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Aviation Fatigue Regulation should Obey the Law of Common Sense


In George’s Point of View

I noticed today that Bloomberg’s Andre Zajac posted an article referencing William Voss, chief executive officer of the Alexandria, Virginia-based Flight Safety Foundation, who said “If anyone wants to advance safety through regulation, it can’t be done without further loss of life.”

The point he was making is in reference the peculiar mechanism of aviation safety law.

To go into effect, an aviation safety law must pass a cost-benefit analysis. This analysis is based on how much benefits outweigh cost (i.e. the cost of human lives). Where the problem occurs the recent fatigue rules exempt freight carriers. All-cargo operations are not required to abide by part rule p. 5-6, 15, 259. This is why IPA filed a Petition for Review in the U.S. Court of Appeals for the D.C. Circuit in order to challenge FAA?s exclusion of cargo operations from the final flight and duty time rule.

Although the “FAA generally acknowledges that “factors that lead to fatigue are universal” (Rule p. 259) and that night-time operations (during pilots circadian lows) and operations that cross multiple time zones warrant stricter measures to guard against fatigue” cargo carriers are exempt.”

Surely the FAA realizes that cargo pilots get just as tired as commercial jet pilots–perhaps more so because so many cargo flights are overnight flights.

Does it really make sense to exempt all-cargo carrier pilots from fatigue regulations for financial reasons? Shouldn’t a rule governing pilot safety cover all pilots? Is an Airbus, Fokker, Antonov, Boeing 737 or 747 less destructive if it falls from the sky if it only has a payload and crew but no passengers?

IPA Points.pdf

Flight Member Duty Requirements.pdf

FRMP Checklist.pdf

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    The Greatest Threat to Aviation Safety

    According to the people who ought to know—the NTSB, Flight Safety Foundation, Boeing—recent studies indicate that the biggest threat to aviation safety is pilots not doing go-arounds.

    Excuse me?

    Apparently,pilots need to recognize and respond faster to unstabilized approaches (approaches that need correction in heading, speed and/or altitude.)

    Pilots tend to want to land when they come in for a landing; and surveys indicate that although airline requirements are to abort landings if their approaches are unstable, go-arounds happen proportionally less often than they should. The Director of Global Programs at Flight Safety Foundation, Rudy Quevedo, “The physics of landing mean that the plane should be centered, on the correct trajectory, the correct descent rate and the right speed.”

    In George’s Point of View

    This conclusion seems to me a major oversimplification of the multitude of aviation problems.

    I would not presume to say that I know if weather, mechanical failures or human failures are most frequently responsible for aviation disasters. I do know that problems tend to occur together.

    I know, for example, that there are countries (like India where a recent aviation school scandal revealed the licensing of pilots who cannot fly or pass flying exams.) When a pilot who couldn’t pass his flying exam has an accident, a go round would not have helped.

    And as for a crash like the Boeing 777 operated by Asiana Airlines that crash landed at San Francisco International Airport–the plane flown by someone unfamiliar with the airport and the plane he was flying came in too low and hit the seawall (among other things.) How can one say that failing to make a go around was the problem–when the plane was too low and at the wrong angle even before reaching the runway.

    It is easy for a statistician to say some of these accidents could have been prevented with a go-around; but in how many of these accidents was a go around actually an option? Planes hit seawalls, encounter wake turbulence, strike cables, have flat tires, flap failures, bird strikes, suffer wind shear, idiots who attempt to open doors in mid-flight, and hundreds of other problems. A go-around is not always an option.

    Undoubtably, especially on small planes, a second or even third shot at landing will correct minor landing physics issues. It’s probably somewhat easier on a small plane than a 777, And if you ask a pilot that had a runway overrun, he will probably tell you the exact instant when he should have gone for the go-around, and knew when it was too late.

    It should be noted that sometimes when the plane is on a wrong trajectory, incorrect descent rate, and wrong speed, it might not be possible to manage a go-around; there may well be a factor like a bird strike, mechanical failure, faulty flight indication, or icing crimping the physics.

    It’s very easy for a guy with a pencil in his hand to say pilots should have aborted their landings at the first sign of trouble. Sometimes we should look at surveys and statistics like Mark Twain, and realize that “There are lies, damned likes and statistics.”

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    Virtual Airport


    At smaller airports, the controllers direct traffic and manage the airfield. Currently, pilots using the Beckley-area airport talk among themselves to advise themselves of traffic.

    An actual, physical tower would cost between $2 million and $3 million, with an ongoing annual expense of $450,000 for maintenance. A virtual tower would be far less expensive.

