Joy O. Banks

Katrina E. Avers

Thomas E. Nesthus

Erica L. Hauck

Civil Aerospace Medical Institute

Federal Aviation Administration

Oklahoma City, OK 73125

November 2009

Final Report

Flight Attendant Fatigue, Part V: 

A Comparative Study of International 

Flight Attendant Fatigue Regulations 

and Collective Bargaining Agreements

DOT/FAA/AM-09/22

Office of Aerospace Medicine

Washington, DC 20591

OK-10-0077-JAH

Federal Aviation

Administration
NOTICE

This document is disseminated under the sponsorship 

of the U.S. Department of Transportation in the interest 

of information exchange. The United States Government 

assumes no liability for the contents thereof.

___________

This publication and all Office of Aerospace Medicine 

technical reports are available in full-text from the Civil 

Aerospace Medical Institute’s publications Web site: 

www.faa.gov/library/reports/medical/oamtechreports
i

Technical Report Documentation Page 

1. Report No. 2. Government Accession No. 3. Recipient's Catalog No. 

DOT/FAA/AM-09/22 

4. Title and Subtitle 5. Report Date 

Flight Attendant Fatigue, Part V: A Comparative Study of International November 2009 

Flight Attendant Fatigue Regulations and Collective Bargaining Agreements 6. Performing Organization Code 

 

7. Author(s) 8. Performing Organization Report No. 

Banks JO, Avers KE, Nesthus TE, Hauck EL 

9. Performing Organization Name and Address 10. Work Unit No. (TRAIS) 

 

11. Contract or Grant No. 

FAA Civil Aerospace Medical Institute 

P.O. Box 25082 

Oklahoma City, OK 73125 

12. Sponsoring Agency name and Address 13. Type of Report and Period Covered 

 

 

 

Office of Aerospace Medicine 

Federal Aviation Administration 

800 Independence Ave., S.W. 

Washington, DC 20591 14. Sponsoring Agency Code 

15. Supplemental Notes 

Work was accomplished under approved task AM-A-08-HRR-521 

16. Abstract 

In 2008, Congress directed the Civil Aerospace Medical Institute (CAMI) to conduct follow-on studies of six 

recommendation areas noted in an integrated report by the National Aeronautics and Space Administration 

(NASA) and CAMI regarding flight attendant fatigue. The report concluded that some degree of fatigue-related 

performance affects were likely under current prescriptive rules. Internationally, fatigue risk is managed almost 

solely through prescriptive rules based on the maximum hours of work and minimum hours of rest. Traditional 

prescriptive rules, however, have limited applications to round-the-clock operations, often excluding fatiguecontributing factors such as time zone transitions, layover and recovery, time of day, and circadian rhythms 

(Cabon et al, 2009). Prescriptive rules directly affect crew scheduling and are critical to operator viability; 

however, due to economic recession, operators are routinely scheduling up to the regulation limits, which could 

result in an increased likelihood of fatigue and fatigue-related mishaps (Nesthus, Schroeder, Connors, et al., 

2007). In the present study, we obtained regulations (n=38) and collective bargaining agreements (CBA) (n=13) 

regarding flight attendant duty time and rest from International Civil Aviation Organization (ICAO) member 

states using several resources: Civil Aviation Authority Web sites, an international cabin safety symposium, Webbased ICAO information exchange, and FAA international field offices and aviation safety inspectors. We 

analyzed each regulation and CBA to identify duty time and rest rules related to working hour limits, sleep and 

rest requirements, circadian rhythms, and other factors. When comparing the United States (U.S.) maximum 

hours of work and minimum hours of rest with other countries, we concluded that U.S. prescriptive rules are 

among the least restrictive, representing a greater than typical risk for fatigue related incidents. We recommend 

the U.S. establish a sanctioned fatigue workgroup of subject matter experts, aviation stakeholders, medical and 

research scientists, and aviation Safety Management System experts to evaluate current regulations and develop 

an adaptive fatigue mitigation safety system combining scientific principles and knowledge with operational 

support. 

 

17. Key Words 18. Distribution Statement 

 

 

Cabin Operations, Cabin Crew, Cabin Attendant, Crew 

Safety, Duty, Rest, Limitations, Safety, Rest Period, 

Operations, Flight Crew, Flight Time Limitation, Fatigue, 

Flight Duty Period, Flight Attendant, Regulations

Document is available to the public through the 

Defense Technical Information Center, Ft. Belvoir, VA 

22060; and the National Technical Information 

Service, Springfield, VA 22161 

19. Security Classif. (of this report) 20. Security Classif. (of this page) 21. No. of Pages 22. Price 

Unclassified Unclassified 19 

Form DOT F 1700.7 (8-72) Reproduction of completed page authorized 

iii

Contents

Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

 Risky Business: Pilot vs. Flight Attendant’s Fatigue. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Misconception Problem. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

 Sample Development. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Inclusion Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

 Content Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Working Hour Limits. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

 Sleep and Rest Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

 Circadian Rhythms. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

 Other Factors. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Discussion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

 Common Practices. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Best Practices. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Recommendations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

 Limitations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

References. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

1

Flight Attendant Fatigue, Part V: 

A Comparative Study of International Flight Attendant

Fatigue Regulations and Collective Bargaining Agreements

Background

While a great deal of research has been conducted on

human circadian processes as applied to scheduling and

training of flight crews, relatively little research has been

accomplished among flight attendants. Performance of

cabin duties is critical to safety and security and the literaturesuggeststhat all humanperformanceis vulnerable

to sleeploss anddaily variationsinphysiologicalprocesses

tied to underlying biological body-clock mechanisms. 

The extent of sleep loss, fatigue, and their impact upon

performance of duties among the cabin crew population

andwithin the current duty regulations are unknown but

are under investigation along with several other congressionally directed research projects with which this report

is associated. 

In 2005, Congress directed the Civil Aerospace Medical Institute (CAMI) to address issues regarding flight

attendant fatigue. CAMI contracted with the National

Aeronautics and Space Administration (NASA) Ames

Research Center’s Fatigue Countermeasures Group

to conduct literature and incident report reviews and

examine a range of typical flight attendant schedules to

assess potential vulnerability to fatigue. NASA delivered

two reports that were integrated and published as a Federal Aviation Administration (FAA) Office of Aerospace

Medicine Technical Report(Nesthuset al., 2007). In this

report, NASA concluded that some degree of fatiguerelated performance affects werelikely under the current

regulations and suggested six areas ofresearch thatwould

facilitate understanding and government-industry decision making. The six recommendations included:

• A survey of field operations.

• Field research on the effects of fatigue.

• A validation of models for assessing flight attendant

fatigue.

• A focused study of incident reports.

• A review of international policies and practices.

• The potential benefits of training.

In 2008, Congress provided another directivefor CAMI

to conduct follow-on studies of the six recommendation

areas noted in the 2007 report. To accomplish this directive,

CAMI researchers developed a project plan for completing

eachrecommendation. Tofacilitatesupportfortheseprojects

andensureparticipation, CAMIresearcherscoordinatedwith

representatives of vested organizations (e.g., Air Transport

Association, Regional Airline Association, CoalitionofFlight

Attendants Association of Flight Attendants, Association

of Professional Flight Attendants, Transportation Workers

Union, International Association Machinists, United Steel

Workers, Delta Air Lines, and non-unionized airlines) and

providedthemwiththeopportunitytoreviewandcomment

on aspects of the project plan. 

