in any Beyond this the
in calendar 365 consecutive 35 hours per week within the next 24 following block
year, 945 days. Also, beyond this, and 75 hours per 28 days consecutive time limitations
block hours in flying hours are month. -800hours hours apply:
12 limited as: within a ‐ 90 hours in -to 60hours per
consecutive -to 18hours in any 3 For single pilot calendar year. any 28 half month
months and consecutive days IFR operations consecutive -to 110hours
100 block -to 30hours in any 7 total block hours calendar per month
hours in 28 consecutive days of each FDP shall days -to 280hours
consecutive - to 240hours in any 3 be less than 6 ‐ 900hours in per 3 months
days. consecutive 28 day hours. any 12 -to 900hours
periods. consecutive per year.
calendar
months.
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The other issues surveyed with the States did not show up significant differences in EMS
provisions. They are briefly summarised below, with the details provided in Appendix 2.
Night, Early and Late Duties: Only the UK responded with provisions (see Section 5 of
Appendix 2). As with AEMS this is an open issue that will be further considered in the RIA.
Duty Extensions due to In-flight Rest/ Augmented Crew: N/A for helicopter operations.
Positioning and Travelling: See Sections 7 and 8 of Appendix 2 for States’ responses. No
specific HEMS provisions were provided by States.
Extension by On-Ground Break/ Split Duty: Section 9 of Appendix 2 presents the States’
responses on split duty. No specific HEMS provisions were provided by States other than
restrictions on combining split duty extensions with EMS related extensions (described in Table
3.6 above).
Pilot in Command Discretion: HEMS specific provisions are covered above under Table 3.6.
Additional general requirements are presented in Section 10 of Appendix 2.
Time Zone Crossing: Generally N/A for helicopter operations.
Nutrition: No provisions for HEMS were provided by States other than a reference to using
Subpart Q OPS 1.1130 by one State.
Record Keeping: Commander discretion reports and duty records relating to HEMS
extensions are the same as in Table 3.2 for aeroplanes. Switzerland noted it operates a flat
rate recording system of duty hours and hence the flight duty time, the numbers of missions,
sectors/legs and flight time per mission are not automatically obvious to the NAA. These
figures are available on request (see Section 17 of Appendix 2).
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4.0 Comparison to CRD 2010-14 for scheduled and charter CAT operations
Sections 1 and 2
Each of the sub-sections of the CRD Sections 1 and 2 of the Subpart on flight and duty time
limitations and rest requirements has been compared to the responses received from the eight
States. Table 4.1 summarises this comparison. The key findings are as follows:
CRD Section 1 presents general requirements covering scope, definitions, operator and crew
member responsibilities and fatigue risk management (FRM). The scope of what constitutes
“EMS” together with extra supporting definitions will be required in future documentation. In
addition, definitions relating to helicopter activities will be required for HEMS and for helicopter
operations more generally.
For AEMS operator and crew responsibilities are well aligned with Subpart Q or equivalent
which match fairly closely to the equivalent CRD sub-sections. For HEMS, some States do not
have equivalent provisions but the CRD text appears generally suitable for HEMS as well. A
couple of specific detailed observations from France about HEMS and operator responsibilities
are made in Table 4.1.
FRM is under development in most States, but the high level CRD text in section 1 is
consistent with what States have developed so far.
There appear to be no significant conflicts in CRD Section 1 with respect to the States’ EMS
provisions. Extra definitions and scope clarifications will be required in future documentation.
CRD Section 2 is more detailed and hence there are more opportunities for potential
inconsistencies with EMS provisions. The main issues are identified in Table 4.1 as:
ORO.FTL.210 Flight duty period (FDP) – there are different basic daily FDP values for
helicopters in general and EMS operations in particular. In addition, EMS related
extensions without crew augmentation (up to 4 hours) for some States (see Tables 3.2
and 3.6) are significantly longer than the 1 hour extension allowed in the CRD.
ORO.FTL.215 Flight times and duty periods – there are significant variations in the
cumulative values for helicopters (HEMS) from the values in the CRD.
ORO.FTL.235 Rest periods – again there are significant variations in basic and
extended recovery rest durations for helicopters (HEMS) from the values in the CRD.
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Table 4.1: Comparison of CRD Sections 1 and 2 to EMS Data supplied by States
CRD Sections States’ Responses
Section 1
ORO.FTL.100 Scope The brief text in the CRD is consistent with the type of information provided by States on their FTL provisions.
The scope of what constitutes EMS (see “Definitions” below) will need to be considered in future updates of the
CRD requirements or a relevant Certification Specification.
ORO.FTL.105 Definitions No obvious contradictions or conflicts based on information provided by States.
Some extra EMS definitions may be required clarifying between different types of EMS flights, i.e. those
involving transporting persons in urgent medical need, those who have already been stabilised at a medical
facility, transport of organs and blood for transplant operations, rescue, etc.
In addition, extra Helicopter related definitions may be required.
ORO.FTL.110 Operator States either have provisions consistent with what is in Subpart Q, OPS 1.1090 paragraphs 1-3 or use Subpart
responsibilities Q for Aeroplanes and hence this is broadly consistent with this CRD sub-section.
Half the States surveyed do not have the equivalent yet for HEMS. For HEMS it was noted that paragraph (h)
in this sub-section of the CRD about ensuring that flights are planned to be completed within the FDP is
potentially difficult as EMS operations can fall outside duty periods and hence some flexibility (e.g.
Commander’s discretion) is required. In addition, it was noted that avoiding alternating day/ night duties as
recommended in paragraph (e) can be difficult to comply with for HEMS.
No obvious conflicts nor gaps in CRD provisions.
ORO.FTL.115 Crew member States either have provisions consistent with what is in Subpart Q, OPS 1.1090 paragraph 4 or use Subpart Q
responsibilities for Aeroplanes and hence this is consistent with this CRD sub-section.
For HEMS reference is made by States to CAT.GEN.MPA.100 (paragraph (a) of this CRD sub-section)
applicable to all crew members, and to EU OPS 3.085 which largely covers the same material. It was noted
that paragraph (b) of the CRD requiring crew members to make optimum use of rest opportunities was not
consistently represented in existing regulations for HEMS and should be in future regulations.
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CRD Sections States’ Responses
No obvious conflicts nor gaps in CRD provisions.
ORO.FTL.120 Fatigue risk States indicated that either their provisions were consistent with CRD (and the ICAO guidance manual) or else
management (FRM) they had a gap with respect to the provisions in this CRD sub-section.
No obvious conflicts nor gaps in CRD provisions.
Section 2
ORO.FTL.200 Flight time specification This sub-section could be applied to EMS operations once the relevant EMS Certification Specification has
schemes been developed. There is nothing in it that is clearly in contradiction or not applicable to the EMS data
provided by the States.
ORO.FTL.205 Home base Some States note the nomination of a home base explicitly (e.g. Poland and Czech Republic), others implicitly
in discussing travel to/ from a home base and in reference to Subpart Q provisions.
No obvious conflicts nor gaps in CRD provisions.
ORO.FTL.210 Flight duty period (FDP) The main inconsistencies between the CRD and the States’ data for EMS with Aeroplanes (fixed wing aircraft)
(a) Operator responsibilities and Helicopters are the following:
(b) Basic maximum daily FDP
(c) Use of extensions without in- Maximum daily FDPs for EMS vary from the tables given in this CRD section (CRD paragraph (b)).
flight rest Helicopter FDPs are generally lower than those for fixed wing.
(d) Use of extensions due to in-
flight rest Some States follow the concept in the CRD (CRD paragraph (b)) of adapting the FDP based on
(e) Commander’s discretion numbers of sectors and WOCL encroachment. Other States just have a single maximum FDP for EMS.
Some States allow extensions without in-flight rest significantly longer than the 1 hour stated in the
CRD (CRD paragraph (c)) in certain EMS situations with the mitigating measures described in Section
3 of this report.
Some States have different formulations under commander’s discretion (CRD paragraph (e)) which
relate to the need to finish the EMS operation (although this is not such a large difference from CRD
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CRD Sections States’ Responses
(e)(1)(ii)).
ORO.FTL.215 Flight times and duty For fixed wing operations, the States are consistent with the cumulative duty hours and total block times from
periods Subpart Q. Thus the additional constraints in the CRD compared to Subpart Q are not reflected in the States’
requirements. In addition some States have annual duty hour limits.
For HEMS there are more variations from the CRD in the cumulative duty hours and total block times (see
Section 3, Table 3.8 of this report for the range on these parameters).
ORO.FTL.220 Positioning For fixed wing operations, most of the States are consistent with Subpart Q provisions and hence consistent
with CRD on positioning.
For helicopters for those States who provided requirements these were consistent with the CRD.
No EMS specific issues. No obvious conflicts nor gaps in CRD provisions.
ORO.FTL.225 Split duty The CRD refers to the relevant Certification Specification for the details of minimum ground break durations,
impact on FDP, facilities to be provided and other factors. Thus this does not contradict the split duty
arrangements set out by the States.
No EMS specific issues raised by States except constraints on combining split duty and EMS related
extensions. No obvious conflicts nor gaps in CRD provisions.
ORO.FTL.230 Standby The CRD refers to the relevant Certification Specification for the details of how Standby should be managed.
The States’ data are not inconsistent with the high level requirements set out in this sub-section of the CRD.
ORO.FTL.235 Rest periods For aeroplanes most States are consistent with Subpart Q and CRD requirements for minimum rest at home
(a) Minimum rest at home base and away from home base (paragraphs (a) and (b)). For reduced rest the CRD (paragraph (c)) refers to
(b) Minimum rest away from the relevant Certification Specification for detailed provisions. States are in line with Subpart Q on extended
home recovery rest (paragraph (d)). Subpart Q does not include the extra provision under the CRD for recurrent
(c) Reduced rest extended recovery rest being increased to 2 days twice within every 28 days. The main EMS specific issue
(d) Recurrent/ recovery rest raised by States on rest for fixed wing operations was the need for extended rest following an FDP extended
(e) Additional rest periods for EMS reasons. This could be considered a gap in this section of the CRD or may be better treated in a
relevant Certification Specification.
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CRD Sections States’ Responses
For helicopters a range of minimum rest periods are provided by the States, 8.5 hours up to 12 hours (see
Table 3.7). For one State reduced rest of 6 hours is possible although for a limited number of days. Some of
the States have explicit requirements on extended recovery rest which vary from the CRD (see Table 3.7). As
with fixed wing, a significant EMS issue is the implication for rest following an extended FDP to handle an
emergency. In addition, there is the limitation on the number of consecutive duty days with reduced rest or
extended FDPs that some States require.
ORO.FTL.240 Nutrition For fixed wing most States are consistent with Subpart Q which covers paragraph (a) of the CRD sub-section.
The CRD sub-section has no obvious inconsistencies or gaps with respect to States’ data.
ORO.FTL.245 Records of flight and For fixed wing most States are consistent with Subpart Q which is broadly in line with this CRD sub-section.
duty times and rest periods However, the CRD requires records to be kept for 24 months whereas Subpart Q requires at least 15 months.
For HEMS there appears to be more variability over records (see Appendix 2 section 17).
ORO.FTL.250 Fatigue management In those States that responded on FRM, FRMS and the required training was in the process of being set up.
training Given the high level nature of the CRD requirements there are unlikely to be inconsistencies between States’
developing requirements and this sub-section.
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5.0 Main Findings
5.1 Aeroplanes (AEMS)
5.1.1 EMS Related FDP Extensions
Some States allow extensions of up to 4 hours to daily FDP to cope with emergency medical
events. PIC discretion can extend this even further. This is judged to have a potentially
significant safety impact. Therefore it is proposed to model different options for extending FDP
in the RIA (Task 1c).
One form of mitigating measure over such extensions is limiting their use to specific EMS
scenarios and having clear criteria for establishing medical need. Some States limit EMS to
just the transport of those in urgent need of medical care to appropriate facilities and transport
of organs or blood for transplant operations. Other States also include transport of stabilised
patients between medical facilities, transport of medical personnel and rescue activities under
national EMS provisions. The UK requires that a medical person is on board to justify the EMS
extension.
Additional measures before and during the FDP used by States to mitigate extension risks
include:
1. Full rest before the extended FDP
2. FRMS
3. Relief pilot for single pilot operations
4. Prohibiting combining EMS operations FDP extension with extension due to split duty
5. Measures covering mixed operations (e.g. air taxi and EMS)
6. Limiting number of persons on aircraft
7. Limiting daily block hours
8. Limiting the frequency of such extended FDPs
After the FDP, mitigating measures include:
9. Extended rest afterwards
10. Records to NAA.
5.1.2 Rest
Beyond the issue of extended rest following extended FDPs from above, there were few EMS
specific issues related to rest. Just France had explicit provision for reduced rest before or
after an extended FDP. Recovery rest is in line with Subpart Q.
