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18 hour duty days are safe?

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suupah

Well-known member
Joined
Jan 31, 2004
Posts
1,779
"...regarding Part 91, tail end ferry. 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, ******* Air will prohibit any flight activity when duty will exceed 18 hours. Currently ****** Air is working to finalizing a Risk Assessment Tool for all repositioning and ferry flights.
After any tail end Part 91 flying adequate rest must be accomplished prior to next 121 flight duties."


Aviators, is this safe?
 
nope.....fatigue clause that s--t unless you're wide awake and its to your advantage/company will do a huge favor for you.
 
I wouldn't even do it if it were advantageous to me.

If it's unsafe it's unsafe

I would be calling fatigued for that $hit. If everyone did it, it would GO AWAY
 
weird...how can you be "off" duty and still doing a repo leg part 91?

So you show your duty off time diffrent than your block in time from the last flight?...

This is bull$hit intrepretation from some dept manager who is trying make himself look good by saving the day with a safety issue.

It dont matter if it's 91,121,135 or whatever part you make up. An air carrier dont have anything called part 91 duty. You can a part 91 LEG but you are duty, 135 or 121.

unsafe..... You can legally accept a part 91 leg at the end of the day if you want to, but the company cant ASSIGN you a part 91 leg that will take you over you duty time. That would not be in compliance with the regulations
 
Last edited:
Ditto what brokeflyer said.

The aircraft might be operated under part 91, but the pilot is subject to part 121 or 135 rest rules. Simple as that.
 
Why do it? Don't your contracts have max duty at 16 or less? Have seen 15.5 and 15hr maxes.
 
At the Pinnacle 3701 hearing, one of the board members was wondering the same thing. Of the course the RAA or the ATA probably had some thugs stop by her place with a case of money in one hand and a pipe in the other.
 
Like I said in another thread, I was pissed off about this as well and called my rep today about it. He said that they are on top of it and will be putting out something late tonight or tommorow concerning this.
 
One of the reasons why ALPA supports H.R. 915. It has this language in it thanks to ALPA:

SEC. 816. DUTY PERIODS AND FLIGHT TIME LIMITATIONS APPLICABLE TO FLIGHT CREWMEMBERS.

Not later than 180 days after the date of enactment of this Act, the Administrator of the Federal Aviation Administration shall initiate a rulemaking proceeding for the following purposes:

(1) To require a flight crewmember who is employed by an air carrier conducting operations under part 121 of title 14, Code of Federal Regulations, and who accepts an additional assignment for flying under part 91 of such title from the air carrier or from any other air carrier conducting operations under part 121 or 135 of such title, to apply the period of the additional assignment (regardless of whether the assignment is performed by the flight crewmember before or after an assignment to fly under part 121 of such title) toward any limitation applicable to the flight crewmember relating to duty periods or flight times under part 121 of such title.


(2) To require a flight crewmember who is employed by an air carrier conducting operations under part 135 of title 14, Code of Federal Regulations, and who accepts an additional assignment for flying under part 91 of such title from the air carrier or any other air carrier conducting operations under part 121 or 135 of such title, to apply the period of the additional assignment (regardless of whether the assignment is performed by the flight crewmember before or after an assignment to fly under part 135 of such title) toward any limitation applicable to the flight crewmember relating to duty periods or flight times under part 135 of such title.


Call your Senator and tell them to insert this language into S.1451.
 

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