UAS Air Carrier Operations Survey: Fatigue

Durham, Justin; Hu, Peter T.; Baumgartner, Hannah M; Nesthus, Thomas E. · 2023 · ROSA P / United States. Department of Transportation. Federal Aviation Administration. Office of Aviation. Office of Aerospace Medicine

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Summary

This report addresses the regulatory gap regarding fatigue, duty time, and shift work for Unmanned Aircraft Systems (UAS) engaged in air carrier operations, such as package delivery and air taxi services. Current Federal Aviation Administration (FAA) regulations, specifically 14 CFR § 107, do not explicitly cover these complex commercial applications, which are traditionally governed by manned flight standards under 14 CFR §§ 121 and 135. As UAS automation and applications evolve, understanding operator fatigue is critical for safely integrating these systems into the National Airspace System. The study aims to gather empirical data from industry experts to inform future policy and standardize safety requirements. The researchers conducted a market survey targeting subject matter experts (SMEs) involved in UAS manufacturing, operation, or education. Eligibility required affiliation with an organization operating or planning commercial UAS operations, possessing established qualification requirements, and employing at least two operators. Recruitment utilized public dockets, waiver lists, and snowball sampling, resulting in 173 respondents, including pilots, managers, instructors, and engineers. The electronic survey, administered via Qualtrics over 90 days, used branching logic to tailor questions to specific job roles. It collected data on demographics, operational parameters, fatigue mitigation strategies, and duty schedules. Results indicate that most respondent organizations are small, employing 10 or fewer pilots with an average of seven years of experience. Anticipated in-flight times for delivery operations are typically 30 minutes or less, while air taxi services are expected to last one hour or less. Although a majority of respondents reported experiencing fatigue on duty—attributing it to workload and scheduling—most disagreed that fatigue represents a significant safety concern. There was considerable variation in opinions regarding when time on duty becomes risky. Organizations generally maintain regular schedules with one to three days off between shifts and routine breaks. While many organizations provide fatigue awareness training and reporting mechanisms, a majority do not maintain records on fatigue prevalence. The findings highlight a disconnect between the reported experience of fatigue and its perceived risk, alongside a lack of systematic data collection on fatigue prevalence. The authors conclude that current industry practices are insufficient for ensuring safety in scaled-up air carrier operations. They recommend standardizing UAS duty time, shift work, and fatigue awareness educational requirements. These measures are necessary to support the safe and efficient integration of UAS into the National Airspace System, ensuring that regulatory frameworks evolve to match the operational realities of unmanned air carriers.

Key finding

Although a majority of UAS operators disagreed that fatigue is a safety concern, most reported experiencing fatigue due to workload and schedules, yet most organizations failed to maintain records on its prevalence despite providing training and reporting mechanisms.

Methodology

survey

Sample size: 173

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tag success vector_similarity 24 2026-06-11
verify success 2 2026-06-10

Summary generated by qwen3.6-27b-prismaquant on 2026-06-10; verification: verified.

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