5.1.3 Commander’s Discretion
PIC discretion can be used instead of the EMS specific extension provisions in Section 5.1.1 or
can be used to further extend FDPs, e.g. up to 20 hours in the case of France. Existing
mitigating measures include:
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Establishing medical need – e.g. patient or organ must be on board
Restricting the additional time available under PIC discretion to a maximum amount
(see Table 3.2)
Restricting to 2 pilot operations
FRMS
Records to NAA.
5.1.4 Cumulative Duty Hours and Block Hours
As noted in Section 3.1.1 the cumulative duty hours and block hours in Table 3.4 are
consistent with Subpart Q. The significance of the extra annual limits on duty hours that some
States have will be considered in the RIA.
5.1.5 In-flight Rest/ Augmented Crew
Some States have provisions for use of crew augmentation to extend EMS FDPs. Options
within the RIA can consider lengths of time for extensions and different mitigating measures.
Existing measures include:
Provision of stretcher or comfortable reclining seat for resting crew member
Establishing medical need
Extended rest after extended augmented FDP
Limiting the frequency of such extended augmented FDPs.
5.1.6 Standby – Airport and Elsewhere
There are variations in how States treat standby. Within the RIA the range of airport standby
provisions will be converted into options considering:
The contribution of standby to FDP if there is a callout and to cumulative duty hours
The quality and type of airport standby facilities
Standby duration
Minimum rest after standby with no callout.
An equivalent set of measures will also be considered in the context of standby elsewhere.
5.2 Helicopters (HEMS)
5.2.1 EMS Related FDP Extensions
The findings for HEMS are similar to those in Section 5.1.1 for AEMS. Extended FDPs up to
15-16 hours are possible in Poland, Switzerland and the UK. Therefore it is proposed to model
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different options for extending FDP in the RIA (Task 1c) together with various mitigating
measures. No additional measures from those listed in Section 5.1.1 were identified for
HEMS.
5.2.2 Rest
The States’ responses show variability in basic rest, reduced rest and extended recovery rest.
Basic rest varies between 8.5 and 12 hours. Reduced rest varies from 6 to 11 hours. The
extended rest provisions in Table 3.7 are quite varied across the States and take a number of
formats depending on working cycles.
The RIA will look at representative options for these rest parameters.
5.2.3 Commander’s Discretion
The same considerations apply for HEMS as those for aeroplanes in Section 5.1.3.
5.2.4 Cumulative Duty Hours and Block Hours
It is understood that most of the values for cumulative duty hours and block hours in Table 3.8
are general to helicopter operations rather than specific to HEMS. However, they will be
considered in the Task 1 RIA.
5.2.5 Daily Duty Hours and Block Hours
Examples of duty hour limits are provided in Appendix 4 from Switzerland and France. In
addition daily block time limits are set in Czech Republic, Switzerland and the UK. These can
also be used for developing RIA options.
5.2.6 Standby – Airport and Elsewhere
As for AEMS in Section 5.1.6.
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6.0 References
1. EASA (2010): ‘Implementing Rules on flight and Duty Time Limitations and rest
requirements for commercial air transport (CAT) with aeroplanes’, 20th December 2010,
Notice of Proposed Amendment (NPA) No. 2010-14A
2. EASA (2012): ‘Comment Response Document (CRD) to NPA No. 2010-14A’, 18th
January 2012
3. Czech Decree 466/2006 Coll. DECREE of 26 September 2006 on the flight safety
standard - SECTION FOUR FLIGHT SAFETY STANDARD FOR HELICOPTER
EMERGENCY MEDICAL SERVICE OPERATOR, Articles 21 - 27
4. The Minister of State, Minister for Ecology, Development and Sustainable Planning,
‘Arrêté du 25 mars 2008 pris en application du règlement (CEE) n° 3922/91 modifié
relatif à l'harmonisation de règles techniques et de procédures administratives dans le
domaine de l'aviation civile, et relatif aux dispositions à prendre par l'autorité en vue de
la mise en œuvre des dispositions relatives aux limitations de temps de vol et aux
exigences en matière de repos des équipages de la sous-partie Q de son annexe III
(EU-OPS)’
5. The Minister of State, Minister for Ecology, Development and Sustainable Planning,
‘Arrêté du 9 août 2007 relatif au contrôle technique des opérations aériennes civiles
d'urgence par hélicoptère’, Version consolidée au 24 août 2007
6. Erste Durchführungsverordnung zur Betriebsordnung für Luftfahrtgerät
(Anwendungsbestimmungen zu Anhang III – EUOPS - der VO (EWG) Nr. 3922/91 (1.
DV LuftBO), 10. Juni 2008
7. Zweite Durchführungsverordnung zur Betriebsordnung für Luftfahrtgerät (Dienst-,
Flugdienst-, Block- und Ruhezeiten von Besatzungsmitgliedern in Luftfahrtunternehmen
und außerhalb von Luftfahrtunternehmen bei berufsmäßiger Betätigung) (2. DV
LuftBO), 6. April 2009
8. Norwegian Regulation on the implementation and harmonization of technical
requirements and administrative procedures in civil aviation with additional provisions
on working hours for crew members (dated 21st February 2008, reg. no. 189)
9. Norwegian Regulations on working hours and more for crew members in civil aircraft
(dated 30th December 2004, reg. no. 1817).
10. Polish ‘Regulation of the Minister of Infrastructure’ (dated 13th December 2002) on the
working time and rest time of aircraft crew members and air traffic controllers
11. Polish Civil Aviation Act 2002, with amendments to Article 103 for HEMS
12. Spanish Circular del Director General de Aviación Civil (dated 17th December 2010)
13. Spanish Real Decreto 1952/2009 (dated 18th December 2010)
14. Spanish Circular Operativa 16B
15. Swiss Supplement, Duty Time Requirements for HEMS OPS, based on directive SR
748.127.1 “Verordnung des UVEK vom 23. November 1973 über die Betriebsregeln
im gewerbsmässigen Luftverkehr“ (VBR I)
16. UK CAA, The Avoidance of Fatigue in Aircrews CAP 371, Guide to Requirements,
January 2004
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17. European HEMS and Air Ambulance Committee (EHAC) website: http://www.ehac.eu/
7.0 Acronyms/ Abbreviations
Term Description
CAA Civil Aviation Authority
CAP Civil Aviation Publication
CAS Circadian Alertness Simulator
CAT Commercial Air Transport
CM Crew Member
consec. consecutive
CRD Comment Response Document
CS Certification Specification
DNV Det Norske Veritas
EASA European Aviation Safety Agency
EMS Emergency Medical Services
EU OPS European Union (Safety Regulations) Commercial Air Transportation Operations
FDP Flight Duty Period
FRM(S) Fatigue Risk Management System
FTL Flight Time Limitations
HEMS Helicopter Emergency Medical Services
hrs hours
IFR Instrument Flight Rules
IR Implementing Rules
JAR OPS Joint Aviation Requirements on Commercial Air Transportation Operations
mths months
NAA National Aviation Authority
N/A Not Applicable
NM Nautical Miles
NPA Notice of Proposed Amendment
para. paragraph
pg. page
PIC Pilot In Command
RIA Regulatory Impact Assessment
SRG Safety Regulation Group
TBC To Be Checked/ Confirmed
TBD To Be Done
VFR Visual Flight Rules
WOCL Window Of Circadian Low
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EASA DNV & Circadian
Appendix 1 – Questionnaire Template
This was the questionnaire used to gather information on AEMS. An identical format was used
for the HEMS data collection.
Examples of Possible FTL
Emergency Medical
Provisions
Services (EMS) by Potential Fatigue Flight Time Limitations
(Note: these are for
'AEROPLANES' ‐ Flight Contributor (FTL) Provisions on
illustration only & NAA
Time Limitations (FTL) (Description) Emergency Medical
should provide specific
Provisions Data Sheet Services (AEROPLANES)
FTL provisions)
Combination of flight E.g. reduced duty/flight
duties with ground duty periods or limitations
Duty Hours
duties on combining flight and
ground duties
High cumulative E.g. limiting successive long
workload duty periods, rolling limits
on duty and flying hours,
Cumulative Duty
managing fatigue through
days‐off, longer rest
periods.
Excessive block times E.g. limitations on total
block times of flights on
Block Time
which individual crew
member is assigned.
Length of Flight Duty E.g. maximum FDP limits,
Period (FDP) extra rest requirements,
Basic Maximum Flight
break/meal opportunities,
Duty Period
post‐flight duty inclusion in
FDP.
Duties between 02:00‐ E.g. reducing maximum
05:59: sleep allowable FDP, additional
Basic Maximum Flight deprivation/deficit due rest, planning for optimum
Duty Period to waking‐up/staying sleep opportunity etc.
awake/finishing duty
in WOCL
Number of sectors / E.g. allowable FDP
Basic Maximum Flight
workload decreased by the number of
Duty Period
sectors worked.
Consecutive night E.g. reducing allowable FDP,
duties maximum number of such
Night, Early & Late duties allowed, limiting
Duties number of sectors and/or
consecutive nights or
additional rest periods.
Consecutive series of E.g. limit number of
early starts and/or late consecutive 'earlies' and/or
Night, Early & Late
arrivals 'late' finishes and provide
Duties
extended rest period
between such series of
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Examples of Possible FTL
Emergency Medical
Provisions
Services (EMS) by Potential Fatigue Flight Time Limitations
(Note: these are for
'AEROPLANES' ‐ Flight Contributor (FTL) Provisions on
illustration only & NAA
Time Limitations (FTL) (Description) Emergency Medical
should provide specific
Provisions Data Sheet Services (AEROPLANES)
FTL provisions)
duties or limit FDP for
regular early starts/arrivals
etc.
Planned extension of E.g. a maximum limit on
duty/FDP extension, restrictions on
Duty Extensions
number of extensions, extra
rest requirements etc.
Flight sectors beyond E.g. in‐flight relief planning,
maximum FDP augmented flight crew,
Duty Extensions due to requirements for minimum
In‐Flight Rest rest periods on‐board and
taking into consideration
type of on‐board rest.
Positioning duties, E.g. does the position duty
before and time count as FDP and for
Positioning immediately after an post‐FDP positioning are
FDP there provisions to prevent
excessive duty day.
Excessive travelling E.g. maximum travel time
time to home base, provisions
Travelling
for limiting travelling time
out of base
'Split‐duty' beyond E.g. establishing minimum
maximum FDP consecutive number of
hours for the break and for
setting a maximum FDP
Extension by on‐ground
based on length of
break (split duty)
break/time of day, or
provide suitable
accommodation for break,
limit number of sectors etc.
Disruption on the day E.g. adapt schedules or
crewing arrangements,
and/or provide a process
for Pilot to extend an FDP
Pilot‐In‐Command
based on circumstances or
Discretion
to reduce a rest period and
requirement for reporting
to the NAA above a certain
threshold.
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Examples of Possible FTL
Emergency Medical
Provisions
Services (EMS) by Potential Fatigue Flight Time Limitations
(Note: these are for
'AEROPLANES' ‐ Flight Contributor (FTL) Provisions on
illustration only & NAA
Time Limitations (FTL) (Description) Emergency Medical
should provide specific
Provisions Data Sheet Services (AEROPLANES)
FTL provisions)
Airport standby time E.g. taking account of
airport standby time when
calculating duty/FDP and
Airport Standby rest period and provisions
for ensuring quality and
type of airport standby
facilities.
Standby elsewhere E.g. take account of standby
time in duty/FDP and rest
calculation. Also are there
Standby other than
specific call‐out
Airport
requirements and/or
limitation on standby
duration.
Disruption before the E.g. crew rosters to allow
day or a lack of rest recovery from cumulative
Basic (Minimum) Rest opportunity fatigue and are minimum
rest periods/sleep hours
defined.
Lack of rest E.g. minimum duration of
opportunity reduced rest, augmentation
of rest period following
reduced rest, reduced
Basic Rest‐Reduced Rest maximum FDP and for
limiting number of reduced
rest occasions and for
number of sectors flown
under reduced rest.
'Circadian disruption' E.g. restricting number of
during mixing duty early/late/night transitions
Extended & Recovery
transitions between or for reduced FDP or
Rest
early/late night duties extended rest periods for
time‐zone crossings.
Time zone de‐ This is predominantly for
synchronization long‐haul operations and
therefore may not be
Time Zone Crossing applicable for EMS
operations. If applicable,
examples may include
extended recovery rest.
Lack of nutrition E.g. to ensure meal/drink
affecting performance opportunity when FDP
Nutrition
exceeds a certain
timeframe.
