The Association of Flight Attendants has focused on the issue of Flight Attendant fatigue for more than two decades. We have recapped chronological markers in order to provide historical reference for members, new activists, and representatives.
In 2012, the Airline First Responder Workplace Fairness Act(H.R. 3824) was introduced by Rep. Mazie Hirono (D-Hawaii). The bill ensures that the FAA addresses fatigue issues, which could impair the performance of Flight Attendants. In 2009, The Department of Labor re-classified Flight Attendants as “Essential Transportation Workers” along with pilots and air traffic controllers due to AFA’s advocacy and lobbying efforts. At the 2012 Flight Attendant Coalition Meeting in June 2012, this topic and Rep. Hirono’s efforts on behalf of our profession was fully supported by all the unions of the coalition (AFA, APFA, IAM, USW, TWU, IBT).
Inadequate rest periods and the resulting fatigue has become an escalating problem for Flight Attendants across the industry throughout the decades.
Flight Attendants are finding schedules that routinely contain the reduced rest period of 8 hours following incredibly long and extended duty days. This is no longer an exception to the rule, but the rule itself. For Flight Attendants, “rest” or “layover” does not mean 8 hours of actual sleep.
“Rest period” is misleading because much more must be done during this period than sleep. The “rest period” generally begins 15 minutes after an aircraft pulls into the gate, and continues until 1 hour prior to the next departure. It includes travel to the hotel, checking-in, possibly eating a meal, getting prepared for bed, getting dressed for work the next morning, travel to the airport, clearing security and traversing the concourse, and last, but certainly not least, sleep time.
As airlines restructure and cut corners to make ends meet, Flight Attendants are experiencing an industry trend that must be put to rest. At many AFA carriers, Flight Attendants are being forced to work to the point of exhaustion because of poorly scheduled duty time, lengthened duty days due to concessionary bargaining, or flagrant company violations of Flight Attendants’ schedules.
In 1985, AFA and the Joint Council of Flight Attendant unions petitioned the Federal Aviation Administration (FAA) to establish flight and duty time regulations similar to regulations for pilots. Finally in 1994 the FAA acknowledged that Flight Attendant fatigue could impact job performance, and implemented the Flight Attendant Duty and Rest requirements “…in the interest of air transportation and air commerce safety.”
Current FAA Flight Attendant rest rules require a minimum of 9 hours, which can be reduced to 8 hours if the following rest period is 10 hours. If, the “rest period” includes exiting the airport, local transportation to a rest facility (hotel), a meal, preparation for bed at night and then transportation back to the airport for the next duty day, perhaps the minimum rest period requirements need to be revisited.
Industry practice has been to schedule the minimum of 9 hours of rest. In some cases, air carriers are scheduling layovers with less than 9 hours. The “reduced rest” of 8 hours is meant to accommodate scheduling when carriers encounter delays out of the carriers’ control such as bad weather or air traffic control delays, but FAA regulations are not so specific.
As part of ongoing efforts to address this issue, AFA met with other unions representing Flight Attendants at a Fatigue Summit in 2005. The unions came together to work out a common agenda on addressing the issues and safety aspects. That same year AFA procured a congressionally mandated and funded study of the issue of fatigue to prove that it was a problem and safety concern for our members. The study was conducted by the FAA Civil Aerospace Medical Institute (CAMI).
The Omnibus Appropriations for FY ’05 contained an appropriation for $200,000 directing the FAA to conduct a study of Flight Attendant fatigue. The FAA was to report back to Congress by June 1, 2005 with their findings.
Report language stated:
“The Committee is concerned about evidence that FAA minimum crew rest regulations may not allow adequate rest time for flight attendants. Especially since the terrorist attacks of September 11, 2001, the nation's flight attendants have been asked to assume a greater role in protecting the safety of air travelers during flight. Current flight attendant duty and rest rules state that flight attendants should have a minimum of 9 hours off duty, that may be reduced to 8 hours, if the following rest period is 10 hours. Although these rules have been in place for several years, they do not reflect the increased security responsibilities since 2001, and only recently have carriers begun scheduling attendants for less than 9 hours off. There is evidence that what was once occasional use of the ‘reduced rest’ flexibility is now becoming common practice at some carriers.”
