New Prescriptive limit in and its background

ALL NIPPON AIRWAYS Capt. Kazuhiko Matsumoto Masato Nagai

1st October 2019, FRMS Forum Conference in San Francisco 1 Executive Summary Japanese Authority/JCAB set New Prescriptive Limit Some contents is very unique.

New Limit for 3 pilots is FTL to 15h FDP to 17h with Class 1 rest facility

We shear the background of the limit

1st October 2019, FRMS Forum Conference in San Francisco 2 CONTENTS 1.Who is ? 2.Geopolitical Position of Japan 3.New Prescriptive limit in Japan 4.FRM Steps in Japan 5.Background - Working Group & Reference Information - Fatigue Survey - Result of Survey 6.At the End 7.Reference

1st October 2019, FRMS Forum Conference in San Francisco 3 Who is All Nippon Airways / ANA ? Biggest Airline in Japan, The launch customer of Boeing 787 ANA brand is operated by ANA, Air Japan/AJX and ANA Wings/AKX OPERATION Domestic + International : about 1,000/day PILOTS : about 2,800

NUMBER OF AIRCRAFT ： about 270

B777-200/200ER B787-8/9 ANA&AJX B767-300/300ER/300F B737-700/800 /300/300ER ANA&AJX ANA&AKX

A380 B737-500 AKX

A320/321 DHC8-400(Q400） AKX

1st October 2019, FRMS Forum Conference in San Francisco 4 Geopolitical Position of Japan ANA Brand Operation from

⇒ Jet Stream ⇒ ⇒ Jet Stream ⇒

To Europe : 11~13hs in Head Jet Stream (3 pilots) To India : 8~10.5hs in Head Jet Stream (2~3 pilots) From N America : 10~14.5hs in Head Jet Stream (2~3 pilots) From Hawaii : 8~10hs in Head Jet Stream (2 pilots) E/SE Asia & Oceania : 5~9.5hs Midnight Flight & 9hs round trip duty Domestic : 4 LDG in Typhoon & Severe Winter Operation 1st October 2019, FRMS Forum Conference in San Francisco 5 New Prescriptive limit in Japan Current New Domestic FTL 2 Starting time of duty To 2 LEG From 3LEG up to 8h pilots 0500-1659 10h 9h International up to 12h 1700-0459 9h 8h 3 Over 12h Limit to 15h pilots *Need appropriate rest facility *Over 13h, need Class 1 rest facility *Not continuous duty in cockpit over 8h 4 Limit to 17h pilots *Need appropriate rest facility *not continuous duty in cockpit over 8h Total FTL 100h in 1 month* 100h in any 28 consecutive days 270h in 3 month* 1,000h in any 365 consecutive days 1,000h in 1 year* *:Calendar month or year

1st October 2019, FRMS Forum Conference in San Francisco 6 New Prescriptive limit in Japan Current New FDP 2 NIL 9h~13h depend on start of FDP and sectors Pilots Start of FDP 1-2 3 4 5 6 7 8 9 10 0000-0459 11 10.5 10 9.5 9 9 9 9 9 0500-0559 12 11.5 11 10.5 10 9.5 9 9 9 0600-1359 13 12.5 12 11.5 11 10.5 10 9.5 9 1400-1559 12 11.5 11 10.5 10 9.5 9 9 9 1600-2359 11 10.5 10 9.5 9 9 9 9 9 3 14h~18h depend on Pilots number, sectors and Class of rest facility Pilots Class 1 Class 2 Class 3 Sector 1-2 3 Pilots 17 16 15 4 4 Pilots 18 17 16 Pilots Sector 3- 3 Pilots 16 15 14 4 Pilots 17 16 15 Total FDP NIL 60h in any 7 consecutive days 190h in any 28 consecutive days

1st October 2019, FRMS Forum Conference in San Francisco 7 New Prescriptive limit in Japan Current New REST Interval NIL Minimum 10h (Sleep opportunity 8h) Add rest after WOCL flight duty Add rest after time zone difference flight duty (Away and Home) Periodical 1 calendar day 36h including 2 nights in every 136h off in 7 If at or over 4 times WOCL flight duty in 7days, add Calendar days more rest time th OtherIssue Acclimate: 4 JUL 2019 NIL Depend on Time difference and Time elapsed Effect : 1st OCT 2019 * since reporting * : EffectiveStandby date willNIL be extend to endStandby of 2021, at appropriate rest facility, if the airline report appropriate availabilityimplementation period 14hplan and to JCAB. Total hour limit of availability & flight duty period FDP + 4 h or 16h for 2 pilots and 16h for for 3&4 pilots Unforeseen No time Limit, FLT limit over only after takeoff (need reporting to condition, but need authority) commander’s appropriate FDP limit + 2h for 2pilots, +3h for 3&4 pilots (need discretion additional rest reporting to authority, when over +1h)