    Quadrex Aviation LLC, based in Melbourne, Fla. is developing a plan for a computer-driven control tower for Raleigh County Airport Authority. The report will be out in September. “If this does work as advertised, or even better than we imagined, then that holds the promise out to a lot of airports that could never afford to justify a control tower in the first place, and to provide that level of safety in an environment where you’ve got a lot of people trying to occupy the same air space.” according to Dr. David Byers, senior development professional for Quadrex Aviation LLC. And, regarding the Beckley area airport, “It’s kind of like an airport graduating from a two-way stop at an intersection to a four-way stop, and you reach a certain point say, at a four-way stop, and if you’ve ever been in that situation, well, who’s next? You may decide, ‘Well, you’re next,’ and somebody has the same opinion and attitude, and the next thing you know, there’s a conflict there. The concept at Beckley is to explore the opportunity of actually setting up a facility where they can test the technologies, to see ‘here’s what we think it’s going to do,’ and to put it in a facility where it can be managed and monitored to see if it’s doing what it’s advertised to do and get some feedback from the pilots and essentially be a prototype of other systems that could go up around the country.”

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    Joy Flight Steals Joy

    Before the Sukhoi Superjet smashed into a ledge on Wednesday, killing 45 people and raining debris down the slopes of Mount Salak, I had never heard the term “joy flight.”

    The “joy flight” is the airline equivalent of you going down to the Ferrari dealership and taking a test drive. Or it would be if you were being driven in the Ferrari for fifty minutes or so, in a party atmosphere courted along with a bunch of other potential buyers.

    The “joy flight” is a selling tool for the manufacturer. They host this ride for potential buyers to show off the features and quality/qualities of a new plane they are trying to sell.

    Until the black box is recovered (we hope one was on the plane!), we won’t have any idea if the pilots had been asked to “buzz” the mountain, or if their request to fly low was a response to the heavy cloud cover. United Aircraft Corporation which built the Superjet says that pilot Alexander Yablontsev (who had logged 10,000 hours in Sukhoi prototypes) was their best test pilot, and had overseen “everything from the designing of the aircraft to its certification.”

    Buzzing mountains renowned as an airline graveyard would not be the smartest thing to do, but everyone does wonder why the pilots requested to lower their altitude right over Mount Salak. Family members are already protesting the hazardous route that had been planned for the demonstration flight.

    There were 35 Indonesians, 8 Russian crew members, 1 French and 1 American.

    The American, Peter Adler was a consultant for Sriwijaya Air, a domestic Indonesian carrier. Adler had been born in São Paulo, Brazil to Auschwitz survivors, grew up in Los Angeles and leaves behind a wife Randi, and family.

    Joy flight is a cruelly ironic term. In catastrophic loss of life cases, loss of joy can be considered part of the damages, as families inevitably remain haunted by the loss of their loved ones.

    We offer our condolences, but we know how insufficient that is, as relatives are only beginning the harsh journey of grief that begins with shock and a sense of immeasurable loss.

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    FAA and Port Authority of New York and New Jersey Reach Agreement on Airport Safety Violations

    WASHINGTON – The Federal Aviation Administration (FAA) and the Port Authority of New York and New Jersey (PANYNJ) have reached a settlement agreement about aircraft rescue and firefighting (ARFF) violations from December 2010 to June 2012 at four New York area airports owned and operated by the PANYNJ — John F. Kennedy, Teterboro, LaGuardia, and Newark Liberty International.

    “We expect all airports to comply with our safety regulations and to correct any deficiencies immediately,” said U.S. Transportation Secretary Ray LaHood. “These violations were egregious, and they will not be tolerated.”

    Under the agreement, the PANYNJ agrees to pay a $3.5 million fine within 30 days. If there is a violation of the settlement agreement, the FAA will impose an additional fine of $1.5 million and will assess an additional $27,500 daily for each violation. In addition to the fine, the PANYNJ has agreed to take the following actions, with FAA approval, to address the underlying problems that led to systemic noncompliance with ARFF requirements at the four airports:

    • The Port Authority will create a dedicated ARFF force to carry out airport-related ARFF functions with no collateral police officer duties.
    • The staff will report directly to the Department of Aviation and be operational no later than March 31, 2014.
    • The Port Authority will hire an ARFF fire chief and facility captains as soon as possible, but no later than March 31, 2014.
    • The Port Authority will submit a curriculum for training to the FAA on or before December 31, 2013, which includes at least 75 hours of initial ARFF training and 40 hours of annual recurrent firefighting training in addition to Part 139 training, pertaining to an airport’s operational and safety standards and providing for such things as firefighting and rescue.
    • The ARFF personnel will work a 12-hour shift.
    • The Port Authority will amend the airport certification manuals for the four airports to include: an organizational chart; a process to maintain ARFF training records; and a description of ARFF operations, including shift assignments, personnel training records management, and Department of Aviation oversight.
    • The Port Authority will conduct monthly internal audits of ARFF training and shift assignments and annual external audits to ensure that all ARFF personnel assigned to a shift are trained.