Introduction

The National Transportation Safety Board (NTSB)

recommended that the Federal Aviation Administration

(FAA) reduce accidents/incidents caused by human

fatigue by setting working hour limits based on fatigue

research, circadian rhythm, and sleep and rest requirements (NTSB, 2008). The FAA currently manages flight

attendant working hours and rest requirements through

prescriptiverules and allows airlinesto schedule duty and

rest within the guidelines found under Title 14 Code of

Federal Regulation (CFR)sections 121.467 and 135.273

(see Table 1). Before 1994 there were no duty limitations

Table 1. Summarized Flight Attendant (FA) Rest Periods According to Title 14 CFR

Scheduled Duty 

Period (Hr) 

Normal Minimum 

Rest Period (Hr) 

Reduced Rest 

Period (Hr) 

Subsequent Rest 

Period (Hr) 

Number of FAs 

Required 

14 or less 9 8 10 Minimum 

14-16 12 10 14 Minimum + 1 

16-18 12 10 14 Minimum + 2 

*18-20 12 10 14 Minimum + 3 

*Applies only to duty periods with 1 or more flights that land or take off outside the 48 contiguous states and the 

District of Columbia 

Note: Generally, off-duty time begins no less than 15 min after the aircraft pulls into the gate and continues until 1 

hr prior to a flight attendant’s next departure. 
2

orrestrequirementsfor cabincrewmembersinthe United

States (Kirkland, 2008). 

Formost aviationauthorities aroundtheworld,fatigue

risk is managed almost solely through prescriptive limits

onthemaximumdurationofworkperiods andminimum

durationofrestperiods(Signal, Ratieta,& Gander,2008). 

Some advantages to using prescriptive rules to manage

fatigueinclude an equitableindustry foreconomic competition among airlines, they establish a gauge to either

achieve or exceed, and they are easy to apply and work

well for daytime operations. However, the disadvantage

is they are limited in scope, and most were developed

without incorporating important human factors elements that affect fatigue such as time zone transitions,

layover and recovery, time of day, and circadian rhythms

(i.e., physiological functions, such as body temperature,

hormonesecretion,sleepiness,wakefulness, andalertness

variations within a cycle of approximately 24 hr). For

example, due to circadian rhythms, a rest break will not

have the same benefits across the day, because when the

break occurs may be more important than the amount of 

timescheduled forthe break. Therefore, prescriptiverules

based on time limitations are unable to account for all

the complexity and interactions of factors that arelinked

to the hours of scheduled work (Cabon et al., 2009). 

Risky Business: Pilot vs. Flight Attendant’s Fatigue

The general public is well aware of the catastrophic

events that can result when aviation personnel work

while fatigued. For example, federal investigators have

uncovered evidence that pilot fatigue might have been a

factorinthe crashof Continental Connectionflight3407

on Feb. 12, 2009 near Buffalo, New York, in which all

49 people onboard and one person on the ground were

killed when the planestalled during icing conditions and

plunged into a house. Human fatigue is a serious threat

to aviation safety, and many airline passengers would feel

uncomfortable boarding a commercialflight knowing the

pilot in command was suffering from fatigue. However,

would the same hold true if they knew the flight attendants were suffering from fatigue?

Misconception Problem

Misconceptions and/or lack of knowledge about the

duties of flight attendants have contributed to the perception that their sole purpose is to provide customer

service. Unfortunately, only during the time of an inflight emergency do some realize and appreciate the

important role of certified flight attendants and their

performance of critical safety functions (e.g., performing emergency assistance by fighting fires, administering first aid, leading evacuations, conducting security

checks). For instance, in the ditching of US Airways

flight 1549, the flight attendants’ professionalism and

expert emergency assistance was critical to successfully

evacuating 150 passengers from the plane floating in the

Hudson River once the flight crew successfully ditched

the aircraft. However, if flight attendants are unable to

assist passengers during times of emergency, the loss of

life or injury could increase dramatically. In the case

of Singapore Airlines Flight 006, 31 October 2000, in

which 83 of the 179 occupants perished, an eyewitness

and survivor of the crash reported, “...that in the crucial

minutes after the crash, panicked flight attendants stood

frozen and wouldn’t show passengers how to unlock the

escape hatches.” (Perrir, 2000, p.16). 

Flight attendants have vigorously fought to change

the misconception that their safety function is secondary to customer service. To protect the flying public and

themselves, they have lobbied Congress to take a serious

look at fatigue-imposing schedules and reduced rest. 

The purpose of the current study is to review the

regulations, policies, and practices that have been used

to manage fatigue internationally. This report provides

specific details associated with an extensive review and

evaluation of international policies and practices and

will be incorporated into CAMI’s consolidated report

to Congress. 

Methods

Sample Development

We collected a final sample of 38 regulations and 13

CBAs within and outside of the United States by using

several means: 1) Reviewing the Web sites of 117 ICAO 

member states; 2) Contacting FAA International Field

Offices; 3) Attending an International Cabin Safety

Symposium; 4) Posting an ICAO Flight Safety Exchange

Information announcement; and 5) Contacting FAA 

Cabin Safety Aviation Safety Inspectors (ASI). 

ICAO Web site. The majority of the regulations (n=

33) were obtained through the ICAO (considered the

global forum for civil aviation) Web site link to the

member states CAA Web sites. In June 2008, we began

our Internet search by reviewing 117 ICAO member’s

Web sites for regulations and policies addressing flight

attendant flight and duty period (FDP) limitations and

restrequirements, andwe commencedevaluationin April

2009. If we could not locate the regulation or policy on

the Web site, we contacted the CAA representative in

flight operations or aviation regulations and directives. 

CAA representatives advised us that some member states

did not have regulations governing flight attendant

duty time and rest or they had a CBA (written contract

negotiated directly between the flight attendants’ union

and the operator) or a FRMS in development. The CAA 
3

representatives of Transport Canada, New Zealand, and

Australia provided a CBA or provided information to

obtain a copy of the CBA. 

We used the following key words during our Internet

search: cabin operations, cabin crew, cabin attendant,

crew safety, duty, rest, limitations, safety, rest period,

operations, flight crew, flight time limitation (FTL),

fatigue, and flight duty period (FDP). We documented

each ICAO member’s Web site noting the following: 1)

Web address of the CAA; 2) Whether or not the CAA 

Web site had an English translation; 3) Web address

where the regulation was located; 4) Whether or not the

Web site was functional; and 5) Contact Email address

for the CAA.

FAA International Offices. We received regulations

from Brazil (English translation), Dubai United Arab

Emirates, and the Philippines after contacting the FAA 

directors of three International Field Offices in Brussels,

Singapore, and Washington D.C. 

International Cabin Safety Symposium. CAMIsent one

project researcher to the Annual International Aircraft

Cabin Safety Symposium held in Montreal, Quebec,

Canada from 11-14 February 2008. Attendees from the

aviation authorities of India and Colombia submitted

their duty time and rest requirement regulations during

a scheduled workshop titled “Global Harmonization

and You.”

ICAO Flight Safety Exchange Information Announcement. We posted an announcement on the ICAO Flight

Safety Exchange Information Web site to notify ICAO 

CAA member states about the flight attendant fatigue

study and solicited their most current English-translated

regulations or policies governing flight attendant fatigue. 

