FC5383 - Extremely fatiguing trip with 18-30hr rest gap
Initial Report
I am a [Location]-based [Airline] captain. It’s come to my attention that we now have a duty in [Location] that I think is probably unacceptable. Day 1 reports at 09:35 to fly to [Location], and day 2 has a return to [Location]. Off duty at 04:10 (technically into a 3rd day). When you think about the times, it really doesn’t work.
I’ll keep all the times in UK. Let’s say you wake up at 08:05L (90 minutes before report. You fly to [Location] at very sociable hours. But you are aware of the long night tomorrow. So you stay up until midnight. (02:00 in [Location]). You sleep a solid uninterrupted 10 hours. Wake up at 10:00 (midday in [Location] (you’ve missed breakfast)). Now you have to operate to [Location], off duty at 04:10. That’s still more than 18 hours awake. That’s assuming it’s on time. If you wake up on day 2 at the same time that you woke up on day 1, the duty is impossible. You’d be expected to land the plane after 19½ hours awake. Assuming that the flight is on time. As BALPA recently communicated, operating after 17 hours awake is the equivalent to being 2.5 times over the alcohol limit for flying.
It’s possibly at the point where it would be negligent of any ATPL holder to operate that duty on its own. Add in 700 plus hours of [Airline] roster and it’s clear that it’s not ok. I happen to know that someone put in an [fatigue report] for it. The fatigue score was [medium]. I think that shows that the Fatigue Risk Management System (FRMS) is based on fantasy, and is a tool used to justify questionable practices.
comments
Company Comment
The [Location] rotations were initially flown as out and back extended Flight Duty Periods (FDPs) but, given issues with their integrity and discretion usage, FRMS recommended a review of the way they were being rostered. Therefore, those with longer sector lengths were amended to become night stop sequences, with a number being asymmetric pairings that start at base but return to a different airport thereby requiring subsequent positioning. The route in question was created as one such asymmetric pairing. FRMS continued to keep under review those pairings which did not have a down-route day separating the inbound and outbound sectors given that the sequences would naturally involve a degree of transition. While FRMS impose strict and comprehensive rules on such early to late transitions, which go beyond regulatory requirements, the [Route] was nevertheless specifically discussed with the scheduling department and subsequently only operated a total of five times in late 2024 before being discontinued.
Although they are not subject to a blanket restriction, we are always mindful of the difficulties with 18-30hr duty gaps because they are contextually dependent on previous duties and the crew member’s circumstances at the time. For example, an off-duty time of 1600 local time and a report at 1000 local time the next day would be a rest period of 18 hours of no fatigue significance in isolation. In this respect there are algorithms within our rostering programme that take all 18–30-hour rest periods into account, along with the expected circadian cycle of the crew member.
We can only identify one fatigue report relating to the route in question during its short existence and this was a request asking us to review the duty in advance and therefore not based on the actual experience of operation. We do not provide [roster assessment scores] for reports concerning anticipated fatigue as we do not wish a relatively low score, based on theoretical conditions, to discourage a crew member from subsequently claiming a fatigued absence on the day of operation. We are therefore unsure, without further detail, of the provenance of the [medium score mentioned in the report]. For information, pre-emptive fatigue report forms are quantitatively assessed purely on roster construction characteristics. An [risk assessment of medium] would signify exceedances of one or more fatigue precursors, identifiable mitigations, when considered in the fatigue context in the referral period. During peak summer workload and disruption, we may see up to 20% of reports exceeding this level and these would almost exclusively be associated with a fatigued absence so with no transference of risk into actual operation. Towards the end of the year, the figure is more around 10%.
CHIRP Comment
CHIRP commends the airline for providing such a detailed response in time for publication of this edition of FEEDBACK. The report describes the well-known problem of 18-30 hr periods between duties. We’ve commented before to the CAA, and in our FEEDBACK newsletters, about the difficulty of getting in the required 2 sleeps within such gaps (see our FEEDBACK Edition 152, Report FC5347). The 18-30hr period between duties is troublesome because, although it’s ‘legal’ and would appear on first sight to give plenty of time for rest, it can also be problematic owing to the difficulty of fitting in 2 sleeps during the period. In the example given, if arriving at the destination and getting to bed at around midnight then it’s not surprising that their body then finds it difficult to get to sleep again about 10-12hrs later as they prepare for Day 3’s early wake-up.
The company involved in this report identifies that it uses rostering algorithms for dealing with fatiguing rosters, but such practices differ from company to company. Nonetheless, there should be a recognition by all airlines that repeated rostering of such 18-30 rest period duties can be very debilitating. Consecutive rosters with 18-30hr duty gaps will soon lead to chronic fatigue in those rostered in such a way.
The CAA is currently conducting a study into FTL/FDP assumptions to make them more coherent for UK purposes. CHIRP has made representations to the CAA before about this concern, so we hope that they will look at the recurring 18-30hr issue in their ongoing FTL review. Of note, the CAA’s role in monitoring rostering practices is to ensure that the patterns are legal and that any fatigue issues raised by crews are appropriately mitigated by the airline, this being done by the CAA oversight team. Any identified systemic issues would then be the responsibility of the operator concerned to mitigate, to the CAA’s satisfaction.