from U.S. airlines on whether their fatigue risk management plans take commuting into account and the committee will discuss the results in its final report.

The FAA approach is compatible with ICAO’s fatigue risk management systems initiative and the trend over the past two decades of many U.S. federal regulatory agencies to shift more responsibility to the organizations they regulate and to encourage cooperative rather than adversarial relationships. Generally, these initiatives rely on management systems using continuous monitoring to identify and mitigate potential risks before they have safety consequences Such voluntary FAA programs include the Aviation Safety Action Program and the Flight Operational Quality Assurance Program.

The Occupational Safety and Health Administration (OSHA) also has several voluntary compliance strategies that take a similar approach.7 (The Food and Drug Administration’s Hazard Analysis and Critical Control Points Program for food safety is another management systems approach. The success of such programs is a matter of some disagreement and, as noted by the U.S. Government Accountability Office (2004) in the case of OSHA, rigorous evaluation is needed to examine their effectiveness.


There are many issues that complicate consideration of whether and how commuting affects pilot fatigue in a manner detrimental to flight safety, not the least of which is the lack of comprehensive, industrywide data on the prevalence and characteristics of commuting. On the basis of the comments and documents the committee has reviewed to date, many airlines and pilots believe that pilot fatigue is a safety concern. However, the extent and circumstances under which commuting contributes to fatigue remain unclear. Airline policies and practices, characteristics of the aviation system, and individual pilot behavior all play a role in pilot fatigue. It seems to the committee that it is important to note that safety in scheduled air transportation has continued to improve over time, to the point where catastrophic, fatal accidents in such operations are statistically rare events. Although much remains to be done in the way of data collection and analysis, pilot commuting appears to be a fairly widespread aspect of these operations.

Over the next several months, the committee will follow up on its requests for information, continue to review relevant literature and information received, and attempt to analyze the role of the many factors involved in the issue of pilot commuting and fatigue. The committee’s final report, in keeping with the charge, will outline its thoughts on potential next steps, possibly including promising practices, recommended changes to FAA regulations, administrative actions, and research priorities.


7For details of OSHA’s cooperative programs, see [January 2011].

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