This resource yielded one inquiry and one suggestion to

contact FAA International Field Office directors to approach and solicit foreign civil aviation authorities for

regulations and polices.

FAA Cabin Safety Aviation Safety Inspectors (ASI).

While the CAA representative provided information on

getting CBA from Transport Canada, New Zealand, and

Australia, the FAA cabin safety ASIs proved to be a valuable resource in obtaining five CBAs from U.S. airlines

American, Delta, Frontier, Lynx, and Northwest. 

Inclusion Criteria

When reviewing all of the available regulations, some

gave clear definitions of cabin and flight crewmembers

while others were ambiguous as to whether the duty

time and rest rules applied to all crew members or a

select group. We used regulations and CBAs with duty

time and rest rules applicable to cabin crewmembers, all

crew members, and flight crewmembers—provided the

cabin crew was included in the definition for flight crew. 

For example, if the flight crew definition excluded cabin

crewmembers (i.e., only flight crewmembers assigned to

act as pilot, flight engineer, or navigator of an aircraft

during flight time) we did not includethe duty time and

rest regulations in the analyses. 

Of the 117 Web sites visited, 38 regulations and 13

CBAs met the criteria for inclusion. 

Most CAA Websiteshad Englishtranslationsorpartial

English translations (n= 82), which enabled us to search

for their regulations, usually located in the operations or

regulation section. 

Content Analysis

We analyzed thetext in each regulation and CBA and

developed a list of duty time and rest rules (n=35) used

to manage fatigue. Definitions for the most commonly

used rules were summarized using their international

similarities (see Table 2). Each rule was classified into

one of four categories (using the NTSB recommendations) to reduce aviation accidents/incidents caused by

human fatigue: 1) working hour limits; 2) sleep and rest

requirements; 3) circadian rhythms; and 4) others. The

“others” category was added for rules that could not be

clearly classified into one of the preceding categories

(e.g., commander’s discretion; see Table 3). Given the

complexity associated with the regulations and CBAs,

three raters reviewed a subsample of the documents to

ensure that the classifications of duty time and rest rules

were made correctly. An analysis of interrater classifications indicated 90% agreement overall. 

Results

We analyzed theregulations (n=38) and CBAs (n=13)

that met the criteria for inclusion in the study and identified duty time and rest rules (n=35) used to manage

fatigue associated with thefour categories: working hour

limits, sleep and rest requirements, circadian rhythms,

and other. We also included a summary of our communications with CAA representatives that indicated they

had a FRMS in development in conjunction with or as

an alternative to duty time and rest rules. 

Table 3 provides a summary of the percentages and

number of duty time and rest rules per category used in

eachregulationand CBA. Themajority(49%)ofdutytimes

and rest rules were associated with working hour limitations, 37% associated with sleep and rest requirements,

6% circadian rhythm, and 8% other. Table 4 summarizes

the number of duty time and rest rules in a regulation or

CBA by member state or operator (n=51). Bosnia and

Herzegovina regulationsprovidedthemostrules associated

with working-hour limitations (n=11), while Northwest

Airlines and Freedom Air Ltd (n=8) represented the most
4

Table 2. Definition of duty time and rest rules used in regulations and CBA 

Terms Definition 

1 Flight and Duty Time 

Period (FDP) 

The time between reporting for an assignment and release from that 

assignment. A continuous period of duty in which a flight attendant 

carries out any task associated with the business of an aircraft 

operator/certificate holder. 

2 Flight Time Limitation 

(FTL) Period 

A continuous period of duty commencing when the aircraft begins a flight 

segment, moving on its own, and finishes after the aircraft comes to a stop 

after a flight segment. 

3 Minimum Rest A continuous period of time during which the flight attendant is free from 

all restraint by a certificate holder. 

4 Reduced Rest Period A continuous period of time during which the flight attendant is free from 

all restraint by a certificate holder reduced to the maximum limitation due 

to unforeseen circumstances. 

5 Compensatory Rest Recovery rest given to make-up for a reduced rest period. 

6 Day Off A period of at least 24 hr available for leisure and relaxation free from all 

duties. 

7 Crew Rest Facilities A hotel room or in case of crew rest onboard aircraft; a chair or bunk 

separated from passengers. 

8 On Duty Rest Break Usually given on a long flight of 6 hr or more. 

9 Positioning/ 

Deadheading 

The time spent traveling from one point to the next on the aircraft 

operator/certificate holder’s time. 

10 Late Finished or Early 

Starts 

Late Finish: Duty finishes between 0100 and 0159 local time. Early Start: 

Duty commences between 0500 and 0659 local time. 

11 Time Zone 

Readjustment 

Given more time to rest to adjust to or recover from a time zone different 

from local time. 

12 Duration of Prone Rest 

(Sleep) 

Rest lying down. Does not mean sleep unless it states in regulation. 

13 Standby/Reserve Duty An aircraft operator/certificate holder places restraints on a flight 

attendant who would be off-duty. The flight attendant is subject for 

assignment to duty and must be ready for duty. 

14 Commander’s/ 

Captain’s discretion 

The pilot in command may exceed the FDP or reduce the rest time in 

certain circumstances. 

15 Fatigue Responsibility To whom the responsibility lies to guard against fatigue. An individual 

may refuse to work if fatigued. 

16 Long Range International flight of 8 hr or more that requires crew complement. 

17 Crew Complement Adding flight attendants to a minimum operating crew to service 

passengers on public aircraft transportation. 
5

Table 3. Number and percentage of regulations and CBA using duty time and rest rules 

Duty Time and Rest Rules (n=35) Regulations % CBA % 

Rules Associated with Working Hour Limits (n=17) (49%) 

Maximum Flight Duty Period (FDP) in 24 hr 36 95 13 100 

Maximum Duty Period in 7 days 10 26 3 23 

Maximum Duty Period in 14 days 7 18 1 8 

Maximum Duty Period in 30 or 28 days 14 37 5 38 

Maximum Duty Period in 365 days 4 10 0 0 

FDP can be 1 hr greater for Flight Attendants 8 21 0 0 

Long Range Maximum 23 60 7 54 

Maximum FDP Crew Complement 1 11 29 3 23 

Maximum FDP Crew Complement 2 10 26 3 23 

Maximum FDP Crew Complement 3 7 18 3 23 

Maximum Hrs of Standby/Reserve Duty 13 34 4 31 

Maximum Hrs Positioning/Deadheading 3 8 8 61 

Maximum FTL in 7 days 9 24 2 15 

Maximum FTLP in 2 weeks 2 5 0 0 

Maximum FTL in 30 or 28 days 20 53 4 31 

Maximum FTL in 1 quarter 3 8 0 0 

Maximum FTL in 365 days 18 47 1 8 

Rules Associated with Sleep and Rest Requirement (n=13) (37%) 

Minimum Rest in 24 hr 35 92 13 100 

Minimum Rest as Long as Preceding Rest 16 42 0 0 

Reduced Rest Period 16 42 10 77 

Compensatory Rest 6 16 4 31 

Crew Rest Facilities 21 55 4 31 

On Duty Rest Break 14 37 6 46 

Duration of Prone Rest (Sleep) 8 21 1 8 

Additional Time for Meals or Travel 10 26 0 0 

Rest during Standby/Reserve Duty 11 29 1 8 

Days Off Within 7 days 22 58 10 77 

Days off Within 28 to 30 days 15 39 5 38 

Days off Within 1 quarter 1 3 0 0 

Days off Within 365 days 4 10 0 0 

Rules Associated with Circadian Rhythm (n=2) (6%) 

