Part 91 Crew Rest Interpretation Debated

AINsafety » April 23, 2012
April 23, 2012, 6:08 PM

The FAA’s recent reinterpretation of crew rest guidance sparked a vigorous discussion at the Flight Safety Foundation Corporate Aviation Safety Seminar in San Antonio last week. During a fatigue management panel, the NBAA’s Doug Carr reminded the audience that, in January, the FAA’s Chief Counsel posted a new interpretation of an old Part 91 controlled-rest definition, essentially outlawing use of the original guidance for two-pilot aircraft. “It could not have been a more baseless opinion,” Carr claimed. “It contradicted all the science [on fatigue].”

Many countries, including Canada, Australia, New Zealand and most of those in Europe, allow pilot napping. Many flight departments still have what were legal crew napping policies in their Flight Operations Manuals, something Alertness Solutions CEO Leigh White said, “They might want to remove.”

White said her company is working with the FAA right now on new research to prove that naps are not a threat to flight safety, but will actually make flying more safe. “We’re designing a data collection survey the FAA can sponsor. We want to make it easy for them to say yes to napping.”

Carr agreed. “There appears to be a move on the part of the agency to allow an alternative means of compliance,” he said. Flight departments can contact White at for information on participation in the survey.

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