Bombardier Safety Standdown 2013: A Sleep Update
The Jan. 4, 2014 implementation date for new Part 117 regulations on fatigue applies only to scheduled air carriers, but many observers believe elements of the new law will eventually work their way to business aviation.
At Bombardier’s Safety Standdown Jim Mangie, a Delta 767 captain and the airline’s fatigue program manager, discussed the practical implementation of fatigue policies from an airline perspective offset by his airline’s current safety management system (SMS). Last year, Delta flew 9,000 charter segments, often on the back side of the clock. “When I look at fatigue I see the safety side, but I also see things from the business side,” Mangie said. “We’re not just talking about tired. We’re all tired at the end of the day. We’re talking about [how to determine when a pilot is] impaired.”
Limiting the operational capabilities of any airplane affects the entire company, which is why fatigue has become such a hot topic. Mangie begins a fatigue assessment with three questions: how long has the pilot been awake; how long has he been on duty; and what time of day is it [when all this comes together]? “We must find a realistic balance. It’s really not rocket science.”
Mangie says the FAA’s AC 120-103 on fatigue risk management system implementation offers some science and the FAA’s guidance on exceptions to the current fatigue rules for Part 121. “There’s a considerable amount of information that will be useful to any Part 91 department,” he added. Operators will most likely see they’re already headed in the right direction on some items. “Part 117 itself is also a great guide. Get started, take a look and see how your operation measures up. Numbers way out of sync with Part 117 limitations could point to a problem in any operation even if they aren’t regulatory.”