Late Finished or Early Starts 20 53 9 69 

Time Zone Readjustment 18 47 1 8 

Other (n=3) (8%) 

Commander’s Discretion 17 45 2 15 

Records Kept on Working Limits and Rest 20 53 0 0 

Fatigue Responsibility 27 71 8 61 
6

Table 4. Number of duty time and rest rules per regulations and CBA by member state or operator 

Documents (n=51) 

Working Hour 

Limitations 

Sleep/Rest 

Requirements 

Circadian 

Rhythm Other 

Regulations 

United States 5 5 0 1 

Barbados 9 9 2 3 

Bosnia & Herzegovina 11 8 1 3 

Brazil 10 6 1 1 

Bulgaria 9 8 2 2 

Cape Verde 8 4 0 2 

Cayman 3 2 2 2 

China 7 2 1 1 

Colombia 3 3 1 0 

Czech 3 3 0 0 

Denmark 3 5 1 0 

Egypt 6 8 2 3 

Dubai U.A.E. 6 5 2 3 

European Union 5 7 2 3 

Fiji 3 6 1 3 

Finland 3 3 1 0 

Germany 1 4 1 0 

Hong Kong 5 8 2 2 

India 8 4 1 2 

Indonesia 5 6 0 0 

Jamaica 6 6 2 3 

Jordan 5 3 0 1 

Kenya 3 5 2 3 

Republic of Korea 1 0 0 1 

Malaysia 4 7 1 3 

Maldives 3 1 0 1 

Malta 3 5 1 0 

Nigeria 1 2 0 1 

Pakistan 8 4 1 2 

Philippines 7 4 0 2 

Singapore 5 7 0 2 

South Africa 4 0 0 1 

Sri Lanka 7 6 0 3 

Sudan 1 0 1 2 

Tanzania 5 2 2 2 

Trinidad & Tobago 8 9 2 2 

Uganda 3 5 1 2 

United Kingdom 8 8 2 2 
7

CBAs. Barbados and Trinidad& Tobagoregulations provided the most rules (n=9) associated

with sleep and rest requirements, while Qantas

Airway Ltd. (n=7) represented the majority of

the CBAs. It is important to note that a larger

number of duty time and rest rules does not

necessarily equate to a superior fatigue risk

management. For example, if a CAA has the

most rules related to duty time and rest but the

rules are outdated and not scientifically based,

their effectiveness to manage risk associated

with fatigue is likely inadequate. 

We anticipated that the number of rules

representing circadianrhythmswouldbelower

than other categories because it is difficult for

prescriptive rules to account for physiological

functions(i.e.,timezonetransitions,layover andrecovery,

time of day, and circadian rhythms). 

Working Hour Limits

Flight and Duty Period (FDP). ICAO Regulation,

Annex 6, Part I requires its members to establish aircrew

flight and duty time limitation and rest requirement

scheduling practices that minimize fatigue. As flight

attendants carry out their duties both on and off the aircraft, their workload varies; and it has been reported that

underload and overload conditions are potential causes

of fatigue(Hancock & Verwey, 1997). The combination

of workload and flight and duty period (FDP) has the

potential to magnify the effects of fatigue significantly;

therefore, prescribing aproper balance betweenworkload

and the number of working hours scheduled is critical

to prevent fatigue. 

Mostoftheregulations(95%) andagreements(100%)

usedFDPtomanagefatigue and41%ofthoseregulations

and 70% of CBAs used a 14-hr daily limitation most

often. Table 5 shows the percentage of regulations and

CBAs using the number of FDP hr. No justification was

offered to validate a 14-hr FDP limitation. The NTSB

safety recommendations issued in recent years regarding

fatigue included the guidance that flight and duty time

limitations and rest requirements should be based on science and standardized across current diverse operations. 

Additionally, scientific and medicalevaluators of the EU 

OPS flight time limitation rules Subpart Q, (Moebus,

2008) was critical of a 13-hr FDP. Moebus warned that

a single FDP should never exceed 13 hr, except under

specific conditions and suggested that FDP periods

greater than 13 hr wereinconsistent with current fatigue

research. Goode (2003) warned that for pilots, the risk

of having an accident was 5.5 times higher when the

Table 4. (continued) 

Documents (n=51) 

Working 

Hour 

Limitations 

Sleep/Rest 

Requirements 

Circadian 

Rhythm Other 

CBAs 

U.S. - American Airlines 2 4 1 0 

U.S. - Delta 5 4 0 1 

U.S. - Frontier 4 4 1 1 

U.S. - Lynx 2 5 0 1 

U.S. - Northwest Airlines 8 4 1 1 

Australia - Qantas Airways Ltd 4 7 0 0 

Australia - Jet Star 3 4 1 0 

Canada - Air Transat 3 5 1 0 

Canada - First Air Canada 3 2 0 0 

New Zealand - Air New Zealand 6 6 2 0 

New Zealand - Freedom Air Ltd 8 4 1 1 

New Zealand - Pacific Airline 5 2 1 0 

New Zealand - Jetconnect 4 3 1 2 

Table 5. Percentage of regulations and CBA using number 

of FDP hr 

FDP Hour Limitation 

Within 24 hr 

% 

Regulations 

% CBAs 

8 5 0 

10 3 0 

11 5 8 

12 8 15 

13 17 0 

14 41 70 

15 12 0 

16 8 0 

17 0 8 
8

FDP is 13 hr or more. “There is a discernible pattern

of increased probability of an accident the greater the

hours of duty time for pilots.” (Goode, 2003, p.311). 

The probability of fatigue also increases as more sectors

are flown, as reported by Powell, Spencer, Holland,et al.,

(2007). Although these studies were pilot specific, they

are consistentwithand relevanttoflight attendant duties,

since many airlines have opted to apply pilot flight time

limitation (FTL) rules to their flight attendants. 

Flight Time. Many airlines have opted to apply FTL 

rules to flight attendant schedules. The majority of the

regulations (53%) and CBA (31%) with a FTL rule

restricted the hr of work within a month (28 or 30 consecutive days). However, there was significant variability

(85 – 210 hr) per month that a flight attendant could

work, depending onthe CAA or operator. This variability

suggests: (1) Lack of international standardization: (2)

Outdated regulations that have not incorporated current

scientific principles and knowledge on human fatigue;

(3) Different flight operations require more or less hours

per month (i.e., night time, long-haul, short-haul, and

international operations). Research results are clear in

describing the differencesin fatigue associatedwith these

diverse operations (Co, Gregory, Johnson, Rosekind,

1999; Nagda & Koontz, 2003; Rosekind, Neri, Miller,

et al., 1997; Rosekind,Miller, Gregory,& Dinges, 2000). 

Most of the CBAs (75%) and 45% of the regulations

with an FTL rule used a 100-hr limitation within a 28

or 30 consecutive day period. This is effective if the 100

hr are spread out evenly within the month, instead of all

occurring during a portion of the month (e.g., a flight

attendant completing 100 hr in thelast two weeks of the

month). Some regulators specified that scheduled flight

hours had to occur evenly during any 28/30 consecutive

day time period which guards against accumulating and

working many hours within a short time frame. 

