suupah
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Fellow Pilots,
In Read and Sign #09-05, Colgan management clarified the FSDO’s interpretation of Flight Time Duty Time regulations, which lead to the Letters of Investigation earlier this year. At this point, we consider that issue resolved. We echo Harry Mitchel in suggesting that all pilots carry with them a copy of ALPA’s Guide to Flight Time Limitations and Rest Requirements which you can access online by going to the Flight Time/Duty Time Committee’s webpage on the ALPA members-only website, https://crewroom.alpa.org, and clicking on “Guide to FTDT Limitations.”
However, your MEC is concerned about the following statement from Harry Mitchel’s memo: “The interpretation is clear that Part 91 flying is not subject to 121 Duty Time Rules. Part 91 is not subject to 8 hrs or 16 hour duty day. However, common sense and in the interest of Safety, Colgan Air will prohibit any flight activity when duty will exceed 18 hours.”
While we agree Part 91 is not subject to Part 121 regulations, Read and Sign #09-05 contradicts FOPPM Bulletin #09-001 which was presented by representatives for our management at the NTSB public hearing and is now included as part of the public record. The FOPPM bulletin states on page 3 of 6 that “Fatigue can also mimic the effects of alcohol. Being awake for 17 hours can have a similar effect to having a blood alcohol level of .05% in terms of reaction times and judgment.” We have contacted the company about this inconsistency and they have promised us an “in depth” response to our inquiry. We will inform you of any changes that result from their response.
In the interim, our Central Air Safety Committee recommends that all crews follow the guidelines in FOPPM Bulletin #09-001 instead of Read and Sign #09-05 regarding duty days in excess of 16 hours.
Please call the Colgan MEC Hotline at 1-877-MEC-CJC1 if you have any questions about these regulations. The ALPA website also has a number of valuable resources regarding the issues of flight time/duty time and fatigue. In addition to the Guide to Flight Time Limitations and Rest Requirements, we also recommend you download The Airline Pilots’ Guide to Fighting Fatigue, also on the ALPA Flight Time/Duty Time Committee’s webpage under “Fatigue Resources.”
Fly safe,
The Colgan MEC
In Read and Sign #09-05, Colgan management clarified the FSDO’s interpretation of Flight Time Duty Time regulations, which lead to the Letters of Investigation earlier this year. At this point, we consider that issue resolved. We echo Harry Mitchel in suggesting that all pilots carry with them a copy of ALPA’s Guide to Flight Time Limitations and Rest Requirements which you can access online by going to the Flight Time/Duty Time Committee’s webpage on the ALPA members-only website, https://crewroom.alpa.org, and clicking on “Guide to FTDT Limitations.”
However, your MEC is concerned about the following statement from Harry Mitchel’s memo: “The interpretation is clear that Part 91 flying is not subject to 121 Duty Time Rules. Part 91 is not subject to 8 hrs or 16 hour duty day. However, common sense and in the interest of Safety, Colgan Air will prohibit any flight activity when duty will exceed 18 hours.”
While we agree Part 91 is not subject to Part 121 regulations, Read and Sign #09-05 contradicts FOPPM Bulletin #09-001 which was presented by representatives for our management at the NTSB public hearing and is now included as part of the public record. The FOPPM bulletin states on page 3 of 6 that “Fatigue can also mimic the effects of alcohol. Being awake for 17 hours can have a similar effect to having a blood alcohol level of .05% in terms of reaction times and judgment.” We have contacted the company about this inconsistency and they have promised us an “in depth” response to our inquiry. We will inform you of any changes that result from their response.
In the interim, our Central Air Safety Committee recommends that all crews follow the guidelines in FOPPM Bulletin #09-001 instead of Read and Sign #09-05 regarding duty days in excess of 16 hours.
Please call the Colgan MEC Hotline at 1-877-MEC-CJC1 if you have any questions about these regulations. The ALPA website also has a number of valuable resources regarding the issues of flight time/duty time and fatigue. In addition to the Guide to Flight Time Limitations and Rest Requirements, we also recommend you download The Airline Pilots’ Guide to Fighting Fatigue, also on the ALPA Flight Time/Duty Time Committee’s webpage under “Fatigue Resources.”
Fly safe,
The Colgan MEC