2.3.5  It is widely accepted in research literature that long hours of work are a key cause of fatigue.

2.3.6  The third key cause of fatigue is the amount and quality of rest before work. Studies by the US Army Medical Corp indicate that anything less than 8 to 9 hours of sleep per night leads to degraded work performance over time. Moreover, the longer a person suffers from restricted sleep, the longer it takes them to recover even when given optimal conditions for sleep.

2.3.7  The time of day at which people seek to sleep is also an important factor in fatigue. Research shows that daytime sleep is not as effective as night sleep and is shorter in duration, even if more time for sleep is available. The best and most recuperative sleep is that which starts at around 9 pm. The worst sleep is sleep initiated in the afternoon.

2.3.8  There is also a body of evidence indicating that working at night is related to a reduction in sleep during time off duty, accumulated sleep debt and a corresponding decline in performance. This is a disturbing finding, as many workers in the transport industry regularly work at night.

2.3.9  Shift work rosters do, of course, provide for time off-duty to allow for rest and sleep. However, it can be extremely difficult to obtain sufficient rest during daylight hours. Professor Dawson notes that:

…as the amount of night work increases, so does the amount of sleep that must be attempted at biologically inappropriate times. Sleeping “out of sync” with the body’s biological clock, results in reduced duration and quality of sleep. This in turn reduces the restorative value of the sleep obtained.

2.3.10  Other factors can also influence the effectiveness of rest sought at these times, such as:

• environmental factors (such as higher levels of ambient noise and higher temperatures during the day); and
• the need to fulfil family and personal commitments.

2.3.11  Workers who are “on-call” during off-duty times can find that their opportunities for rest are disrupted significantly.

2.3.12  Many argue that not only are the three causes of fatigue (long hours of work, night work and the lack of restorative sleep) ever present in the transport industry, they are exacerbated by other factors common in the industry, such as:

• insufficient staff numbers;
• poor rostering practices;
• poor work scheduling;
• methods and rates of pay that induce employees to work longer hours;
• commercial pressures on companies that are passed on to employees;
• regulatory requirements, which compel or allow fatigue inducing practices;

• work related stress;
• environmental factors in the workplace.

2.3.13  Any fatigued person will exhibit the same problems:

• sleepiness, difficulty concentrating, apathy, feeling of isolation, annoyance, increased reaction time to stimulus, slowing of higher-level mental functioning, decreased vigilance, memory problems, task fixation, and increased errors while performing tasks.

2.3.14  None of these are good things to happen to an ATCO, much less if there is no one else to help out. In a variety of studies, fatigued individuals consistently underreported how tired they really were, as measured by physiologic parameters. A tired individual truly does not realize the extent of actual impairment. No degree of experience, motivation, medication, coffee, or will power can overcome fatigue.

2.4 Air traffic controllers and fatigue

2.4.1  Poorly managed fatigue in the provision of air traffic control services can represent a significant threat to public safety, it is inappropriate that hours of work for air traffic controllers be a matter for industrial negotiation. Hours of work for air traffic controllers should be regulated in the same manner as hours of duty for flight crew are regulated.

2.4.2  Service providers however, seem disinclined to vary the current arrangements, preferring to “take a broad, less prescriptive approach to managing fatigue”. They cite, in support of their position, the situation in the United Kingdom whereby the UK air traffic control authority has to continually issue dispensations to their strict regulations due to the lack of flexibility in the system.

2.4.3  That said, legislative bodies do have a clear responsibility for protecting the safety of third parties.

2.4.4  The risk of allowing hours of work to be settled solely in the industrial negotiations arena is that safety and hours of rest can be bargained away. Some employers may believe, falsely, that longer hours and more night shifts always represents better productivity and some employees can be tempted by the prospect of more money to do more work.

2.4.5  The development of this new regulatory environment is a crucially important task, with profound consequences for aviation safety.

2.4.6  PLC also thinks it appropriate that ANSPs take action to ensure that, in the interim, they manage their fatigue risk more effectively.

2.4.7  Regulators should test the ANSPs’ shift rosters for their current staff against one of the fatigue management models that are currently available. Unfortunately it is extremely difficult to obtain a reputable model as most models are developed in conjunction with the ANSP or employer and seem to favour the ANSP or employer and not the employee.

2.4.8  Prescriptive legislation will continue to have a place in the industry for some time yet. The advantages of a legislative approach are that the rules can be clearly described, they apply uniformly across the industry or across particular parts of the industry and they provide a basis for consistent enforcement action. In an area where concerns about personal and public safety are growing, legislated rules provide a high degree of certainty and confidence.

2.10 The impact of fatigue

2.10.1  During Operation Desert Storm the United States Air Force observed that cumulative fatigue in C-5 air transport flight crews resulted in the fumbling of radio frequency changes, slowed reaction times, impaired judgment, diminished checklist discipline, decreased aircrew coordination and increased irritability, unfortunately there are not indebt studies on ATCOs like there is on pilots. In some situations, fatigue induced mistakes may be inconsequential, creating minor delays in completing a task or rectified by failsafe systems. In other situations, the risks of damage to equipment, of personal injury and to public safety can be far greater. The costs of badly managed fatigue can be catastrophic: for companies, for individuals and for the community.