In order to complete the study, representatives of the FAA from CAMI initiated an agreement with NASA Ames Research Center to perform an evaluation of the Flight Attendant fatigue issue. After more than a one-year delay in meeting the June 1, 2005 deadline, the FAA released the report in July 2007. The report contains a review of existing literature on the issue, an evaluation of Flight Attendant duty schedules, and a comparison of those schedules to the current regulations regarding rest concluded that Flight Attendants are “experiencing fatigue and tiredness and as such, is a salient issue warranting further evaluation.” The report recognizes fatigue as a problem, acknowledges that the very limited 6 - 8 month time frame the researchers were given by the FAA to conduct the study was not adequate, and clearly stated that a more meaningful, detailed study needed to be conducted, including surveys and research to gain a “complete understanding of the phenomenon/problem of Flight Attendant fatigue.”
In 2008, Congress directed CAMI to conduct a series of additional Flight Attendant fatigue studies in each of the 6 recommendation areas noted in the 2007 report. The studies were completed and the final reports began being issued in late 2009.
FAA Certified Flight Attendant participants in two of the studies included: Alaska, American, Continental, Delta, Northwest, United, and U.S. Airways from the Network carriers; and, AirTran, America West, Frontier, JetBlue, Southwest, and Spirit from the Low-Cost carriers. Participants from Regional carriers came from Air Wisconsin, American Eagle, Atlantic Southeast, Chautauqua, Colgan, Comair, ExpressJet, Horizon, Mesa, Mesaba, Piedmont, PSA, Republic, Shuttle America, and SkyWest.
Study requirements and recruitment materials were prepared in cooperation with CAMI officials, several airlines, and Flight Attendantlabor organizations. Organizations issued recruitment notices soliciting volunteers using websites, e-mail, and/or newsletter in February 2009 and February 2010 encouraging Flight Attendants to participate in the field study.
These studies demonstrated that reaction time and performance diminishes with extreme fatigue, an unacceptable situation for safety-sensitive employees. Flight Attendants are on board to assist in case an aircraft emergency evacuation is necessary.
In addition, they are inflight first responders who are trained to handle inflight fires, medical emergencies including CPR, emergency births and security problems. Any impact to reaction time or inability to function due to lack of adequate rest jeopardizes the traveling public and the entire crew.
While pilot regulations allow them to notify their carrier that they are too fatigued to fly, Flight Attendant rules are less clear. A Flight Attendant’s option is to call in sick and at some carriers as few as three absences due to illness in one year sets a Flight Attendant on the path for termination.
Both FAA and the CAMI have publically stated that Flight Attendant fatigue is a serious issue. Congress has spent millions of dollars to determine what we already know—namely that under current duty time and rest regulations, one too many Flight Attendants are not receiving adequate rest to perform FAA-mandated safety and security functions. New FAA rules addressing fatigue will incorporate these findings and fix this problem.
AFA is not seeking, nor does H.R. 3824 contain any language that would limit or cap Flight Attendant flying. It only calls for the creation of an Aviation Rulemaking Committee (ARC) to consider the recommendations of the CAMI studies and then propagate a Notice of Proposed Rulemaking to ensure Flight Attendants receive adequate rest.
“The Airline First Responder Workplace Fairness Act”, H.R. 3824 establishes a working group to incorporate findings from the already paid for seven (7) Congressional Flight Attendant fatigue studies to create a comprehensive rule providing for necessary additional rest rules for Flight Attendants.
Summary of the FAA Flight Attendant Fatigue Studies
Follow-on studies from the 2007 report resulted in six additional reports. A description of the six studies and an overview on each study follows.
Part I: National Duty, Rest, and Fatigue Survey, Report date December 2009. This survey report addressed 7 main operational factors that may contribute to Flight Attendant fatigue: work background, workload and duty time, sleep, health, fatigue, work environment, and general demographics. http://www.faa.gov/library/reports/medical/oamtechreports/2000s/media/200924.pdf
Respondents to the survey were active Flight Attendants certificated by the FAA (DOT/FAA-issued government certificate) and listed in its Civil Aviation Registry. Using the Registry’s certification records, a random and representative sample was selected from each of the 30 operators included in this study. A total of 20,826 surveys were distributed.