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Examples of Possible FTL
Emergency Medical
Provisions
Services (EMS) by Potential Fatigue Flight Time Limitations
(Note: these are for
'AEROPLANES' ‐ Flight Contributor (FTL) Provisions on
illustration only & NAA
Time Limitations (FTL) (Description) Emergency Medical
should provide specific
Provisions Data Sheet Services (AEROPLANES)
FTL provisions)
Inadequate recording E.g. maintenance of records
system for flight duty for flight duty and rest
Records for Flight Duty
and rest periods periods and pilot‐in‐
& Rest Periods
command discretion
reports.
Provide details on
specific FTL provisions
that are in place for
other elements e.g.
awareness of fatigue
Other Elements
risk (training/other),
implementation of
safety management
system (SMS) and/or
FRMS?
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Appendix 2 - Collation of State’s FTL Data
1. Duty Hours:
Duty Hours (Regulations)
CRD ‘Duty’ means any task that a crew member performs for the operator,
including flight duty, administrative work, giving or receiving training,
checking, positioning, and some elements of standby.
‘Duty period’ means a period which starts when a crew member is required
by an operator to report for or to commence a duty and ends when that
person is free from all duties.
Post‐flight duty shall count as duty. The operator shall specify in its
Operations Manual the minimum time period for post‐flight duties.
No limit on maximum allowable daily duty period.
EU OPS Subpart Q Definitions similar to above. No limit on maximum allowable duty period.
However, addressed through rest requirements.
Duty Hours (Aeroplanes)
UK Duty defined as “Any continuous period during which a crew member is
required to carry out any task associated with the business of an aircraft
operator.” Any duty that does not have minimum rest between it and an
FDP is counted as FDP.
No restrictions on duty hours.
Switzerland Duties shall count in total. Generally no difference between ground or
flight duty.
Spain When a FDP is assigned after ground duty, without a minimum rest period
in between, ground duty shall be included as 100% FDP in subsequent FDP.
Germany Ground and flight duties combined as in Subpart Q.
France As in Sub Part Q.
Norway As in Sub Part Q.
Poland Duty time shall not exceed 15 hours 30 minutes in 24 hours.
Czech Republic As in Sub Part Q.
Duty Hours (Helicopters)
UK As for Aeroplanes table above.
Switzerland Duty time is a period which starts on reporting to operator for duty & ends
30mins after block of last flight. If duty was not connected to FDP, then it
ends after finalising work for operator. The FTL System in Switzerland is
based on a flat rate recording regulation. Depending on the time of the
“Airport Standby” period during a 24 hour‐day a flat rate has to be
recorded as “Duty Time”, e.g. 9.5 hours a day.
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Duty Hours (Helicopters)
Spain As for Aeroplanes table above.
Germany As for Aeroplanes table above.
France ‘Duty period’ is defined as a period of time including on site standby, flight
periods, pre and post flight duties, training, recurrent training and medical
examinations.
‘On site standby’ is a defined period of time spent on the work site,
including periods of inactivity, during which a technical crew member
(including flight crew) may receive an assignment for a flight.
Daily limits for onsite standby are set for different cycles ranging from 12‐
14 hours (see Appendix 4 for more details).
Norway All duty (ground duty & flight duty) counts as 100%. This is also valid for
breaks where suitable rest arrangement does not exist.
Poland Duty time shall not exceed 15 hours 30 minutes in 24 hours.
Czech Republic Duty period defined consistent with Subpart Q. Total duty period for HEMS
crew member shall not exceed 15 hours during 24 consecutive hours.
2. Cumulative Duty:
Cumulative Duty (Regulations)
CRD ORO.FTL.215 Flight times and duty periods
(a) The total duty periods to which a crew member may be assigned shall
not exceed:
(1) 60 duty hours in any 7 consecutive days;
(2) 110 duty hours in any 14 consecutive days; and
(3) 190 duty hours in any 28 consecutive days, spread as evenly as
practicable throughout this period.
(c) Post‐flight duty shall count as duty. The operator shall specify in its
Operations Manual the minimum time period for post‐flight duties.
EU OPS Subpart Q Total duty periods must a) not exceed 190 duty hours in any 28 consecutive
days & b) 60 duty hours in any 7 consecutive days
Cumulative Duty (Aeroplanes)
UK Max cumulative duty hours shall not exceed: 55 hrs in any 7 consecutive
days (but can be increased to 60 hrs when a rostered duty schedule is
subject to unforeseen delays), 95 hrs in any 14 consecutive days & 190 hrs
in any 28 consecutive days.
Switzerland If limits are reached according to Subpart Q the flight crew must have a
rest period.
Spain Subpart Q‐OPS 1.1100: 60 duty hours in 7 consecutive days &
190 duty hours in 28 consecutive days spread as evenly as possible. Plus
1800 duty hours (+200 extra hours for transport other than passenger) in
calendar year.
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Cumulative Duty (Aeroplanes)
Germany As per Subpart Q. Also, maximum of 2000 hours per calendar year.
France As in Subpart Q.
Norway As in Subpart Q. Plus annual maximum of 2000 duty hours, including
standby hours converted to duty hours.
Poland As in Subpart Q but some flights are ad‐hoc.
Czech Republic As in Subpart Q.
Cumulative Duty (Helicopters)
UK Maximum duty hours shall not exceed 60hours in any 7 consecutive days &
200 hours in any 28 consecutive days.
Switzerland 2000 hours work per year.
Spain 2000 duty hours per year.
Germany 210 hours within 30 consecutive days and 1800hrs within 12 consecutive
months.
France 2000 duty hours per year. Cumulative duty period over a week is limited to
maximum of 44 hours.
Norway Annual working hours shall not exceed 2000hours (including EMS).
Poland 190 hrs in any 28 consecutive days spread as evenly as possible, 60 hrs in
any consecutive 7 days
Czech Republic Total duty hours must not exceed: 200 hrs in any 28 consecutive days, 60
hrs in any 7 consecutive days & 1800 hrs in any 12 consecutive months.
3. Block Time:
Block Time (Regulations)
CRD ORO.FTL.215 Flight times and duty periods
(b) The total flight time of the flights on which an individual crew member
is assigned as an operating crew member shall not exceed:
(1) 100 hours of flight time in any 28 consecutive days; and
(2) 900 hours of flight time in any calendar year; and
(3) 1 000 hours of flight time in any 12 consecutive calendar months.
EU OPS Subpart Q Total block times must not exceed a) 900 block hours in a calendar year b)
100 block hours in any 28 consecutive days
Block Time (Aeroplanes)
UK Subpart Q‐OPS 1.1100: 900 block hours in a calendar year and 100 block
hours in 28 consecutive days.
Switzerland As in Subpart Q 1.1100
Spain Subpart Q‐OPS 1.1100: 900 block hours in a calendar year and 100 block
hours in 28 consecutive days.
945 block hours in 12 consecutive months
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Block Time (Aeroplanes)
Germany Subpart Q‐OPS 1.1100
France Subpart Q‐OPS 1.1100
Norway Subpart Q‐OPS 1.1100
Poland Sub Part Q OPS 1.1100 ‐ 1.2. a) and b) ‐ 900 block hours in a calendar year;
and 100 block hours in any 28 consecutive days
Czech Republic Subpart Q‐OPS 1.1100
Block Time (Helicopters)
UK CAP371ref.23.4/pg16: Absolute limits on flying hours: Maximum flying hrs
=90 hrs in any 28 consecutive days & 800 hrs in 12month period.
Also, beyond this, flying hours are limited as:
‐to 18 hours in any 3 consecutive days
‐to 30 hours in any 7 consecutive days
‐ to 240 hours in any 3 consecutive 28 day periods.
Switzerland ‐ Per day 7 hours (At one day per month block time can be extended to 8
hours)
‐ Per half month 60 hours
‐ Per Month 110 hours
‐ Per 3 month 280 hours
‐ Per year 900 hours
Spain Total duty periods shall not exceed 900 block (flying) hours in calendar
year, 945 block hours in 12 consecutive months and 100 block hours in 28
consecutive days.
Germany Block time must not exceed 900 hours during calendar year. But for
helicopter rescue service this is limited to 600 hours within 365 consecutive
days.
France Flight duty is defined as total time between rotor engagement and rotor
stopped. Maximum durations of flight duty are 8 hours in 24 hrs, 35 hours
per week and 75 hours per month.
Norway Maximum of 900 hours per calendar year.
Poland Flight time for helicopter EMS shall not exceed:
‐80 hours within the next 28 days
‐800 hours within a calendar year.
Czech Republic Total time of all flights (Decree art.23) must not exceed: a) 7 hrs in any 24
consecutive hours b) 90 hrs in any 28 consecutive days c) 900 hrs in any 12
consecutive months.
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4. Basic Maximum FDP:
Basic Maximum FDP (Regulations)
Length of Duty Period Duties between Number of
02:00 & 05:59 sectors/workload
CRD ORO.FTL.210 Flight duty period (FDP) Max. daily FDP Max. daily FDP
(a) The operator shall: adjusted to take adjusted to take
(1) define reporting times appropriate account of this in account of this in
to the operation; CRD Table for CRD Tables for
acclimitised crew acclimatised and
(b) Basic maximum daily FDP. members. unknown
(1) The maximum daily FDP without the acclimatization
use of extensions for acclimatised crew state.
members shall comply with CRD table
(pg 78)
(2) The maximum FDP when crew
members are in an unknown state of
acclimatisation shall comply with the
next CRD table (page 78)
EU OPS Subpart Subpart Q of EU OPS 1.1105 states ‐ not Subpart Q of EU Subpart Q of EU
Q relevant to EMS operations OPS 1.1105 states ‐ OPS 1.1105 states ‐
not relevant to not relevant to
EMS operations EMS operations
Basic Maximum FDP (Aeroplanes)
Length of Duty Period Duties between 02:00 & Number of
05:59 sectors/workload
UK CAP371/13, pg8‐10: Pre & post flight duties are part of FDP. See Tables A‐C on FDP
allowances with 2 or more crew & with single crew. The FDPs are determined by
local start time of duty, number of sectors & whether crew is acclimatised or not.
Switzerland As in Sub Part Q OPS 1.1105
Spain Circular Operativa 16B
Maximum FDP function of report time and number of sectors worked for flight crew
(single pilot and minimum 2 pilots) and passenger cabin crew in passenger
operations = Tables in Article 5.3.1.1.
For 2 or more pilots in passenger ops. the max. FDP is 14 hours.
Germany DVLuftBO1ref.§10 Maximum FDP is 13 hours with 30 minute‐reductions
For operations with one per sector (starting from 3rd sector) and reductions
pilot and for medical for WOCL encroachment.
emergency operations
maximum FDP is in
accordance with the
provisions of Sub Part Q‐
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Basic Maximum FDP (Aeroplanes)
Length of Duty Period Duties between 02:00 & Number of
05:59 sectors/workload
OPS 1.1105.
If EMS involves single pilot,
max. FDP is reduced to 10
hours and extension
provisions from OPS 1.1105
are not allowed.
France Subpart Q but if special EMS Subpart Q (reduction by If special EMS provisions
provisions are in place (with 100% of the are implemented sector
2 Pilots & FRMS encroachment when the reduction : ‐30
implemented) then: a) FDP FDP starts in the WOCL minutes/sector from the
is 18hrs max b) if and reduction by 50% 4th sector (with a
FDP >14hrs then when it ends in the maximum reduction of 2
consecutive rest is at least WOCL. Reduction is up hours)
24hrs including local night to a max of 2 hours.
except if reduced rest
provisions are applied c)
Post flight duty = duty, not
FDP.
Maximum FDP is 18 hours
for EMS with two pilots and
with FRMS implemented.
1 hour extension from OPS
1.1105 allowed providing
18 hour cap not exceeded.
Norway Covered by SubpartQ‐ Covered by SubpartQ‐ Covered by SubpartQ‐
OPS1.1105. Basic Max FDP OPS1.1105. OPS1.1105. FDP reduced
for ambulance flights is by 30min from &
increased by 2hrs. including 3rd landing.
Hence up to 15 hours is
possible.
Poland Regulation of the Minister No provisions No provisions established
of Infrastructure, 2002 ‐ established for this. for this.
Journal of Laws, § 36
(working time of aircraft
crew member shall not
exceed time standards for
carrying out aviation
activities 12 h within
subsequent 24 hours).
Czech Republic As per Subpart Q OPS 1.1105.
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Basic Maximum FDP (Helicopters)
Length of Duty Period Duties between 02:00 & Number of
05:59 sectors/workload
UK CAP371: See Table ‘D’ (page 15) for FDP for different start times, limits on maximum
flying times and single pilot provisions.
Maximum FDP is 12 hours (with two pilots and when FDP starts between 08:00‐
13:59) in a single day.