Long Range and Crew Complement. Most regulations

were ambiguousregardingwhether or notthey addressed

short- andlong-rangeoperations. Forexample,ina section

of one country’s regulation, the rule stated the operator

shall not assign a cabin crewmember an FDP to exceed

14 consecutive hr within 24 consecutive hr. However, in

anothersectionofthesameregulation,theFDPwas16hr

or more, provided they added cabin crew membersto the

original crewcomplement. Wemade an assumption that,

if the regulation had a provision for crew complement,

then it had “long-range” or “long-haul” operations. Also,

the organization of some regulations were ambiguous

in differentiating between the duty time and rest rules

applied at home base vs. during a layover. 

The long-range rule used in 63% of the regulations

and 54% of the CBAs had an average 18-hr FDP per 24

consecutivehr. The United Arab Emirateshadaprovision

intheregulationthat anoperatorshallhave anestablished

FRMS in place for ultra long-range operations.

FDP One Hr Greater for Flight Attendants. Length of

duty is one of several factors that contribute to flight attendant fatigue (Nesthus et al., 2007). Pilots and flight

attendantsworking thesameflightmaynothavethesame

reporting time because some operators schedule their

flight attendants to report one hr earlier than pilots to

accommodate for pre-flight preparations and a briefing. 

None of the CBAs had a rule for cabin crewmembers to

report one hr before the flight crew, while 22% of the

regulations had this provision. One recommendation is

for airlines to develop moreefficient briefing strategies to

allow the cabin crew to have the same FDP as the flight

crew because the level of fatigue for flight attendants

maybe greater, since they normally exert more physical

activity than flight crews (Moebus, 2008). Additionally,

an FDP longer than 13 hr is contrary to some scientific

evidence (Goode, 2003). 

Standby Rules. Standby duty may be counted as full or

half working time, depending on whether the flight attendant is in the airport, at home, or in a hotel. However,

fatigue normally increases over a period of time during

wakefulness, whether an individual is performing tasks

with higher than normal workload or idle (Åkerstedt,

Folkard,&Portin,2004; Hancock&Verwey,1997). Some

regulators provide limitations on the maximum hours

for standby and also require that the accommodations

provided by the operator during standby will be suitable

to allowrest. Themaximumperiod a flight attendantwas

allowed to spend on standby for the regulations (34%)

and CBAs (31%) was approximately 12 hr, but 66% of

the regulations and 69% of the CBAs had no maximum

allowable standby period provision. Only 29% of the

regulations and 7% of the CBAs provided guidance on

the rest period associated with standby duty.

Positioning. Depending upon whether positioning

precedes or follows an FDP and rest period, at least half,

orin some cases all, ofthetimerequired for positioning is

countedtowardthe cumulativetotaldutyhours. Although

a flight attendant might have a sleep opportunity during

positioning, the duration and quality of that sleep is expectedtobesignificantly reduced. The averagemaximum

time for positioning for the CBAs (18-hr) was greater

than the regulations (13-hr) and 7% of the regulations

and 61% of the CBAs had a provision for extending the

maximum time allowed for positioning. 

Sleep and Rest Requirements 

Minimum Rest. The duration and timing of the rest

period are critical factors in fatigue management. The

National Sleep Foundation recommends that adults

get 7-9 hr of sleep during the night. When an adult
9

chronically gets less than 7-9 hr of sleep, impaired brain

function and cognitive performance deficits are likely

to occur and increases risk (Van Dongen, Maislin, Mullington, & Dinges, 2003). Cumulative fatigue becomes

problematic when minimum rest is reduced and occurs

repeatedly across a three- to four-day trip. 

Most of the regulations (92%) and all of the CBAs

mandated a minimum rest period ranging from 8-16 hr,

with the regulations averaging approximately 11 hr and

the CBAs 10 hr. Type of operations and lack of an internationalstandardizationmay explainthe variablerangein

minimumresthr. The U.S. was among the17%ofregulations with a lower than the average minimum rest period

(9 hr), however; if the operator provided transportation

(not local), travel time was not included as part of the

rest period. India had the longest minimum rest period

of 16 hr while Nigeria had the least at 8 hr. Barbados,

Trinidad, and Tobago regulationsexcluded travel timeto

and from the rest facility and also allowed time for hotel

check-in and check-out, personal hygiene, and meals to

permit 8 hr of sleep in suitable accommodations.

Johnson (2009) recommends a procedure to “count

sleep” to ensurethat we are getting 7-9 hr of sleep. People

typically overestimate the amount of sleep they get by

not considering the time necessary to prepare for sleep,

get ready for work, and all of the activities that normally

occur in between. Table 6 demonstrates the “counting

sleep” concept and how difficult it might be for a flight

attendant to get 7-9 hr of sleep after working a 14-hr

FDP with a 10-hr minimum rest period. Accounting

for thetimeit takes to prepare meals, interact with other

familymembers, and other normal adultresponsibilities,

it would be impractical to expect a flight attendant to

function optimally and maintain a high quality of life

with only a 9-hr rest period for an extended period of

time at home. Table 7 demonstrates how a flight attendant would dramatically modify his/her normal lifestyle

to obtain 7-9 hr of sleep. 

Additionally, it is important to notethat rest periods

should be protected from interruptions such as calls

from the airlinefor variousroutinereasons. Someregulations have a clause that doubles the rest period if the

Table 6. Time calculated for routine activities following a 14-hr FDP getting less than 8 hr. of sleep 

Hr Min Activity 

 30 Wake-up, groom and dress 

1 Wake-up children and help get them ready 

 30 Make and eat breakfast 

 30 Commute to work – drop kids at school/daycare on the way 

14 FDP 

 30 Commute home – pick-up kids on the way home 

1 Family activities or household responsibilities 

1 Prepare dinner 

1 Clean kitchen, check homework assignments, put kids to bed 

1 Unwind, watch TV, read, pay bills, etc 

 30 Prepare for bed-time; brush teeth, hair, wash face, shower, etc. 

21 30 Total hr of activities 

2 30 Number of hr left for sleep 

 

Table 7. Time calculated per activity following a14-hr FDP with dramatic adjustments to allow for 8 hr 

of sleep 

Hr Min Activity 

 30 Wake-up, groom and dress, grab breakfast on the go 

 30 Commute to work 

14 FDP 

 30 Commute home; get fast food at drive-through and eat in car 

 30 Prepare for bedtime; brush teeth, wash face, shower, etc. 

16 0 Total hr of activities 

8 0 Number of hr left for sleep 
10

airline interrupts the sleep period. However, Bulgaria

allows a limited amount of interrupted rest and interruption of night rest is admissible for not more than 3

consecutive nights.

Reduced Rest. Almost half (45%) of the regulations

and 77% of the CBAs had the provision to reduce the

minimum rest period when unforeseen circumstances

occur in the schedule. To take full advantage of the sleep

period during a reduced rest period, the scientific communityrecommendsthattheregulatorshouldschedulethe

reduced rest period to occur during theentire window of

circadian low (WOCL) period to maximize quality sleep

(Akerstedt, 2003). Uganda defines a sufficientrest period

if it includes a period of 8 hr falling between 2200 and

0800 hr local times; however, it had the lowest reduced

rest period (6 hr). Of the regulations and CBAs with

reduced rest period, 59% and 50%, respectively, had an

8-hr limitation. To compensate for the reduced rest period, 16% of theregulations and 31% of the CBAs had a

provisionfor compensatory rest,extending theminimum

required rest period following the next duty period.

