Debunking Pilot Flight Time Limitations myths
The fatigue risk analysis falters at the 1st step when there is a generic comparison between a 0900-1700hrs office work schedule and a shift job including consecutive night duties or alternating day and night shifts. While sleeping patterns can be analyzed, the key differentiator is the stress arising out of the working environment. It’s crucial to consider the impact of extended hours and irregular shifts on the overall well-being of employees, as well as the potential effects on their personal and social lives. Furthermore, the nature of the work itself, such as physically demanding tasks or high-pressure decision-making, can significantly contribute to fatigue and stress levels. Therefore, a comprehensive fatigue risk analysis should take into account not only the timing of work but also the nature of the tasks and the overall working conditions.

A study on pilots operating short-haul flights concluded that even far fewer duty and flight hours than legally allowed according to flight time limitations lead to high levels of fatigue, sleep problems, and significant mental health issues among pilots. SH pilots were even more affected than LH pilots. Pilot fatigue should be considered an immediate threat to aviation safety and pilots’ fitness to fly by promoting fatigue and burnout.
Venus M, Holtforth MG. Short and Long Haul Pilots Rosters, Stress, Sleep Problems, Fatigue, Mental Health, and Well-Being. Aerosp Med Hum Perform. 2021 Oct 1;92(10):786-797. doi: 10.3357/AMHP.5812.2021. PMID: 34641999.
In general, ICAO Standards and Recommended Practices (SARPs) in various Annexes support two distinct methods for managing fatigue:
- a prescriptive approach that requires the Service Provider to comply with duty time limits defined by the State, while managing fatigue hazards using the SMS processes that are in place for managing safety hazards in general ; and
- a performance-based approach that requires the Service Provider to implement a Fatigue Risk Management System (FRMS) that is approved by the State.
They must be based on scientific principles, knowledge and operational experience.
Even if fatigue is managed through a prescriptive system, the principles of Safety Management System as given in ICAO Annex 14 must be used. Therefore both options must follow the principles of risk management.
The 3 short videos will briefly explain the science behind the limits and certain myths that need to be busted.
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