Switzerland If duty = 9.5 hours per day No FDP adjustments No FDP adjustments
can work for 5 consecutive specified for duties specified to take into
pikett days. If duty = 13 between 02:00 & 05.59 account sectors or
hours per day can work for but states minimum rest workload.
2 consecutive pikett days. requirements for flights
between 22:00h &
(Pikett is effectively a 06:00.
period of standby other
than at the airport. A pikett
day is a period of 24 hours
including all pikett time,
airport standby time, flight
duty period, post flight duty
time and block time.)
Spain Basic Maximum FDP is limited to 12 hours ‐ see Circular Operativa 16B ref. 5.3.1.1
Tables (minus ‐1 hour) for details on reporting times & number of sectors worked.
Germany Unrestricted flight time No FDP adjustments No FDP adjustments
between 2 rest periods is 10 specified for duties specified to take into
hours (max). between 02:00 & 05.59. account of sectors or
workload.
France Maximum duty duration is ‐ ‐
12 hours.
Norway N/A ‐ no maximum FDP limit defined.
Note: FTL requirements for EMS helicopters are determined by agreement between
the operator and their aircrew.
Poland Article 103a gives a No FDP adjustments No FDP adjustments
maximum working time of specified for duties specified to take into
15 hours 30 minutes over between 02:00 & 05.59 account of sectors or
24 hours. in Article 103a. Other workload in Article 103a.
regulations on general
‘helicopter flying’
include impact of time
of day on duty time.
Czech Republic Decree art 25 ref.4, 6 & 7: Total duty must not exceed 15hrs during 24hr
consecutive hours. Max FDP for multi‐pilot helicopter crew is: a) 12hrs for VFR
operations b) 10hrs for IFR. For single pilot helicopter crew this = 10hrs.
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5. Night, Early & Late Duties:
Night, Early & Late Duties (Regulations)
Consecutive series of early starts &/or
Consecutive night duties
late arrivals
CRD No explicit provisions ORO.FTL.110
An operator shall, where applicable to
the type of operation:
(e) allocate duty patterns which avoid
practices that cause a serious
disruption of established sleep/work
pattern such as alternating day/night
duties
EU OPS Subpart Q No explicit provisions OPS 1.1090 para 3.3. Operators shall
allocate duty patterns which avoid such
undesirable practices as alternating
day/night duties or the positioning of
crew members so that a serious
disruption of established sleep/work
pattern occurs.
Night, Early & Late Duties (Aeroplanes)
Consecutive series of early starts &/or
Consecutive night duties
late arrivals
UK Ref: CAP371‐7.2: Max of 3 consecutive duties that occur between 0100 to
0659hrs local time. No more than 4 such duties in any 7 consecutive days. Any
run of consecutive duties (late finishes, or nights or early starts) can only be
broken by a period of not less than 34 consecutive hours free from such duties.
The 34 consecutive hours may include a duty that is not Early, Late or Night duty.
Switzerland No provisions. No provisions.
Spain N/A (No provisions) N/A (No explicit provisions)
Germany No provisions covering this. No explicit provisions covering this.
France No provisions covering this. No provisions covering this.
Norway N/A ‐ no provisions N/A ‐ no explicit provisions
Poland No provisions established for this. No explicit provisions established for
this.
Czech Republic No special provisions No special provisions
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Night, Early & Late Duties (Helicopters)
Consecutive series of early starts &/or
Consecutive night duties
late arrivals
UK As for Aeroplane table above.
Switzerland For bases which work regularly HEMS Addendum ref. 1.6.6: If during a
between 22.00 and 06.00, pikett duty duty day there is >1 flight starting
periods are usually restricted to 2 days. 22:00‐06:00hrs local time, then
minimum rest period of 6hrs must be
received after flight duty.
Spain N/A (No provisions) N/A (No provisions)
Germany No provisions covering this. No provisions covering this.
France No provisions No provisions
Norway N/A ‐ no provisions N/A ‐ no provisions
Poland No provisions established for this. No provisions established for this.
Czech Republic No special provisions No special provisions
6. Duty Extensions:
Duty Extensions (Regulations)
Duty Extensions Duty Extensions due to In‐Flight Rest
CRD ORO.FTL.210 Flight duty period (FDP) ORO.FTL.210 Flight duty period (FDP)
(c) Maximum daily FDP with the use of (d) Maximum daily FDP with the use of
extensions without in‐flight rest. extensions due to in‐flight rest.
(1) The maximum daily FDP may be (1) Flight time specification schemes
extended by up to 1 hour up to two shall specify the conditions for
times in any 7 consecutive days. In that extensions of the maximum basic daily
case: FDP with in‐flight rest in accordance
(i) the minimum pre‐flight and post‐ with the Certification Specification
flight rest periods shall be increased by applicable to the type of operation,
2 hours; or taking into account:
(ii) the post‐flight rest period shall be (i) the number of sectors flown;
increased by 4 hours. (ii) the minimum in‐flight rest allocated
(2) The use of the extension shall be to each crew member;
planned in advance, and shall be (iii) the type of in‐flight rest facilities;
limited to a maximum of: and
(i) 5 sectors; or (iv) the augmentation of the basic flight
(ii) 4 sectors, when the WOCL is crew.
encroached; or
(iii) 2 sectors, when the FDP encroaches
the WOCL by more than 2 hours.
(3) Extension of the maximum basic
daily FDP without in‐flight rest shall not
be combined with extensions due to in‐
flight rest or split duty in the same duty
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Duty Extensions (Regulations)
Duty Extensions Duty Extensions due to In‐Flight Rest
period.
(4) Where the extensions are used for
consecutive FDPs, the additional pre
and post‐flight rest between the two
extended FDPs shall be provided
consecutively.
(5) Flight time specification schemes
shall specify the limits for extensions of
the maximum basic daily FDP in
accordance with the Certification
Specification applicable to the type of
operation, taking into account:
(i) the number of sectors flown; and
(ii) WOCL encroachment.
EU OPS Subpart Q OPS 1.1105 is N/A to EMS although See OPS 1.1115
some States do make reference to it.
Duty Extensions (Aeroplanes)
Duty Extensions Duty Extensions due to In‐Flight Rest
UK Ref. CAP371 air ambulance A further 2 hours may be added to the
supplement AnnexB,pg16: 4 already allowable subject to the
Air ambulance flight FDP may be following additional conditions being
extended by max of 4hrs subject to met:
conditions: a) A third Captain qualified crew
a) qualified medical staff on flight member must be on board.
b) only immediate family/next of kin b) A stretcher or comfortable reclining
allowed in addition to patient and seat must be available for the resting
medical staff crew member.
c) crew must have had full rest c) Maximum duty will be 18 hours or as
entitlement prior to duty. per Table A plus 6 hours whichever is
Single Pilot: FDP extension>4hrs the lesser.
permitted providing additional relief d) The air ambulance operation will
Pilot used until organ/patient is terminate when the patient or organ
disembarked. has been offloaded and full rest
Two‐Pilot: Pilot may use discretion to entitlement must be taken at that
extend FDP>4hrs to offload/deliver point.
patient/organ to destination. At least e) An additional 'day off' (minimum 34
48hrs must elapse between end of one hours which includes 2 local nights)
extended air ambulance FDP & start of must be taken on completion of the full
another. Pilot can fly 3 air ambulance rest entitlement.
extended FDPs in any 28 consecutive f) All 'heavy crew' duty days carried out
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Duty Extensions (Aeroplanes)
Duty Extensions Duty Extensions due to In‐Flight Rest
days. must be notified to the CAA.
For combined 'public transport/air
ambulance work: FDP extension by a) Only 2 'heavy crew' duty days will be
split duty & Pilot discretion is allowed. permitted in any 28 consecutive days.
The extension permitted for dedicated b) In any 28 day period containing a
air ambulance (above), does not apply 'heavy crew' duty day:
in this case. i) A minimum of 10 days off will be
achieved.
Air ambulance FDP can be extended ii) Maximum duty hours must not
from values in Tables A‐C by up to 4 exceed 160 hours.
hours subject to conditions. Therefore iii) Maximum flying hours shall be
maximum FDP permitted is 18 hours limited to 75 hours.
for 2‐pilot crew if daily start time and iv) A maximum of 60 hours flying
number of sectors allow. In exceptional averaged over 3 such 28 consecutive
circumstances, FDP may be extended day periods.
beyond 4 hour extension. v) If one or more such periods contain
'heavy crew' duty days then the
allowable flying hours for the 12 month
period must be reduced to 700 hours.
Switzerland Not applicable as already at limit. Augmented flight crew have following
limits:
Extensions beyond 13 + 1 hours ‐ 3 Flight Crew Members (FCM) 3
(Subpart Q) would involve augmented sectors max 20 hours, 5 sectors max 16
crew. hours, 8 sectors max 10 hours FDP /
‐ 4 FCM < 6 sectors max 34 hours.
Spain N/A (No provisions) Article 9 and 10, Real Decree to
1952/2009
Flight Crew;
≥ 70º pitch seats, augmented → +5h,
max 16h30min
≥ 70º, double crew→ +7h, max
18h30min
≥ 45º, augmented→ +4h30min, max
16h15min
≥ 45º, double crew→ +6h30min, max
18h
‹ 45º, augmented, additional rest
requirements→ +4h, max 16h
‹ 45º, double crew, additional rest
requirements→ +5h30min, max
17h30min
Germany Subpart Q: OPS 1.1105 is valid NAA may grant FDP extensions up to
18hrs max twice within 7 consecutive
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Duty Extensions (Aeroplanes)
Duty Extensions Duty Extensions due to In‐Flight Rest
days ‐ providing crew is augmented
and there is suitable sleeping
arrangement in‐flight.
Cannot be pilot flying if served over 12
hours.
France The following paragraphs of Subpart Q Same as for commercial air transport
are applicable for flights operated Theoretically :
under special EMS provisions : OPS a. Flight crew :
1.1105 §2.1 (+1h extension), §2.2 (5 _1 additional pilot :
sectors max) and §2.5 (2 extensions in . bunks (90°): FDP up to 18h
7 consecutive days). Maximum . reclinable seat (not precisely
allowable FDP is 18h in all cases defined) : FDP up to 16h
e.g. : _minimum consecutive rest of 90
1. one may plan a service commencing minutes
at 4h30 in the morning (1h30 b. Cabin crew (no additional cabin crew
encroachment) with 4 sectors (0h30 member required):
reduction). In that case, allowable FDP . bunks (90°): FDP up to 18h
would theoretically be: 18h‐1h30‐0h30 . reclinable seat : FDP up to 16h ( near
= 16h. It can be extended up to 17h bunks for the NPA)
thanks to the +1h extension . minimum rest of 90 minutes
2. one may plan a service commencing c. Sectors requirements : 4 max (‐30
at 5h30 in the morning (0h30 minutes/sector from the third) for FDP
encroachment) with 3 sectors (no of 16h or less and 2 sectors max for
reduction). In that case, allowable FDP FDP of more than 16h (which need
would theoretically be: 18h‐0h30 = bunks)
17h30. It can be extended up to 18h d. Minimum rest at home base
with the 1h extension (18h30 capped following extended FDP is 48h with 2
to 18h) local nights
Maximum FDP up to 18 hours is In practice, the extension for in flight
allowed. rest is "pointless" considering the
possibility to operate 18h FDP under
1 hour extension on FDP is allowed as EMS provisions with 2 flight crew
in Subpart Q up to 18 hour cap. members
Norway Subpart Q: OPS 1.1105 is valid. N/A (No provisions)
2 hours extension allowed for
ambulance mission.
Poland Regulation of the Minister of No provisions established for this.
Infrastructure, 2002 ‐ Journal of Laws,
§ 37 ‐ can extend by 2 hours if
participating in rescue action or 3 hours
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Duty Extensions (Aeroplanes)
Duty Extensions Duty Extensions due to In‐Flight Rest
if flying ill or wounded patient to
medical care or to deliver blood or
human organs for transplant.
Maximum duty time shall not exceed
15 hours 30 minutes in 24 hours.
Czech Republic As in Sub Part Q. No national provisions.
FDP extension of 1 hour is permitted –
as in Subpart Q. No special EMS
extension provisions stated.
Duty Extensions (Helicopters)
Duty Extensions Duty Extensions due to In‐Flight Rest
UK Same as Aeroplane table. The Helicopter scheme in Annex D of
CAP 371 is based on no use of in‐flight
Air ambulance FDP can be extended relief.
from values in Tables D by up to 4
hours subject to conditions .
Therefore maximum FDP permitted is
16 hours for 2 pilot crew if daily start
time allows.
In exceptional circumstances, FDP may
be extended beyond 4 hour extension –
controls on this are described in CAP
371.
