EU - Transport Policy

Written evidence from the British Air Line Pilots’ Association (BALPA)

(EU 16)

The British Air Line Pilots’ Association is campaigning to make every flight a safe flight.

On 20 December 2010 the European Aviation Safety Agency (EASA) published its proposed changes to Flight Time Limitations (FTLs) which would pose a real threat to flight safety.

Current FTLs are governed by the Civil Aviation Authority’s regulations known as CAP371. Under this scheme the UK has the best air safety record in Europe. New European legislation will supersede CAP371 and will  apply across the EU.

Our principal concern is that these new rules (known currently as the EASA’s Notice of Proposed Amendment) have been developed with little regard for the science behind FTL calculation. The current rules are based on 40 years of scientific research into fatigue and its impact on transport safety. The new proposals have never been subject to scientific or medical evaluation.

What will the impact of these changes be?

Fundamentally, the new rules would mean pilots flying for longer, with less rest time. Under current regulations a pilot’s maximum ‘single sector’ Flight Duty Period (FDP) is 12 hours (including an hour’s extension at the Captain’s discretion). The new regulations would instead have a maximum 14 hours FDP. They would also then be expected back on duty more quickly too: down to 7.5 hours in certain circumstances.

The black line in the above graph is what is known as the ‘Karolinska sleepiness scale’, a well-respected model for evaluating subjective sleepiness used by, amongst others, NASA. EASA’s new proposals are shown as clearly unsafe and would result in medium-severe fatigue at every point on the graph.

Truck drivers are restricted in the amount of time they can drive to 9 or 10 hours per day. Pilots would be expected to fly significantly longer hours than truck drivers under this new scheme, and, of course, pilots cannot pull over or take a break when they feel tired.

Pilot fatigue is already a global air safety problem – 15-20% of all air accidents have pilot fatigue as a contributing factor – and these new regulations, if implemented, would make matters far worse.

The Science

BALPA is not against EU-wide FTLs as long as they are based on the scientific and medical evidence and would not put air safety at risk.

EASA commissioned a report into this issue, known as the Moebus Report, but did not take this report into consideration, or draw on it, when drafting its current proposals.

BALPA would like the Committee to ask the Minister to oppose any moves to change FTLs which are not based on the scientific evidence and to encourage EASA to take the Moebus report into consideration before issuing the next draft of its proposals, known as the Comment Response Document (CRD)

We are happy to provide the Committee with further evidence and would welcome the Committee raising this matter with the Transport Minister at the evidence session on 1 February 2011.

January 2011