1st October 2019, FRMS Forum Conference in San Francisco 8 FRM Steps in Japan 1992 Current Limit was effected, based on FAA regulation, but using fatigue blood test in actual flight, etc. 2011- The survey was conducted by working group for catching up global 2016 development of FRM The WG was consisting of authority and airlines in Association of Air Transport Engineering and Research / ATEC. 2017 FRM for pilots in SMS was issued and effective Phase - 1 Fatigue Call is clearly describe in each company OM FRM concept in SMS is - FRM education for pilots, scheduling staff and Executive common basic education material in Japan - Fatigue report and risk management procedure 2018 JCAB Working Group for new Prescriptive limit and fatigue survey. 2019 New Prescriptive Limit was issued at 4th JUL 2019, Phase - 2 Effect at 1st OCT 2019. As transition phase, operator must be applied by the end of 2021 at the latest, reporting appropriate implementation plan to JCAB. 1st October 2019, FRMS Forum Conference in San Francisco 9 Background – Working group JCAB Working Group - Medical Doctor / Aviation Medicine - ex Pilot / Director of Japan Aircraft Pilot Association - Doctor / Safety Information - Specialist / Fatigue Science - Medical Doctor / Sleep Science Reference information for WG - ICAO Doc 9966 2nd Ed. - Prescriptive limit in other country, especially FAA, EASA, CASA, CAA - Background reference study paper of FAA, EASA prescriptive limit - Fatigue reports gathering in each airlines. - Hearing from ALPA Japan and The Scheduled airlines Association of JAPAN - Fatigue Survey

1st October 2019, FRMS Forum Conference in San Francisco 10 Background – Fatigue Survey Purpose of the Survey For reference information of working group, focus to the difference point of current JCAB standard rather than FAA/EASA Item (2 pilots and 3 pilots) 1. Continuous flight hours (2 & 3 pilots) 2. WOCL (2 & 3 pilots) 3. Number of Segment (2 pilots)

In order to eliminate as much as possible the influence of factors other than the target items, the conditions are limited for selection of the targets flights. Method Follow the methods recommended by ICAO DOC 9966

1st October 2019, FRMS Forum Conference in San Francisco 11 Background – Fatigue Survey Conditions - Reporting time - Home / Away （If Away, interval in local) For one segment Cruise - Survey Pilot (Need Motivation) : PIC Climb Descent - Home in Japan Start Measurement End Measurement - Survey 3-5 times for each For multi segments - Well learned about survey and PVT-192 End - Measurement Start Measurement Measurement - Timing : Before departure briefing and just after block in cockpit - Location : Rooms with less disturbing - Tool : PVT – 192 (5mins) and Samn-Perelli/SP Checklist - Observer : Need a learned person who support, observe and record - Record : Measurement Condition, Disturbing factor, Signs of Fatigue, 72 hours Sleep Log, Commute, Any other fatigue factor, etc - Size of survey flight 15 flights or pattern for each survey subdivision Total 270 flights/pattern (15 flights/pattern x 18 subdivision) ,9 Airlines

1st October 2019, FRMS Forum Conference in San Francisco 12 Background – Fatigue Survey Method of analysis - Method is based on advise from specialist in Working Group - If delay over 1h, eliminate form database - PVT-192 - △PVT (%)= Mean Reaction Time at End / Mean RT at Start - Mean and deviation △PVT for comparison each subdivision - Statistical evaluation - Samn-Perelli - △SP = SP at End – SP at Start - Deviation of △SP for comparison each subdivision - Statistical evaluation

1st October 2019, FRMS Forum Conference in San Francisco 13 Background – Result of Fatigue Survey 1A. Continuous flight hours (2 & 3 pilots) from Home（Japan） ・Reporting at 0700-1159 at Japan ・Flight hours 5, 7, 8, 9, 10h for 2 pilots, 10, 11h for 3 pilots

Flight hours vs △PVT 2 pilots Flight hours vs △SP 3 pilots

Ave JST time of measurement at end

Ave time of measurement at start 5h 7h 8h 9h 10h 10h 11h 5h 7h 8h 9h 10h 10h 11h Flight Hours 2pilots --> <-- 3 pilots 2pilots --> <-- 3 pilots

Fig-1 Flight hours vs △PVT Fig 2 Each value of △PVT Result ・△PVT and △SP tended to increase with increasing flight hours. ・Fatigue level for 3 pilots is better than 2 pilots. It seems the effect on inflight rest.

1st October 2019, FRMS Forum Conference in San Francisco 14 Background – Result of Fatigue Survey 1B. Continuous flight hours (3 pilots) from Away（North America） ・Reporting at 0700-1159 at LCL time ・Time zone difference 7h to 10h from Japan ・Pilots stay at LCL 36h to 48h ・Flight hours 12, 13, 14h for 3 pilots (RMKS 14h : only winter from North America) Flight hours vs △SP Flight hours vs △PVT △PVT(%)

Ave time of measurement at end

Ave JST time of measurement at start 12h 13h 14h 12h 13h 14h Flight Hours △ Fig-4 Flight hours vs △PVT 3pilots Fig 5 Each value of △PVT 2pilots Fig-6 Flight hours vs SP Result ・The relationship between flight hours and △PVT /△SP could not be confirmed ・It seems that pilots fatigue is recovered in all of surveyed flights, - In-flight rest facility is class 1 - Pilots duty in cockpit seat is not so long due to rest pattern.

