Managing Risk by “Bits & Pieces”

After many years of dilly-dallying, conducting hearings, and being pressured by a concerned public – the FAA has finally and officially recognized something that even a child understands.
Tired pilots are a risk when flying aircraft.
Was that a surprise? Who could really argue with that obvious verdict? Why did it take so long to decide it? What should be done about it? How can that risk be avoided?
The root of this seemingly clumsy, slow, and maddening process of managing risk is conflict – not about the risk itself but what to do about it. The FAA has the nasty job of resolving that conflict.
Society is complex. It consists of folks with many differing interests. So airlines, pilots, passengers, aircraft controllers, medical experts, airport managers, aircraft manufacturers, and trade unions among many others potentially have “an ox to gore” in reducing the risk.
Pilots suffer three types of fatigue – transient, cumulative, and circadian. The first is acute fatigue resulting from extreme sleep restriction or extended hours awake within 1 or 2 days. Cumulative fatigue is produced by repeated mild sleep restriction or many hours awake for a series of days. Circadian fatigue is reduced performance during nighttime – especially between 2 and 6 AM.
So how tired should a pilot allowed to be—before the risk is too high? How will we know the pilot is that tired? What has to be done to prevent tired pilots from flying? Who will enforce prevention of tired pilots being required to fly?
The FAA issued a 314-page rule to answer those questions. But don’t relax yet.
It only governs pilots of passenger airliners! Those flying cargo aircraft are exempt!
So . . . more “bits and pieces” management of aircraft risk . . .