Days Off. It is important that operators give crew

members the opportunity to plan quality sleep by notifying them well in advance of their days off; likewise, it is

important for crewmembers to effectively use their days

off. Additionally, operators employing flight attendants

working part-time and who have other employment

shouldensuretheyhavethesameopportunityfor adequate

rest. The United Arab Emirates has provisions for crew

members who have other employment.

Over half (58%) of the regulations and 77% of the

agreements required flight attendants have at least 1

day off during 7 days (See Table 8). While this may be

adequate rest during daytime operations (depending on

the FDP), 1 day off after working 6 days of nighttime

operations would not give crew members the multiple

periods of sleep during the entire WOCL period to

combat cumulative fatigue. Bosnia & Herzegovina, Jet

Star, and Qantas Airways Ltd. required flight attendants

have 2 days off during 7 days.

Crew Rest Facilities. The sleeping quarters used by

crew members during long-range operations and layover are critical to obtaining quality sleep. Some of

the regulators specified that the operator will provide

adequate or suitable crew rest facilities, but they did not

define “adequate” or “suitable” to establish an acceptable

standard. Two regulators provided good examples of

detailed descriptions of crew rest facilities. The United

Arab Emirates (e.g., the rest environment should have

a comfortable bunk, separated and screened from the

flight deck and passengers, equipped with the ability to

control humidity, temperature, lighting, and noise) and

the U.S. Advisory Circular 121-31, Flightcrew Sleeping

Quarters and Rest Facilities. Although AC 121-31 offers

a detailed description to reduce sleepiness and improve

flight crewmember performance, it applies indirectly to

flight attendants. Over half (55%) of theregulations and

31% of the CBAs provided a basic description of rest

facilities on or off the aircraft. 

On-Duty Rest Break. On-duty rest breaks usually apply

to long-range operationswith aircraft designed to accommodatesleeping crew members. Almost half of the CBAs

(46%) and 37% of the regulations had a duty rest break

provisioninwhichtheoperatorwillprovide crewmembers

uninterrupted rest (usually around 4 consecutive hr) in

suitable in-flight accommodations. 

Duration of Prone Rest (Sleep). Generally,therestperiod

referred to in theregulationsincludesthetimeit takesfor

travel, meals, and personal hygiene. A “prone rest” rule

separates actualsleeptimefromother activitiesduring the

restperiodandallowsflight attendants “behind-the-door”

or “prone” rest protection. Only 21% of the regulations

and 7% of the CBAs had a protective provision requiring

operators to give crewmembers prone rest. 

Additional Time for Meals or Travel. Some regulations

specifically noted that the operator should consider the

time it takes to travel to and from the rest facility, hotel

check-in and check-out, personal hygiene, and meals

when computing minimum rest. For example, the FAA 

issued an interpretation emphasizing that transportation

considered “local in nature” means that transportation

to the rest facility should not be so time-consuming that

crewmembers are unable to obtain sufficient sleep. One

ofthemostrecommended changes U.S. flight attendants

Table 8. Number and % of regulations and CBA with average days off per duty period 

Regulations Collective Bargaining Agreements 

Duty Period Days 

Average 

Days Off N % 

Average 

Days Off N % 

7 1 22 58 1 10 77 

28 or 30 7 15 39 9 5 38 

90 10 1 3 0 0 0 

365 96 4 10 0 0 0 
11

suggested in the National Duty, Rest, and Fatigue Survey

was to start the scheduled rest period after arrival at the

rest facility (Avers, King, Nesthus, et al., 2009 under review). On average, U.S. flight attendantswait 16minutes

for transportation, with a total of 49 minutes spent on

travel to the rest facility. This leaves less than 8 hr for

check-in, meals, personal hygiene, and sleep when given

a minimum rest period of 9 hr (Avers et al., 2009, under

review). Over one quarter (26%) of the regulations and

7% of the agreements had a provision for the operator

to allow additional time for rest.

Circadian Rhythms

Late Finishes and Early Starts. Circadian rhythms are

linked to environmental cues of daylight and darkness. 

Night duty brings increased fatigue and when flight attendants work during the WOCL (periods from 2200

to 0459), they are especially susceptible to severe fatigue

(Samel, Wegmann, & Vejvoda et al., 1997; Spencer &

Robertson, 1999). Some regulations had a provision to

limit the FDP during the circadian low or they avoided

scheduling crews for duty during this time. Forexample,

Hong Kong’s CAD 371 cautioned schedulers to avoid

the circadian low period when making crew rosters, and

Trinidad and Tobago stipulated that crew members’ rest

should not be interrupted between 2200 and 0600 local

time. Theregulations (53%) and CBAs (69%) indicated

some provision for late finishes or early starts. 

Time Zone Readjustment. An international jet aircraft

can cross 6 time zones between the U.S. and Europe in

7 hr; however, the rate at which humans can adjust is

at minimum, 1 time zone change per day (Caldwell &

Caldwell,2003). A provisionforincreasing theminimum

rest period due to time zone readjustment appeared in

less than half (47%) of the regulations and 7% of the

CBAs. Malta included a time zone table that was easy

to understand when explaining how the minimum rest

will be increased (see Table 9). 

Other Factors

Fatigue Responsibility. During the investigation of the

Buffalo, New York (Feb. 12, 2009) accident in which 50

people died, NTSB officials discovered that the captain

and first officer commuted from different regions of the

country to perform their jobs prior to the accident. The

airline commented that it was a pilot’s responsibility

to commute to work and be fit for duty. Operators are

aware that they can not control a person’s personal life

and, although theymay givetheiremployeesrest periods,

this does not guarantee that they will take full advantage

of the time to get the necessary sleep to recover from

fatigue. Morethan 70% of theregulations indicated that

a crewmember, the operator, or bothwereresponsiblefor

managing fatigue. 

Commander’s Discretion. The pilot-in-command (PIC)may

exceed the FDP or reduce the minimum rest period due to

certain unforeseen circumstances (weather, air traffic control,

maintenance,etc.). In 48% of theregulations and 15% of the

CBAs, the “commander’s discretion” applied. To guard against

fatigueself-assessmenterrors,the FijiIslands had a provision for

the PIC to gain the concurrence of other crewmembers before

extended the FDP. Barbados limited how long the PIC could

reducetheminimumrestperiodbutgavethePIC thediscretion

toincreasetheminimumrestperiodduetodelaysintraveltoand

fromtherestfacility, hotel check-in and check-out, andmeals. 

Fatigue Records Kept. Keeping organizational and

individual records of actual duty and rest periods is

helpful when looking back at actual duty and rest times. 

This procedure can help prevent illegal operations and

providesinsightinto pastschedules or circumstancesthat

Table 9. Example of Malta’s time zone minimum rest table 

Malta Example 

When the location of rest is 3 time zones or more from where the FDP commenced, 

minimum rest following a FDP shall be increased as follows: 

Time Zone Difference Minimum Rest Increased By

0 – 2 time zones NIL 

3 – 5 time zones 1 hr 

6 – 7 time zones 2 hr 

8 time zones or more 3 hr 
12

produced orelevated fatiguerisk factors. Over half(52%)

of the regulations had a provision that the operator or

the individual should keep duty and rest period records

for a specific amount of time.

