The past week has been marked by the publication of EASA’s final opinion on new Flight and Duty Times Regulation for air crew. ECA’s initial assessment is that this overall package of rules – despite some improvements compared to the current Sub-part Q regulation – is UNSAFE and must be changed.

EASA decided not to include major recommendations from human fatigue scientists by declaring them as irrelevant or incorrect. EASA believes it can safely second-guess

what the scientists presented to them – even without any in-house scientific or medical expertise . The Agency believes that the foundation of this regulation should be the operational experience of the airlines. The airlines’ voices have clearly dominated the drafting process. Not surprisingly, the Association of European Airlines already welcomed the proposal – while still insisting on further ‘improvements’ in line with their commercial needs.

Pilots across Europe, on the contrary, have started to question EASA’s motto: “Your safety is our mission”. In a press statement, EASA’s Executive Director, Patrick Goudou said that these rules are based on scientific evidence, risk assessment and best practice. But when reading the proposal you can barely see any parts where scientific evidence has been taken into account. Most strikingly, night flights of up to 12 hours are clearly not in line with the unanimous scientific recommendation for a 10-hour limit. 

For years we have been asking for safe and science-based rules. In 2006 pilots and cabin crew were promised a scientific evaluation and subsequent changes to Subpart Q. This promise has not been kept. And pilots are tired, dead tired, of  voicing their concerns if no-one is listening.

ECA CANNOT ACCEPT this proposal as it stands. It MUST be changed into a safe package. Otherwise, we will, together with the cabin crew unions in ETF, have no choice but to make it very clear and very visible that safety cannot be compromised!