MC Explains: Flight duty time limitation and why Indian airlines are seeking more time to enforce the new norms

Indian Pilots

Commercial pilots undergo months of rigorous training and testing before they are allowed to operate commercial flights to ensure peak functionality when operating an aircraft full of passengers.

To remain completely attentive before a flight, pilots have to follow certain prescribed rest rules to be eligible to operate a flight at peak functionality to ensure that they can make quick and correct decisions to ensure the safety of their passengers.

Across the world, civil aviation regulators use various criteria to control flight crew scheduling and rest periods to reduce fatigue among pilots and thus improve airline safety.

In India, the Directorate General of Civil Aviation (DGCA) defines its flight duty time limitation (FDTL) norms to ensure that pilots are in good shape before operating a flight.

What are FDTL norms, and why are they required?

Fatigue has been defined as the decreased capability to perform
mental or physical work, or the subjective state in which one can no
longer perform a task, produced as a function of inadequate sleep, circadian rhythm disruption, or time on task.

Pilots of both short and long-haul flights, have often complained about acute fatigue related to sleep deprivation, which they associated with certain aspects of work schedules, including night flights, crossing multiple time zones, and repeated early wake-up requirements.

The International Civil Aviation Organization (ICAO) mandates that the country where an airline is based shall establish regulations to manage fatigue. The civil aviation authorities of the country are required to issue prescriptive regulations for flight time, flight duty period, duty period, and rest period limitations.

"Functional impairment associated with human fatigue is increasingly
being recognised as a significant risk in commercial airline flight operations," a flight safety inspector with the DGCA told Moneycontrol.

Therefore, to ensure that pilots are well-rested and able to make quick decisions, the DGCA has created certain guidelines to ensure adequate rest timings for pilots and flight attendants and prevent fatigue-related safety issues.

What are the new FDTL norms introduced by the DGCA?

The DGCA on January 8 revamped its FDTL regulations and as part of its latest rules ensured additional rest for pilots, revision of night duty regulations, and directed airlines to submit pilot fatigue reports.

The Indian aviation regulator also mandated airline operators to comply with the new notification by June 1, 2024.

The DGCA had shared the draft of the new norms for public consultation in November 2023 and gave airlines a month to share feedback before announcing that the new norms will be implemented by June 1.

As part of its revised regulations, the DGCA mandates increased weekly rest periods from 36 hours to 48 hours for flight crew.

Further, the DGCA has amended the definition of night as part of the new FDTL norms, to now cover the period of midnight to 6 am as opposed to midnight to 5 am under the previous regulations.

This enhancement of one hour during the early morning will ensure adequate rest and also align the night duty period which encompasses Window of Circadian Low (WOCL) from 0200-0600 hours i.e. the time during which the circadian body clock cycle is at its lowest in terms of alertness.

The revised regulations also now take into consideration different types of operations across time zones.

The maximum flight time and maximum flight duty period for flight operations encroaching night have been restricted to 8 hours flight time and 10 hours flight duty period respectively and the number of landings have been limited to only two landings as compared to a maximum permissible six landings during night operations under the previous regulations.

Why did India need new FDTL norms?

The new FDTL norms proposed by the DGCA came after two young pilots died of cardiac arrest in India.

On November 16, 2023, 37-year-old Captain Himanil Kumar was returning from the Diwali break for his scheduled training session to transition to fly another type of aircraft. Kumar suffered a cardiac arrest at the Delhi airport and was declared dead when taken to a nearby private hospital.

Similarly, in August 2023, 40-year-old Manoj Subramanyam died in similar conditions just minutes before his flight in Nagpur.

These deaths bring home the reality of pilot fatigue in the aviation industry.

In April this year, the Indian Commercial Pilots’ Association (ICPA), a commercial pilots’ body, had written to Air India, demanding their grievances against the roster system be redressed.

The ICPA had flagged how rosters were being amended with nil or short notice to the flight crew and ending up affecting their health.

Why are airlines asking the DGCA for an extension to the June 1, 2024 deadline to implement the FDTL norms?

Last month, the Federation of India Airlines (FIA), a lobby group that consists of IndiGo, Air India, Vistara, and SpiceJet, warned that the new rules will require them to increase the number of pilots by 25 percent and hiring and training them will not be possible by June 1, forcing them to cancel up to 20 percent of flights.

The airlines also said that the new rules are ambiguous and more restrictive than anywhere in the world and will make the Indian aviation industry less competitive than other countries.

The airlines also asked the DGCA to consider letting airlines implement their own Fatigue Risk Management Systems (FRMS) instead of prescribing uniform rules for all airlines.

FRMS is a process where airlines collect data and analyse them using software to monitor fatigue among their pilots. Global aviation watchdog ICAO also prescribes the use of FRMS against the traditional approach of regulators prescribing limits.