Position Paper: Flight Time Limitations

The European Transport Safety Council (ETSC) recognises that fatigue is a significant contribution to accident risk across the transport modes. It also recognises that the management of fatigue is a complex process and that the proposals from the European Aviation Safety Agency represent a comprehensive attempt to resolve this problem. However, it believes that the proposals do not fully and properly reflect the scientific evidence that should underpin fatigue management. Nor do they fully incorporate the scientific evidence which EASA itself commissioned.