Last week's National Transportation Safety Board hearing into the August crash of a UPS cargo plane in Alabama revealed that the pilots were extremely fatigued
during the flight, but the independent agency hasn't made any determinations about the cause, and UPS is cautioning about any rush to judgement that its policies were too lax.
Crew rest is a shared responsibility and "overnight workers must pay special attention to their rest regimen," UPS Airlines spokesman Mike Mangeot said in an email to American Shipper
The Federal Aviation Administration recently stiffened hours-of-service rules for passenger airline pilots, but the rules were not in effect yet at the time of the UPS accident, and they don't apply to pilots of all-cargo planes because the agency determined the costs outweighed the societal benefit. Cargo airlines can adopt the new standard if they choose.
The rulemaking particularly addressed the cumulative fatigue caused by repeatedly flying at night. FAA studies show that pilot performance substantially deteriorates after the third consecutive nighttime flight duty period.
UPS takes many steps to build rest into its crewmembers' schedules, Mangeot said. A typical UPS pilot is on duty 70 hours per month and actually flies about 30 hours per month, well within FAA limits. The airline's maximum domestic scheduled duty day is 13.5 hours, well inside the FAA's 16-hour limit, and UPS pilots are provided with up to 50-percent longer rest periods than required by FAA regulations, he said.
"UPS policies emphasize the importance of proper rest, whether they are on or off duty. In fact, a crewmember has an obligation under regulations and UPS policy to report to work rested and fit for duty. If for some reason a pilot is not able to obtain proper rest and determines he, or she, is unfit to safely operate a flight by FAA regulation and UPS policy, each has an obligation to disqualify him- or herself from duty," Mangeot said.
The UPS crew's scheduled duty days also complied with the recently-enacted passenger crew rest rules, and both the captain and first officer came off extended time off, according to the NTSB docket. The captain had been off for eight days before beginning the trip, and the first officer had flown just two of the previous 10 days, Mangeot pointed out.
Both pilots were on the second day of their trip that week. The captain’s duty period the first day was 3.5 hours. The first officer’s was 9.5 hours. Their second, and final, duty day reached eight hours, 11 minutes at the time of the accident. Less than three of those hours were spent actually flying. More than two hours between the two flights were spent in UPS sleep rooms.
The sleep rooms, Mangeot said, are an example of how UPS exceeds regulatory requirements to ensure proper rest. Other examples include reviewing schedules with the Independent Pilots Association and working with a sleep scientist.
However, the Independent Pilots Association, the dedicated union for UPS' 2,600 pilots, has fought to get cargo pilots included in the FAA's anti-fatigue regulation.
UPS also has an active Fatigue Risk Management Program, as required by the FAA since 2010, to help spot potential fatigue in pilots, Mangeot said.
"UPS has had overnight operations since it was founded over 100 years ago. Today, thousands of employees around the world work nighttime hours as a matter of routine business. In 26 years as an airline, we have operated more than 7.6 million hours, the bulk of them during night hours," he said.
"Proper rest comes down to shared responsibility. UPS provides for proper rest opportunities, and our pilots are expected to follow a rest regimen that enables them to report fit for duty," Mangeot said.