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Flight crew fatigue (Part 121)

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CFI duty time

May I chime in a comment about instructor duty time? Please - don't laugh.

The FARs limit instructors to eight hours a day of flying. I had plenty of days where I flew eight hours. Add to that all the ground time and pre and post oral time with students and we're up to 12-14 hours a day of duty, not to mention the time and mental gymnastics needed to prepare schedule requests. At one place at times I barely had fifteen minutes to scarf down lunch. Factor in working six or seven days a week and the mental energy expended monitoring and evaluating students.

I realize your paper is about 121 pilots but I thought you might appreciate feedback from another sector of aviation.
 
Hey, nobody has yet mentioned the continuous duty overnights. You go to work at 8:00 pm, fly several legs, hit a hotel for a couple of hours, fly back (one, two, more legs back), then sleep for a couple of hours till noon and try to straighten out your head to fly again that night. Three in a row are killers, four as are allowed in our contract are dangerous. The pilots that bid these lines (pure CDO's) are zombies. The rest of us just survive them as they are included in our schedule. My wish is that they are made illegal. Think of the sleep pattern disruption such a schedule causes and then throw in ice, darkness, thunderstorms, turbulence, traffic, uncontrolled airfields if you're a regional pilot, and then an emergency (lost engine or severe ice or anything you can imagine), or even better - or worse - having to fly an aircraft with the autopilot and flight director deferred. There will be a terrible accident sometime due to these CDO's.
 
trace the politics behind the regs

It seems to me that it would be a valuable part of your research to include the story of how each duty time reg came about and who lobbied for what at each stage of the development. I have no real knowledge of the issue, but I would bet that there were major battles fought by the Airtransport Association and the airlines to keep the rules in their favor.
If I were doing the paper, I would concentrate on showing that the rules were influenced by monetary concerns. I would be looking for evidence that showed that the industry has disregarded credible research (pertaining to the negative effects of fatigue). It seems to me that fatigue is fairly well accepted as a causative factor in accidents. You only need show that the regulators/industry is ignoring the truth.
regards
 
I wrote in a previous post......

>>>I work for a Part 121 supplemental carrier flying B-727 aircraft carrying passengers.

>>>For a trip that is conducted internationally, what is the maximum duty day for me?


>>>Here's a bonus: What is the minimum rest required before an international trip under part 121 supplemental rules?(assume you just deadheaded the night before to begin a trip out of a different city than your base, and prior to that you have been off for a week)


>>>Keep in mind that we are flying similar equipment and hauling passengers to and from the same destinations as the Major Airlines.


The answer for the first question is there is no maximum duty day/time for 121 supplemental rules for an international flight, meaning that the government has seen no reason to impose ANY limits in this regard for operators conducting these type of flights. I once had an international 121 supplemental trip (included in international rules because of the flight to Alaska) where I deadheaded from Detroit to Dallas, waited 3 hours at the airport, then flew to Washington state, then to Fairbanks, Alaska and back to Washington state in one day. My duty day was about 22 hours and there were no delays. It was perfectly legal to schedule me for that flying. If we would have experienced any weather or mechanical problems on the last leg, it begs the question whether the crew would have been alert enough to handle them properly.

As for the bonus, the answer is very similar. There is no rest required before a trip under these conditions. As far as SCHEDULED air carriers are concerned, rest is defined as occuring BEFORE the trip, which makes sense. By doing that, they protect those crews from doing long deadhead travel just prior to a full duty day. Under their provisions, they would likely need at least 8 hours of rest following a long deadhead in order to be legal to complete a full days schedule. The supplementals can deadhead you 4 or 5 hours and still expect you to fly 12 hours internationally without any intervening rest, or at least no defined rest period.

On a side note, I also sympathize with CFI's and the way their rules are written. Nothing like doing bounces in the pattern with your 4th primary student of the day. But it is true that a lot of times the stark terror that you are experiencing when first teaching em how to land is enough to keep you awake.:p
 
That is why we formed an in house union and one of the work rules is that we will not fly more than a 16 hour day. Some days a 16 hour day can be no problem, other days it can be disaster depending really on you sleep and scedule 48 hours prior. That is where fatigue is dangerous, you cannot define it, higher stress level(kids, job, home, finance) the greater the fatigue.
 

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