National Flight Attendant Duty/Rest/Fatigue Survey

BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, D.C.

------In the matter of : : Request for Comments, : National Flight Attendant : Duty/Rest/Fatigue Survey : ------

COMMENTS IN RESPONSE TO SURVEY NOTICE

The Air Transport Association of America, Inc. (“ATA”),1 on behalf of its airline members respectfully offers the following comments on FAA’s National Flight Attendant Duty/Rest/Fatigue Survey (FA Survey).2 The proposed FA Survey does not meet OMB requirements because it is not necessary for the proper performance of the functions of the Department, the information obtained will not have practical utility, and the survey will not add to the FAA’s efforts to define, enact, and support policies and practices that effectively manage fatigue in aviation operations.3 These conclusions are based on three considerations: 1) the proposed survey will not add practical information to existing knowledge, 2), extensive information already exists on fatigue in aviation and 3) the Federal Register notice does not adequately describe the FAA proposal.

I. The proposed survey will not add practical information to existing knowledge. A Committee on Appropriations House Report accompanying the 2005 Departments of Transportation and Treasury and Independent Agencies Appropriations Act4 (“TTIAA”) included a directive to the FAA to conduct a study of flight attendant fatigue. Specifically, the Committee expressed concern about “FAA minimum crew rest regulations that may not allow adequate rest time for flight attendants.” Issues related to reduced rest were identified and it was requested that the report include “recommendations on potential regulatory revisions.”

To address this directive, FAA representatives from Civil Aerospace Medical Institute (CAMI) engaged the NASA Ames Fatigue Countermeasures Group to perform an

1 ATA is the principal trade and service organization of the major scheduled air carriers in the United States. ATA airline members are: ABX Air, Inc.; AirTran Airways; Alaska Airlines, Inc.; Aloha Airlines; American Airlines, Inc.; ASTAR Air Cargo, Inc.; Atlas Air, Inc.; Continental Airlines, Inc.; Delta Air Lines, Inc.; Evergreen International Airlines, Inc.; Federal Express Corporation; Hawaiian Airlines; JetBlue Airways Corp.; Midwest Airlines, Inc.; Northwest Airlines, Inc.; Southwest Airlines Co.; United Airlines, Inc.; UPS Airlines; and US Airways, Inc. ATA Airline Associate Members are: Air Canada, Air Jamaica Ltd. and Mexicana.

2 73 FR 15042, March 20, 2008. 3 See 5 CFR 1320.8(d). 4 See House Report 108-671, September 8, 2004.

evaluation of flight attendant fatigue issues. In July 2007, the outcome of this evaluation was a NASA Technical Report (DOT FAA AM-07 21) published on Flight Attendant Fatigue. It includes a literature review, examination of schedules, identifies incident reports and provides six recommendations for continued research to address the topic of flight attendant fatigue. The first recommendation is for “A scientifically-based, randomly-selected flight attendant Survey of Field Operations.” The proposed FA Survey appears to be based directly on this first recommendation in the NASA Technical Report.

If the intent of the proposed FA Survey is to address the TTIAA directive related to minimum crew rest regulations, reduced rest and potential regulatory revisions, then it clearly does not meet this objective. Just the fact that the proposed FA Survey represents self-reported, subjective data eliminates its utility to address the regulatory issues in question. The proposed FA Survey involves 12,000 respondents annually (though unclear for how many years) and apparently would include a broad range of questions given the broad goals stated. While a properly designed survey could provide an array of perceptions broadly describing flight attendant fatigue, due to the retrospective, self- reporting nature of surveys it could not address the TTIAA directive.

At a minimum, addressing this directive requires a comparison of scheduled flight/duty periods with actual flight/duty logbooks and hard data. The use of actigraphs (wrist worn device that provides estimates of sleep quantity and quality) would provide some objective sleep data to see the effects of schedules. A challenge for any such study is defining a range of considerations related to number of participants, flight schedules, number of flights studied, duties, duty/off-duty cycles, etc. and the ability to generalize findings to the diverse operating environments where flight attendants currently work.

The TTIAA directive also questions the need for regulatory revisions. Therefore, the design and outcomes of any effort should include a clear path from study findings to an evaluation of whether further regulatory action is needed or warranted.

