Turbulence Ahead: Safeguarding Aviation Safety Amidst Operational Demands

Aashnaa Mehta

Despite efforts to amend duty hour regulations through the Revised Civil Aviation Requirements on Flight Duty Time Limitations (2024) , opposition from airlines and regulatory deferments highlight ongoing tensions between safety and commercial priorities, necessitating proactive regulatory evolution to ensure pilot well-being and passenger safety.

Pilot fatigue has long been a contentious issue, often overshadowed by commercial priorities at the expense of safety. Airlines have resorted to various tactics, including rostering irregularities and disregarding pilot duty hour regulations, with recent fines levied against Air India highlighting the severity of the problem. However, a series of pilot deaths linked to exhaustion has brought overdue attention to the issue.

Recent incidents, including fatalities among Indian pilots, underscore the mounting fatigue stemming from increased flight demands in a rapidly expanding domestic aviation sector. These tragedies include a pilot of Indian descent flying for a West Asian carrier, a pilot from a major Indian private airline who collapsed before boarding in Nagpur, and an incident involving a Latin American flight where the pilot collapsed mid-flight, requiring the co-pilot to land the aircraft. The death of the Nagpur pilot, poised for a multi-sector flight, serves as a stark reminder of the urgency for action.

In response to pilot concerns and the escalating fatigue crisis, the Directorate General of Civil Aviation (DGCA) had announced amendments to its duty hour regulations, focusing on reducing nighttime flying and bolstering weekly rest periods in January of the year 2024.

Revised Civil Aviation Requirements on Flight Duty Time Limitations (2024)

  • Pilots flying between midnight and 6 a.m., known as “night duty,” can now conduct a maximum of two landings, down from the previous allowance of six, with no more than two consecutive night duties permitted.
  • The definition of night duty has been extended to include operations until 6 a.m., aligning with the Window of Circadian Low (WOCL) from 0200-0600 hours, enhancing rest and alertness levels.
  • Weekly rest periods have been extended to a continuous 48 hours, including two local nights falling between 10 p.m. and 8 a.m. local time, providing pilots with adequate recovery time.
  • Airlines are now required to publish crew rosters sufficiently in advance to assist pilots in planning their schedules effectively.
  • Quarterly submission of pilot fatigue reports, along with corresponding action plans, is now mandatory for airlines, enhancing transparency and accountability in addressing fatigue-related concerns.
  • The implementation of the Fatigue Risk Management System (FRMS) aims to improve fatigue monitoring and reporting through a data-driven approach, although pilots express reservations about potential reductions in prescribed rest periods. It’s important to highlight that FRMS has been widely adopted in many countries since as early as 2003. Despite its established presence elsewhere, India is still in the planning stages of introducing it.

While pilots have welcomed the recent changes in pilot duty regulations, their call for a ban on consecutive night duties remains unaddressed. They argue that flying two consecutive nights without resetting the circadian rhythm is highly stressful, leading to increased fatigue-related impairment due to sleep debt accumulation. According to IATA’s Fatigue Management Guide, recovering alertness and performance after accumulating sleep debt may take longer than two nights of uninterrupted sleep.

Pilots have also highlighted the uncertainty surrounding crew rostering requirements, pointing out that airlines are already stretching the boundaries of current regulations through aggressive scheduling tactics. This ambiguity in regulations can lead to extended duty periods, inadequate rest intervals between flights, and heightened fatigue levels among pilots. Such practices not only strain pilots but also compromise safety standards during flight operations.

The FIA’s Stand

The Federation of Indian Airlines (FIA), representing Air India, IndiGo, and SpiceJet, urged the Directorate General of Civil Aviation (DGCA) in February to postpone the June 1 deadline for implementing new regulations on pilot duty hours. They argued that the abrupt change could significantly affect both business operations and customer satisfaction, as airlines would need to recruit 15% to 25% more pilots—a process taking 8-10 months per recruit. FIA cautioned that failure to delay the deadline could lead to a 15%-20% flight cancellation rate across most airlines, including some long-haul international routes.

FIA’s argument for postponing the implementation deadline revolves around the potential impact on business operations and customer satisfaction. They assert that the sudden need to recruit a significant percentage of new pilots could disrupt flight schedules and lead to a substantial increase in flight cancellations. This concern reflects the delicate balance airlines must maintain between ensuring safety standards and meeting operational demands to maintain profitability and customer service levels.

Additionally, FIA criticized the new regulations as overly restrictive and ambiguous, potentially diminishing the competitiveness of the Indian aviation sector compared to global standards. The ambiguity surrounding the regulations may create uncertainty for airlines in terms of compliance requirements and operational planning, potentially affecting their ability to compete effectively in the international market.

