90% of accidents are pilot error.
SA untreated has been shown to be the equivalent of 0.08 alcohol.
Now read 67.113, 67.213, and 67.313 and tell me he doesn't have the authority.....
Enough, Nate. Enough.
Those are medical and legal fact. What hasn't been established is that it's actually causing accidents.
A more difficult question: Is the standard zero accidents? If it is, is it worth the cost?
Those are part of the overall FAA mission to answer. The Doc has the authority, but perhaps shouldn't be the final say when factoring in the overall goals of the organization.
That's what I'm questioning. Not his work. It's the groups around him that seem disconnected and unprepared for his professional medical assessment. You'd think they'd be prepared to present their data along with his, since it is the Federal *Aviation* Administration, not the Federal Pilot Medical Administration after all.
That's just his piece. He's fine.
Where's the administrator saying, "Here's our evidence to back the Doc's claim. The following accidents were found to be fully or partially caused by fatigue unrelated to unreasonable work schedules, and crew transportation issues (e.g. Commuting halfway across the country), and the airmen who survived, were found, post-accident or incident, to be afflicted with sleep apnea that was untreated."
The Administration is disjointed individual groups not working together. If this is high enough on the Doc's list to trigger a $1B bill to airmen, it's reasonable for the airmen to ask for the evidence linking the Doc's data to... Oh you know... Airplanes?
Someone pointed out that DOT did this to truckers. I have a hunch that sleep related accidents didn't drop. Why? The rest rules are changing again in June.
And there's the elephant in the room. Crew rest rules are about 1000% more likely to be the cause of accidents in commercial aviation, where one might say they *really* count... But FAA won't touch that political third rail.
Honest opinion Doc. You ever read an accident report where fatigue was a significant factor (say, Colgan) and think to yourself, "I bet the FO needed a CPAP!"
I'm sorry I'm digging this one. I know it's tilting at windmills but they're barking up the much smaller of the fatigue trees here.
There's a reason commercial pilots joke that long haul intercontinental flights are "dozing for dollars", but it's not very likely that it's because they need a CPAP. It's because it's frakking 3AM over the Pacific. Luckily that's a fairly non-risky portion of the flight.
I read a lot of accident reports. Probably not as many as you, Doc. Nor have access to "insider" info on them. But I think they've made a mountain out of a molehill with this one.