– Executive Summary –

This study sought to identify the legal and social considerations affecting the implementation of wearable technology to assess crew fatigue in the U.S. Coast Guard (USCG), and specifically provide recommendations regarding how to incorporate these new technologies into preflight operation risk assessment processes. The study includes a business case analysis, in which the theoretical cost of a USCG aviation wearables program is compared to the historical financial cost of Class A and B aviation mishaps attributed to fatigue-related causal factors. Qualitative analysis then addresses three key aspects policymakers should consider as part of implementing such a program: accuracy, authority, and acceptance.

Qualitative analysis of existing studies indicate that some wearables are capable of providing accurate physiological data that may provide insights into aircrew fatigue.  Specifically, devices which measure heart rate variability and ocular measurements, like blink rate, may prove useful in providing an improved quantitative depiction of aircrew fatigue.  However, existing research indicates that the field of wearable technology is rapidly changing, and capabilities are specific to each device and software configuration.  As such, policymakers should leverage recent, scientifically sound assessments of specific devices considered for any specific program.

The rapidly evolving field of wearable devices creates another dimension of ambiguity related to the USCG’s authority to monitor its members’ physiological markers both on and off duty. While military service members have historically been deemed to have a reduced expectation of privacy by military courts, the Supreme Court has yet to rule on cases in which limitations on Fourth Amendment protections are defined.  Further, the evolving application of privacy laws to increasingly capable and ubiquitous personal devices provides as many questions as answers. The USCG may have the authority to mandate that its members participate in wearable monitoring programs, both on and off duty.  However, such a mandate would be an unprecedented test of military authority. In the context of Carpenter vs. the United States, policymakers would do best to assume that the Court may place an increased emphasis on citizens’ technological privacy expectations, even if they are military members.[1]

To provide insight into the potential acceptance of wearables by USCG aviation personnel, this study issued a wearable wrist strap to 20 active-duty aircrew for a 30-day period, and allowed members to utilize the data that the straps provided as part of their normal preflight operational risk-management practices. Using a modified version of the Unified Theory of Acceptance and Use of Technology (UTAUT) as a model,[2] pre- and post-surveys gathered input from subjects on the relative importance of five key influencing variables related to acceptance, as well as changes in subjects’ preferences based on a 30-day exposure to the device. The results of the observation were statistically inconclusive, primarily due to the small sample size and short duration of the experiment.  However, the descriptive statistics suggested that subjects may experience an increase in performance expectancy after using the device. Subjects rated their relative trust for information to determine their level of fatigue (1–6 scale) between their own intuition (1) and a wearable device (6). Over the course of observation, mean responses shifted from slight distrust of wearables on pre-survey scores (M = 2.90) to slightly greater trust for wearables (M = 3.45) on post-surveys. Additionally, survey responses regarding privacy concerns about commercial (M = 3.81) and USCG (M = 3.87) data access identified privacy as a potential factor for inhibiting wearable acceptance, and remained ostensibly unchanged between pre- and post-surveys. Qualitative input received from subjects in the form of survey comments provided additional support for this likelihood. Sleep data gathered by the wearable devices reported a mean nightly hours of sleep for all subjects as M = 6.82 and identified three subjects who averaged less than six hours of sleep over the course of the 30-day period. These data align with previous studies that raise questions as to whether existing USCG aviation crew rest policies are effective at ensuring that aviators receive adequate sleep prior to flight.

The results of this study do not support an immediate investment in a full-scale USCG aviation wearables program. However, they do highlight the potential role that wearables might play in helping policymakers quantify the fatigue experienced by aircrew under current policies and practices. Additional research should seek to leverage such devices on a larger scale and for a more prolonged period. The data provided by such research might be useful for other USCG subgroups as well. Training environments in particular (Bootcamp, Aviation Survival Technician A-School) could gather objective measurements of the strain and recovery placed on students, and modify programs based on quantifiable data.

The importance of trust in facilitating the effective implementation of a wearables program became clear throughout the study. In particular, survey results regarding privacy concerns identified this factor as a potential roadblock to successful implementation.  Based on these observations, this study recommends that only voluntary programs be pursued in the near term in order to continue to normalize wearable use. Finally, the study recommends the potential preemptive application of legal privilege to wearable data used by aircrew as part of risk-management processes.  Though unprecedented, this strategy may enable the application of a proven safety concept that would enable military members to incorporate wearable data into their risk-management decisions without fear of having that data used against them in a legal or administrative processes.

[1] Carpenter v. United States, 585 U.S. No. 16-402 (2018), 119. Justia Law, https://supreme.justia.com/cases/federal/us/585/16-402/.

[2] Viswanath Venkatesh et al., “User Acceptance of Information Technology: Toward a Unified View,” MIS Quarterly 27, no. 3 (2003): 425–78, https://doi.org/10.2307/30036540.

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