UPS Guidelines regarding pilot rest and ground warning systems
The following information is from UPS Airlines Public Relation Manager Mike Mangeot:
Crew rest is a complex concept. And for some, it's easy to jump to the conclusion that a pilot who flies at night must be tired. It's also easy to presume that if they are tired, it's induced by their assigned work schedule. Neither is necessarily accurate.
First, it's important to understand that under FAA guidelines and UPS policy proper crew rest is a shared responsibility. Both the pilot and the company have obligations to ensure safety of flight.
UPS pilots are among the 4 million U.S. third shift workers. Overnight workers must pay special attention to their rest regimen. This includes workers adhering to proven techniques for rest, making good personal choices and being disciplined with their schedules.
From the employer perspective, UPS takes many steps to build rest into our crewmembers' schedules. Most notably, our pilots work reduced hours:
- A typical UPS pilot is on duty 70 hours per month.
- They actually fly less than half of that time, about 30 hours per month.
- Our duty days are well within FAA limits.
- Our maximum domestic scheduled duty day is 13 1/2 hours, well inside the FAA's 16-hour limit.
- And our pilots are provided with 25-50 percent longer rest periods than required by FAA regulations.
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.
Crew rest opportunities
Today's NTSB docket shows that the crew's scheduled duty days also complied with recently enacted passenger crew rest rules.
The NTSB reports also indicate that both the captain and first officer were coming off extended time off. The captain had been off for eight days before beginning his final trip. The first officer had flown just two of the previous ten days.
According to the CVR transcript released today, the pilots discussed scheduling and fatigue at the beginning of their flight. 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.
UPS rest measures
The aforementioned sleep rooms go well beyond any measures required by the FAA. They are just one example of how the company exceeds regulatory requirements to ensure proper rest. Other examples include:
- Reviewing schedules with our pilots union, the Independent Pilots Association
- Operating a fatigue working group with the union
- Operating a fatigue safety action group (SAG)
- And working with a sleep scientist
Recent regulatory and media discussions of crew rest have overlooked the FAA's Fatigue Risk Management Program, mandated in 2010 for all U.S. airlines. Beyond crew rest regulations, the FRMP is a second layer of FAA protection against pilot fatigue. The program's purpose is to monitor fatigue incidents and take corrective action. UPS has an active FRMP.
Experience at night
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.
Proper rest comes down to shared responsibility. UPS provides for proper rest opportunities through the measures and safeguards we've already discussed, and our pilots are expected to follow a rest regimen that enables them to report fit for duty.
Ground proximity system
An early story has called into question the Enhanced Ground Proximity Warning System (EGPWS) in use at UPS. (The EGPWS is a warning system that goes off if an aircraft comes too close to the ground.) It's important to understand that the EGPWS in use at UPS is fully compliant with FAA regulations.