Review Policy on Hours of Work

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Review Policy on Hours of Work

46TH ANNUAL CONFERENCE, Istanbul, Turkey, 16-20 April 2007

WP No. 165

Review Policy on Hours of Work

Presented by PLC

Introduction

1.1  The purpose of this working paper is to review the IFATCA policy on working hours with respect to the new tendencies in ATC work.

1.2  The Work Hours section of the IFATCA Manual was last reviewed in 1999.

1.3  There were duplicates of information scattered throughout which needed to be tidied up.

Discussion

2.1  The environment in which air traffic controllers work has changed in the last years. The controllers’ work is becoming more and more air traffic management, a combination of air traffic control and constant monitoring in a complex highly technical computerized operation room, which demands high levels of concentration and precision. There has been a large increase in security and anti terror measures, as well as an increase in air traffic volume especially during night hours and also the privatization/ commercialization process that seeks to minimize staffing and maximize productivity. All these factors, and the need for increased vigilance and awareness, in an occupation which has especially high demands in relation to the level of concentration and precision might affect the performance of the air traffic controller physiologically and mentally and increase physical and mental fatigue.

Roster design should reflect fatigue risk management principles in respect to safety and efficiency. The work hours section needed to be reviewed in relation to the work/rest scheme, four eyes principle (4EP) and single person operation (SPO), the legal liability of the air traffic controller and the difference between male and female controllers.

2.2  There are 3 subjects in the IFATCA Manual that are related to work hours but not covered in the hours of work policy, namely:

  • The Four eyes principle (4EP);
  • Work as an ATCO when pregnant;
  • Legal liability.

2.3 Due to the nature of air traffic, Air Traffic Control is a 24 hour-a-day, 365 days-a-year job, requiring staff to work shifts at all times of the day and night. In recent years computer scheduling programs have been increasingly used to construct rosters. These programs primarily look at numbers – how many controllers are required on watch at any given time based on traffic levels. Unfortunately, these programs pay scant regard to social considerations when choosing work cycles. Long, complicated and erratic work schedules all contribute to disrupting the body’s circadian rhythm. This in turn makes it very difficult for the body to get used to the schedule, consequently making recovery between shifts more difficult. Air Traffic Controllers are required to keep themselves medically fit for work. In turn employers must do their part to medical fitness, by providing rosters which reflect fatigue risk management principles.

2.4  The 4EP is a safety net that influences staffing. SPO shall be avoided. Air Traffic Control is a system for the ‘safe and efficient movement of air traffic’. The use of SPO degrades the safety aspect of the system by placing undue stress on the controller. This includes the inability to have regular breaks away from position and increased fatigue associated with the extra vigilance required.

2.5  Pregnancy is a normal female human condition which can be accompanied by physiological changes that can intensify the general fatigue. Special attention and sensitivity should be exercised to provide extra rest hours when requested by the controller involved.

2.6  Referring to the IFATCA manual 4223 /2.5 Fatigue in ATC 2.5.2:

“Management has the prime role for providing fatigue management and prevention of fatigue-related catastrophes”.

 

Controllers shall not be held liable in the case of an accident or incident if the controller has previously registered a formal complaint of exaggerated working hours or lack of fatigue management.

2.7  The Work Hours section had some duplicates of information, the following changes were made to tidy it up:

  • Paragraph 3.1.6 was moved to follow 3.1.10 (and all sections renumbered accordingly). This keeps all information on night shifts together, then moves on to night/ morning, then morning shifts.
  • Paragraph 3.2.4 amended to read ‘The continuous operational duty for a controller should be 2 hours maximum…’.
  • Paragraph 3.4.3 Minimum working hours must be increased ‘at difficult positions or sectors’. This was removed as it is covered in paragraph 3.4.2.
  • Operational duty is defined in paragraph 3.2 and as such deleted from paragraph 3.5.2.
  • As traffic levels can change quickly, especially with new airlines coming and going, and summer and winter schedules changing, once a roster is worked out, it should be reviewed regularly with reference to traffic levels, recurring peaks, LOA’s, rostering schedules and procedures.

Conclusions

3.1  The Hours of Work section has been reviewed with the minor amendments made as outlined in point 2.7 above.

3.2  Rosters should be constructed following a simple pattern, with shifts of the same or very similar length and adequate breaks between shifts and shift cycles.

3.3  Special attention and sensitivity should be exercised with pregnant controllers. Extra rest hours shall be provided when requested by the controller.

3.4  The close link between rest hours and safety must be considered in the context of legal labiality of the controller in case of accidents or incidents.

Recommendations

4.1  To accept the amendments made as outlined in point 2.7 above.

4.2  To add:

‘Rosters should be constructed following a simple pattern, with shifts of the same or very similar lengths and adequate breaks between shifts and shift cycles’

as 3.2.1.

4.3  To add:

‘Extra rest hours shall be provided when requested by a pregnant controller’

as 3.2.7.

4.4  To add:

‘Controllers shall not be held liable in the case of an accident or incident if the controller has previously registered a formal complaint of exaggerated working hours or lack of fatigue management and the incident or accident is a result of the lack thereof.’

References

IFATCA Manual.

EUROCONTROL study report on selected safety issues for staffing ATC Operations.

Staffing. A health concern-Doug Churchill EVPP. Controller magazine.

