Saturday, June 21, 2014

Sleep Deprivation: a Dangerous Accepted Aviation Practice

The problem with proper rest periods for aviation personal is not limited to pilots and air traffic controllers. It is a systemic problem that also has negative effect on the maintenance personal. It has to do with the way this regulation is interpreted.

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14 CFR 121.377 Maintenance and preventive maintenance personnel duty time limitations.

Within the United States, each certificate holder (or person performing maintenance or preventive maintenance functions for it) shall relieve each person performing maintenance or preventive maintenance from duty for a period of at least 24 consecutive hours during any seven consecutive days, or the equivalent thereof within any one calendar month.
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In my experience as an aviation professional, I have run into this problem on almost every job. The maintenance industry interpret this "or the equivalent thereof within any one calendar month." to mean that the maintenance person may be worked 26 days in a row, then give them 4 days off, and that is compliance. I say that defeats the purpose of the intention of 14 CFR 121.377. That being, to ensure that fresh minds are maintaining the air-fleet, which makes a safer environment for both the worker, and the users (passengers & flight-crew) of the aircraft. The FAA seems to agree, but are fought on this point by the aviation industry.

I interpret that CFR 121.377 to mean that each maintenance personal shall have one 24 hour rest period  after working 6 days in a row. My experience tells me this is very reasonable, safer, and more cost effective. A person who is sleep/rest deprived will have more accidents, make more mistakes and have a lower moral along with a lower quality of life. This has negative effect on the tranquility of the home too!

The aircraft in the United States fleet must be brought into maintenance on a regular basis. Sometimes it is minor maintenance. Other times it is something called a C check, or D check. When this happens, the aircraft is brought into the depot level maintenance facility and completely stripped down, thoroughly inspected, and all problems corrected, and Fleet Directives addressed. Normally this is contracted to be done within a fixed amount of time. If that time is exceeded, penalties are incurred by the maintenance facility. That can run into $1000's a day.

So, in order to meet these deadlines, the maintenance facility will often work maintenance personal 12 hours a day, 7 days a week for 26 days in a row, then give them 4 days off. In my opinion, and in the opinion of most aviation personal, this is not a safe environment for the worker or the passenger.

Personal example: When I was working at Dalfort at Love Field in Dallas, Tx., the management wanted me to work 16 hour shifts. I agreed, and after two of those shifts, I made an error on a wing to body cowling that cost $1000's. The error was a direct result of fatigue brought on by having worked 30 hours with only 4 hours of sleep, and being rushed to meet a deadline. There are other stories out there I'm sure.

Sleep deprivation is a problem throughout our modern world. Most industrial accidents occur during graveyard shifts. There has been some very bad accidents caused by the sleep deprived worker. Chernobyl, Three Mile Island, The Challenger (space shuttle) Explosion, the Exxon Valdez Oil Spill, the American Airlines Flight 1420 Crash were all caused by sleep deprivation. That is only a short list too! I could go on and on with this gruesome list.

Sleep deprivation costs our world billions of dollars, and many, many lives each year. The fallacy of it is, sleep deprivation is a simple thing to fix. The FAA has addressed this problem with CFR 121.377, but remains under pressure from the aviation industry to resend decisions that favor a 24 hour rest in a 7 day period, and even argues what is considered duty!
(read this report: https://www.federalregister.gov/articles/2011/04/15/2011-9236/interpretation-of-duty-and-rest-provisions-for-maintenance-personnel)

Sleep deprivation is a world wide problem with an easy fix. I say addressing this serous problem in a proactive way is not only over due, it is mandatory.

Please share this important message. Lets eliminate this problem NOW! Go get some rest.

http://abcnews.go.com/WNT/video/sleepless-schedules-air-traffic-controllers-putting-public-safety-24134521?tab=9482930&section=1206853&playlist=1363340