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has been demonstrated through previous experience at easyJet. Operators are responsible and are accountable for their own risk with the overall requirement of achieving a level of risk as low as reasonably practicable.
The UK CAA has expressed this concern in FODCOM 10/2009 as follows: “The high levels of crew utilisation now being achieved has led to concerns that the degree of protection against fatigue offered by basic compliance with those quantitative FTL provisions specified in CAP 371 Annex A is no longer sufficient for larger companies”

S. Stewart, F. Koornneef, R. Akselsson, and C. Turner  - HILAS 2009

 

1.5 Fatigue and Regulation
1.5.1 Adequacy of current fatigue controls: Flight Time Limitations (FTL)
Flight Time Limitations (FTL) or Hours of Service (HOS) guidance are the traditional regulatory approach for addressing the fatigue risk of flightcrew. They are applied at the schedule development stage to provide proactive compliance criteria to the rostering team in the design of optimal commercial schedules. FTL function is to limit duty and provide guidance on minimum rest breaks between shifts (recovery time). FTL’s thus provide guidance to rostering staff on maximum duty and block hours operated per week, month and annual rolling limits.
The UK CAA introduced an FTL scheme based on the available scientific knowledge at the time (Bader, 1973) to provide operators with guidelines for the avoidance of fatigue in aircrews in Civil Aviation Publication (CAP) 371 (UK CAA, 2004, 4th edition). The Bader report however, duly acknowledges the lack of available objective scientific and operational studies to support the development of the FTL scheme. The document was periodically reviewed in light of industry experience and advances in aeromedical knowledge (CAA, 1982, 1990 and 2004). The committee report states that “no

industries is compliance with FTL, or other limitations on hours of service (HOS). The effectiveness of FTL as a control for fatigue risk has been criticized on the basis that limitations tend to be used as a rostering target, rather than guidance. In this context, there are a number of reservations regarding FTL. It has been argued that HoW limitations are not scientifically defensible, do not enable actual workforce fatigue to be measured or predicted and can inadvertently encourage rostering practices that increase fatigue (Fatigue Expert Group, 2001). In addition, FTL have been criticized because there is significant variability between prescriptive rule sets offered by different aviation regulation authorities (Cabon et al, 2002).
S. Stewart, F. Koornneef, R. Akselsson, and C. Turner  - HILAS 2009

FTL schemes by their nature are a form of static safety management and do not consider:
. Sleep opportunity and quality associated with roster design - circadian influence
. The awareness of risk associated with the flight from a rostering perspective e.g.
weather, ATC, Terrain, crew experience; aircraft serviceability
　
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