FRMS. Several CAA representatives advised us that

they were developing provisions for a FRMS, including

Transport Canada, the European Union, and New Zealand. Additionally,ICAO is currently requiring operators

to use a FRMS in conjunction with or as an alternative

to scientifically-based, prescriptivefatiguerules. Also, any

deviationfromthememberstates’prescriptivelimitations

on flight time, duty periods, flight duty periods and rest

periods by the operator should mandate an FRMS. 

Transport Canada. Canadian aviation regulations

(CARs)haveduty time andrestrulesforflight crewmembers(pilots), but flight attendant flight and duty time and

rest requirements are currently governed by the Canada

Labor Code and by CBAswith theindividualemployers,

where they exist. Transport Canada proposed duty time

and rest regulations for their flight attendants through

formal consultations with all stakeholders, which began

in February 2004; however, a final proposed amendment

to the CARs has yet to be introduced. During the initial

consultation process, it was determined that further research and consultation was necessary, with an objective

to coordinate any regulatory initiatives in relation to this

issuewithother areas ofthe aviationindustry,particularly

aviation maintenance personnel who also lack duty-time

limitations under the CARs. Transport Canada is taking

preliminary steps to require by a rulethat operators must

implement a fatiguemanagementsystem. Inlightofmore

recent considerations towards operators implementing

a fatigue management program as part of their broader

Safety Management System (SMS), theinitialregulatory

proposals have been temporarily suspended so that work

can progress to harmonize with the concept of fatigue

risk management and to take into account the efforts

and recommendations of the ICAO (C. Dann, personal

communication, Oct. 16, 2008).

European Union. The European Aviation Safety Agency

(EASA) and The Joint Aviation Authorities (JAA) temporarily transferred their FTL operations responsibilities

to European Union Operations (EU OPS) 1899/2006

governing 27 countries(Z. Savina, personal communication,Jan. 9,2008). OnJanuary30,2009, EASA proposed

changes affecting cabin crew training, medical fitness,

and FTL and also proposed adding a FRMS as the next

step after the update of the prescriptive flight time, FDP,

and rest period requirements. They issued certification

specifications, taking into account the latest scientific

and technicalevidence, and they standardizedflight-time

limitation schemes to provide for uniformity and fair

competition in the aviation market. However, member

states may deviate from the agency’s FTL requirements,

subject to review and approval. For example, in April

2005, easyJet, a large European low cost carrier became

the first major airline to be granted alleviation from the

FTL prescriptiverules based on theresults of a safety case

report during a 6- month roster trial. 

Some of the European Union member states (i.e.,

Germany, Czechoslovakia, Finland, and Denmark) are

included in this analysis, in addition to the main EU 

OPS regulation, becausethey have written a supplement

that imposes stricter rules than the governing authority. 

New Zealand. The New Zealand CAA indicated that

there are no prescriptive rules governing flight attendant

fatigue, but the operators areresponsiblefor monitoring

their work load, which could be done through a fatigue

management program. The CAA is taking preliminary

steps to require by a rule (initial draft of rule proposal

expected in September 2009) that operators must have

established a fatigue management system. This requirement is limited to agricultural operations and work on

it has begun (E. Randall, personal communication,

September 9, 2008). 

Discussion

The examination of international policies and regulations has revealed 2 overarching types of regulatory

practices: commonpractices andbestpractices. Common

practices manage fatigue risk almost solely through prescriptivelimitsonthemaximumdurationofworkperiods

and minimum duration of rest periods. Best practices

manage fatigue incorporating science-based knowledge

regarding time zone transitions, layover and recovery,

time of day, and circadian rhythms (i.e., physiological

functions,such as body temperature, hormonesecretion,

sleepiness, wakefulness, and alertness variations within a

cycle of approximately 24 hr). 

Common Practices

The results indicate that internationally, common

practices are based on prescriptiverules that specify duty

time and rest limitations within a period of time. Globally, each operator schedules flight attendants based on

prescriptive rules, while bracing for likely disruptions

that increase the costs of airline operations. “Domestic

flight delays last year cost the U.S. economy as much as

$41 billion and raised airlines’ operating costs by $19

billion” (Fleming, 2008, p.1). 

Due to recent cost increases, operators appear to be

scheduling to the prescriptivelimits morefrequently. An

FAA cabin safety ASI explained, “Now as a result of the

economics, airlines are now scheduling down to therule. 

When [airline] changed from the agreed labor contract
13

down to therequirements of 121.467, in 2002,this office

received over 108 national hotline complaintsin a 90-day

period” (T. Blower,personal communication, October30,

2008). Some U.S. flight attendants have complained that

airlines arenowsofocusedontheir “on-timeperformance”

thatthey don’tleaveenough timein thescheduleformeal

breaks, particularlywhen they areworking domestic trips

with multiple legs and quick turns (Avers, et al., 2009,

under review). Ultimately, going without nourishment

gradually decreases energy levels during a 12-14 hr duty

day with multiple legs, which undoubtedly increases the

risk of fatigue and reduces safety margins.

These reports indicate that the existing prescriptive

rules are insufficient for effectively managing fatigue in

round-the-clock operations. Dawson and McCulloch

(2005)reported that using prescriptiverules aloneislimiting and inflexible because they permit legal scheduling

to extreme fatigue levels and do not take into account a

schedule with night flying, early starts, late finishes, and

time zone changes. Prescriptive rules also do little to addressindividualfatigueissuesthatmany flight attendants

endure (e.g., interrupted sleep, difficulty falling asleep,

and lack of proper nutrition). Essentially, prescriptive

rules manage the duty time of flight attendants but,

they do not effectively account for the amount of sleep a

flight attendantwillreceivebetweendutyperiods. Hence,

they fail to optimally manage the risk of fatigue. When

comparing U.S. prescriptiverules with the other nations

in this study, U.S. flight attendants are required to work

a longer FDP and long-range maximum hr per day and

havelessrecovery time dueto a shorterminimumrest and

reduced rest period (See Fig. 1). Hence, U.S. prescriptive

rules are among theleastrestrictive,representing a greater

than typical fatigue risk.

Best Practices

Best practices are adaptive and manage

fatigue by incorporating science-based

knowledge. An FRMS is a popular solution to counterbalance the inflexibility

of the prescriptive rules and shows some

effectiveness within airlines currently

applying this approach to fatigue mitigation. TheICAO isrequiring international

regulatory authoritiestointegrate aFRMS 

as part of their overall SMS, while the

EU-OPS requires the implementation of

a FRMS if a country has a reduced rest,

extendedduty,orsplit-timeruleprovision. 

However, it should be noted that simply

modifying the prescriptive rules to allow

forincreased flexibility in FDP limits does

not necessarily lead to improved or more

comprehensive management of fatigue (Signal, Ratieta

& Gander, 2006). Only a mature FRMS program with

the following should be considered:

• Data-driven.

• Adaptive.

• Recognizes fatigue risks.

• Develop and evaluate mitigation strategies.

• Manage any emerging operational risk. 

• Iterative feedback and solutions.

• Identifiesoperational aspectsthat contributetofatigue. 

Recommendations

Werecommend establishing a flight attendant fatigue

workgroup of subject matter experts, aviation stakeholders, medical and research scientists, and aviation

SMS experts to evaluate 14 CFR sections 121.467 and

135.273 for possiblerevision and to develop an adaptive

fatigue mitigation safety system, such as a FRMS, that

combines the scientific principles and knowledge with

operational support. 

