Emery in fact did request and was approved for an exemption that allowed its crewmembers to operate utilizing domestic scheduled rules as opposed to domestic supplemental. The primary reason for the grant of the exemption was to prevent precisely what we are talking about specifically circadian flips. Domestic Supp rules forced the Emery pilots into operating not only circadian flips, but also extended layovers, which in fact contributes to sleep deficit. Empirical data, (yes hard scientific studies run by Dr. Paula Tsung University of Ohio and NASA) confirmed that extended layovers in and of themselves not only contributes to sleep deficit, but makes acclimation to circadian transitions through the period defined as a circadian low more difficult.
At that time everyone opposed the exemption despite the fact that hard data sanctioned by the FAA, NTSB, NASA, the Flight Safety Foundation, University of Texas at Austin, University of Ohio, and Stanford University Medical Center Sleep Disorders Clinic confirmed that operating under domestic supp rules not only made no sense, but contributed to a quantifiable and measurable decrease in safety. Ultimately the exemption was approved and the net result was a huge improvement in the quality of schedules, days on, days off and even more important that ever non-existent and not discussed safety gremlin--the commute.
Contrary to popular belief, or the assumed belief, there is hard empirical (yes scientific studies, valid data, calibrated instruments on live human beings in cockpits while flying and while sleeping) that supports every aspect of an exemption request that prevents circadian flips. That is why EVERY country in the world, except for France and the US have moved away from flight time and established a formula for duty time + cycles + time of origin (circadian baseline) as the means for determining what is reasonable and safe from a work standpoint.
Logic (and data) supports the concept that operating 8+ cycles with 8 hours aloft and 16 hours of duty with duty beginning at 2300 is inherently less safe than one that begins at 0900. Having said that, and once again logic (and data) supports the notion or concept that its not unsafe to begin a pairing at 0900 fly west, come east and end your day at your circadian baseline having flown NOT MORE than 2 cycles and receiving 12 hours off to sleep on your own baseline circadian low and receive an opportunity to sleep through your own period of circadian low. Not conjecture, experience, but hard data supported by NASA, FSF, Ohio State, and numerous other hard studies too numerous to mention. The most significant of which involved wiring a statistical sampling of pilots to measure their sleep and alertness responses (both inside and outside the cockpit) measuring brainwave activity to determine the quality and amount of REM sleep, and T-wave data followed by coordination testing which established alertness and tendencies to exhibit episodes of "micro-sleeps" which is in fact the medical issue that is exhibited with extended period of sleep deficit (read circadian transition disturbance). The alternative to this is a daylight departure (short duty day) followed by an attempt at a day sleep, followed by a redeye, followed by another day sleep, followed by a evening departure and night sleep and a day sleep. Optional to that, would be 24-hour layovers, which in fact has been scientifically proven NOT to work. The MINIMUM period established by science and data to acclimate to a circadian transition is 3 days with at least two periods through the circadian low of the new circadian baseline. It was finally this data that convinced the Canadians (who have historically been light-years ahead of the US on flight and duty time issues) to adopt a system that finally ties duty, to circadian, to cycles and encourages schedules that enhance your opportunity to sleep and rest while penalizing those schedules that are produced during the known periods of maximum risk and reduced safety margins.
Assuming the data, the studies, and findings are found to be valid, the concept of a carrier(s) or pilot group(s) taking advantage of that concept and moving towards an improvement in safety margins and quality of life should not be shocking, or the subject of scorn and ridicule. The idea of improving safety AND quality of life should not be mutually exclusive.
An exemption (or even a regulatory change) that encourages multiple cycles and extended hours aloft does not make sense and is completely invalidated by scientific data and would not be approved. By the same token, the same concept taken with the idea to operate through the period defined as a circadian low would also make no sense and would not be supported by data.
Finally, by and large the same science that brought us today’s flight and duty time rules is now refined, with modern instruments, testing techniques, statistical analysis, computers, and yes accident data, that tells us changes should be made along the lines that the exemption is exploring. To repudiate the new science, and data, makes a mockery of the argument that supports the very foundation of what is currently in place. Ultimately, ridiculing the current Science also repudiates the previous Science and therefore completely invalidates current regulatory restrictions. There is a significant difference between destroying the old for the sake of destruction and selfishness, and adjusting that very same reality to new data, refined data, and a new environment with the primary goal of enhancing safety and reducing risks.
To do any less would be compromising safety for absolutely no gain whatsoever and that is what our profession has never been about.
