New Flight Time and Duty Day Regulations

[Carl_Spackler]

If the company contacts you during your rest period, you should have the option to extend your rest period. period.

The transportation "local in nature" has to go. Your show time and duty day should start in the hotel lobby and end when you get to the hotel that night. And forget calling sked to let them know you are at the hotel, they need to invest in some technology so we can send a text message and get an automated one back with an adjusted show time in the morning if it is required. I don't want to be on hold for 30 min waiting for 1 of the 2 schedulers working to pick up the phone.

And to throw a bone to us commuters, they should positive space us to work and provide a hotel.

 

[Blue Dude]

A 12 hr max duty day seems popular, and I think that's a good idea, but with a twist. Eliminate flight time requirements and focus on duty day. We know that sit time at the airport is at least as fatiguing as time in the cockpit, so eliminate that from consideration. Instead, reduce the max duty day according to the number of legs flown, say by one hour per leg over 2. If 3 legs, then 11 hr max, if 4 legs then 10, etc.

Further reduce the duty day if any part of it will occur overnight. If any part of the duty day touches 0100 to 0500 base time, then the max duty day is reduced 3 hr. Back-side of the clock covers redeyes and high-speeds.

The duty day should also include average transit time to/from company provided hotels, just as average taxi-in time and pre- and post-flight duties are included under Whitlow. It should also include 2 hrs transit time before show. Min rest is 10 hrs, period. With the pre-show transit, min rest in base is effectively 12 hrs.

Any max duty day cannot be scheduled to be exceeded, but legal to start, legal to finish the duty day, extendable by only 2 hrs if circumstances outside of the carrier's control (IROP). The back side of the clock reduction doesn't apply if you go into it inadvertently.

Summary:
Base duty day: 12 hrs
-1 hr for each leg over 2
-3 hrs for back side of the clock duty
+2 hrs for IROP

Min rest 10 hrs, which doesn't include average hotel transit time or 2 hrs of pre-trip transit.

Examples:
Turn max (2 leg): 12 hr, 9 hr if back-side. IROP: 14 and 11.
Busy max (4 leg): 10 hr, 7 hr if back-side. IROP: 12 and 9.
Regional max (6 leg): 8 hrs, 5 hr if back-side (which makes it impossible to schedule heavily front- or back-loaded high-speeds). IROP: 10 and 7.

 

[FBN0223]

A 12 hr max duty day seems popular, and I think that's a good idea, but with a twist. Eliminate flight time requirements and focus on duty day. We know that sit time at the airport is at least as fatiguing as time in the cockpit, so eliminate that from consideration. Instead, reduce the max duty day according to the number of legs flown, say by one hour per leg over 2. If 3 legs, then 11 hr max, if 4 legs then 10, etc.

Further reduce the duty day if any part of it will occur overnight. If any part of the duty day touches 0100 to 0500 base time, then the max duty day is reduced 3 hr. Back-side of the clock covers redeyes and high-speeds.

The duty day should also include average transit time to/from company provided hotels, just as average taxi-in time and pre- and post-flight duties are included under Whitlow. It should also include 2 hrs transit time before show. Min rest is 10 hrs, period. With the pre-show transit, min rest in base is effectively 12 hrs.

Any max duty day cannot be scheduled to be exceeded, but legal to start, legal to finish the duty day, extendable by only 2 hrs if circumstances outside of the carrier's control (IROP). The back side of the clock reduction doesn't apply if you go into it inadvertently.

Summary:
Base duty day: 12 hrs
-1 hr for each leg over 2
-3 hrs for back side of the clock duty
+2 hrs for IROP

Min rest 10 hrs, which doesn't include average hotel transit time or 2 hrs of pre-trip transit.

Examples:
Turn max (2 leg): 12 hr, 9 hr if back-side. IROP: 14 and 11.
Busy max (4 leg): 10 hr, 7 hr if back-side. IROP: 12 and 9.
Regional max (6 leg): 8 hrs, 5 hr if back-side (which makes it impossible to schedule heavily front- or back-loaded high-speeds). IROP: 10 and 7.

In other words, we at Jetblue(a non-union carrier) want to do turns that but that eight hour rule screws us.

 

[Blue Dude]

I couldn't care less about transcon turns. I would just rather fly than sit, even if that means three legs worth 9 hrs vs four legs worth 7 with a three hour sit in the middle. Which is more *fatiguing*, genius? Now how about some constructive input?

 

[WMUSIGPI]

I'm nowhere near as optimistic as most of you.

1. I was working for a frac operation during the 135 "re-write" which essentially changed nothing but made it a helluva lot more complicated.

