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Gomerski'
- Joined
- Jun 12, 2005
- Posts
- 195
Flight and Duty Time regulations have been a very sensitive topic for all of us the last several months. Colgan Air has been fully engaged with our local FAA FSDO to work out the issues in a collaborative effort. We are pleased to advise you many issues regarding 121.471 have been resolved. One major area 121.471(g) - the FAA agrees that a flight crewmember can go over 8 hrs of flight time in 24 hours under certain conditions. Conditions are:1. Circumstances beyond the control of Colgan Air such as ATC, Weather, and Diversions (not last leg - anytime during the day).
2. Your original schedule has not been modified where it would put you over 8 hours. Example, your original schedule is 4.3 hrs and your actual projection for the day is still 4.3 hrs. During the day your schedule is modified and added 2.0 hrs block time for a total of 6.3 hours
projected for that day. No issue, you can still exceed 8 hours due to circumstances beyond the control of the operator.
3.
Crews that go over 8 hours of flight time, Colgan Air will keep a record on reasons why. This will protect Colgan Air and the applicable flight crew.
Thank you for your support and understanding in this very important matter.
Additionally, if on the last day (not last flight) a pilot was approaching the weekly, monthly or annual maximum flight times (scheduled correctly to not exceed limitation), if circumstances beyond the control of the operator causes the pilot to go over these maximums, it is fully in compliance with the regulations.
The other item is 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, Colgan Air will prohibit any flight activity
when duty will exceed 18 hours. Currently Colgan 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.
Since Flight and Duty time regulations are very difficult to interpret and apply, one of the best documents I have studied is the ALPA “Guide to Flight Time Limitations and Rest Requirements”, 6-A edition, June 2004. This document supports FAA Legal Interpretations and is in-line with airline industry practices. Please check the ALPA website to obtain a copy which provides excellent clarity by means of Q&A’s. This document will provide you proper guidance to comply with 121.471, including accurate guidance on the limited conditions which allow more than 8 hours of flight time within 24 hours.
The other item is 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, Colgan Air will prohibit any flight activity
when duty will exceed 18 hours. Currently Colgan 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.
Since Flight and Duty time regulations are very difficult to interpret and apply, one of the best documents I have studied is the ALPA “Guide to Flight Time Limitations and Rest Requirements”, 6-A edition, June 2004. This document supports FAA Legal Interpretations and is in-line with airline industry practices. Please check the ALPA website to obtain a copy which provides excellent clarity by means of Q&A’s. This document will provide you proper guidance to comply with 121.471, including accurate guidance on the limited conditions which allow more than 8 hours of flight time within 24 hours.
Thank you for your support and understanding in this very important matter.
And they wonder why morale is low?
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