Finally, the NASA Technical Report includes a literature review of fatigue in aviation, flight attendant specific issues, and extrapolation of pilot data. Given the extensive knowledge base that exists already, as demonstrated by the NASA review, the proposed FA Survey will not add information to the existing knowledge base and the notice fails to explain why this is not the case. Because the proposed method to study flight attendant fatigue would include solely subjective perceptions of fatigue and not an examination of hard objective data, this survey will not provide practical or useful information.

II. Extensive information already exists on fatigue in aviation As OMB advises, an agency considering a survey should conduct “A review of related studies, surveys, and reports of Federal and non-Federal sources to ensure that part or all of the survey would not unnecessarily duplicate available data from an existing source…”5 The question of whether fatigue represents a relevant safety issue in aviation has been considered and examined for decades, with scientific and physiological study of

5 Office of Management and Budget, Standards and Guidelines for Statistical Surveys, September 2006, page 5.

fatigue for at least 30 years. The FAA has conducted and funded an extensive array of projects, including efforts through the CAMI, NASA, and a variety of other supported organizations. In 1980, a Congressional request was the basis for NASA to initiate a Fatigue/Jet Lag Program to examine the issue of whether fatigue was a safety concern in aviation operations. For 25 years, NASA examined diverse flight environments, collected data from over 500 pilots in field studies and thousands of others in survey projects, and based on findings created educational materials and workshops, accident investigation approaches to examine fatigue factors, policy input with Principles and Guidelines documents, and showed the effectiveness of fatigue countermeasures to increase alertness and performance in flight operations. Internationally, efforts to examine fatigue in flight operations have included major activities globally, including in the United Kingdom, Germany, Sweden, Netherlands, Japan, Singapore, New Zealand, Australia, Ireland, Canada, and more.

These 30-plus years of activity have involved a broad range of projects that have included pilots, flight attendants, air traffic controllers, and mechanics across the diverse array of operational activities in aviation. For example, studies have examined short haul, long haul, ultra-long-range, overnight cargo, and other operations in both fixed-wing and rotorcraft environments. These projects have employed diverse methodologies and measures, including surveys, logbooks, sleep diaries, physiological (e.g., brainwave, eye movement, core body temperature), and performance (pilot and aircraft) outcomes. These activities have created an extensive scientific foundation to understand fatigue in aviation operations, including policies and practices that can reduce fatigue and enhance sleep, performance, and alertness.

There are almost 40,000 publications related to fatigue in aviation. A search of flight attendants and fatigue identifies 14,800 related publications. This is just one measure of the extensive scientific foundation that already exists related to fatigue in aviation. This large number of publications is a reflection of the diverse operational environments studied, the different groups that have participated (i.e., pilots, flight attendants, air traffic controllers, mechanics), and include a wide range of measures for outcomes. Regardless of the actual participants or measures in specific studies, the findings can be generalized and applied to the human operators in aviation, whether pilots, flight attendants, air traffic controllers or mechanics. The outcomes related to sleep and circadian disruption, performance decrements, and safety issues can be understood in the context of the human operators’ physiological design and generalized across people, settings, and demands.

Therefore, this proposed survey does not comply with OMB guidance because the broad goals identified for the FA Survey (i.e., type of fatigue experienced, frequency, and safety consequences) can be addressed by the extensive, existing scientific and operational information already available.

III. The request does not meet OMB guidance OMB regulations recommend that an agency provide the public with “…a copy of the proposed collection of information, together with the related instructions…”6 If this information is not provided, OMB recommends more than a 60-day comment period and

6 5 CFR 1320.8(d)(2).

how the public can gain access to the proposed collection of information and related instructions.7 The published request provides only one paragraph of description and a copy of the proposal and related instructions are not included in the request. We therefore respectfully request the FAA to provide, at a minimum, a more complete description of the proposal and we also recommend access to the collection proposal on FAA’s website, so the public will have an opportunity to review and comment.

The current proposed FA Survey does not request practical or useful information because it seeks subjective perceptions instead of hard data. While such information may provide interesting insights, on its own it will not provide the kind of data to address questions about fatigue in a scientific manner. The FA Survey also does not acknowledge the extensive scientific foundation that already exists or address the original Appropriations Bill directive. Finally, the FAA Federal Register notice does not provide a description to allow pubic comment. For all of these reasons, ATA respectfully requests the FAA provide additional information on the information it seeks to collect and additional time to comment.

Respectfully submitted,

David A. Berg Vice President & General Counsel AIR TRANSPORT ASSOCIATION OF AMERICA, INC.

May 19, 2008

7 5 CFR 1320.8(d)(2)(i) & (ii).