For those of us who have been frustrated by the FAA’s inability to issue a comprehensive duty and rest rule for mechanics, it was disappointing to see the agency’s latest attempt at tackling the issue. Even as the FAA specifically recognizes in this latest draft Advisory Circular the significant fatigue issues that face maintenance workers: “Of concern to [the FAA] is the finding that maintenance personnel tend to get three hours less sleep per night than is recommended. That is a sleep debt twice the national average. Sleepiness and fatigue associated with sleep debt is cumulative. This means that losing even an hour of sleep every other night over the course of a week will produce conditions that negatively affect performance.”
Instead of proposing clear maximum duty times and minimum rest requirements, the FAA has instead proposed a draft advisory circular to manage mechanic fatigue risk. Since an AC is not regulatory and therefore not mandatory, its chances of being complied with are limited by the usual factors: time and money. So, no doubt, the best carriers will take this AC to heart and integrate its proposals into their safety management systems. But the rest–of which there are many–will not. And there won’t be anything the FAA can do, of course, because no one needs to comply with an advisory circular. The FAA makes that abundantly clear in the draft itself: “Not Mandatory. This AC is informational and is not mandatory. It does not constitute a regulation.”