Story ID: 
FAA Releases Part 135 Fatigue Recommendations
By: Kerry Lynch
Caption: The report, which suggests alertness management programs, was submitted to the agency 18 months ago.
Word Count: 345
The FAA recently released a 77-page report from a government/industry group recommending that the agency adopt an alertness management program (AMP) concept for Part 135 operations to protect against pilot fatigue. While not made public until this month, the report containing the recommendations of the Part 135 Pilot Duty and Rest Aviation Rulemaking Committee (ARC) was submitted to the FAA in July 2021.
Under the ARC concept, an AMP would provide for fatigue monitoring and mitigations to enable an operator to increase duty times and/or reduce rest times. The complexity of the program would depend on the type of operation, the ARC noted, but it said that for AMPs to be effective they must be comprehensive and enforceable and an advisory circular should be issued defining the requirements.
The ARC envisioned AMPs that could be scalable from single-pilot operators to increased levels that would include customized flight, duty, and rest limits. The AMP should be accepted by a principal operations inspector if it meets set criteria. For operators choosing not to adopt an AMP, the ARC recommended strengthened limits that are “deliberately more restrictive to avoid the potential for unmitigated fatigue but are sufficient for many operations that limit most operations to hours of the day.”
While unclear on whether the recommendations would be adopted, the FAA has included a flight, duty, and rest update as part of its list of future rulemakings. Also, in releasing the report, it noted that the agency “incorporated the ARC’s recommendations in the safety management systems notice of proposed rulemaking” that had been released the day before for on-demand and air tour operators, as well as manufacturers.
That proposal referenced the report and said that as part of a safety management program, “the identification of hazards through SMS may include analyzing the potential risk associated with crewmember fatigue when compounded by variations in individual [Part] 135 operations, such as scheduling variances, frequency of operations, distance, and number of pilots.”