If the 4 hour extension is granted under
the following conditions then the use
of spilt duty to further extend the FDP
is not permitted.
Switzerland HEMS Addendum ref. 1.7 Exceedances No provisions (Flight sectors N/A).
of Flight & Duty Time Limitations: At
Pilot's discretion the following may
apply:
1) FDP may be extended to max of
15hrs (excl. 30mins of post flight duties
at end of FDP &
2) if on final sector within FDP,
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Duty Extensions (Helicopters)
Duty Extensions Duty Extensions due to In‐Flight Rest
additional unforeseen circumstances
occur after take‐off, resulting in
permitting hours being exceeded then
flight may continue to planned
destination or alternate
3) if life is in danger then Pilot may
extend Duty Time as appropriate after
consultation with crew members.
Also, if exceedance > 1hour then copy
of discretion report must be sent to
CAA.
Spain Stated as N/A Stated as N/A
Germany Up to 2 hours FDP extension allowed. No national provisions stated.
Therefore a maximum FDP of 12 hours
is permitted.
FDP + Standby time (between two rest
periods) must not be more than 15
hours 30 minutes.
France No special EMS provisions are stated No provisions.
for FDP extension (as provided for
fixed‐wing) on the basic 12 hours.
However, there is a possibility of a 2‐
hour extension through the use of
captain’s discretion.
Norway N/A ‐ no provisions N/A ‐ no provisions
Poland Regulation of the Minister of No provisions stated.
Infrastructure, 2002 ‐ Journal of Laws,
§ 37 ‐ (in case of participation in rescue
action ‐ by 2 h, and flight with an ill or
wounded patient to the medical care
point or deliver blood or human organs
for transplants ‐ by 3 h).
§ 38 Flight time 8 h within subsequent
24 hours may be exceeded upon of the
approval of the aircraft commander
when carrying out tasks by 2 hours.
§ 39 time of carrying out aviation
activities, referred to in § 37 or 38 may
be exceeded only on two subsequent
days, observing a weekly working time
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Duty Extensions (Helicopters)
Duty Extensions Duty Extensions due to In‐Flight Rest
standard in the assumed settlement
period not exceeding 3 months.
Maximum working time limit of 15
hours 30 minutes over 24 hours.
Czech Republic (Decree art25/5): Air emergency
services flight duty can be extended, if
during duty a helicopter receives
request for HEMS flight, by the time
necessary to perform such flight.
Total duty must not exceed 15hrs
during 24hr consecutive hours. N/A
7. Positioning:
Positioning (Regulations)
CRD ORO.FTL.220 Positioning
If operators assign crew members to positioning, the following shall apply:
(a) Positioning after reporting but prior to operating shall be counted as
FDP but shall not count as a sector.
(b) All time spent on positioning shall count as duty time.
EU OPS Subpart Q N/A to EMS (ref. OPS 1.1105 ‐ 5)
Positioning (Aeroplanes)
UK Positioning duties count as FDP prior to a flight but only as duty 'post
flight'. Total length of duty day is used for calculating subsequent rest
period. CAP371,pg7‐ref11: Positioning does not count as a
sector when calculating FDP. However, if after positioning journey, CM
spends less than minimum rest period at suitable accommodation provided
by operator and then carries out an FDP, positioning must be counted as a
sector if split duty is claimed when calculating allowable FDP. If it is not,
then split duty FDP can't be used.
Switzerland Before flight it counts as flight duty, after flight as duty only.
Spain Article 3, Circular Operativa 16B;
Position duties shall be counted as FDP when immediately prior to an FDP
Article 5 Circular del Director General de Aviación Civil, 17/12/2010;
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Positioning (Aeroplanes)
After 18 hours of duty (FDP+Post‐FDP positioning) crew members will be
able to choose if they want to proceed to positioning or take minimum rest
Germany Subpart Q: OPS 1.1105 point 5 is valid
France Applicable to Subpart Q ref. OPS1.1105‐5 Positioning
Norway OPS 1.1105 is valid.
Poland Subpart Q: OPS 1.1105 point 5 is valid
Czech Republic Subpart Q‐OPS 1.1105 ‐ 5
Positioning (Helicopters)
UK Same as Aeroplane table above.
Switzerland No provisions stated.
Spain Circular Operativa 16B ref. article 3: Position duties shall be counted as
FDP when immediately prior to an FDP.
Germany Time spent on positioning is counted as duty. Positioning at the end of the
rest period, but prior to the service shall be included as part of the flight
duty time but will not count as a sector.
France No provisions stated.
Norway N/A ‐ no provisions
Poland No provisions stated.
Czech Republic Decree art.22(1)(b): positioning is part of duty period.
8. Travelling:
Travelling (Regulations)
CRD ORO.FTL.205 Home base
An operator shall assign a home base for each crew member.
EU OPS Subpart Q No provisions stated about times, but does have following:
OPS 1.1090 3.1. An operator shall nominate a home base for each crew
member.
Travelling (Aeroplanes)
UK Travelling limit is 90mins to home base as a maximum standard & where
travelling is required to another base then all the time >90mins is classed
as positioning.
Switzerland Counts as duty period.
Spain Article 7 Circular del Director General de Aviación Civil, 17/12/2010;
When travelling time out of base goes over one hour, the time exceeding
this hour shall be taking into account for the subsequent rest period
Germany No provisions stated.
France No provisions stated.
Norway N/A
Poland No provisions established for this.
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Travelling (Aeroplanes)
Czech Republic No provisions stated.
Travelling (Helicopters)
UK Same as Aeroplane table above.
Switzerland If travel time exceeds 3hrs from home to mission then the time is counted
as flight duty time.
Spain Circular Operativa 16B ref. art 6.1: when travelling time out of base
is >1hour, the time exceeding this 1hour is taken into account for
subsequent rest period.
Germany No provisions stated.
France No provisions stated.
Norway N/A
Poland No provisions established for this.
Czech Republic N/A
9. Split Duty:
Split Duty (Regulations)
CRD ORO.FTL.225 Split duty
(a) Flight time specification schemes shall specify the following elements
for split duty in accordance with the Certification Specification applicable
to the type of operation:
(1) the minimum duration of a break on the ground;
(2) by derogation from ORO.FTL.210 (b), the possibility to increase the FDP
taking into account the duration of the break on the ground, and facilities
provided to the crew member to rest and other relevant factors.
(b) The break on the ground shall count in full as FDP.
(c) Split duty shall not follow a reduced rest.
EU OPS Subpart Q N/A to EMS (ref. OPS 1.1105 ‐ 6)
Split Duty (Aeroplanes)
UK Air ambulance supplement see note Annex B, pg16‐1j: use of split duty to
extend the FDP is not permitted as EMS extension capability already
covered.
Switzerland In accordance with Swiss national provision for split duty. This states the
following:
A split duty must be defined and announced to the crew before the
beginning of the FDP.
Consecutive hours break Increase in FDP
0‐3 hours NIL
3‐7 hours ½ length of break
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Split Duty (Aeroplanes)
7‐10 hours 2/3 length of break or full length if 7 hours
of the break fall between 2000‐0800 local time
Parts of the FDP before and after the break may not be longer than 10
hours.
The total length of the increased FDP must not be more than 20 hours
including the break.
Only one break may be used for applying split duty rules.
Split duty rules may not be combined with augmented flight crew rules.
Suitable accommodation must be provided if planned break is 6 hours or
more or when the break is covering 3 hours or more of the period 2200‐
0600. Otherwise adequate facilities must be provided.
In addition there are time difference constraints and split duty shall not be
before or after a reduced rest period.
Spain Article 5, Circular Operativa 16B;
Max FDP increase of 4 hours or 50% of the time in the rest facility,
whichever is most restricted, is allowed.
Germany §11 Intermittent flight duty time
If the flight time in OPS 1.1105 or § 10 schedule is interrupted by a pause of
at least three hours and a secluded room with sleeping accommodation is
available for the member of the crew during a break in the immediate
vicinity of the airfield the related service period could be extended up to 18
hours.
France Same as for CAT operations (no specificity for EMS operations). The French
national rule is similar to the rule soon to be implemented in the
framework of EASA rulemaking :
a. Minimum consecutive number of hours for the break : 3h ≤ break ≤ 10h
b. Maximum Flight Duty Period (FDP) based on the length of the break :
FDP< FDPmax +0.5 (break‐30min)
c. Suitable accommodation for the break:
‐ Break <6h : comfortable and quiet place with no public access
+…(minimum conditions to be included OPS manual)
‐ Break ≥6h : room
d. Take account of non acclimitisation: crew must have spent at least 48h in
the time zone where the split duty begins, if a preceding duty was more
than 3 time zones away from home base
Norway The following is valid for all operators that are using Subpart Q. Provisions
for split duty are 1) break on ground counts 50%towards max FDP provided
a rest facility with bed is available 2) if break is planned to be >4hrs then
time is = 0 towards max FDP.
Poland No provisions established.
Czech Republic No provisions stated.
Split Duty (Helicopters)
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Split Duty (Helicopters)
UK Air ambulance supplement see note Annex D, pg17‐1j: use of split duty to
extend the FDP is not permitted as extension capability already covered.
Switzerland No provisions stated.
Spain Circular Operativa 16B ref. art 5: Maximum increase in FDP of 4hours or
50% of the time in the rest facility, whichever is most restricted, is allowed.
Germany FDP may be extended up to 18 hours providing consecutive rest period
(break) is at least 3 hours.
France No provisions stated.
Norway No provisions stated.
Poland No provisions stated.
Czech Republic No provisions stated.
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10. Pilot Discretion:
Pilot Discretion (Regulations)
CRD ORO.FTL.210 Flight duty period (FDP)
(a) The operator shall:
(2) establish procedures specifying how the commander shall — in case of
special circumstances which could lead to severe fatigue, and after
consultation with the crew members affected — reduce the actual FDP
and/or increase the rest period in order to eliminate any detrimental effect
on flight safety; and
(3) require the commander to submit a report whenever an FDP is
increased beyond the maximum at his/her discretion, or when a rest period
is reduced below the minimum, in actual operation. Where the increase of
an FDP or the reduction of a rest period exceeds 1 hour, the operator shall
send a copy of the report, together with its comments, to the competent
authority, no later than 28 days after the event.
(e) Unforeseen circumstances in flight operations — commander’s
discretion
(1) The conditions to modify the limits on flight duty, duty and rest periods
by the commander in the case of unforeseen circumstances in flight
operations which start at the reporting time shall comply with the
following:
(i) the maximum basic daily FDP which results after applying (b) and (c) and
ORO.FTL.225 may not be increased by more than 2 hours unless the flight
crew has been augmented, in which case the maximum flight duty period
may be increased by not more than 3 hours;
(ii) if on the final sector within an FDP unforeseen circumstances occur
after takeoff and result in the permitted increase being exceeded, the flight
may
continue to the planned destination or alternate;
(iii) the rest period following an FDP may be reduced but never below 10
hours.
(2) The commander shall, in case of unforeseen circumstances which could
lead to severe fatigue, reduce the actual flight duty period and/or increase
the rest period in order to eliminate any detrimental effect on flight safety.
(3) The commander shall consult all crew members on their alertness levels
before deciding these modifications.
(4) The operator shall require the commander to submit a report to the
operator when an FDP is increased or a rest period is reduced by his/her
discretion.
(5) Where the increase of an FDP or reduction of a rest period exceeds 1
hour, a copy of the report, to which the operator shall add its comments,
shall be sent to the competent authority not later than 28 days after the
event.
(6) The operator shall implement a non‐punitive process for the use of the
discretion described under this provision and shall describe it in the
Operations Manual.
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Pilot Discretion (Regulations)
EU OPS Subpart Q See OPS 1.1120
Pilot Discretion (Aeroplanes)
UK Single Pilot: FDP extension>4hrs permitted providing additional relief Pilot
used until organ/patient is disembarked.
Two‐Pilot: Pilot may use discretion to extend FDP>4hrs to offload/deliver
patient/organ to destination.
Switzerland In case of unforeseen circumstances, the flight may be continued to
destination or alternate. No other PIC discretion.
Spain Subpart Q‐OPS 1,1120 + Article 11, Circular del Director General de
aviación Civil, 17/12/2010;
Pilot‐in‐Command Discretion and FDP extensions by split duty and in flight
rest cannot be combined.
Germany As per Subpart Q‐OPS 1.1120.
France The maximum extension under Captain's discretion is 2 hours, whatever
the circumstances.
Norway N/A ‐ no provisions
Poland As in Subpart Q‐OPS 1.1120
Czech Republic As in Subpart Q‐OPS 1.1120
Pilot Discretion (Helicopters)
UK Same as Aeroplane table.
