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FAA Rest Rules: FATIGUE: Impact of Requiring Pilot to Sign RELEASE to Indicate Rested

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Doctor: "What are all those bruises you've got?"
Patient: "My boss is beating me with a stick. Can you help?"
Doctor: "Absolutely. Here's a pamphlet on how hide the fact that you work for someone who beats you with a stick."

Thanks a lot, FAA.
 
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Not at all. It has a few warts, like allowing 10 hours of block during certain times of day, but overall, it's pretty damned good.
Actually, I don't mind that so much.

If I can start a trip on day 1, fly 2 or 3 legs for 5-6 hours of block (which takes 9-10 hours of duty), go to the hotel for 12-14 hours, fly two legs for 10 hours block, 12 hours duty on day 2, then do another 2 or 3 legs for 5-6 hours of block on day 3, I'd be all about it. That's a 20-24 hour 3-day.

If I have to work a 12 hour duty day, I'd rather fly two legs at 5 hours each than 5 legs at 90 minutes a piece. I consider the multiple legs MUCH more fatiguing than a couple hours of extra block, but that's just me...

The warts I don't like on this are the possible crap management may be able to pull with the "fatigue specialists". That and the commuting question make me more wary than the new hour limits of flying. I think they got THAT part (hours on duty, circadian rhythm, eliminating reduced rest unless you agree, etc) right.
 
The part I don't like is that these rules do nothing to address multiple duty periods in a single day. We can work all night, day sleep , and be back at it in the early evening. We can also work a normal day, sleep all night, do a 3 hour flight in the morning, day sleep, then work multiple legs through the night. Those are the most fatiguing trips I have ever flown, because you can't get any decent rest after being awake for just 5 or so hours. Roll that into a 4 or 5 day trip and no one is safe. I know we can negotiate better with a CBA and we are working on that but it won't help us for a couple of years.
 
If I can't drop / trade / or otherwise bid away from those, I just call fatigue when I hit the end of Day 2 and can't rest properly before duty period 3 because my circadian clock is all screwed up.

I don't call fatigue very often, but when I'm fatigued, I don't hesitate. Eventually, they'll stop scheduling like that if enough people say they can't do it... Also, if you're on reserve, they figure out pretty quickly who the people are that can do those trips and who the people are that can't.

Learned a long time ago; you can't count on the FAA to do the right thing to address all the problems that crew scheduling creates with fatigue issues when they don't have enough people to cover all the flying and start getting "creative". Sometimes you just have to be the professional and politely but firmly decline. When you're fatigued, you're fatigued. Just part of the job.
 
I've done that multiple times on those trips. Unfortunately it is not them getting creative, they keep building them that way.
 
Do you have any constructive criticism of the NPRM, or are you just being a typical flightinfo malcontent with plenty of complaints, but no solutions?


Your high-and-mighty attitude is laughable considering your past decision- making ability in this career.



Increasing flight times should be an absolute no-go item, irrespective of what is in the rest of it. 9 hours of rest? Inadequate. Seems it can still be reduced to 8 at times, also inadequate. Either 8 hours of rest is too little, or it isn't. Which is it? There is no middle ground there. If you are going to allow 8 hours at any point, then apparently it is ok.

There are 3-4 items in this POS that to me are no-go, regardless of what else is supposedly better. Something half-donkey is not acceptable. It needs to be sterling on all counts. Even you said the flight time was no good. There should be -zero- items that are unacceptable.

I'm sure, however, you will say "mostly good is good enough."
 
Your high-and-mighty attitude is laughable considering your past decision- making ability in this career.




I'm sure, however, you will say "mostly good is good enough."


Hardly surprising.

'Humpty Dumpty' is like an STD. Embarrassing, persistent and nestled into a spot he never earned or deserved ;)
 
Increasing flight times should be an absolute no-go item, irrespective of what is in the rest of it.

I don't really like that part, either. Unfortunately, the science doesn't back up an 8 hour limit across the board. I think they went too far with the 10 hours, though, so hopefully we'll be able to correct that during the comment period.

9 hours of rest? Inadequate. Seems it can still be reduced to 8 at times, also inadequate.

The 9 hours is time actually at the hotel, which makes a big difference. I think 10 would be better, but again, that's something we can try to fix in the comment period. The important part in the NPRM is that the FAA based the time on time at the hotel, rather than including transportation time like it is now. That's a big step.

There should be -zero- items that are unacceptable

I agree, but I think you would admit that we probably won't accomplish that. We're dealing with politicians here, remember. We should do everything we can to clean it up in the comment period, though.
 

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