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Remarks to the International Brotherhood of Teamsters Air Cargo Symposium, Washington, DC
Jim Hall
International Brotherhood of Teamsters Air Cargo Symposium, Washington, DC

Thank you. I appreciate being invited to participate in the International Brotherhood of Teamsters' Air Cargo Symposium - especially just a few days after we all have celebrated the 118th Labor Day - a day dedicated to recognizing the contributions workers have made to the strength, prosperity, and well-being of America.

The subject of your symposium, "Protecting Our Profession," is one that the National Transportation Safety Board and I are vitally interested in. Like you, we work every day to ensure the safety of the transport system, the people who use it, and the people who operate it.

Thomas Jefferson once said, "The care of human life and happiness…is the first and only legitimate object of good government." His statement is as true now as it was in the 18th century and it accurately describes the mission and goals of the Safety Board.

There are those who suggest that the marketplace and the States are sufficient to ensure the safety of our transportation systems - that the federal government isn't needed - or wanted. However, I can say from my years of experience working at the State level, and six years as the Board's Chairman, that, without federal involvement and support, certain safety functions would not be performed.

When it comes to safety and security, the government has a responsibility to protect the interests and well being of all of its citizens. This is true whether it's maintaining a military force, protecting our borders, inspecting our food supply, or ensuring that all Americans are beneficiaries of policies which support one level of safety for all.

As many of you may know, the Safety Board is a small, independent agency - of about 450 employees - all of whom are charged with the responsibility of investigating aviation, rail, highway, marine, pipeline, and hazardous material accidents and issuing safety recommendations to prevent similar accidents in the future. All at a cost of about 18 cents a year to each American - I think that's a great bargain by anyone's calculation.

Among all of the organizations that endeavor to ensure the safety of the nation's transportation systems, the Safety Board stands apart. We focus on every facet of the transportation system - the private and public transportation owners and operators, the manufacturers, and the regulators - looking for ways to improve the system's safety. It's important to note that the Board has no regulatory authority.

We effect safety improvements primarily through indirect pressure - mainly by issuing and advocating our safety recommendations. And, of course, our ability to be effective and to influence change depends on our reputation for doing quality work.

I think our record speaks for itself. Over the years, more than 80 percent of our recommendations have been implemented and those recommendations have led to such improvements as ground proximity warning systems, windshear training and alert systems, and improved de-icing procedures.

Obviously, the Safety Board hasn't achieved these successes alone. The effectiveness of our safety initiatives are also a result of the enforcement efforts of the regulatory agencies, such as the Federal Aviation Administration (FAA), and the oversight provided by State and local governments.

But, ultimately, the success of any safety measure rests with the transportation industries, the operators, the manufacturers, and the employees. And, over the years, the Safety Board's investigations have benefited from the excellent support and expertise provided by the Teamsters, other transportation unions, and the cargo operators.

But, none of us would be here today if our job was done. Today, I want to focus on still needs to be done to protect your profession - by the Board and all of you - in the areas of human factors and operations to improve the safety of the system and those who operate it.

It certainly won't surprise anyone here that the United States has the most developed airfreight market in the world. The rising popularity of electronic commerce, mail-order retailing and faster, freer and more frequent international trade is creating exponential growth in demand for airfreight and express delivery. The latest U.S. Department of Transportation (DOT) figures indicate that cargo-only flights make up almost ten percent of domestic air carrier operations. The aircraft fleet dedicated to cargo flights is growing as well. Over 900 large aircraft are in service now, with that number expected to grow by 50 percent or more over the next ten years. In addition, cargo feeders using smaller aircraft, such as the Cessna Caravan, are expanding into more and more market areas.

In 1999, 60 percent of the world's cargo tonnage moved to, from, or within the United States. One analytical consulting firm, MergeGlobal, estimated that world air freight tonnage increased by 38 percent in just five years - from 16.6 million tons in 1994 to 23 million tons in 1999. As economic globalization increases, and international commerce expands, we can expect air freight traffic to grow as well. Cargo operators, such as Federal Express and United Parcel Service, are among the largest airlines in the world, and new carriers such as Atlas, Polar Air Cargo, Gemini and others, are continuing to grow.

