ALPA's Fatigue Recommendations to the FAA
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SpiraMirabilis
Possible Subversive
Re: LPA's Fatigue Recommendations to the FAA
I read it but I was wondering how they define airline. Is an on-demand/non-scheduled 135 air carrier an airline?
I read it but I was wondering how they define airline. Is an on-demand/non-scheduled 135 air carrier an airline?
TheOneMarine
Well-Known Member
Re: LPA's Fatigue Recommendations to the FAA
So, stupid question but what exactly is a Notice for Proposed Rule Making? It's not the actual rule correct? Where in the whole scheme and process of things does it fall?
So, stupid question but what exactly is a Notice for Proposed Rule Making? It's not the actual rule correct? Where in the whole scheme and process of things does it fall?
SpiraMirabilis
Possible Subversive
Re: LPA's Fatigue Recommendations to the FAA
NPRM is a process where the FAA (or other governmental body) publishes the fact that they intend to change the rules or regulations so as to give the public the opportunity to do, ahh I don't know. Protest feebly and futilely?
NPRM is a process where the FAA (or other governmental body) publishes the fact that they intend to change the rules or regulations so as to give the public the opportunity to do, ahh I don't know. Protest feebly and futilely?
Nick
Well-Known Member
The 'meat' of it:
ALPA’s 6-point recommendation plan focused on securing the following for our members: (1) one rule for all airline pilots, not “carving out” the cargo and supplemental operators; (2) a minimum 10-hour rest period; (3) a reserve rest rule for all pilots; (4) having multiple segments and circadian rhythm disruptions addressed; (5) establishing limitations on duty periods, flight duty time, and block time based on the fact that excessive working hours affect flight safety; and (6) requiring the operator to prepare and publish reliable schedules.
“We must have a single rule for all types of flying: domestic, international, and supplemental,” said Capt. John Prater, ALPA president. “There is no basis in science, nor is there a true operational need, to have separate rules.”
ALPA’s recommendations, based on operational experience and scientific study, incorporate ICAO and IFALPA guidelines and represent a comprehensive framework, in concept and in detail, of a flight- and duty-time and rest requirement rule. The concepts within your union’s recommendation demonstrate a scientific way of addressing both short-term and cumulative (long-term) fatigue safeguards for all operations.
Other concepts that ALPA addressed included a non-punitive provision for pilots to be removed from flight duties when they are fatigued, and a fatigue education program. ALPA is also proposing the following block and flight duty-time limits, as well as a 10-hour minimum rest.
Maximum Flight Time (Block) Limits:
Time of Report (Home Base) Maximum Flight Time (hours)
0000–0459 7
0500–0659 8
0700–1259 9
1300–1959 8
2000–2359 7
Flight Duty Period: Non-augmented Operations
Time of Report (Home Base or Acclimated) Maximum Flight Duty Period (hours) for Lineholders Based on
Number of Flight Segments
1 2 3 4 5 6 7+
0000–0359 9 9 9 9 9 9 9
0400–0459 10 10 9 9 9 9 9
0500–0559 11 11 11 11 10 9.5 9
0600–0659 12 12 12 12 11.5 11 10.5
0700–1259 13 13 13 13 12.5 12 11
1300–1659 12 12 12 12 11.5 11 10.5
1700–2159 11 11 10 10 9.5 9 9
2200–2259 10.5 10.5 9.5 9.5 9 9 9
2300–2359 9.5 9.5 9 9 9 9 9
ALPA’s 6-point recommendation plan focused on securing the following for our members: (1) one rule for all airline pilots, not “carving out” the cargo and supplemental operators; (2) a minimum 10-hour rest period; (3) a reserve rest rule for all pilots; (4) having multiple segments and circadian rhythm disruptions addressed; (5) establishing limitations on duty periods, flight duty time, and block time based on the fact that excessive working hours affect flight safety; and (6) requiring the operator to prepare and publish reliable schedules.
“We must have a single rule for all types of flying: domestic, international, and supplemental,” said Capt. John Prater, ALPA president. “There is no basis in science, nor is there a true operational need, to have separate rules.”
ALPA’s recommendations, based on operational experience and scientific study, incorporate ICAO and IFALPA guidelines and represent a comprehensive framework, in concept and in detail, of a flight- and duty-time and rest requirement rule. The concepts within your union’s recommendation demonstrate a scientific way of addressing both short-term and cumulative (long-term) fatigue safeguards for all operations.
Other concepts that ALPA addressed included a non-punitive provision for pilots to be removed from flight duties when they are fatigued, and a fatigue education program. ALPA is also proposing the following block and flight duty-time limits, as well as a 10-hour minimum rest.
