Pilots say the current rules regarding rest breaks are no longer fit for purpose and need to be overhauled.
The Civil Aviation Authority is reviewing its fatigue risk-management plan.
Cabin crew, backed by the union E Tu, have already told the authority they often work long hours without a break.
Dave Reynolds, senior technical officer of the Air Line Pilots' Association, said the rules for pilots were also inadequate as they did not take into account varying distances and altitudes flown.
"The main issue that concerns us at the moment is the lack of any real, prescriptive rules around fatigue management," he said.
"Currently, those in place are inadequate to say the least and fall short of international standards.
"Many pilots operate at an atmosphere of 10,000 feet, and many travellers will know how tiring that is."
The Civil Aviation Authority would not comment while its review takes place.
The submission period ended earlier this week.