2. CDO's are not inherently unsafe. What makes them unsafe is the pilots who get scheduled into them outside of their normal rythym and/or the idiot pilots who choose not to get the rest when they have the chance. While CDO's are great to constantly whine about they are simply the night shift, nothing more.

Increase the transition period so scheduling cannot flip a reserve pilot to a CDO and back as easily and you might have something.

3. I am absolutely all for simple, but that simply won't happen. More likely the new rules will complicate all kinds of stuff but accomplish nothing except the opposite of their intentions. That is the spirit of all new/modern FAA rules.

4. I do expect commuters to be hurt by anything new.

I love bidding CDO reserve. I don't want to see that lost. My problem with it is when you are on P3 (CDO reserve) and set up your sleep schedule to match then the second night scheduling calls at 1925 to put you back to rest (after already sleeping for the proper contact times) to show at 5:30 for 8 hours of ready reserve that now you need to be functional to be AT THE AIRPORT at 5:30 and available to work til 19:30. Two days of that then it's back to the CDO period availablity you last night... that's VERY unsafe and impractical but done all the time here.

It's the daily shift changes that pose the biggest problem. You never know WHEN to sleep because things can be changed on you on a whim.

This type of thing has also burned me as a lineholder too. You have a reduced rest overnight with 2 short legs the next morning. No big deal. Oh but wait get to the overnight city, and how bout a repo flight back to the hub then a flight back to the overnight getting there about 6 hours after you were scheduled/planned to be there (and basically usless on that last approach). If I go off duty with 2 legs the next day then dangit 2 legs is it period.

 

[BoilerUP]

Having done a transcon turn within a 14 hour duty day part 91, they are MUCH less fatiguing than a 2-4 hour sit in the middle of the day.

 

[XJohXJ]

I love bidding CDO reserve. I don't want to see that lost.

This is where pilots work against themselves when it comes to safety. You and sever others don't see any problem with CDO's per se. That's fine, I can't argue with your experience.

Myself and several others believe that CDO's are just plain unsafe. Why? Because I know that I can't do them. They f#ck me up too much, even when I flip to the backside for a full month. I'm not alone in my inability to adjust.

You want to keep them. I want to ban them. How about protecting those of us who simply know that we are not safe in a CDO environment from ever having to do them? I'm amazed that ALPA is not fighting CDO's with full force. I know that they aren't because some pilots like them so much.

However, there is science to back up the assertion that some individuals can do them and some can't. Some individuals can do things which others cannot. It has nothing to do with being a pilot and everything to do with individual physiology.

If you want to keep CDO's, fine, take them all. Just fight for some protections for those of us who can't do them.

 

[Splert]

The FAA, led by former ALPA MEC Chairman Randy Babbitt, is looking to rewrite the flight time and duty day regulations for FAR 121 carriers.

My questions to this forum is, if you had the authority to write the regulation and implement new flight time and duty day rules, what would they look like.

For me, I would suggest no more than a 12 hour duty day (domestic), 14 hour (international), and current Ultra Long Haul rules, but keep the 8 hour flight time restriction for two pilot aircrews. Comments?

Just my opinion, I could be wrong.

Champ 42272

How about making:

1 for 1.5 Actual Duty Time Rig an FAR
1 for 3 TAFB Trip a FAR
6 hour daily and duty period min a FAR
1.25 Night Rig Override a FAR
Etc...

Then every airline will schedule efficiently as opposed to what works for marketing. Otherwise a 12 hour duty day may only credit 2 hours and we will all work longer hours away from home for less pay.

 

[BoilerUP]

One must not confuse the desire to improve safety with that to improve their W2s.

 

[XJohXJ]

You are absolutely right, Boiler.

However, do you think that a motivated crew is likely to be safer than a dejected, demotivated crew?

 

[Splert]

One must not confuse the desire to improve safety with that to improve their W2s.

I'm not...

Marketing schedules is what drives pilot schedules.

Long duty days are necessary to fit enough block hour into a day of flying.

Efficient schedules drive safety. Long duty days with very few block hours or long duty days with 10 legs hurt safety.

 

[BoilerUP]

While financial motivations are very powerful and not having to worry about affording a hotel room if you commute in the night before is important, truly professional pilots shouldn't now or ever tie how professional or safe they act and fly to their income or income potential.

The best way for airline pilots to squander the current outrage (and therefore leverage for improvements) Joe Q Public feels on this issue is to so much as appear to be more concerned about your wallet than the safety of the traveling public.

Shortening maximum duty and lengthening minimum rest will both improve overall safety and should reduce overall crew fatigue in a way palatable to the flying public & politicians without coming off as a money grab by labor. How those changes are best implemented will be largely out of the hands of line pilots (and probably even ALPA).

