Whitlow application to 121.467

[Andy Neill]

I'm in BBB's corner on this one. Just as pilots need a minimum of 8 hours rest in the last 24, 121.467b(3) requires a minimum of 8 in the last 24. While the FA may not be on duty while on reserve call, he/she is certainly not resting. I can't see how a 24 hour reserve call period would be legal if the crewmwmber is actually expected to fly 16 hours into the callout period.

 

[igneousy2]

Whitlow does not apply to to FA's. It is a narrow letter only refering to pilots. However, I do agree that the concept is the same and if tested, it would probably be ruled that the rule applies the same to FA's as to pilots.

As far as the question "is 24 hour reserves legal", again, remembering the fact that Whitlow does not legally apply to FA's, I will answer the question is a "PILOT allowed to be on reserve for 24 hours".

Whitlow, and all of the rest and duty time limitations does not limit your duty, it limits when you can FLY REVENUE under 121.

What Whitlow changed was the fact that you had to look back 24 hours and find 8 hours of REST which is defined as free from ALL duty (no phone answering, no carrrying a pager, no throwing bags, no training, no mx test hops, etc.) The significance of this fact is the company MAY require you to be on "reserve" for 24 hours a day for 365 days straight and still be "legal", however, as soon as they want you to fly, they would have to relieve you from duty for 8 hours. So, what a company could do is have you on reserve 24/7, when a trip opened up they could assign you the trip and then release you into 8 hours of rest. They could call at Midnight, release you into rest, and have you report to the airport at 0800 and you would be legal under Whitlow.

Luckily, this is not practical for most carriers so they developed the RAP system to ensure that pilots were in fact available immediatelly during their normal operating times.

Whitlow and other rest rules do not apply to any other "duty" that pilots may be assigned. MX test hops, training flights, ground school don't get restricted by Whitlow or any other rule. You could be assigned 10 days straight of MX test hops followed by 20 days of ground school, followed by 7 days of reserve but you would need 24 hours off before you could accept an assignment for a revenue flight.

This is under the regs, your contract probably offers tighter standards...hopefully.

Later

Later

 

[thowe21]

can someone please explain the 9 in 8, 10 in 9, and 11 in 10 rule of 121.471(c), and how you can be scheduled more than 8 hours

 

[slowto250]

can someone please explain the 9 in 8, 10 in 9, and 11 in 10 rule of 121.471(c), and how you can be scheduled more than 8 hours

As the resident rocket scientist, here goes :

Must have had 9 hours rest within preceeding 24 hours when scheduled to fly up to 8 hours (flight time).
Must have had 10 hours rest within preceeding 24 hours when scheduled to fly up to 9 hours.
Must have had 11 hours rest within the preceeding 24 hours when scheduled to fly upto 10 hours.

You can be scheduled to fly more than 8 hours as long as you have had sufficient rest time (see above) within the last 24 hour period.

Capiche ?

Back to my day job at Morton Thiokol.

 

[JAFI]

Normally a Legal Interpitation lists the regulations the interpitation is for. I do not have a copy of the Witlow letter handy, but re-read the letter for the specific regulation. Also, if an Interpitation or regulation uses the words "Flight Crewmember" it is about the Cock Pit Crew. If the word "Crewmember" is used, it is about the entire crew required on the aircraft for flight.

Flying Dawg, any one can report a possible violation of the regulations or a safety concern. The FAA Safety Hotline is 800-255-1111. The more information you can provide: date, time, flight number, person(s), situation, etc. the better/quicker the investigation can go. You can ask for feed back, not ask for feed back, give your name, not give your name, and set some conditions of report. It is up to you to decide. PM me if you have any questions.

If there is not union assistance at that airline, sometimes another companies union will assist because if they can fight a battle elseware they won't have to fight it at home, or they might give you some information you do not have.

JAFI

 

[thowe21]

ok so the 8 hours maximum flight time between rest periods does not apply as long as you have the required resting time betweeen periods see above... just making sure thanks

 

[Andy Neill]

No, that's not quite it. You may not be scheduled for more than 8 hours of flight time in any given duty period. However, since more than one duty period may be found in a 24 hour period, you must have the prescribed amount of normal (or reduced) rest in those 24 hours. For instance, let's say someone is scheduled to be on duty from 0600 to 1000 with 3 hours of flight time. After a 12 hour rest, he/she begins another 8 hour duty period ending at 0600 with 6 hours of flight time. The total amount of flight time scheduled in the 24 hours is 9 and within that 24 hours he/she must have at least 11 hours of consecutive rest. In the example given, it is legal because the required rest was there and no more than 8 hours of flight time was found in any duty period between required rest periods.

 

[thowe21]

wow that was way to simple, don't know why I didn't get that. Thanks for your help