2.10.2  While the causes of fatigue in the transport industry are plain (time of day, hours of work and inadequate rest), fatigue presents itself as a multifaceted problem requiring sophisticated management. It is not just a matter of limiting hours of work (although this is often part of an appropriate response to fatigue), but is a matter of ensuring that rostering arrangements are sensitive to optimal time of work and time of rest considerations. It is a matter of shared responsibility and proper regulation: employers establishing safe working environments and practices; employees presenting themselves in a fit state for duty.

2.10.3  Many of the approaches that have been taken to fatigue management to date recognise and respond to one or other of these matters. Very few tackle all of them successfully.

2.10.4  PLC is of the opinion that the challenge facing Regulators now is to fill in the gaps (in the areas of research and education); and select good practice from bad (promoting the former and dispensing with the latter).

2.11 Antidote to Fatigue

2.11.1  Obtaining adequate sleep is the best way to prevent or resolve fatigue. Sleep provides the body with a period of rest and recuperation. Insufficient sleep will result in significant physical and psychological problems. On average, a healthy adult does best with eight hours of uninterrupted sleep, but significant personal variations occur. For example, increasing sleep difficulties occur as we age, with significant shortening of nighttime sleep.

2.11.2  A variety of medical conditions can influence the quality and duration of sleep. To name a few: sleep apnoea, restless leg syndrome, certain medications, depression, stress, insomnia, and chronic pain.

2.11.3  Some of the more common social or behavioural issues are: late-night activities, excessive alcohol or caffeine use, travel, interpersonal strife, uncomfortable or unfamiliar surroundings, and shift work.

2.12 Prevention

2.12.1 No one is immune from fatigue. Yet, in our society, establishing widespread preventive measures to combat fatigue is often a very difficult goal to achieve. Individuals, as well as organizations, often ignore the problem until an accident occurs.

2.12.2 Even then, implementing lasting change is not guaranteed. Lifestyle changes are not easy for individuals, particularly if that person isn’t in complete control of the condition. For example, air traffic controllers and pilots must contend with shift work and circadian rhythm disruption. Often, they also choose to commute long distances to work, so that by the time a work cycle starts they have already travelled for some time.

2.13 Lifestyle Recommendations for a goodnights sleep

2.13.1  Don’t…

• Consume alcohol or caffeine 3-4 hours before going to bed.
• Eat a heavy meal just before bedtime.
• Exercise 2-3 hours before bedtime. While working out promotes a healthy lifestyle, it shouldn’t be done too close to bedtime.
• Use sleeping pills (prescription or otherwise).

2.13.2  Do…

• Be mindful of the side effects of certain medications, even over the- counter medications – drowsiness or impaired alertness is a concern.
• Consult a physician to diagnose and treat any medical conditions causing sleep problems.
• Create a comfortable sleep environment at home. Adjust heating and cooling as needed. Get a comfortable mattress.
• When travelling, select hotels that provides a comfortable environment.
• Get into the habit of sleeping eight hours per night. When needed, and if possible, nap during the day, but limit the nap to less than 30 minutes. Longer naps produce sleep inertia, which is counterproductive.
• Try to turn in at the same time each day. This establishes a routine and helps you fall asleep quicker.
• If you can’t fall asleep within 30 minutes of going to bed, get up and try an activity that helps induce sleep (watch non-violent TV, read, listen to relaxing music, etc).
• Get plenty of rest and minimize stress before a shift. If problems preclude a good night’s sleep, rethink the shift and postpone it accordingly if it can be accommodated.

2.14 Fatigue and the law

2.14.1 A key aspect of this is the “increasing” desire of different legislatures to shift liability for breach of those regulations from individuals to their employers. Although legal approaches to the issue of fatigue are still evolving it is clear that there is a move away from a sole focus on the individual to a more inclusive approach that considers the legal responsibility of other players such as managers, executives and company owners. Good regulations should be enforced at all times by the regulator to ensure compliance.

3.1 Defining fatigue in humans is extremely difficult and there are various influences that act as stressors in humans causing fatigue. PLC defines fatigue in Air Traffic Control as:

“Fatigue is a condition characterized by increased discomfort with lessened capacity for work, reduced efficiency of accomplishment, loss of power or capacity to respond to stimulation, and is not necessarily accompanied by a feeling of weariness and tiredness.”

(Federal Aviation Administration, “Fatigue in Aviation”)

3.2  In recent years the aviation community became more aware of fatigue and its relation to incidents / accidents. As a consequence, there is greater pressure to regulate hours of service as a means to reduce the likelihood and consequence of fatigue related incidents or accidents.

3.3  There is a significant amount of published literature on the subjective, neurobehavioral and electrophysiological effects of sleep loss over a single or multiple nights. It can be extrapolated from this data to conclude that it is unlikely that prior to commencing work an individual obtaining less than the required sleep is likely to be unimpaired at a level consistent with a safe system of work. Caution should be taken as in Air Traffic Control the occupational tasks may well be more susceptible to fatigue-related error or the consequences of fatigue-related error are so severe it requires the ATCO to be very vigilant.

3.4  IFATCA has policy regarding Fatigue in Air Traffic Control, Work and Rest Scheme, Vacation Scheme and Duty Roster. Present policy does not address fatigue management systems with respect to the role of the regulator / legislator.

4.1 It is recommended to insert on Page 4227 of the TP Manual:

Fatigue Management Systems

4.1. The Regulator / Legislator should:

• develop comprehensive hours of duty regulations for air traffic controllers, incorporating fatigue management principles;
• require all air traffic service providers to maintain auditable fatigue management systems.

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