Switzerland HEMS Addendum ref. 1.7 Exceedances of Flight & Duty Time Limitations:
At Pilot's discretion the following may apply:
1) FDP may be extended to max of 15hrs (excl. 30mins of post flight duties
at end of FDP) &
2) if on final sector within FDP, additional unforeseen circumstances occur
after take‐off, resulting in permitting hours being exceeded then flight may
continue to planned destination or alternate.
3) if life is in danger then Pilot may extend Duty Time as appropriate after
consultation with crew members. Also, if exceedance > 1hour then copy of
discretion report must be sent to NAA.
Spain Circular Operativa 16B ref art. 7.1: FDP increase >2hours at Pilot discretion
will only allowed under very special circumstances. When FDP is increased
at Pilot discretion, due to special circumstances, a report must be sent to
CAA no later than 5days after return to home base.
Circular Operativa 16B ref art.8.1: Pilot‐in Command Discretion & split
duty cannot be combined.
Germany If during the last flight sector within the flight duty time unforeseen
circumstances occur, which lead to a violation of the permitted extension,
the flight may continue to the destination aerodrome or to an alternate
aerodrome. The commander must record the reasons for the decision in
writing. If there is an FDP extension or a shortening of the rest period by
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Pilot Discretion (Helicopters)
more than an hour, this must be reported to the regulatory authority
within 30 days, stating the reasons in writing. Important reasons for
extending the flight duty period or for shortening the rest period can be in
particular:
1. Impracticability of a flight due to the required flight duty and rest
periods and the lack of suitable airfields for stopovers
2. adverse impact on the overall burden of crew members for compliance
with the required flight duty and rest periods,
3. disproportionately high overhead of some flights at Flight Service, and
compliance with prescribed rest periods.
Extensions of the flight duty time or shortening the rest periods referred to
shall only be permitted if overall safety is balanced.
France No provisions stated.
Norway N/A ‐ No Provisions
Poland Regulation of the Minister of Infrastructure, 2002 ‐ Journal of Laws,
§ 38 Flight time 8 h within subsequent 24 hours may be exceeded upon of
the approval of the aircraft commander when carrying out tasks by 2 hours.
§20 1. Time of carrying out aviation activities, including flight time, may be
exceeded over subsequent 24 hours upon approval of the aircraft
commander, in the event that:
1) It is necessary to carry out the flight for search or rescue purposes;
2) The flight is delayed for justified reasons, in particular due to:
a) Unfavourable weather conditions,
b) Waiting for passengers,
c) Removing defects,
d) Extended taxing
‐ However no more than by 2 hours, notwithstanding §2.
2. Time of carrying out aviation activities in the subsequent 24 hours may
be exceeded by the 3 hours, if the flight is carried out by a bigger crew.
3. The commander shall submit a written report to the employer about
each exceeded time to carrying out aviation activities or reduced rest time.
4. If the time of carrying out aviation activities is exceeded or rest time is
reduced by 1 hour or longer, the employer shall submit a copy of the report
referred to in §3, together with an explanation of the circumstances in
which the time of carrying out aviation was exceeded or rest time reduced,
to the President of the Civil Aviation Office, within 14 days from the date of
receiving the report
Czech Republic N/A.
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11. Airport Standby & Standby Elsewhere:
Airport Standby & Standby Elsewhere (Regulations)
Airport Standby Time Standby Elsewhere
CRD ORO.FTL.230 Standby
If operators assign crew members to standby, the following shall apply in
accordance with the Certification Specification applicable to the type of
operation:
(a) Standby shall be rostered and the start and end time of standby shall be
defined and notified in advance to the affected crew members to provide them
with the opportunity to plan adequate rest.
(b) Flight time specification schemes shall specify the following elements:
(1) the maximum duration of any standby;
(2) the impact of standby on the maximum FDP that may be assigned resulting
from standby, taking into account facilities provided to the crew member to rest,
and other relevant factors such as the need for immediate readiness of the crew
member, the interference of standby with sleep and/or sufficient notification to
protect a sleep opportunity between the call for duty and the assigned FDP;
(3) the basic minimum rest period following standby which does not lead to
assignment on an FDP;
(4) how time spent on standby shall be counted for the purpose of cumulative
duty hours.
EU OPS Subpart Q See OPS 1.1125 ref. 1 (Airport Standby) See OPS 1.1125 ref. 2 (Other forms of
standby)
Airport Standby & Standby Elsewhere (Aeroplanes)
Airport Standby Time Standby Elsewhere
UK Airport standby counts in full as FDP CAP371 ref:12.1: As for 'airport
from the start of the standby. standby' except ‐ when standby is
Ref.CAP371, pg8,12.4: Standby undertaken at home or suitable
duty=12hrs max. For Standby followed accommodation provided by operator,
by an FDP i.e. CM is called out from during 2200 & 0800hrs local time & CM
standby to conduct an FDP ‐ see 'Cases is given 2hrs or less notice of report
A & B' for calculating total FDP. time, then allowable FDP starts at the
Rest requirements (CAP371‐12.5): report time for the designated
When standby period finishes but call‐ reporting place.
out did not happen then at least 12hrs
rest must follow prior to next duty
period. Also, following end of
contactable period(s) minimum 10hrs
must elapse prior to next duty period.
Switzerland N/A for the single EMS service in Standby at Hotel or home does not
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Airport Standby & Standby Elsewhere (Aeroplanes)
Airport Standby Time Standby Elsewhere
Switzerland. count as duty.
Spain SubpartQ‐OPS 1.1125 + Artículo 9, Hotel Standby;
Circular del Director General de Subpart Q‐OPS 1.1125+Article 1a),
aviación Civil, 17/12/2010; Real Decreto 1952/2009;
When a FDP is immediately followed Hotel standby; is defined as the
by a standby and during this standby a standby performed in the hotel
new flight duty begins, the previous designated by the operator, providing a
FDP as well as the standby will be part suitable accommodation to the crew
of the last FDP for adequate resting
However, when a rest period is Article 9, Circular del Director General
followed by standby and during this de aviación Civil, 17/12/2010;
standby a new FDP begins, the FDP When a FDP is immediately followed
counts from the reporting time. by a standby and during this standby a
new flight duty begins, the previous
Article 2, Real Decreto 1952/2009; FDP as well as the standby will be part
Standby shall be provided in a suitable of the last FDP
accommodation ("suitable
accommodation" is defined in the Article 11.3, Real Decreto 1952/2009;
article 3 Real Decreto 1952/2009) Hotel standby period is limited to 12
hours
Article 11.3 Real Decreto 1952/2009;
Airport standby period is limited to 12 Article 11.4, Real Decreto 1952/2009;
hours % of Hotel standby vs FDP (and DP);
0% < 6 hrs, 0% FDP > 6 h, 100% DP > 6 h
Article 11.8 Real Decreto 1952/2009;
When standby period goes over 8 Article 11.5, Real Decreto 1952/2009;
hours and is not followed of flight duty The rest period following a hotel
a minimum rest period shall be standby with FDP shall be increased by
provided according to OPS 1.1110 the time elapsed between the sixth
standby hour and the beginning of the
FDP
Article 11.8 Real Decreto 1952/2009;
When standby period goes over 8
hours and is not followed by flight duty
a minimum rest period shall be
provided according to OPS 1.1110
Home Standby;
OPS 1.1125+ Article 1b), Real Decreto
1952/2009;
Home standby; standby other than
airport and hotel standby
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Airport Standby & Standby Elsewhere (Aeroplanes)
Airport Standby Time Standby Elsewhere
Article 9, Circular del Director General
de aviación Civil, 17/12/2010;
When a FDP is immediately followed
by a standby and during this standby a
new flight duty begins, the previous
FDP as well as the standby will be part
of the last FDP
Article 11.3, Real Decreto 1952/2009;
Home standby period is limited to 24
hours
Article 11.6, Real Decreto 1952/2009;
% of Home standby vs FDP (and DP);
0% < 12 hours, 0% FDP > 12 h, 50%
DP > 12 h
Article 11.7, Real Decreto 1952/2009;
When standby begins at home and
then changes to hotel or airport, or
vice‐versa, 50% of the home standby
time will contribute as hotel or airport
standby, depending on the place where
the previous or subsequent standby
takes place.
Article 11.8 Real Decreto 1952/2009;
When standby period goes over 8
hours and is not followed by flight duty
a minimum rest period shall be
provided according to OPS 1.1110
Germany As per Subpart Q‐OPS 1.1125. (3) Standby time following a rest period
§15 Standby (OPS 1.1125) in which the crew member is in their
1) Standby time shall be counted as own home or an appropriate
flight duty time if flight duty time not accommodation at a particular place
separated by a rest period in where he may have the opportunity to
accordance with OPS 1.1110 sleep shall be counted as rest time. The
and either same applies to a corresponding
1. the crew member during the standby standby time before a rest period.
time has no secluded space with
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Airport Standby & Standby Elsewhere (Aeroplanes)
Airport Standby Time Standby Elsewhere
sleeping accommodation available,
2. or the crew member during the
standby time has a secluded room with
sleeping accommodation available, but
the standby time is less than two hours,
unless the standby time is spent
following a rest period.
(2) If a secluded room with sleeping
accommodation is available to the crew
member, the Standby time will be
counted as a break.
France Same as for CAT operations (no Same as for CAT operations (no
specificity for EMS operations) : specificity for EMS operations) :
At airport (or at a place required by the ‐ No impact on Duty and FDP
operator): ‐ Limit on standby duration : 24h
‐ Standby is considered as duty renewable
‐ Reduction of the subsequent FDP
corresponding to the standby period
spent beyond 6 hours
‐ Limit on Standby duration : 12h
‐ Minimum rest after standby with no
FDP : 11h
Norway Subpart Q ‐ OPS 1.1125 applies. In Subpart Q applies & shall not >14hrs.
addition: 1) if standby is immediately (Valid for all operators that are using
followed by a FDP then 100% of subpart Q) FOR 2008‐ 02‐21 § 11.
previous standby time counts towards Norway.
max daily FDP & 2) if standby period is 1) All activities shall be planned ahead
not followed by duty period then and/or the crew shall be informed
minimum rest in accordance with OPS beforehand.
1.110 applies. 2) The time of start and end of the
standby period shall be defined and the
crew informed beforehand.
3) The standby time must not exceed
14 hours.
4) The flight crew shall have access to
rest in a bed during the standby period.
5) Not counting the exceptions below,
the standby time outside the airport
shall count as 50% towards cumulative
duty hours (OPS 1.1100 1.1) and daily
FDP.
6) If the standby period is preceded by
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Airport Standby & Standby Elsewhere (Aeroplanes)
Airport Standby Time Standby Elsewhere
a rest period, the first 4 hours of the
standby period shall not count towards
cumulative duty hours (OPS 1.1100 1.1)
and daily FDP. If called for flight duty,
item 8) below is still valid.
7) If there is no call for flight duty
between 22.00 and 06.00, the time in
this period shall not count towards
cumulative duty hours (OPS 1.1100 1.1)
and daily FDP.
8) By the time being called for flight
duty, 50% of the time from the call
until start of the flight duty will count
towards cumulative duty hours (OPS
1.1100 1.1) and daily FDP.
9) If being called in the time period
06.00‐22.00 with early enough warning
that the time between the call and
reporting time for flight duty is at least
5 hours, the time between the call and
reporting shall not count towards
cumulative duty hours (OPS 1.1100 1.1)
and daily FDP.
10) Standby duty elsewhere for
Emergency Medical Services by
aeroplane shall count at least 20%
towards cumulative duty hours (OPS
1.1100 1.1)
Poland Subpart Q‐OPS 1.1125 ‐ 1.2. Airport Regulation of the Minister of
standby will count in full for the Infrastructure, 2002 ‐ Journal of Laws,
purposes of cumulative duty hours. § 22 ‐ 1. If duty is carried out outside
1.4. Where the airport standby does the mother port, when it exceeds 6
not lead to assignment on a flight duty, hours or when more than 4 hours fall
it shall be followed at least by a rest between 22:00 – 06:00 local time, the
period as regulated by the Authority. employer shall provide respective
1.5. While on airport standby the accommodation conditions.
operator will provide to the crew 2. If duty is carried out at the airport,
member a quiet and comfortable place the employer shall provide respective
not open to the public. conditions for carrying out duty.
3. Time of telephone duty shall be
included in working time as 50 % of the
duty time, excluding the first 4 hours.
4. If the flight is delayed, the time
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Airport Standby & Standby Elsewhere (Aeroplanes)
Airport Standby Time Standby Elsewhere
between the planned take‐off hour and
the new take‐off hour shall be included
in the time of carrying out duty.
Czech Republic As in Sub Part Q. No extra provisions.
