The A&P/AME and Fatigue – They Don’t Play Well Together

R. Fred Polak – President/CEO

In late 2013, the Federal Aviation Administration addressed the issue of implementing long-overdue new fatigue standards for airline pilots. The new regulations revise hours-of-service rules that more accurately reflect our understanding of human fatigue. The rules set a ten hour minimum rest period before flight duty, a two hour increase from the previous standard. This allows pilots a chance to get eight hours of sleep before a duty period, instead of the five or six hours they were getting under the old rules. A pilot will also be allowed only so much on-duty time in a 28 day period.

It appears that once more the FAA has addressed the issue of the dangers posed to the flying public by fatigued pilots, and I take my hat off to them for doing so. But like many things the feds have done of late, they are only addressing part of the problem. It is sort of like seeing someone drowning 100 feet from their boat and throwing them a floatation device just 50 feet out. Well, we met them halfway, what more do you want says the FAA.

What do I mean by saying they are only addressing part of the problem? The new requirements won’t apply to cargo aircraft pilots, not even when they’re flying a Boeing 747 halfway around the world. By excluding cargo pilots from its new rules, the FAA is failing to adhere to its mission of making safety its first priority. And what about helicopter pilots, where do they fit into the scheme of the new regulations? I have not seen anything so far in that arena.

Now we come to the heart of this issue. What about fatigue standards for the men and women who work to maintain aircraft in safe, reliable flight status? Whether working on fixed wing or rotary wing aircraft, why is there no concern for the hours worked by aircraft maintenance technicians? Do the feds honestly believe that maintenance and fatigue go well together?

For the uninitiated, an aircraft maintenance technician as defined in the United States, refers to an individual who holds a mechanic’s certificate issued by the Federal Aviation Administration; the rules for certification, and for certificate-holders are detailed in Subpart D of Part 65 of the Federal Aviation Regulations (FAR’s), which are part of Title 14 of the Code of Federal Regulations. Aircraft Maintenance Technicians (AMTs) inspect and perform or supervise maintenance, preventive maintenance and alteration of aircraft and aircraft systems. In the U.S., aircraft maintenance technicians usually refer to themselves as A&Ps for airframe and powerplant mechanics. In Canada and elsewhere around the globe, they refer to themselves as Aircraft Maintenance Engineers, or AMEs. These are highly qualified individuals and someone at the fed forgot that without them doing their jobs, pilots could not do theirs safely.

Fatigue comes in two main categories; physical fatigue and mental fatigue. Physical fatigue says that the muscles just don’t want to work anymore. That is easy enough to understand, but what about mental fatigue? Mental fatigue can be defined as a temporary inability to maintain optimal cognitive performance. (Yes, I know, big words, Google them if you have to, but read on.) The onset of mental fatigue during any cognitive activity is gradual, and depends upon an individual’s cognitive ability and also upon other factors, such as sleep deprivation and overall health.

Mental fatigue has also been shown to decrease physical performance. It can manifest itself as somnolence, lethargy or directed attention fatigue. It may also be described as a more or less decreased level of consciousness. In any event, this can be dangerous to the extreme when performing tasks that require constant concentration such as operating large vehicles, surgery, or performing maintenance on aircraft.

So if the feds are so worried about the hours a pilot needs to rest between flights, does it not make sense that they should be just as worried about the amount of rest an AMT is allowed between work shifts? What good does it do to have a well rested pilot, if your maintenance crew can’t keep their eyes open while working on the aircraft? Will those persons who will fly on the aircraft really be any safer if just the pilot is well rested?