This greater demand, while economically beneficial, presents safety challenges that must be met on a daily basis. The first of these challenges is how we effectively deal with fatigue.

Your workday usually begins as everyone else's is ending - and, we've learned over the years, inverted work schedules can contribute to fatigue-related accidents and incidents. The Safety Board has long been interested in the effects of fatigue on pilots, mechanics, and other transportation professionals. The first Board recommendation on pilot rest and duty limitations was made to the FAA in 1972.

And, recommendations on pilot fatigue and fatigue in all modes of transportation have been on the Safety Board's "Most Wanted List" of safety improvements since the list's inception in 1990. In just the past 11 years, the Board has issued more than 70 fatigue-related recommendations across all modes of transportation. During that same time period, we've also investigated seven aviation accidents that involved fatigue-related issues.

No one would disagree that sleep loss or a disturbed circadian rhythm has a direct relationship to errors, accidents and safety. However, identifying fatigue as factor in an accident can be very difficult. We can test a piece of metal to find out whether it has been weakened, but human fatigue is elusive and subjective. There is no "fatigue" test for humans and we are poor judges of our own state of fatigue. In research done by NASA on international flight crews, pilots reported that they felt at their highest state of alertness just six minutes before they fell asleep. On the scientific scale, these pilots qualified as having a severe sleep debt, yet they felt very alert.

In 1989, we asked the DOT to review the hours-of-service regulations in all transportation modes to assure that they were consistent and that they incorporated the results of the latest research on fatigue and sleep issues. Flight and duty time regulations were again the subject of Safety Board recommendations in 1994 and 1995.

Also in 1995, the Board, in conjunction with NASA, convened an international symposium on managing fatigue. As a result of that meeting, we made recommendations to require fatigue education for everyone in the aviation industry and to develop scientifically-based flight time, duty and rest regulations, as well as special regulations governing overnight flying that take into account proven physiological human factors.

Last year, the Board reiterated the 1995 recommendations and asked the FAA to establish scientifically based hours-of-service regulations that consider circadian rhythms and rest requirements.

In the years since we made our first flight crew fatigue-related recommendations, there has been a lot of activity, but little action. However, last year, as a result of your efforts to improve pilot rest rules, the FAA announced that it intended to enforce the existing regulations concerning flight time limitations and rest requirements - regulations that date back to 1985.

These rules require airlines to provide reserve pilots with a pre-scheduled and protected eight-hour rest period sometime during the 24-hour period prior to completion of a flight assignment. Because these regulations weren't enforced, airlines could require their reserve pilots to be "on call" 24 hours a day for several consecutive days without giving them the legally mandated crew rest.

Although we're pleased that the FAA intends to enforce its existing regulations, the Board is still concerned that no further rulemaking has been undertaken to resolve the overall issue of hours of service and to equalize the duty and rest requirements for Part 121 and Part 135 operations. I think we'd all agree that further delays are unacceptable and endanger the traveling public as well as flight crews and that it's time to move forward.

A second challenge to the safety of your professions is operator use of prescription or over-the-counter drugs while operating a vehicle. Since 1987, we have investigated over a hundred accidents in which the use of a licit medication by a vehicle operator has been either a cause or a contributing factor in the accident.

As a result of our findings, earlier this year, the Board recommended to the Federal Drug Administration that it institute a single, clear, consistent, easily recognizable warning label for all prescription and over-the-counter medications that may interfere with an individual's ability to operate a vehicle. The Board believes that such a label could allow operators to avoid searching through the fine print to determine whether they can reasonably use a specific medication while flying.

A third challenge is to better understand "fly by wire" technology and how it can better interface with the human operator. We know from our investigations of both aviation and marine accidents that operators of highly automated equipment may not monitor onboard systems as attentively as operators of less automated equipment. When systems do not function as expected, operators may not recognize the problems and may not respond as needed before a serious event occurs.

There are a number of other issues - issues such as collision avoidance devices on all large cargo aircraft and identification of and better manifests for hazardous materials onboard flights - that are equally important to protecting your profession and the professionals in it.

