FC5357

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Fatigue/tiredness/use of in-seat napping

I am increasingly concerned with the use of in-seat napping as a tool to stave off the inevitable fatigue issues the company’s rostering is producing. In-seat napping is meant to be a last resort but is continuously used on day and WOCL flights in order to continue with the safe operation of the flight schedule. Two pilots operating through the WOCL is a gruelling schedule and I believe the company are not approaching the task with the greatest of safety in mind. If you look at the flight reports, I can assure you that most will have the in-seat napping check box ticked. This is becoming the norm when it should be a last resort. We do have a FRMS in place, but the reporting system is overly complicated and when you’ve landed it normally gets forgotten due to tiredness. The flight reports will show when in-seat napping is used though. I believe we need to move away from these 2 pilot schedules and allow the crew to rest correctly to ensure the safe conduct of our flights before the inevitable incident occurs due to tiredness. Pilots are regularly sleeping for over 2 hours at a time, in seat, in one block on both the outbound and inbound sectors. Not for 30mins as advised.

Company Comment

The report was passed to our FRM Team by our Safety Team. It was noted that the reporter operates the A330, some of which do not have dedicated crew-rest facilities. These aircraft are due to be phased out in the coming years, but they do have the option to curtain off 1 to 5 business-class seats that create a class 2 rest facility for crew if needed. These seats will be used if these aircraft are used on longer trips that require IFR (In Flight Rest) to extend FDPs.

Currently the difference between rostering 2 or 3 pilots is the requirement of rest based on FDP under an approved Flight Time Limitations (FTL). However, as a result of FRM work, we also monitor double-WOCL trips with 2 pilots and one night down-route, and either restrict these to one per roster period or add a third pilot dependant on layover length. That said, Flight Crew Management have an industrial agreement soon to be implemented (timescales to be confirmed) that gives greater protections than the current CAA regulations. It is also worth noting that these agreements were underpinned by work achieved by the FRM department. The relevant IR rule states that:

All flights will be assigned two operational pilots unless:

    • An extension of an FDP is required as per OMA 7.1.6.1 and then in accordance with OMA 7.1.6.4.1. In this case an additional crewmember will be rostered on the flight.
    • If the outbound or inbound sector BTRT is 9.5 hours or greater an ACM will be assigned on both the outbound and inbound flight.

In the case where an A330 is used, and until the fleet rollover of the A330-300 to the A330-900 is completed, the following variation on the above rule applies:

Instead, any 2-pilot flights on the A330, or an intermix pairing of the A330 and the A350 (SFF), where the outbound sector of 9.5 hours BTRT or greater, will be rostered two local nights free of duty at destination if the flight arrives at the destination after 00:00 UK time.

In reference to the CRR statistics, FRM do monitor this and are able to pull data supplied to us by the Pilots on the Flight reports. It can also be noted that there is potential to add further fields to the flight report that will allow FRM to ask questions more specific to fatigue. This is yet to be agreed but ideas are Karolinska Sleep Scale (KSS) score at TOD, CRR and CRR length. These questions are asked in our FCAFs but as the reporter says, the old forms have become troublesome to complete. This is not necessarily due to the design but more to do with a recent update issue that will be hopefully resolved soon. We appreciate that filling in extra forms after a long flight is not ideal, hence why we are looking at incorporating some FRM questions into the flight report and only asking for extra, confidential, voluntary information if the reporter scores themselves highly on the KSS. We have already achieved something similar with our Cabin Crew and we are receiving reporting rates close to 70%. If agreed, we hope to implement this by the middle of 2025 however, with the data we receive from the flight reports, we see that 36% of our pilots report taking CRR on all flights and, when isolating the A333 these numbers increase to 37%.

We hope to implement this by the end of the year [2024] but, until then, we can only draw on the FCAFs we have received. If we take a closer look at the data, we currently have a reporting rate of 9% (YTD to Oct) for our Flight Crew and from that snapshot we see that 56% of our pilots report taking CRR on all flights. Of that 56%, only 6% suggested they took longer than an hour by selecting the “other” field under time taken in CRR. There is no field for multiple occurrences, but this is something we have addressed in the new FCAF form mentioned above. When isolating the A333 these numbers are very similar at 56% and 7% but this of course relies on the user inputting the details correctly. With that in mind, and according to the data our pilot’s supply, we can see that just over half our pilots take CRR and approximately 4% potentially take more that 1hrs CRR.

As to what we have in our Ops Manuals regarding CRR, we have several references and, to summarise, our procedures suggest this is not a last resort option and it does not state that multiple uses of CRR cannot be utilised.

In-seat napping (more correctly referred to as Controlled Rest (CR)) appears to be becoming a prevalent practice due to some rosters pushing the boundaries of FTL/FDP and reluctance to roster 3 crew for transatlantic flights. CR had originally been intended as an occasional short-duration relief for crews, but it now appears to be becoming more widespread in its use. Current CAA guidance material is contained within GM1 CAT.OP.MPA.210 ‘Crew members at stations’ and, at para (6), allows crew members to take more than one period of CR in a flight if necessary, subject to restrictions.

CHIRP has commented before on this issue (see ATFB149 Editorial for our most recent comments) and, as we commented there, although we acknowledge that multiple use of CR during a flight can be acceptable (as long as it is used properly), it must be carefully planned not only to ensure that not too much sleep is taken in one go (which, despite the temptation to sleep for extended periods, can result in increased drowsiness on waking), but also so that sufficient recovery time from the nap is factored in so that individuals are suitably alert and free from ‘sleep inertia’ before demanding, high-workload tasks are performed.

As noted elsewhere, the CAA have commenced an overall review of FTL regulations and we strongly support the inclusion of more guidance on the use of CR within this review. This would also usefully consider the long-term medical implications of fatigue and ‘napping’. As people age, some cope less well with fatigue and disruption to their circadian rhythm, so this should also be considered in fatigue management terms. The review should also consider the introduction of standardised ways of measuring alertness for fatiguing flights and after the use of CR so that comparative assessments of alertness can be made across the industry for sleepiness statistics. In the short term, crews are encouraged to keep on reporting fatigue issues and the use of CR so that data is accumulated to promote changes.