On 18 January, the European Aviation Safety Agency (EASA) published its revised proposal for Europe’s future air crew fatigue rules. It took 50.000 stakeholder comments and the reports from three eminent scientists to make the Agency carry out some urgently needed changes to its initial proposal from 2010. And it took surveys among pilots in several EU countries to demonstrate that fatigue is a reality in Europe’s cockpits. But while the revised proposal brings some welcome changes, it still ignores key scientific findings on some important issues. Further changes are therefore required to protect passenger safety.

71%-90% of pilots surveyed in Sweden, Denmark and Norway said they made operational errors due to fatigue, with 50-54% acknowledging they dozed off in the cockpit without agreeing this with their colleague. In the UK, a recent survey showed that, of those pilots who say they have fallen asleep, 31% have woken up and found the other pilot asleep. And a survey among UK Aero-medical examiners (AMEs) shows that 68% of AMEs think pilots often fall asleep without even realising it themselves, and 75% of AMEs consider that up to 25% of pilots are too tired to fly safely.

These and other comparable surveys confirm what we already know: that we do have a safety issue in Europe’s cockpits. They also confirm what scientific research has shown: today’s EU fatigue rules are insufficient to protect airline passengers against the safety risks of fatigued pilots.
It is therefore difficult to understand that EASA disregards unanimous scientific and medical evidence in many provisions of its latest proposal. Whereas some clearly unsafe provisions of its previous proposal have been removed – like the French regional airline inspired practice of reducing rest time between duties to as little as 7:30 hrs, EASA closes its eyes to other issues.
For example, the three scientific assessments EASA commissioned in 2011 conclude that flying at night should be limited to 10 hours, as anything above would create critical levels of fatigue and hence a potential safety risk. And yet, after the airlines claimed this would hurt their business, EASA set the limit at 11 hours at night.
 
Another example is airport standby followed by a flight. EASA’s proposal would allow a crewmember having started his/her standby at 07:00 in the morning to fly until 01:00 next morning, or even 03:00 in case of unforeseen delays. This is 20 hours from the start of the standby and would require the pilot to land the plane safely having been awake for 22 hrs. Under the new USA fatigue rules this would be illegal.
 
EASA needs to do better. And it can. Scientific and medical research shows the way, but EASA stopped half way with its latest proposal. Now it is time to take the remaining steps.