Trust Us — We’re Professionals

June 11th, 2014 by Ron Rapp

I’ve seen some ill-conceived policies emanate from the FAA over the course of my professional flying career. Some diktats are just busy work, while others fail to achieve an otherwise admirable end. But the worst are those that create the very hazard they are supposed to prevent.

Case in point: the recent adoption of 14 CFR 121.542(d), which prohibits the use of any personal electronic devices in flight. According to the FAA, this rule is “intended to ensure that non-essential activities do not affect flight deck task management or cause a loss of situational awareness during aircraft operation.”

Sounds great on the surface, doesn’t it? I mean, who could possibly oppose a rule which the Feds ostensibly see as the aeronautical equivalent of a ban on texting while driving? Keeping distractions at bay and pilots focused on flying has got to be a wonderful enhancement for safety.

But it’s not. The flight profiles of airlines, cargo haulers, charter companies, fractionals, corporate flight departments, and even private GA operators often dictate long stretches of straight-and-level flight with the autopilot on. Surely the FAA is aware of this. Now add in circadian rhythm issues associated with overnight flights, a dark cockpit with minimal radio traffic, and a flight crew pairing who have run out of things to talk about. There’s nothing to do but stare off into the inky darkness for hour upon hour. It’s a recipe for falling asleep.

Say what you will about distractions on the flight deck, but I’d much rather see a pilot peruse an issue of AOPA Pilot while in cruise than to have that individual zoned out or inadvertently napping. For one thing, the process of waking up takes time, whereas an alert human need only change focus. We already do that dozens of times on every flight anyway. Check in on the engine instruments, then answer a question from a passenger, then look out the window, then consult a chart. We do this all day long.

Is there much difference between reading a magazine and delving into the minutia of some random page of the Jeppesen manual when they’re both a form of busy work to keep the mind engaged during slow periods in cruise? I sincerely doubt a roundtable of experts in automation and human factors would have come up with a PED ban.

I can understand prohibiting them below, say, 10,000′ when the sterile cockpit rule is in effect. That’s a busy time for pilots, and non-essential items are naturally stowed at that point anyway. But electronic devices in and of themselves can be helpful in staving off the ultimate distraction. “Flight to Safety” author and Airbus pilot Karlene Petitt said it best:

Numerous studies have shown that one of the tips to help fall to sleep is to NOT watch television or work on your computer at a minimum of an hour before bedtime. The light suppresses melatonin production and stimulates brain activity. I’m not sure about you, but I want my pilots alert with stimulated brains. Give them something to do to keep them awake.

As many of you have probably noted, this rule is located in Part 121 and therefore only applies to scheduled airlines. From maintenance requirements to medical certification, their regs are the strictest around, so perhaps this seems much ado about nothing for a general aviation audience. But the FAA is of the opinion that this limitation should reach a lot further than United and Delta:

Recommended Actions: This prohibition on personal use of electronic devices on the flight deck in the final rule is applicable only to operations under part 121. However, Directors of Safety and training managers for all operators under parts 135 and 125, as well as part 91K, are encouraged to include operating procedures in their manuals and crewmember training programs prohibiting flightcrew members from using such devices for personal use during aircraft operation.

Will this eventually reach down to Part 91? Who knows. Even if it doesn’t, the real problem is that the FAA is spoon-feeding each and every individual action and prohibition to us without making allowances for the differences inherent in each type of operation. One-size-fits-all is wonderful for tube socks and scarves, but when it comes to flight safety, it’s just bad policy.

The smart way to go about this would be to leave it to the individual company, flight department and/or individual to determine what PED policy best serves the cause of safety. If you’re Southwest Airlines or a charter operator company flying VLJs, you probably aren’t flying long-haul trips and might be fine with reasonable PED limitations. Certainly using them below 10,000′ could be prohibited. But if you’re flying international cargo in a jumbo jet or hopping continents in a Global 5000 on legs of twelve or thirteen hours? That personal electronic device could be incredibly helpful in maintaining alertness.

Whether it’s a vocation or an avocation, pilots are a professional lot who can be trusted to make their own decisions about portable electronic devices.

Ron Rapp

Ron Rapp is a Southern California-based charter pilot, aerobatic CFI, and aircraft owner whose 7,000-plus hours have encompassed everything from homebuilts to business jets. He’s written mile-long messages in the air as a Skytyper, crop-dusted with ex-military King Airs, flown across oceans in a Gulfstream IV, and tumbled through the air in his Pitts S-2B. Visit Ron’s website.

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The opinions expressed by the bloggers do not reflect AOPA’s position on any topic.

  • Kevin O’Brien

    Point very well made Ron, thanks for your astute evaluation.

    Captain O’Brien, A320.

    • http://www.rapp.org/ Ron Rapp

      Thanks for reading, Kevin!

  • Dan Williamson

    UPS and the Teamsters decided 40 yrs ago an awake driver distracted by talking on the CB sure beat a driver with the 1000 mile stare. For what ever my 3 million miles of beating ruts in I35 taught me was ANYTHING which caused my mind to shift thoughts was a good thing.