Airport Standby & Standby Elsewhere (Helicopters)
Airport Standby Time Standby Elsewhere
UK Same as Aeroplane table
Switzerland HEMS Addendum ref. 1.3.4 & 1.1.13: HEMS Addendum ref.1.3.3: For
Max standby at airport=12hrs. A standby at accommodation or at home:
20mins notification time is given by a) does not count as duty
operator during which CM is required b) no rest time is required after
to be at airport for assignment. standby at home or accommodation
Any time between two assignments c) notification time in this case is
exceeding 1 hour is counted as a break 60mins
and not counted as duty. d) may not be planned into a minimum
rest time following a flight duty period
or following airport standby.
Spain Circular Operativa 16B ref. art. 5 & 3: Circular Operativa 16B ref. art. 5 & 3:
Standby period is limited to 24 hours. Standby 'other than at airport' shall be
When FDP is immediately followed by provided in a suitable accommodation.
standby & during this standby a new Standby period is limited to 24 hours.
flight begins, then the previous FDP When FDP is immediately followed by
+Standby will be counted part of the standby & during this standby a new
last FDP. flight begins, then the previous FDP
However, when a rest period is +Standby will be counted part of the
followed by standby and during this last FDP.
standby a new FDP begins, the FDP
counts from the reporting time.
Germany §14 Standby Time (3) Standby time following a rest period
(1) Standby time shall be counted as in which the crew member is in their
flight duty time if not separated from own home or an appropriate
flight duty time by a rest period and accommodation at a particular place
either where he may have the opportunity to
1. the crew member during the standby sleep shall be counted as rest time. The
time has no secluded space with same applies to a corresponding
sleeping accommodation available, or standby time before a rest period.
2. the crew member during the standby
time has a secluded room with sleeping
accommodation available, but the
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Airport Standby & Standby Elsewhere (Helicopters)
Airport Standby Time Standby Elsewhere
standby time is less than two hours,
unless the standby time is spent
following a rest period.
(2) If a secluded room with sleeping
accommodation is available to the crew
member, the Standby time will be
counted as a break.
France On site standby is a defined period of No provisions stated.
time spent on the work site, including
periods of inactivity, during which a
technical crew member (including flight
crew) may receive an assignment for a
flight.
The daily limit for onsite standby is 12
hours and the 3 cycles have additional
limits per 24 hours.
Duty periods include on site standby (in
full), flight periods, pre and post flight
duties, training, recurrent training and
medical examinations.
Norway Shall count as at least 50% per duty Shall count as at least 50% per duty
hour. hour.
Poland No provisions stated. No provisions stated.
Czech Republic Decree ref. art25 1b: standby counts as N/A
50% of duty period.
12. Basic Minimum Rest:
Basic Minimum Rest (Regulations)
CRD ORO.FTL.235 Rest periods
(a) Minimum rest period at home base.
The minimum rest period provided before undertaking an FDP starting at
home base shall:
(1) be at least as long as the preceding duty period, or 12 hours, whichever
is greater; or
(2) comply with (b), if the operator provides a suitable accommodation to
the crew member.
(b) Minimum rest period away from home base.
The minimum rest period provided before undertaking an FDP starting
away from home base shall be at least as long as the preceding duty
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Basic Minimum Rest (Regulations)
period, or 10 hours, whichever is greater. This period shall include an 8‐
hour sleep opportunity in addition to the time for travelling and
physiological needs.
(e) Flight time specification schemes shall specify additional rest periods to
compensate for:
(2) additional cumulative fatigue due to disruptive schedules; and
(3) a change of home base.
EU OPS Subpart Q See OPS 1.1110
Basic Minimum Rest (Aeroplanes)
UK CAP371, pg11‐ref.17: Minimum rest period before undertaking a FDP shall
be: a) at least as long as preceding FDP or b) 12 hours, whichever is greater.
Other rest period requirements apply for when away from base and when
at home base (CAP371 ref.17.2.1‐2). If preceding duty period (including
positioning time) is >18hrs then rest period must include a local night. After
being called out from standby duty, minimum rest period is determined by
length of standby duty + time spent on positioning & any FDP completed.
Switzerland As in Sub Part Q: Basic rest 12 hours at home base. 10 hours away from
home base.
Spain OPS 1.1110 and article 7, Circular del Director General de aviación Civil,
17/12/2010;
— At home: max (12 hours, length of the preceding duty period)
— Away from home base (flight crew): max ( 10.5 hours, length of the
preceding duty period) with 8 hour sleep opportunity
— Away from home base (passenger cabin crew): max ( 10 hours, length of
the preceding duty period) with 8 hour sleep opportunity
—Operator must take due account of travelling and other physiological
needs.
Germany As per Sub Part Q‐OPS 1.1110: basic minimum rest period of 10 hours
must not be reduced.
France If FDP is within limits set out in Subpart Q, then rest provisions in Subpart Q
apply.
If FDP> 14 hours, then consecutive rest is 24h including a local night except
in case of reduced rest.
Norway N/A ‐ no provisions
Poland As per Sub Part Q‐OPS 1.1110 paras 1.1 and 1.2.
Czech Republic As Sub Part Q.
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Basic Minimum Rest (Helicopters)
UK Same as Aeroplane table.
Switzerland 12 hours is the minimum before any Pikett Period regardless of its length (2
days to 5 days).
Minimum rest requirements in between duties not explicitly stated –
determined by duty hours.
Spain Circular Operativa 16B ref. art.6.1: Basic (minimum) rest for flight crew is
maximum of (10.5 hours or length of the preceding duty period whichever
is greater) with at least 8 hours in accommodation.
Germany Minimum daily rest period is 10 hours.
France Minimum daily rest period is 10 hours.
If duty period (including flight) encroaches by 2hours or more the 22.00 –
6.00 window then crew will have 10 consecutive hours rest.
Norway N/A
Poland Regulation of the Minister of Infrastructure, 2002 ‐ Journal of Laws, § 40 ‐
Minimum rest time is 8 hours and 30 minutes
Duty period which include rest time < 10 hours within subsequent 24 hours
must not exceed 4 days.
Czech Republic (Decree art26): basic rest (minimum) 11hours (rest in bed >8hrs).
Within the 11 hour minimum rest there should be possibility of at least 8
hours in a bed).
13. Basic (Reduced) Rest:
Basic (Reduced) Rest (Regulations)
CRD ORO.FTL.235 Rest periods
(c) Reduced rest
By derogation from (a) and (b), flight time specification schemes may
reduce the minimum rest periods taking into account the following
elements in accordance with the Certification Specification applicable to
the type of operation:
(1) the minimum reduced rest period;
(2) the increase of the subsequent rest period; and
(3) the reduction of the FDP following the reduced rest.
EU OPS Subpart Q See OPS 1.1110‐1.4.1‐2: Reduced rest provisions subject to Article 8,
operational experience, scientific knowledge etc.
Basic (Reduced) Rest (Aeroplanes)
UK CAP371 ref.17.21‐2: No reduced rest provisions but Pilot may reduce rest
to set minimums i.e. 12hrs at home & 10hrs for away from home.
Switzerland Rest may not be reduced below basic rest of 10 hours or as long as
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Basic (Reduced) Rest (Aeroplanes)
previous duty whichever longer.
Spain OPS 1.1110 and Article 7, Real Decreto 1952/2009;
Rest reduction limited to 3 hours
Minimum duration of reduced rest = 10 hours out of home base or 12
hours in base
Minimum of 9 hours at the suitable accommodation
Subsequent rest shall be augmented by the shortfall
FDP following reduced rest shall be reduced by the shortfall
Number of reduced rest occasions is limited to 3 times scheduled in 90
days
Reduction not allowed when: pre or post‐FDP is extended by in flight rest
and/or time zone crossing at the previous or next FDP
Germany §13 Shortened rest periods in special cases (OPS 1.1110 Nr.1.4.1 and 2.1)
The supervisory authority may, upon written request grant deviations from
the requirements of § 12 and in accordance with OPS 1.1110 permit No.
1.4.1, if there are important reasons for shortening the rest period. The
minimum rest periods may be shortened by no more than two hours. A
minimum rest period of ten hours must not be reduced.
France There are French national provisions for CAT operations.
All these provisions can also be used under EMS provisions. Yet, there are
some differences:
‐ no limitation in sector duration on the one hand (sector duration may be
greater than 3h contrary to CAT operations)
‐ no possibility to conduct back to back operations on the other hand: if the
reduced rest was taken more than two time zones away from home base,
the consecutive FDP shall end at home base. In such case, home base shall
never be considered as a destination for the purpose of rest calculation.
Besides, if the FDP before or the FDP after the reduced rest lasts more than
14h, then :
a. reduced rest is 10h or more (even in the case of use of captain's
discretion)
b. The subsequent FDP shall be reduced by the time difference between
the basic minimum rest and the reduced rest (called shortfall) number of
sectors of the subsequent FDP is 4 or less (instead of 3 or less)
c. The subsequent rest period shall be extended by the time difference
between the basic minimum rest and the reduced rest. It shall include one
local night and not be less than 24h.
An alternative consists in extending the weekly rest period (OPS 1.1110
§2.1) of all shortfalls generated during the week.
d. The reduced rest shall normally include 2h at least of the WOCL. Yet, if
needed by circumstances, this rule may not apply, in which case every
"non‐compliance" shall be reported to the Authority.
Norway N/A
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Basic (Reduced) Rest (Aeroplanes)
Poland No provisions stated.
Czech Republic No provisions stated.
Basic (Reduced) Rest (Helicopters)
UK CAP371 ref.17.21‐2: No reduced rest provisions but Pilot may reduce rest
to set minimums i.e. 12hrs at home & 10hrs for away from home.
Switzerland HEMS Addendum ref.1.6.6 ‐ minimum of at least 6 hours if flight between
22.00 and 06.00
No provisions for reduced rest stated.
Spain Circular Operativa 16B ref. art.6.3: Provisions are a) rest reduction limited
to 3hours b) minimum duration of reduced rest =10hours c) FDP following
reduced rest shall be reduced by the shortfall.
Germany Duty period which include rest time < 10 hours within subsequent 24 hours
must not exceed 4 days.
Minimum rest may be reduced to 8 hours 30 minutes within 24 hours. This
is permitted up to 3 times within 4 consecutive days.
France Rest period may be reduced to 8 hours.
Also if an operation encroaches the planned rest period, the rest period
may be reduced by 2hours but not less than 8hours. Subsequent rest
period is augmented by the shortfall (=difference between planned and
actual rest).
Norway N/A
Poland No provisions stated.
Czech Republic Basic rest of 11 hours may be reduced to 9 hours provided following
conditions are met:
‐HEMS operations are during daytime only
‐There is suitable accommodation for crew during basic rest period at
home base.
14. Extended & Recovery Rest:
Extended & Recovery Rest (Regulations)
CRD ORO.FTL.235 Rest periods.
(d) Recurrent extended recovery rest periods
Flight time specification schemes shall specify recurrent extended recovery
rest periods to compensate for cumulative fatigue. The minimum recurrent
extended recovery rest period shall be 36 hours, including 2 local nights,
such that there shall never be more than 168 hours between the end of
one recurrent extended recovery rest period and the start of the next. The
recurrent extended recovery rest period shall be increased to 2 days twice
every 28 days.
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Extended & Recovery Rest (Regulations)
EU OPS Subpart Q See OPS 1.1110‐2: Periodic extension of weekly rest periods (36hrs period
including 2 local nights so <= than 168hrs between end of one weekly rest
period & start of next.
Extended & Recovery Rest (Aeroplanes)
UK Crew members shall:
a) not be on duty more than 7 consecutive days between days off, but may
be positioned to the usual operating base on the eighth day, provided they
are then allocated at least 2 consecutive days off, and
b) have 2 consecutive days off in any consecutive 14 days following the
previous 2 consecutive days off, and
c) have a minimum of 7 days off in any consecutive 4 weeks, and
d) have an average of at least 8 days off in each consecutive 4 week period,
averaged over 3 such periods.
A single day off shall include 2 local nights, and shall be of at least 34 hours
duration.
Switzerland As in Sub Part Q.
Spain As in Sub Part Q.
Germany As in Sub Part Q.
France As in Sub Part Q.
Norway As in Sub Part Q.
Poland As in Sub Part Q.
Czech Republic As in Sub Part Q.
Extended & Recovery Rest (Helicopters)
UK Additional (recovery) rest requirements for helicopter aircrew are:
‐ Not work more than 7 consecutive days
‐ Have 2 consecutive days off following a period of 7 consecutive days duty
‐ Have 2 consecutive days off in any consecutive 14 days and have at least 3
days off in any consecutive 14 days and
‐ Have a minimum of 7 days off in any consecutive 4 weeks and
‐ Have an average of at least 8 days off in each consecutive 4 week period
averaged over 3 such periods.