Maximum Flight Time (Block) Limits:
Time of Report (Home Base) Maximum Flight Time (hours)
0000–0459 7
0500–0659 8
0700–1259 9
1300–1959 8
2000–2359 7
Flight Duty Period: Non-augmented Operations
Time of Report (Home Base or Acclimated) Maximum Flight Duty Period (hours) for Lineholders Based on
Number of Flight Segments
1 2 3 4 5 6 7+
0000–0359 9 9 9 9 9 9 9
0400–0459 10 10 9 9 9 9 9
0500–0559 11 11 11 11 10 9.5 9
0600–0659 12 12 12 12 11.5 11 10.5
0700–1259 13 13 13 13 12.5 12 11
1300–1659 12 12 12 12 11.5 11 10.5
1700–2159 11 11 10 10 9.5 9 9
2200–2259 10.5 10.5 9.5 9.5 9 9 9
2300–2359 9.5 9.5 9 9 9 9 9
400A
New Member
Re: LPA's Fatigue Recommendations to the FAA
Interesting. Any idea how they will define "acclimated" and what the duty limits/flight limits may look like for reserve holders?
Also, any talk of cleaning up the duty language (out of the gutter boys) and getting a more clear definition of what is duty and what and how rest must be assigned?
Interesting. Any idea how they will define "acclimated" and what the duty limits/flight limits may look like for reserve holders?
Also, any talk of cleaning up the duty language (out of the gutter boys) and getting a more clear definition of what is duty and what and how rest must be assigned?
Nick
Well-Known Member
That's what I was wondering about too.
ALL research I have ever read on the subject says that a healthy human body needs a day for each hour.
Screaming_Emu
Well-Known Member
Re: LPA's Fatigue Recommendations to the FAA
Sounds good. I'm curious as to why it specifies "lineholder". I really hope this isn't another thing where reserve pilots get screwed on. It already seems like every good thing in our contract has a part on it that says
*does not apply to reserve pilots
Sounds good. I'm curious as to why it specifies "lineholder". I really hope this isn't another thing where reserve pilots get screwed on. It already seems like every good thing in our contract has a part on it that says
*does not apply to reserve pilots
surreal1221
Well-Known Member
Re: LPA's Fatigue Recommendations to the FAA
Pay your dues beyotch!
Not calling Joe a beyotch. . .so don't get your feathers in a ruffle.
Pay your dues beyotch!
Not calling Joe a beyotch. . .so don't get your feathers in a ruffle.
kellwolf
Piece of Trash
Re: LPA's Fatigue Recommendations to the FAA
So, how is this gonna affect high speeds? Looks like it would kill those (not that I'm REALLY complaining). Be kinda hard to complete a high speed with 11 hours of duty, but at that point you'd basically just be working the night shift. For the average of our 5 leg days, this would knock off about 1-2 hours of duty from what we have now. Not THAT much of an improvement, IMO, but I really like the min 10 hours of rest.
So, how is this gonna affect high speeds? Looks like it would kill those (not that I'm REALLY complaining). Be kinda hard to complete a high speed with 11 hours of duty, but at that point you'd basically just be working the night shift. For the average of our 5 leg days, this would knock off about 1-2 hours of duty from what we have now. Not THAT much of an improvement, IMO, but I really like the min 10 hours of rest.
OldTownPilot
Well-Known Member
Re: LPA's Fatigue Recommendations to the FAA
I like the 9 hours on a 2 man crew to please all the senior mainline guys so that they can be even more productive.
NOT!
You'll see a lot of european flights that can squeeze 8 hours east bound, and be less than 9 coming back being flown without a 3rd pilot that get one now. Plus a lot of carribean turns from NYC are in that 8.5 hour range that loose a relief pilot. Its great for a lot of regionals but in some aspects its concessionary for a good chunk of pilots as well
I like the 9 hours on a 2 man crew to please all the senior mainline guys so that they can be even more productive.
NOT!
You'll see a lot of european flights that can squeeze 8 hours east bound, and be less than 9 coming back being flown without a 3rd pilot that get one now. Plus a lot of carribean turns from NYC are in that 8.5 hour range that loose a relief pilot. Its great for a lot of regionals but in some aspects its concessionary for a good chunk of pilots as well
Polar742
All the responsibility none of the authority
Re: LPA's Fatigue Recommendations to the FAA
Yeah, but according to the table, that 9 hours of flying needs to be done in, at most, 13 hours of duty. Tough to do, at least in my kind of operation.
Yeah, but according to the table, that 9 hours of flying needs to be done in, at most, 13 hours of duty. Tough to do, at least in my kind of operation.
OldTownPilot
Well-Known Member
Re: LPA's Fatigue Recommendations to the FAA
Passenger airline wise you could easily do 9 hours on three legs in under 13 hours of duty.