Of those who responded, 9,180 (online = 4,039; paper = 5,141) met the criteria for inclusion (i.e., were employed as an active Flight Attendant with their current airline for at least a month and had flown within the previous bid period), resulting in a 44% adjusted response rate. Participants included Flight Attendants from each type of operation, network, low-cost and regional carriers.
Data was collected from 9,180 Flight Attendant representing 30 operators.
Responses indicated that Flight Attendant had experienced fatigue (84%) and the majority felt Flight Attendant fatigue was a safety risk.
Two of the primary contributors to fatigue were scheduling and physiological requirements.
Part II: Flight Attendant Work/Rest Patterns, Alertness, and Performance Assessment, Report date December 2010. This study explored the physiological and psychological effects of fatigue, sleepiness, circadian factors and rest schedules on Flight Attendants’ ability to perform their duties over 3-4 week period of 202 flight attendants. http://www.faa.gov/library/reports/medical/oamtechreports/2010s/media/201022.pdf
This report provided an overview of the field study results, focusing on objective measures of sleep patterns and neurocognitive performance (Psychomotor Vigilance Test, PVT) over a 3 to 4 week period in 202 U.S.-based Flight Attendants of all seniority levels working for network, low-cost, and regional carriers embarking on domestic and international flight operations.
On average, Flight Attendant slept 6.3 hours on days off and 5.7 hours on workdays. Those working international operations slept less and less efficiently compared to domestic Flight Attendant. All Flight Attendant exhibited significant impairments during pre-work testing.
This study supports the subjective data from Part I that noted that Flight Attendant felt that fatigue was a common problem and that it is a pervasive condition across the Flight Attendant community. In fact, it appears that chronic sleep restrictions and fatigue are considerably worse than the Flight Attendant perceptions noted in Part I.
Part III, when published, will look at validation of fatigue models for assessing how fatigued a Flight Attendant will become. This will help ensure that model predictions are consistent with data gathered from Flight Attendant s during the field operations be scheduled.
This Part has yet to be published.
Part IV: Analysis of Incident Reports, Report date December 2009. The FAA CAMI reviewed and analyzed the content from 2,628 reports found in the NASA ASRS database related to Flight Attendant fatigue in order to identify the frequency and conditions of fatigue noted in the reports. http://www.faa.gov/library/reports/medical/oamtechreports/2000s/media/200925.pdf
The narratives in the reports mirror the findings in the other parts of this study in that Flight Attendant fatigue is a salient issue and there should be scheduling based on science and that in addition some type of training should be supplied to the Flight Attendant.
Part V: A Comparative Study ofInternational Flight Attendant Fatigue Regulations and Collective Bargaining Agreements, Report date November 2009. CAMI personnel obtained and analyzed 38 regulations and 13 collective bargaining agreements from around the world. http://www.faa.gov/library/reports/medical/oamtechreports/2000s/media/200922.pdf
When comparing U.S. maximum hours of work and minimum hours of rest with other countries the U.S. prescriptive rules were the least restrictive.
The study recommends establishing a Flight Attendant fatigue work group of subject matter experts to evaluate the current regulations, 14 CFR 121.467 and 135.273, for possible revision.
Part VI: Fatigue Countermeasure Training and Potential Benefits, Report date October 2009. Education about the dangers of fatigue, causes of sleepiness, importance of sleep and proper sleep hygiene is a tool that can assist with mitigating fatigue if used with other risk mitigation tools like scheduling. http://www.faa.gov/library/reports/medical/oamtechreports/2000s/media/200920.pdf
CAMI personnel reviewed 50 training programs from diverse workgroups and identified the critical components of a fatigue countermeasures training program and the study recommended that airlines implement a training using some of the suggested components as well as integrating the training into a broader program that addresses fatigue risk management strategies.
The survey noted that 35% of Flight Attendant surveyed were provided some type of training or material on fatigue; however, almost 80% indicated the training did not help reduce or minimize fatigue.
 Federal Register, Vol. 59. No. 160, Friday, August 19, 1994