India’s pilot unions are once again locking horns with the aviation regulator over a contentious new system designed to manage crew fatigue. The unions have outright rejected this proposed airline-controlled, data-driven approach, claiming it dangerously undermines the duty hour limits previously mandated by the Delhi High Court. They also argue the system is ‘dangerously premature’ for a country whose safety oversight mechanisms are still developing.
This strong opposition comes in response to a draft advisory from the Directorate General of Civil Aviation (DGCA) regarding the implementation of a Fatigue Risk Management System (FRMS). The FRMS is intended to be a data-based method for monitoring and managing fatigue risks among pilots to maintain their alertness. Under this system, individual airlines would be responsible for developing and overseeing their own FRMS.
The Federation of Indian Pilots (FIP) expressed deep concern, stating that the DGCA’s move to introduce a ‘flexible’ FRMS framework through a less formal ‘Operations Circular’ instead of a legally mandated Civil Aviation Requirement (CAR) is unacceptable. A CAR would ensure stricter legislative scrutiny, greater transparency, and a proper consultation process involving all relevant parties. The FIP warned that bypassing this formal procedure could lead to a serious ‘degradation of safety.’
This new FRMS proposal is particularly controversial because it emerges just months after the Delhi High Court issued new, stricter limits on pilot duty and rest periods. An order from February 24, 2025, mandated an increase in weekly pilot rest from 36 to 48 hours, effective July 1. Additionally, airlines are required to reduce night flying hours for pilots starting November 1.
The FIP strongly believes that implementing the FRMS in India’s current aviation landscape is ‘dangerously premature.’ They cite the International Civil Aviation Organisation (ICAO), a UN safety watchdog, which emphasizes that effective FRMS oversight requires highly trained government inspectors and ample resources. The ICAO also cautions that without strong, clear fatigue regulations and robust regulatory backing, the intended safety benefits of an FRMS could be severely compromised.
Consequently, the unions are demanding that the DGCA first prove full compliance with the new court-ordered duty and rest period norms, which, according to them, have not yet been completely put into practice.
The Airlines’ Pilots Association of India (APAI), another influential pilots’ group, has also weighed in, highlighting concerns that airlines tasked with developing their own FRMS tools have failed to foster a ‘just culture.’ The APAI points to instances where pilots reporting fatigue are unfairly reclassified as ‘sick,’ leading to penalties and loss of pay, which discourages honest reporting.
Both pilot unions share a critical concern: the potential for manipulation within the statistical models of FRMS tools. They argue that these models, which use scientific data on sleep and circadian rhythms combined with operational data like shift lengths, could be easily swayed by airlines choosing specific filters to influence the predicted fatigue and alertness levels, potentially compromising accuracy and safety.
To ensure impartiality and proper oversight, both unions are demanding direct representation. They insist that pilot unions must be included in every airline’s Fatigue Safety Action Group (FSAG) and all DGCA-level committees and task forces dedicated to fatigue oversight. Their rationale is that relying solely on airline-appointed senior pilots for monitoring can undermine independent assessment and introduce bias.