1st October 2019, FRMS Forum Conference in San Francisco 15 Background – Result of Fatigue Survey Unique point of Japanese 3 pilots operations ・CAP x 2 + COP x 1 ・6 divisions in-flight rest time almost equal total time even for rookie COP ・Class -1 Rest Facility especially Europe and North America route

12h from Away 13h from Away 14h from Away 11h from Home 11h from Home 12h from Home

Rest Rest CAP1

Rest Rest CAP2

Rest Rest COP

Actual Flight hours Rate of TTL inflight Sleep time / TTL inflight Rest time inflightRest / TTL time Sleep TTLof inflight Rate Fig : Example of 6 divisions in-flight rest Fig : Rate of TTL Sleep time inflight rest / TTL inflgiht rest time vs Flight hours Flight hour is 13hours (Taxi out &in 45mins) From the hearing document of The Scheduled airlines Association of JAPAN (3 pilots inflight sleep log survey data of ANA and JAL) 1st October 2019, FRMS Forum Conference in San Francisco 16 Background – Result of Fatigue Survey 2. WOCL (2 & 3 pilots) from Home

WOCL vs △PVT WOCL vs △SP ・Flight hours 7h for 2pilots 11h for 3pilots Ave JST time of measurement at end ・WOCL（0200-0559JST) include Not, Partial, Full for 2pilots

Ave time of measurement at start NOT PARTICAL FULL Not, Partial for 3pilots NOT PARTICAL FULL WOCL include WOCL include

Fig-7 WOCL vs △PVT 2pilots Fig-8 WOCL vs △SP Result ・2 Pilots △PVT and △SP WOCL vs △PVT WOCL vs △SP tended to increase with increasing WOCL Ave JST time of measurement at end ・The relationship between WOCL and △PVT /△SP could not be confirmed It seems the effect on Ave time of measurement at start NOT PARTICAL NOT PARTICAL WOCL include WOCL include inflight rest.

Fig-9 WOCL vs △PVT 3 pilots Fig-10 WOCL vs △SP

1st October 2019, FRMS Forum Conference in San Francisco 17 Background – Result of Fatigue Survey 3. Number of Segment (2 pilots) from Home ・Reporting at 0700-1159 at Japan ・Total flight hours 5h

Number of Segment vs △PVT Number of Segment vs △SP

Ave JST time of measurement at end

Ave time of measurement at start Segment 1 2 3 4 5 6 Segment 1 2 3 4 5 6 Fig-11 Number of Segment vs △PVT Fig-12 Number of Segment vs △SP

Result ・△PVT and △SP tended to slightly increase with increasing number of segments. ・△PVT at 6 segments show big distribution.

1st October 2019, FRMS Forum Conference in San Francisco 18 Background – Result of Fatigue Survey Summary of Result

2 pilots 3 pilots 1. Continuous ・Fatigue Level is increase ・Fatigue level is better than flight hours with increasing flight 2 pilots operation hours. ・The relationship between flight hours and fatigue could not be confirmed 2. WOCL ・Fatigue Level is increase ・The relationship between with increasing WOCL WOCL hours and fatigue could hours. not be confirmed 3. Number of ・Fatigue Level is slightly － Segment increase with increasing number of segments.

1st October 2019, FRMS Forum Conference in San Francisco 19 At the end While referring to standards such as FAA and EASA, New Prescriptive limit in Japan is the standards that take into account the characteristics of operations in Japan.

⇒ Jet Stream ⇒ ⇒ Jet Stream ⇒

The result report of working group also mention about three important comment. 1st October 2019, FRMS Forum Conference in San Francisco 20 At the end 1. New prescriptive limit is minimum standard. For effective fatigue management, it is important Airline and Pilots shall act in FRM based on each responsibility.

2. There is still some issues about fatigue management in japan - Controlled Rest - Conditions for taking sleep medication - More flexible fatigue management standard fit for each operation, such as FRMS

3. Continues improvement of fatigue management standard in Japan - Fatigue is affected by all action from wakeup to sleep. There are many differences between individuals. And also there are many parts that have not yet been fully elucidated scientifically. - EASA still study continually after new standards is implemented.

1st October 2019, FRMS Forum Conference in San Francisco 21 Reference ・New Prescriptive limit in Japan New Circular (Japanese Language Only) http://www.mlit.go.jp/notice/noticedata/pdf/20190717/FS104-36.pdf

・Result report of Working Group (Japanese Language Only) Summary https://www.mlit.go.jp/common/001283206.pdf Full contents https://www.mlit.go.jp/common/001283350.pdf

・Contact Capt. Kazu Matsumo : [email protected] Masato Nagai : [email protected]

※This presentation will be shared by FRM Forum Member HP 1st October 2019, FRMS Forum Conference in San Francisco 22