Prior to this exchange, DGCA rejected airlines’ pleas for postponement, emphasizing the urgency highlighted by recent pilot fatalities attributed to exhausting schedules. DGCA urged FIA to recognize these fatalities as a pressing call to action, emphasizing the need for prompt implementation of revised regulations to address pilot fatigue. Furthermore, DGCA mandated that airlines comply with the new rules by June 1 and submit internal company schemes aligning with the regulations by April 15.

Overall, the opposition from FIA highlights the inherent tension between safety imperatives and commercial pressures in the aviation industry. While ensuring the well-being of flight crew is paramount, finding a balance between safety regulations and operational efficiency remains a complex challenge for regulators and airlines alike.

Reversing Course

The recent decision by the Directorate General of Civil Aviation (DGCA) to allow scheduled air transport operators to continue following the 2019 norms until their internal schemes align with the new regulations marks a significant development in the aviation industry. This amendment, made on March 26, effectively grants airlines discretion in implementing the revised Civil Aviation Requirement (CAR) without imposing a specific timeline for compliance.

However, this decision raises concerns about the legal validity of the Revised CAR, as it places discretionary power in the hands of operators rather than prioritizing the interests of pilots and the Indian aviation sector as a whole. By allowing airlines to operate under outdated regulations until they align with the new rules, the DGCA risks compromising safety standards and undermining regulatory oversight.

The request from the Delhi High Court during a hearing of a writ petition filed by multiple pilot unions challenging the DGCA rules on pilot duty hours adds further complexity to the situation. In response to the court’s observations, the DGCA has sought timelines from airlines for implementing the new pilot rest duty rules. This indicates a recognition of the need for clarity and accountability in implementing regulatory changes, particularly in light of legal challenges and safety concerns raised by pilot unions.

Moving forward, airlines are expected to provide a timeline for preparing a roadmap for implementing the revised Flight Duty Time Limit rules and subsequent implementation. This underscores the importance of transparency and adherence to safety standards in the aviation industry, particularly in addressing issues related to pilot fatigue and duty hour regulations. However, the effectiveness of these measures in ensuring the safety and well-being of flight crew remains to be seen, as the industry continues to grapple with the complex interplay between regulatory requirements, operational demands, and safety concerns.

Navigating the Future

In the backdrop of a pilot shortage, the Indian aviation market is experiencing rapid expansion, with increased flying stemming from an expanding route map both domestically and internationally. However, this growth is accompanied by significant stress on the well-being of flight crew, exacerbated by factors such as the rising prevalence of ultra-long haul flights and the addition of more widebody aircraft to India’s fleet.

Amidst the COVID-19 pandemic, the necessity to prioritize pilot wellness had intensified, as changing travel demands and operational disruptions heightened the challenges faced by aviation professionals. This unprecedented situation underscored the crucial need to address fatigue-related concerns to safeguard the safety and well-being of pilots amidst the evolving landscape of the aviation industry. Despite these mounting concerns, the pressure on aviation workers persists. India’s domestic air passenger traffic soared to unprecedented heights in 2023, surpassing pre-pandemic levels and signaling a complete recovery from the impact of Covid-19. Projections indicate a staggering 225 million total air passengers in the upcoming year, with estimates suggesting this number will surpass 300 million by 2030, according to Civil Aviation Minister Jyotiraditya Scindia.

The Directorate General of Civil Aviation (DGCA) made a significant move in January this year by proposing changes to flight duty time limitations (FDTL), aiming to address the pervasive issue of fatigue in a methodical and scientific manner, or tackle what crews refer to as the challenge of red-eye flights. However, as numerous aviation experts highlight, with the DGCA now choosing to lower a safety net, pilots will continue to grapple with fatigue-related challenges. The decision by the aviation safety regulator to indefinitely defer the implementation of new pilot rest and duty norms is deemed by many as jeopardizing pilot safety and, consequently, passenger safety as well.

Maintaining independence and upholding regulatory standards aligned with safety is paramount for the DGCA. While operational continuity is crucial, compromising on policy changes for expediency, risks undermining safety concerns and eroding trust in regulatory oversight.

The aviation sector is inherently dynamic, characterized by continuous technological advancements, structural transformations, and the impact of global events. These factors continually reshape the landscape of aviation labor, necessitating corresponding adaptations in regulatory frameworks. As the industry evolves, so too must the legal frameworks governing the work of aviation professionals. These frameworks serve as critical safeguards, ensuring that safety standards are upheld, operational practices remain compliant, and the well-being of aviation personnel is prioritized amidst evolving industry dynamics. Consequently, a proactive approach to regulatory evolution is essential to effectively address emerging challenges, foster innovation, and sustain the overall safety and integrity of the aviation industry.

References

Aashnaa Mehta is a research intern at IMPRI, who is currently pursuing her Bachelors in Political Science from Mumbai University.

Acknowledgment: The author would like to thank Aasthaba Jadeja, Vishavjeet Singh and Ankita Nawani for their valuable feedback and constructive suggestions that helped in improving the article.

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This article was posted by Aashnaa Mehta, a research intern at IMPRI.

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