I personally think a max 14 hour duty day with minimum non-reducible rest of 10 hours would be a BIG improvement and the most likely change as it would be (mostly) in line with 91K and 135 requirements. If we want to limit the max scheduled duty time to 12 hours, that'd probably help too. In order to avoid the law of unintended consequences from this change causing a loss of days off & QOL due to utilization, raise the max daily flight time to a hard 10 hours (if placing any limit on it at all).

But we've all got our opinions...

 

[BoilerUP]

Efficient schedules drive safety. Long duty days with very few block hours or long duty days with 10 legs hurt safety.

Agreed...but proposing pay rigs become LAW is the wrong way to go about improving safety because it doesn't appear to have safety as the primary interest.

 

[Splert]

Agreed...but proposing pay rigs become LAW is the wrong way to go about improving safety because it doesn't appear to have safety as the primary interest.

I disagree...as long as marketing determines when we fly, our schedule will not be as safe. All airlines need the same incentive to include fixed pilot cost into the mix. A short duty day with a limit on landing will only lead to 6 days off a month for most pilots who don't have strong work rules.

Work rules should be the law just like min. wage and other requirements.

 

[IBNAV8R]

12 hour max duty days - could extend two hours for irops (this extension may be applied only twice per calendar month).

10 hours minimum rest scheduled. Could be reduced to 9 ONLY for irops.

Reduced rest may only be applied twice in any calendar month.

Any reduced rest requires 12 hours compensatory rest beginning no later than 24 hours after the beginning of the reduced rest period.

A rest period begins at the hotel AFTER check-in and ends BEFORE getting on the shuttle.

Scheduled Duty day will not exceed rest period immediately prior. This may be extended up to two hours for irops. However, there shall be no allowance for irops following a rest period.

CDOs must be agreed to by crewmember with NO repercussions from company.

CDOs shall be flown as schedule with NO additional flights. A single flight may be added during irops to get flight crew to it's home base.

Fatigue calls shall have no repercussions. Company may track excessive fatigue calls.

10 hours flight time w/2 landings max.
9 hours flight time w/3 landings max.
8 hours flight time w/4 landings max.
8 hours flight time w/6 landings max. - 11 hour max duty day
7 hours flight time w/8 landings max. - 10 hour max duty day

No more than 8 landings - including irops.

Each crewmember shall have 30 minutes away from the aircraft at least once for each 5 hours of duty time as landings allow. No duties shall be required during this period.

30/7 still applies 24 off in 7 still applies.

At least once per calendar month, a pilot must have at least 3 consecutive days off.

Hotels would be required to provide comfortable quiet rooms for the ENTIRE rest period (no knocks from housekeeping, no vacuum cleaners banging your door, ice machines, elevators, construction, property maintenance, etc.)

Hot food available at beginning and end of rest period (Jack in the Box that won't serve walk-ups at the drive through doesn't count).

 

[Raskal]

XJohXJ I understand the dislike for CDO's/highspeeds/stand-ups and whatever else they're called. I don't like them myself. However, working the backside of the clock is pretty normal in anything aviation. It's only recently that many of the "red-eye" flights went away from airlines. I think removing CDO's as an option would hurt both our company and our pilots; financially and through quality of life.

I also hate the same thing you do, scheduling changing reserve periods whenever they want. I have no idea what other airlines are like regarding this, but if I bid P3 I rarely stay on it for the whole month. That is wrong-no question. Good luck getting that strengthened though.

I agree with a couple of others too, bring the 14 hour duty day (with 10 hours of rest) to our side of aviation. Reduced rest is often dangerous, especially during heavy winter ops.

 

[OO pilot]

I agree with the max duty being tied with the number of landings.
Cycles is the main cause for fatigue, not flying:
6 hours of flying in one leg is a LOT less tiring than 6 hours of flying with 6 legs.

 

[Raskal]

I agree with the max duty being tied with the number of landings.
Cycles is the main cause for fatigue, not flying:
6 hours of flying in one leg is a LOT less tiring than 6 hours of flying with 6 legs.

Really? Maybe it's personal, but I find myself more awake on a 6-leg day than I used to on the east to west coast runs. I was flat out wiped after 5-6 hours in one leg. More cycles seem to keep me a bit more aware.

 

[Going2Baja]

All great ideas!!! Hopefully it will take place soon and the end result will prevent furloughs! Keep up the great brainstorming!

Baja.

 

[Spud]

Max scheduled duty period.... 12hours.

Max allowed on duty...... 14 hours

Minimum scheduled Rest.... 10 hrs

No limit on flying within that scheduled 12 hr. Duty Period.

Some limitations on A.M. / P.M. mixing in pairing and line construction. Keeping similar circadian rhythm.

K.I.S.S. plus I think this lines up pretty well with the NTSB guidelines from their fatigue study.