Switzerland Rest requirements stated are:
‐within 10 consecutive days, pilot shall receive at least one 48 hour rest
period.
‐ within each calendar month, pilot shall receive at least 8 local days free of
duty and pikett.
Within each calendar year, pilot shall receive at least 96 local days free of
duty and pikett.
Before and after each pikett period, a minimum of 12hours rest period
must be ensured.
Also for rest period between pikett periods the following limits apply:
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Extended & Recovery Rest (Helicopters)
‐ for up to 3 pikett days, minimum of 1 (24hours) rest day
‐for up to 5 pikett days, minimum of 2 (48hours) rest days.
Spain No provisions stated.
Germany A rest period of 48hours is allowed after each period of service.
France Cycle 1 : two consecutive rest days after 5 consecutive days of planned on
site standbys
Cycle 2 : 6 consecutive days after 12 consecutive days of onsite standby
Cycle 3 : 7 consecutive days after 7 consecutive days of onsite standby
Norway No provisions stated.
Poland A rest period of 24hours minimum must be taken before each duty period.
Also a duty period which includes rest time of less than 10hours within
subsequent 24hours shall not exceed 4 days.
Czech Republic (Decree art26/3): operator can extend basic rest period a) to 36hrs ‐
including 2 local nights during 7 consecutive days b) to 60hrs including 3
local nights during 10 consecutive days c) or pursuant to this provision.
15. Time Zone Crossing:
Time Zone Crossing (Regulations)
CRD ORO.FTL.235 Rest periods
(e) Flight time specification schemes shall specify additional rest periods to
compensate for:
(1) the effects of time zone differences and extensions of the FDP;
EU OPS Subpart Q OPS 1.1110: 1.3 An operator will ensure that effects on crew members of
time zone differences will be compensated by additional rest, as regulated
by the Authority subject to the provisions of Article 8.
Time Zone Crossing (Aeroplanes)
UK The UK has air ambulance flights that cross time zones but these are not
emergency flights (more medevac).
Switzerland Rest times have to be increased beyond time zone crossing >3 hours.
Spain SubpartQ‐OPS 1.1110 + Article 6, Real Decree to 1952/2009;
Rotation; FDPs starting and finishing at home base, or in a place where
time difference is no more than one hour compared to the home base, and
including at least one flight crossing 4 or more time zones .
Additional rest will be achieved following the rotation and at home base or
in a place with time difference no more than one hour compared to the
base.
Additional rest + basic minimum rest (due to previous duty) will include 2
local nights and will be as follows:
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Time Zone Crossing (Aeroplanes)
a)When time elapsed between departure and arrival to the home base is
less or equal to 60 hours= max (36, 4 time the time difference between the
home base and the location with the greatest local time difference).
b) When time elapsed between departure and arrival to the home base is
greater than 60 hours= max (36, 6 time the time difference between the
home base and the location with the greatest local time difference).
c)With FDP extension by in flight rest, the rest defined in a) and b) will not
be in any case less than 48 hours.
Before a FDP crossing 4 or more time a minimum 14 hours rest shall be
respected.
Rest according to a), b) and c) could be reduced (respecting OPS 1.1110)
when: prior FDP finishing at home base a rest including 3 local night had
been provided and subsequent flight duty less than 11 hours and its
following rest includes 3 local nights as well.
Period rest between Eastward‐Westward and Westward‐Eastward time
zone transitions, or vice‐versa, shall be at least 3 local nights. This rest
could be reduced to 2 local nights if the rest following both rotations
includes 4 local nights.
Article 12,Circular del Director General de aviación Civil, 17/12/2010;
In the computation of time differences, seasonal time corrections will not
be taken into account.
The number of rotations in 28 consecutive days or in one month is limited
to 5 for each crew member being not applicable split duty.
Germany § 12 Taking into consideration resting periods between time zone
differences
If there exists between the place of commencement of the air service and
the location of the termination of air service a time zone difference of four
or more time zones, the minimum rest period is increased to 14 hours.
France Same as for CAT operations (no specificity for EMS operations) :
a. Rest / days off requirements at home base following time zone crossing
duties :
If one sector > 3000 NM or crew away more than 3 time zones, minimum
rest is 36h including 2 local nights.
b. Augmented minimum rest at destination :
If FDP takes crew more than 3 time zones away from home base, rest =
max[duty, 14h]
Norway No provisions stated.
Poland No provisions stated.
Czech Republic No provisions stated.
Time Zone Crossing (Helicopters)
UK Annex D on Helicopters within CAP 371 assumes "Operations are confined
within an area where local time varies by not more than one hour"
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Time Zone Crossing (Helicopters)
Switzerland No provisions stated.
Spain Circular Operativa 16B ref. art.6.2 referenced.
Germany No provisions stated.
France No provisions stated.
Norway No provisions stated.
Poland No provisions stated.
Czech Republic No provisions stated.
16. Nutrition:
Nutrition (Regulations)
CRD ORO.FTL.240 Nutrition
(a) A meal and drink opportunity shall occur in order to avoid any
detriment to a crew member’s performance, especially when the FDP
exceeds 6 hours.
(b) An operator shall specify in its Operations Manual how the crew
member’s nutrition during FDP is ensured.
EU OPS Subpart Q See OPS 1.1130: Meal/drink opportunity must occur especially when
FDP >6hrs.
Nutrition (Aeroplanes)
UK Subpart Q requirements apply to EMS & Air Ambulance.
Switzerland No provisions stated.
Spain As in Sub Part Q‐OPS 1.1130
Germany Subpart Q ref. OPS 1.1130 applies .
France Subpart Q ref. OPS 1.1130 applies.
Norway N/A stated.
Poland As in Sub Part Q‐OPS 1.1130
Czech Republic As in Sub Part Q‐OPS 1.1130
Nutrition (Helicopters)
UK Subpart Q requirements apply to EMS & Air Ambulance.
Switzerland No provisions stated.
Spain N/A stated.
Germany No provisions stated.
France No provisions stated.
Norway N/A stated.
Poland No provisions stated.
Czech Republic N/A stated.
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17. Records for Flight Duty & Rest Periods:
Records for Flight Duty & Rest Periods (Regulations)
CRD ORO.FTL.245 Records of flight and duty times and rest periods
(a) Operators shall maintain, for a period of 24 months:
(1) Individual records for each crew member including:
(i) flight times;
(ii) start, duration and end of each duty period and FDP;
(iii) rest periods and days free of all duties; and
(iv) assigned home base.
(2) Reports on extended flight duty periods and reduced rest periods.
(b) Upon request, the operator shall provide copies of individual records of
flight and duty
times and rest periods to:
(1) the crew member concerned; and
(2) to another operator, in respect of a crew member who is or becomes a
crew
member of the operator concerned.
(c) Records referred to in CAT.GEN.MPA.100 (b)(5) in relation to crew
members who
perform functions for more than one operator shall be kept for a period of
24 months.
EU OPS Subpart Q See OPS 1.1135: records to be kept for block times, start/end times of flight
duty periods, rest periods & free days.
Records for Flight Duty & Rest Periods (Aeroplanes)
UK As per CAP371 ref. 25 requirements: 12 mths of flight and duty records & 6
mths of discretion reports maintained.
Switzerland Have to be filed by individual crew member and by company.
Spain As in Sub Part Q OPS 1.1135
Germany Subpart Q ref. OPS 1.1135 applies.
France Subpart Q ref. OPS 1.1135 applies.
Norway N/A stated.
Poland Subpart Q ref. OPS 1.1135 applies.
Czech Republic As in Sub Part Q OPS 1.1135
Records for Flight Duty & Rest Periods (Helicopters)
UK Same as Aeroplane table.
Switzerland Due to the "Flat rate system" of recording the flight duty time the numbers
of missions, sectors/legs and flight time per mission are not automatically
obvious to the NAA. These figures are available on request.
Spain Circular Operativa 16B ref. art.8.4: provisions for operator to establish a
recording system containing flight time, duty time and rest time.
Germany Records are kept by the operator for at least 3 months.
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Records for Flight Duty & Rest Periods (Helicopters)
France No provisions stated.
Norway N/A stated.
Poland Art.149 Labour Code ‐ records of working time shall be held by the
employer
Czech Republic As in JAR‐OPS 3, Subpart P.
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18. Other Elements – including SMS/FRMS:
Other Elements – including SMS/FRMS (Regulations)
CRD ORO.FTL.250 Fatigue management training
(a) The operator shall provide initial and recurrent fatigue management
training to crew members, crew rostering personnel and concerned
management personnel.
(b) This training shall follow a training programme established by the
operator. The syllabus for the training shall cover the possible causes and
effects of fatigue, and fatigue countermeasures.
EU OPS Subpart Q ‐
Other Elements – including SMS/FRMS (Aeroplanes & Helicopters)
UK None yet but SMS provisions will become a requirement with the
introduction of the Basic Regulation for Air Operations ‐ this year.
Switzerland The operator has to run a SMS system and will start a new FRMS to
mitigate risks.
Spain Not stated.
Germany Not stated.
France 1. Operators conducting EMS operations may not apply provisions of §3
and 4 of OPS 1.1105 (difference in reporting time between cabin crew and
flight crew members + operational robustness)
2. As stated before, operators conducting EMS operations shall comply
with CAT FTL rules. If they operate their aircraft with two pilots and under
FRM, they may use specific provisions as described above.
3. For single pilot operations :
For IFR operations or operations at night, total block hours of each FDP
shall be less than 6h
Maximum block hours for each sector shall be :
‐ 4h or less if the aeroplane is equipped with a full autopilot
‐ 2h in all other cases
Norway BSL D2‐4 §6, §7 and §10: The operators and the flight crew (or their
organisations) should make agreements regarding duty and rest
restrictions, and they shall produce a rosters for at least four weeks,
released at least two weeks ahead.
Poland Regulation of the Minister of Infrastructure, 2002 ‐ Journal of Laws, § 42
duty time shall not exceed 15 hours 30 minutes per 24 hours, § 44 If due to
special circumstances the pilot gets tired prematurely, which poses a threat
to safety, the pilot shall be obliged to take a decision to finish duty.
Czech Republic None stated.
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Appendix 3 – States’ Basic Maximum FDP Tables
Spain
Table A – Single Pilot, Passenger Operations
Table B – Two or More Pilots, Passenger Operations
Table C – Single Pilot, Cargo Operations
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Table D - Two or More Pilots, Cargo Operations
UK
Table A - Two or More Flight Crew, Acclimatised
Table B - Two or More Flight Crew, Not Acclimatised
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D & Circaddian
Tab
ble C - Sing
gle Flight Crew
C
ble D in UK
Tab K CAP 371 shows
s max
ximum FDP
P hours in any single day.
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1.05)
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Appendix 4 – Example HEMS Shift Patterns
Certain States noted that operators adopted patterns of duty hours suited to HEMS operations.
Switzerland and France provided the examples below. The FTL System in Switzerland is
based on a flat rate recording regulation. Depending on the time of the “Airport Standby” period
during a 24 hour-day a flat rate has to be recorded as “Duty Time”. Some example schedules
are given below:
Flat Rate Duty
Time over the
year
a) Fix Airport Standby Time: 0800 h to 1800 h 9.5 hours
Max. 15 duty/ standby days per month
b) Or changing duty times as follows:
January – March: 0800 h to 1730 h
April – June: 0800 h to 1830 h
July – August: 0800 h to 1930 h 9.5 hours
September – October: 0800 h to 1830 h
November – December: 0800 h to 1630 h
Max. 5 duty/ standby days per period and max 15 duty/ standby days per month
c) Or changing duty times as follows:
Summer: 01.04. – 31.10. 0800 h to 2200 h
Winter: 01.11. – 31.3. 0800 h to 2000 h 13 hours
Max. 2 duty/ standby days per period and max 11 duty/ standby days per month
If the Airport Standby Time is extended to 14 hours the recording flat duty time
over the year has to be increased to 13 hours of flight duty time.
The duty pattern in c) is typically used at bases in the non-mountainous parts of Switzerland.
Extensions into the night beyond 2200 are relatively common in such bases. The shorter daily
duty times in a) and b) are typical of the HEMS bases serving the mountainous parts of
Switzerland.
In France, duty hours and on-site standby can be organised in three different cycles:
1. Weekly cycle: comprising 5 on-site standbys, by day only (no night standby) between
periodic rests (periodic rest being : 24h+rest generated by previous on-site standby)).
2. 18 weeks cycle: comprising on site standbys, by day only (no night standby), limited to
12 consecutive days between periodic rests.
3. 12 weeks cycle : comprising on site standbys, by day or by night, limited to 7
consecutive on site standbys, between periodic rests.
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