Flight Operation Manual

[FlyaLear35]

I work for a fairly large Pt 91 management company, managing jets and turboprops for some clients. We have an FOM which talks about all the things it probaby should, everything from dress code to company minimum weather and duty times. It's substantial and compehensive.

Let's take a duty time issue. A nice contentious issue we all love to talk about. We have a 14 hour duty, 10 hour rest restriction in the FOM, similar to 135. It doesn't say we can exceed it, and it also says if we do exceed it we get extended rest. It also says the pilot has discretion about continuing a flight if he becomes too tired to fly.

My question is: If we don't abide by the rules in the FOM, is the FAA going to care? If we had an incident and we had exceeded the 14 hour duty day, (even though Pt 91 has no duty limits), what's going to happen?

Is the FAA going to look at our FOM, or just Pt 91?

 

[Spooky 1]

I work for a fairly large Pt 91 management company, managing jets and turboprops for some clients. We have an FOM which talks about all the things it probaby should, everything from dress code to company minimum weather and duty times. It's substantial and compehensive.

Let's take a duty time issue. A nice contentious issue we all love to talk about. We have a 14 hour duty, 10 hour rest restriction in the FOM, similar to 135. It doesn't say we can exceed it, and it also says if we do exceed it we get extended rest. It also says the pilot has discretion about continuing a flight if he becomes too tired to fly.

My question is: If we don't abide by the rules in the FOM, is the FAA going to care? If we had an incident and we had exceeded the 14 hour duty day, (even though Pt 91 has no duty limits), what's going to happen?

Is the FAA going to look at our FOM, or just Pt 91?

Yes, they are going to care a lot about your not abiding by the manual so don't write it down, if don't want to relive it at the end of the long green table.

 

[SCT]

Spooky, I disagree with your answer. Being part 91 I believe the Feds would not care about a companie's ops manual concerning duty time. Now if it was 135-121-125, they would be very interested. Now on the otherr hand, if there was an incident or accident involving the company a/c, a lawayer would probably be very interested in the information.

I used to work for a large 91 department in the midwest that had a company ops manual. But the manual was written to be very sketchy at best. Also, if there was a statement like duty times or runway minimums, there was always an * next to it saying the CP could over rule. Except for the dress code, the manual was worthless.....

 

[fokkerjet]

We had a former NTSB official come and talk to us and he said that the NTSB would be very interested in why you violated your Ops Manual........if you can't live by your own procedures, why write them into the manual?

 

[Spooky 1]

Spooky, I disagree with your answer. Being part 91 I believe the Feds would not care about a companie's ops manual concerning duty time. Now if it was 135-121-125, they would be very interested. Now on the otherr hand, if there was an incident or accident involving the company a/c, a lawayer would probably be very interested in the information.

I used to work for a large 91 department in the midwest that had a company ops manual. But the manual was written to be very sketchy at best. Also, if there was a statement like duty times or runway minimums, there was always an * next to it saying the CP could over rule. Except for the dress code, the manual was worthless.....

Reading my answer again I would agree with your assessment more than mine. The issue is, if you are going to create a FOM, or what ever you want to call it, you should plan to operate in accordance with it at "all times", otherwise your just setting yourself up for a big problem if you are found outside the limitations, policy, and protocals written down in the first place. We are just wrapping our arms around an IS-BAO document that is hugh in scope and I'm sure that the first time someone gets on the wrong side of the language, they are risking both their jobs and the rath of the FAA. Perhaps duty time is a poor example, but there are a mirid of other opportunities to screw the pooch in a manual that is as conclusive as the one we are working with.

 

[smfav8r]

Are you operating under 91K?? 91K operators are now required to have an approved FOM (2005). It's more like 135 then 91....I think they would care more if you were a 91K operator.

 

[Spooky 1]

Are you operating under 91K?? 91K operators are now required to have an approved FOM (2005). It's more like 135 then 91....I think they would care more if you were a 91K operator.

We are Part 91, but we also operate a couple of our larger aircraft on Part 125 with a Part 91 exemption. FAA Part 125 is very mild to say the least and many issues are not even addressed so we use the Part 91 manual as an underlying document for how we fly our aircraft. An example of where Part 125 ignores the obvious is oxygen requirements above FL250 for crewmembers. There simply is no reference to it in our Part 125 manual so we observe the FOM language.

This all about to change as Part 125 has been under review byt the FAA for the last 24+ months and they are about to issue a revised and much more compreshensive document soon. It will look a lot more like Part 135.

 

[HMR]

My question is: If we don't abide by the rules in the FOM, is the FAA going to care? If we had an incident and we had exceeded the 14 hour duty day, (even though Pt 91 has no duty limits), what's going to happen?

Is the FAA going to look at our FOM, or just Pt 91?

Wierd! I was just working on our FOM and asking myself this same question 2 minutes ago. Personally, I'm keeping the language as vague as possible.

Our dept is small and the Captain's decisions are never questioned by the owner so we don't run into the same issues (i.e., duty time and rest requirements) as bigger dept's. When writing your manual I say only include what HAS to be in there for your particular operation. Don't hang yourself with your own rope.

 

[Spooky 1]

Wierd! I was just working on our FOM and asking myself this same question 2 minutes ago. Personally, I'm keeping the language as vague as possible.

Our dept is small and the Captain's decisions are never questioned by the owner so we don't run into the same issues (i.e., duty time and rest requirements) as bigger dept's. When writing your manual I say only include what HAS to be in there for your particular operation. Don't hang yourself with your own rope.

Probably sage advice but when you set out to be IS BAO complient, it is difficult if not impossible to brush issues under the rug. There are some advantages to the IS BAO approval, and it does not come cheap or easy to comply with their doctrine, but it would appear to be a pretty sound program all in all.

 

[HMR]

Probably sage advice but when you set out to be IS BAO complient, it is difficult if not impossible to brush issues under the rug. There are some advantages to the IS BAO approval, and it does not come cheap or easy to comply with their doctrine, but it would appear to be a pretty sound program all in all.

Agreed.

A neighboring flight dept. just paid the big bucks for the IS BAO. It's a pretty serious manual and necessary for the large # of pilots they employ and the frequent international trips they fly. I looked into it awhile back for us but couldn't justify the cost for our little operation. I was able to get an excellent manual from a large, well known PT91 dept. I pared it down to about half it's original size. We're so small, there really isn't much that needs to be in our manual. It's main purpose is to get contract pilots up to speed before a flight.