Limitations

Thisstudy foundsome variabilitybetweenthenumber

of duty time and restrules provided intheregulations and

CBAsevaluated. Thismayhave beentheresult ofpossible

misinterpretation of the ambiguities and inconsistencies

in the regulations and CBAs, since some were found to

be difficult to understand. Also, fewer rules were found

for some European states because we only examined a

partial supplement of a primary regulation. 

The data reported in this study reflect a fairly comprehensive review of information provided in the form of

officialregulations and CBAsobtainedfrominternational

sources. Some of the information reviewed (particularly

0

5

10

15

20

25

Daily FDP Long Range Max Min. Rest Reduced Rest

Hours 

U.S. Others

U.S. Duty and Rest Rules Compared With Other Countries

Figure 1. U.S. regulation comparison.
14

with regard to the CBAs) may have changed between

the time the documents were collected and when this

report was written. While many ICAO member states

had regulations for pilot’s FDP and rest requirements,

guidance specifically written for flight attendants was

minimal. Also, there was some variability with respect to

the number of duty time and rest rules found between

countries. Again, this might have been a result of our

interpretation and the inherent ambiguities and inconsistencies in those regulations and CBAs. 

References

Akerstedt, T., Folkard, S. &Portin, C. (2004). Predictions

fromthethree-processmodel of alertness. Aviation, 

Space and Environmental Medicine, 75 (Supplement 

1), A75-A83.

Akerstedt, T. (2003). Shift work and disturbed sleep/

wakefulness. Occupational Medicine, 53, 89-94. 

Avers, K., King, J., Nesthus, T., Thomas, S., Banks, J. 

(under review). Flight attendant fatigue, Part I:

National duty, rest, and fatigue survey. Report in

review, Federal Aviation Administration, Office of

Aerospace Medicine, Washington, DC.

Caldwell, J.A., & Caldwell, J.L. (2003). Fatigue in

aviation: A guide to staying awake at the stick. 

Burlington, VT. Ashgate. 

Cabon, P., Mollard, R., Debouck, F., Chaudron, L.,

Grau, J.Y., Deharvengt, S. (2009). From flight

limitations to fatigue risk management systems. 

Retrieved January 9, 2009 from www.resilienceengineering.org/RE3/papers/Cabon_Mollard_

Debouck_Chaudron_Grau_Deharvengt_text.pdf.

Co, E.L., Gregory, K.B., Johnson, M.J., Rosekind,

M.R. (1999). Crew Factors in Flight Operations

XI: A Survey of Fatigue Factors in Regional Airline Operations (NASA Technical Memorandum

208799). Moffett Field, California: NASA Ames

Research Center. 

Dawson, D., & McCulloch, K. (2005). Managing Fatigue: It’s About Sleep. Sleep Medicine Review, 9,

365-80. 

Fleming, S. (2008). Commercial aviation: Impact of airline crew scheduling on delays and cancellations of

commercialflights. Report GAO-08-1041R Airline

Crew Scheduling, Washington, DC.

Goode, J.H. (2003). Are pilots at risk of accidents due

to fatigue? Journal of Safety Research, 34, 309-13. 

Hancock,P.A.,&Verwey,W.B. (1997). Fatigue,workload

and adaptive driver systems. Accident Analysis and 

Prevention, 29, 495–506.

Johnson, B. (2009). Counting sleep. Retrieved Jul. 14,

2009, from http://hfskyway.faa.gov/hfskyway/

index.aspx.

Kirkland, G., (June 2008). Crewmember Flight, Duty

and Rest Requirements: FAA Regulations, Initiatives, and Challenges. Presented atthe FAA Fatigue

Management Symposium: Partnerships for Solutions; Vienna, VA: Retrieved June 22, 2009, from

theFederal Aviation AdministrationWeb site:www.

faa.gov/about/office_org/headquarters_offices/

avs/offices/afs/afs200/media/aviation_fatigue_

symposium/KirklandAppComplete.pdf.

Moebus, P. (2008). Scientific and Medical Evaluation

of Flight Time Limitations. Final report 1.0 no. 

TS.EASA.2007.OP.08 for EASA by Moebus Aviation, Sept. 30, 2008.

National Transportation Safety Board (2008). Most

Wanted Transportation Safety Improvements,

Aviation Issues. Reduce Accidents and Incidents 

Caused by Human Fatigue in the Aviation Industry. Retrieved Apr. 28, 2009, from www.ntsb.

gov/Recs/mostwanted/aviation_reduce_acc_inc_

humanfatig.htm.

Nagda, N.L., & Koontz, M.D. (2003). Reviewofstudies

on flight attendant health and comfort in airliner

cabins. Aviation, Space, and Environmental Medicine, 74, 101-9.

Nesthus, T., Schroeder, D., Connors. M., RentmeisterBryant, H., & DeRoshia, C. (2007). Flight attendant fatigue. Report DOT/FAA/AM-07/21, Federal Aviation Administration, Office of Aerospace

Medicine, Washington, DC.

Perrir, A. (2000). Jet crew did more harm than good,

survivors say. USA Today, Nov. 3, 2000, 16. 

Powell, D.M.C., Spencer, M.B., Holland, D., Broadbent, E., & Petrie, K.J. (2007). Pilot fatigue in

short-haul operations: Effects of number ofsectors,

duty length, and time of day. Aviation, Space, and 

Environmental Medicine, 78, 698-701.

Rosekind, M.R., Miller, D.L., Gregory, K.B., & Dinges,

D.F. (2000). Crew Factors in Flight Operations

XII: A Survey of Sleep Quantity and Quality in

On-Bard Crew Rest Facilities (NASA Technical

Memorandum2000-209611). Moffett Field, California: NASA Ames Research Center.
15

Rosekind, M.R., Neri, D.F., Miller, D.L., Gregory,

K.B., Webbon, L.L., Oyung, R.L. (1997). Crew

Fatigue Research Focusing on Developmental and

Use of Effective Countermeasures. ICAO Journal, 

52, 20 - 22.

Samel, A., Wegmann, H.M., Vejvoda, M., Drescher, J.,

Gundel, A.,Manzey, D., &Wenzel,J. (1997). Twocrewoperations: Stress and fatigue during long-haul

night flights. Aviation, Space, and Environmental 

Medicine, 68, 679-87.

Signal, L.T., Ratieta, D., Gander,P.H. (2008). Flight crew

fatigue management in a more flexible regulatory

environment: An overview of the New Zealand

aviation industry. Chronobiology International, 25,

373-88.

Signal L., Ratieta D., Gander P.H. (2006). Fatigue management in the New Zealand aviation industry. 

Australian Transport Safety Bureau Research and

Analysis Report. Retrieved April 24, 2009, from

www.atsb.gov.au/media/32736/grant_20040048.

pdf.

Spencer, M.B., & Robertson, K.A. (1999). The Haj

operation: alertness of aircrew on return flight

between Indonesia and Saudi Arabia. DERA 

Report No. DERA/CHS/PPD/CR980207/1.0,

Farnborough, UK.

Van Dongen, H.P., Maislin, G., Mullington, J.M., &

Dinges, D.F. (2003). The cumulative cost of additionalwakefulness: dose-responseeffects on neurobehavioral functions and sleep physiology from

chronic sleep restriction and totalsleep deprivation. 

Sleep, 15, 117–126.