1 hour for checkin
9 hours for flying
2 hours on the ground betwween flights (1 each)
and 15 minutes for checkout
Thats 12:15
Internationally a 9 hour light is only 10:30 duty.
Passenger airline wise you could easily do 9 hours on three legs in under 13 hours of duty.
1 hour for checkin
9 hours for flying
2 hours on the ground betwween flights (1 each)
and 15 minutes for checkout
Thats 12:15
Internationally a 9 hour light is only 10:30 duty.
FLflyer
Well-Known Member
Re: LPA's Fatigue Recommendations to the FAA
The problem with this is that the airlines will still have an "out" with duty times. Sure, they will only be able to schedule to, for example 13 hours duty, but it will be able to be extended to 15 hours (WX, delays, etc.) That's BS. They should NOT be able to extend the duty times for ANY reason. 13 hours is here? I'm a pumpkin, bad WX or not. Watch what happens though, we'll get screwed again on that one.
The problem with this is that the airlines will still have an "out" with duty times. Sure, they will only be able to schedule to, for example 13 hours duty, but it will be able to be extended to 15 hours (WX, delays, etc.) That's BS. They should NOT be able to extend the duty times for ANY reason. 13 hours is here? I'm a pumpkin, bad WX or not. Watch what happens though, we'll get screwed again on that one.
sherpa
Well-Known Member
Re: LPA's Fatigue Recommendations to the FAA
Is the average crew scheduler and pilot smart enough to keep track of all this???!!!
Is the average crew scheduler and pilot smart enough to keep track of all this???!!!
kellwolf
Piece of Trash
Re: LPA's Fatigue Recommendations to the FAA
Our crew schedulers can't even get our current stuff right, and those rules have been in place for 10 years if you count the contractual stuff. Throw this sliding scale in there, and you'll need a fool-proof chart at every station. Even then, we're still gonna get in arguments on the phone. Either way, it's gonna be a nightmare when it finally happens.
"No, we puts you on dis trip. It be legal."
"No, you can't as of yesterday. See, it's a 5 leg trip with a 14 hour duty day that starts at 6 am"
"Uh.....huh?"
Our crew schedulers can't even get our current stuff right, and those rules have been in place for 10 years if you count the contractual stuff. Throw this sliding scale in there, and you'll need a fool-proof chart at every station. Even then, we're still gonna get in arguments on the phone. Either way, it's gonna be a nightmare when it finally happens.
"No, we puts you on dis trip. It be legal."
"No, you can't as of yesterday. See, it's a 5 leg trip with a 14 hour duty day that starts at 6 am"
"Uh.....huh?"
surreal1221
Well-Known Member
Re: LPA's Fatigue Recommendations to the FAA
The average? Probably not.
The above average? You'll be damn skippy. I won't be violated because of the company's below average crew scheduler can't follow the software.
The average? Probably not.
The above average? You'll be damn skippy. I won't be violated because of the company's below average crew scheduler can't follow the software.
ClearedForOption
Displaced... again.
Re: LPA's Fatigue Recommendations to the FAA
One big problem with all of these changes is a true definition of when our rest period begins and ends.
Is it... 15 min after block in to check in time - i.e. after we wait for the hotel van for 45 minutes for the 30 min drive to the hotel - with a hotel that only runs vans on the half hour - so with a 5:56 show time we have to take a 5 am van. Where a currently 'legal' 9 hour regular rest becomes 7 hours behind the door with maybe 5 hours of sleep. (because everyone can instantly drop off to sleep after a 13 hour day fighting the weather in and out of ORD and shooting aproaches to mins when you are switching your body from afternoon shift to morning shift - throw in that shave and shower to look professional when you aren't being treated like one - and you have a night)
Or... time behind the door... door to door.
There will always be an out unless we have the language to support these new (potential) rules. There are stooges always looking for the loopholes.
One big problem with all of these changes is a true definition of when our rest period begins and ends.
Is it... 15 min after block in to check in time - i.e. after we wait for the hotel van for 45 minutes for the 30 min drive to the hotel - with a hotel that only runs vans on the half hour - so with a 5:56 show time we have to take a 5 am van. Where a currently 'legal' 9 hour regular rest becomes 7 hours behind the door with maybe 5 hours of sleep. (because everyone can instantly drop off to sleep after a 13 hour day fighting the weather in and out of ORD and shooting aproaches to mins when you are switching your body from afternoon shift to morning shift - throw in that shave and shower to look professional when you aren't being treated like one - and you have a night)
Or... time behind the door... door to door.
There will always be an out unless we have the language to support these new (potential) rules. There are stooges always looking for the loopholes.