One safety area where we've succeeded in making great strides is collision avoidance. Obviously, collision avoidance is a key safety issue for any pilot, and has been of concern to the Safety Board for years. Last year, the Board looked into two near midair collisions in which at least one of the aircraft involved was an all-cargo flight. As you know, there are currently no U.S. regulations requiring the installation and use of airborne collision avoidance equipment in aircraft with less than 10 passenger seats. We believe cargo flights should be afforded the same level of safety as passenger carrying aircraft.

This has been the Board's position since the inception of the Traffic Collision Avoidance System (TCAS). TCAS is a proven, effective collision avoidance tool - since the early 1990s there has not been a single midair collision involving two aircraft with TCAS or a TCAS-equipped aircraft and an aircraft with a mode C transponder.

The Board's investigations resulted in recommendations to the FAA to mandate TCAS systems on all large cargo airplanes as well as a study on the feasibility of TCAS on all cargo aircraft operating under CFR 121, 125, and 129. In response to these recommendations, the FAA has announced that it plans to issue rulemaking this month to require TCAS on cargo transport airplanes.

Although the Board appreciates the efforts of Federal Express and other cargo carriers to voluntarily equip their aircraft with TCAS, other countries are well ahead of us. Earlier this year, the European Civil Aviation Conference amended its Joint Airworthiness Regulations to have the same requirements that we have proposed. And, Australia, India, Japan and other Pacific Rim nations are implementing similar requirements.

In addition, the recent tests using the Automatic Dependent Surveillance-Broadcast (ADS-B) technology have been encouraging and could be the wave of the future for aircraft separation technology. ADS-B does show promise in collision avoidance, and we'd welcome any system that works with, and as well as, TCAS. I understand that the transport category version of ADS-B may be granted certification in the near future - perhaps this month.

A number of recent accidents - Valujet in the Everglades and FedEx in Newburgh, New York and Newark, New Jersey, have also highlighted the need for crews to have better information about what type of hazardous materials are aboard their aircraft. The Board is very concerned about both the specific knowledge flight crews have about each flight as well as what hazmat training is being provided to pilots and other aircraft personnel.

Our recommendations following those accidents have spurred the FAA into increasing its surveillance effort. It has increased the number of inspectors examining hazardous cargo and the Department of Justice is taking a much closer look at hazmat violations than they have in the past. Northwest Airlines has banned hazardous cargo from its aircraft altogether.

However, other efforts, like those of FedEx, to track the hazmat on board its aircraft, have not been widespread within the air cargo industry. As a result, it is still difficult for flight crews and rescue personnel to determine exactly what types of hazmat are onboard the aircraft. More needs to be done to ensure that this information is available to those who need it - especially on those occasions that require the flight crew to evacuate the airplane - such as when there's an onboard fire.

Before I close, I want to talk about one last safety measure - cockpit video recorders. Several accidents currently being investigated by the Board, such as EgyptAir flight 990 and Alaska Airlines flight 261, have highlighted the need for video recorders on board aircraft.

Last summer, in its report on an accident involving a public use aircraft in Montrose, Colorado, the Board asked the FAA to require video recorders on single engine, turboprop aircraft operating under Part 135. Recently, the Board staff also recommended the installation of cockpit video recording cameras in Part 121 cockpits, so that the characteristics of the cockpit environment and the actions of the flight crew can be clearly documented.

I know that many groups and individuals are vehemently opposed to video recorders in the cockpit. These same concerns were voiced many years ago when the rules governing the installation of cockpit voice recorders were being promulgated. Frankly, I can't understand why opposition to video cameras is so strong. I believe that they can help clarify what actually happens during an accident or incident.

When investigators can see what actions were being taken in the cockpit, they can quickly eliminate unnecessary and unwarranted speculation. Video cameras in the cockpit can potentially provide a great deal of information that is simply not available now following an accident. They have the potential to become one of our most valuable investigative tools. I understand the privacy concerns being raised by those who oppose the introduction of these systems. However, the Board is working to address those issues to ensure that the video recordings will have the same protections currently afforded voice recorders.

Thank you, again, for inviting me to be here today. As you can see, there is still much to be done to protect your profession and the air cargo system. I have always been impressed with the dedication and professionalism of the members of the air cargo community.

And, I have always appreciated the advice and assistance you have provided to the Board. Although we may occasionally disagree on issues, we all take our responsibility to ensure a safe transportation system seriously. By continuing to work together, we will fulfill that responsibility.