    “We expect the Port Authority to have trained safety personnel to ensure the safety of the travelling public and airport personnel, just like we have at all airports in the United States,” said FAA Administrator Michael P. Huerta.

    The FAA became aware of ARFF violations as a result of an annual airport certification safety inspection of JFK in December 2011. The FAA also discovered similar violations at Teterboro, which prompted a full review of training at LaGuardia, Newark Liberty International, and Stewart International Airports. The review of ARFF training revealed violations at LaGuardia and Newark, with no violations at Stewart.

    The FAA believes the settlement agreement provides the best long-term solution to ensure ARFF compliance, given the systemic nature of the PANYNJ airport problems.

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    Nigeria working toward ICAO Standard

    Long known for substandard aviation, changes seem to be in Nigeria’s future.

    Nigeria’s airports are slated to be revamped to meet international standards according to Stella Oduah, Minister of Aviation. Safety and security are intended to be the new priority, as they aim for “zero” accidents.

    Infrastructure and services are also slated to be improved.

    The ICAO’s AFI plan is part of the Third Pan-African Aviation Training Coordination Conference.

    The conference is organized by the ICAO Comprehensive Regional Implementation Plan for Aviation Safety in Africa (AFI Plan) in cooperation with the aviation regional organizations in the AFI Region, and hosted by the Government of South Africa will be held in Cape Town, South Africa from 27 to 29 July 2011.

    The agenda for the conference is here.

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  • Airworthiness Directive: Life

    In an aviation disaster, what happened is never a true mystery. A true mystery is something that baffles understanding and cannot be explained. We know there’s an explanation. We know something tangible happened. There is a tangible explanation. We just don’t know what it is. What happened. Or in what sequence. Or if one or two of the events in the sequence didn’t happen, could the disaster have been prevented.

    Most aviation disasters live in a realm of tragic mystery. We are always walking around, picking up the pieces of the puzzle. In fact, there are usually few pieces of evidence to pick up–and the ones we do find crumble in our hands, or they’re inexplicable or perplexing. So when we put the puzzle pieces together, they may fit a multiplicity of ways. There may be huge gaps. Or there may be no way at all to fit together the disparate elements. Oh, sure, we come up with a thousand theories–perhaps a different theory for each time we consider, each time we try to take another perspective, each time we speak to another expert. These experts agree; those experts disagree. Perplexing, an enigma, a riddle the answer of which remains forever out of reach. The alleged mystery—the answered question— remains, all the more tantalizing because we know there is an answer.

    As troubling as it is for those of us who look for the answer to “how” it happened, families struggle with fathomless questions a thousand times harder to deal with: why my loved one? Of all the thousands of trips, why this particular flight, why this particular plane, why this January, why this Monday?

    Families play the questions back in their heads, rewind their lives and replay the events as if somehow in the thinking of it, they could reach back through time, stop their loved one from boarding that plane, or otherwise change a single factor–make the pilot leave his phone behind. Make the mechanic give that lug nut an extra turn. Bless that plane designer—or the parts designer—with something extra so that on that long ago day when he came up that design, it was flawless. The thing that if it had been done just a little differently, would have kept the tragedy from ever happening. That magic something that could undo what has been done with such conclusive finality. As if the moment could be rewound as in a movie, and come out differently. These are the questions which are beyond inscrutable, profound questions heavy with the weight of life, of love wrenched away before its time.

    The answer may be elusive.

    But there’s always rigid hard reality behind a crash. There’s always an actual sequence of events that instigated the tragic event.

    So any time I see an airline being proactive, I think of lives that will be saved.

    Alaska Airlines begun inspecting their 14 Boeing 737 jetliners because of the emergency airworthiness directive issued Friday. Severe vibration occurred in some European flights was due to “lug failure on an elevator control mechanism. The elevator controls the plane’s pitch.”

    There are mysteries hanging about 737s such as ITEK & PERM and recently Ethiopia. In the first two it was determined that it was human error.

    I have always believed that pilot error alone will not bring down a plane.

    This vibration opens a whole new window of possibility of answers to our unanswerable questions. In some of these past crashes where we have not found the answers, is it possible these tragic flights encountered turbulence which was exacerbated by this vibration? Could this flaw have been instrumental in the Aeroflot-Nord B735 crash at Perm on Sep 14th 2008? or to Itek Air B732 at Bishkek on Aug 24th 2008? Or more recently, to Ethiopian Airlines B738 in the Mediterranean Sea on Jan 25th 2010?

    So I am glad to hear that Alaska Airlines begun inspecting their 14 Boeing 737 jetliners. I am glad to hear that Alaska Airlines is committed to safety. They should be commended for wasting no time in ordering an inspection.

    If only all carriers were so diligent, there might be fewer grieving families. And that wouldn’t be a bad thing, would it?

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