Annex 1 – Proposed new ‘Hours of Work’ section

3 HOURS OF WORK

3.1 Duty Rosters

3.1.1  The duty roster should be based on at least 2 consecutive days off in every 7 days.

3.1.2  Duty rosters should be agreed with the air traffic controllers involved.

3.1.3  SPO shall be avoided. See IFATCA manual page 4114 p.1.6.1

3.1.4  An optimal roster should be promulgated, based on the maximum allowed number of working hours per week and per shift, a minimum number of break periods of an agreed minimum length, both during a shift and between shifts and on an optimal night/day switch number per week or per month as appropriate. This roster requires definition of personnel strength based on the number of sectors and traffic density. It must allow for attribution of a minimum number of days paid leave, sick leave, extraordinary leave and unpaid leave. It must be such that a minimum number of weekends per month and of public holidays per year can be taken as they occur and not later. Conditions for overtime and night work (e.g. rest facilities) must be defined and the regulations governing the various kinds of leave be clearly stated.

3.1.5  Duty rosters including night shifts should be of a rapidly rotating shift system in a morning, evening, night cycle. Consecutive night shifts are not recommended (Toulouse 98.C.5).

3.1.6  Shift systems should not include night shifts that commence on the same day that a morning shift ends.

3.1.7  Change-over times between night shift and the following morning shift should not take place before 6 am local time, to ensure that sleep duration for the morning shift is adequate before commencement of their duty time (Toulouse 98.C.5).

3.1.8  Shift systems should include preferably single night duties only but where consecutive nights are required they should be restricted to the minimum.

3.1.9  In respect of the nature of night shift duties Member Associations pursue additional time off for night shifts worked as compensation. (Rio 1988)

3.1.10  After a night shift, an off-duty period of a minimum of 30 hours is recommended (Toulouse 98.C.5, amended Santiago 99.C.20).

3.1.11  The number of consecutive early starts (shifts starting in the period between 0600 and 0659) should be limited to a maximum of two in a period of 144 hours (6 days) (Santiago 99.C.21).

3.2 Work and Rest Scheme

Definition – Operational Duty: The period which a controller is actually exercising the privileges of the controller’s licence at an operational position.

3.2.1  Rosters should be constructed following a simple pattern, with shifts of the same or very similar lengths and adequate breaks between shifts and shift cycles.

3.2.2  The average time of operational duty and breaks should not exceed 32 hours per week (Jerusalem 95.C.2).

3.2.3  Each shift should not exceed 7 hours 30 minutes including breaks (Jerusalem 95.C.2).

3.2.4  A minimum rest period of 11 consecutive hours per day should be provided (Santiago 99.C.22).

3.2.5  The continuous operational duty for a controller should be 2 hours maximum and should be reduced to 90 minutes for controllers working with visual terminals and/or radar displays; after which a minimum 30 minutes break, away from the working environment should be given to controllers (Copenhagen 78.C.6, amended Jerusalem 95.C.2).

3.2.6  At least one break of a minimum of 1 hour duration, on both day and afternoon shift, shall be given to controllers for the purpose of eating at regular times and to prevent gastrointestinal dysfunctions (Santiago 99.C.23).

3.2.7  Extra rest hours shall be provided when requested by a pregnant controller.

3.2.8  By night the total operational duty time should not exceed 5 hours (Jerusalem 95.C.2).

3.2.9  Controllers shall not be held liable in the case of an accident or incident if the controller has previously registered a formal complaint of exaggerated working hours or lack of fatigue management and these have been determin- ed to be a major contributing factor to the incident or accident.

3.3 Vacation Scheme

3.3.1 The annual leave for a controller should be not less than 30 working days (this is the equivalent of 6 weeks), excluding public holidays, of which 3 weeks must be consecutive.

3.4 Recency and Competency

Controllers involved in other important tasks such as Training (classroom and/or On-the-Job), Supervising, Management and developing New Systems need a minimum amount of working hours in the OPS room to keep them current. In this context the following policy was adopted:

3.4.1 Each Member Association should agree with the appropriate Regulatory Authority a minimum of operational working hours, per rating, for their controllers who are involved in other ATC-related duties (Ottawa 94.C.14).

3.4.2  The minimum operational working hours must be appropriate for the workload of each position (Ottawa 94.C.15).

3.4.3  The minimum working hours may be increased in the following cases:

  • at the introduction of new procedures or ATC systems;
  • at the instigation of an individual controller (Ottawa 94.C.16).

3.5 Extra Duty Link to Policy

3.5.1  Extra duty is defined as any operational or non-operational duty or a combination of both performed outside of the scheduled hours of work which will result in an increased total duty time for the controller.

3.5.2  Non-operational duties are other duties for which the controller is not required to exercise the privileges of the controller license which, from time to time, are assigned to a controller (Theoretical controller training, investigation, etc.).

3.5.3  Extra duty should be voluntary and used only in exceptional situations.

3.5.4  In the interest of aviation safety and the well being of the controller population, extra duty control should be considered as an undesirable method of staffing Air Traffic Control positions and should be avoided.

3.5.5  IFATCA recommends that each Member Association inform its members of the ill effects of sustained extra duty on their health and on the performance of their duties as controllers.

3.5.6  Member Associations should, through consultation with their respective employer, attempt to acquire adequate staffing which considers established documentation on the adverse effects of extended hours of work.

3.5.7  The allocation of overtime should be carried out with limitations in human performance in mind. The combination of overtime and night shifts clearly increase the risk of fatigue among controllers, because resting periods are reduced, and the possibility for sleep-loss recovery may be reduced accordingly (Toulouse 98.A.5).

3.5.8  Member Associations should attempt to have duty time regulated by the appropriate body. Where legislation is not achievable, hours of work and extra duty should be stipulated in their respective collective agreements. (Jerusalem 95.C.2)

Last Update: September 29, 2020  

April 9, 2020   821   Jean-Francois Lepage    2007    

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