Colgan 18 hour days ???

[L-16B]

After 3407 and the NTSB and everything that has happened..... Really??

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.

 

[wheelsup]

What really sucks is they will continue to win contracts and get awarded flying from the other companies out there that treat their employees only semi-inhumanely. What a joke.

 

[L-16B]

Colgan Air Safety,

The Read and Sign Memo DO #09-05 published today, July 21, 2009, clarifies some very important issues regarding flight and duty times. We thank Colgan Air and the FAA for their diligent work in resolving the interpretations of FAR 121.471.

The one troubling item in the memo is the extension of the duty day to 18 hours for Part 91 tail end ferries. Colgan Air has recently issued a Fatigue Bulletin to our Flight Operations Policies and Procedures Manual stating that after 17 hours of being awake a person is experiencing the equivalent of a 0.05% alcohol level. This blood alcohol level is intoxicated according to the FAA and operating an aircraft, under any Part of the FAR's would be illegal. Please note that after 16 hours of duty crewmembers have been awake for at least 17 hours as duty time does not include time necessary for personal needs, hygiene, nutrition, or local transportation to the airport prior to reporting time.

A properly formulated risk assessment tool would recognize the above and simply result in a "no fly" for anyone exceeding 16 hours of duty. According to Colgan Air's own documentation, pilots would be operating with the diminished capabilities of an intoxicated individual. Obviously operating an aircraft in this manner is simply unsafe and no valid risk assessment tool can come up with any other answer.

Thank you for your consideration of this very important safety concern. We trust that the memo will be revisited and revised to ensure a safe operation.







This was written by our Alpa Air Safety Committee. 18 Hours is too long of a duty day, part 91 or part 121. I heard after the crash that Colgan wasn't going to count repo flights as 91? Guess not....

 

[wheelsup]

Here's the thing - unless you guys put another Q400 into a building full of people while ferrying no one is going to care. Even the Flagship 3701 crash where the pilots were fooling around in, the public didn't care about because no innocent folks were killed.

So either a crew is going to have to take one for the team, or it'll never change. Sad as that it.

 

[Hernandezcfi]

That's all good man because we can just drop the "F Bomb" (Fatigued) whenever we need to if we feel like calling it a day. People are no longer afraid to make that call. I have been activated three times in the past month for Fatigue calls.

If they try to get cute with you by extending you after even 10 hours, just drop the F Bomb and tell them to stick it. The new fatigue policy seems bulletproof...at least for now.

 

[SmitteyB]

That's all good man because we can just drop the "F Bomb" (Fatigued) whenever we need to if we feel like calling it a day. People are no longer afraid to make that call. I have been activated three times in the past month for Fatigue calls.

If they try to get cute with you by extending you after even 10 hours, just drop the F Bomb and tell them to stick it. The new fatigue policy seems bulletproof...at least for now.

We wouldn't have the amount of ferry flights if our MX was in a hub, not an outstation!!

Q400 and IAH guys- You don't ferry at all do you?

In the SAAB in the Northeast it is much different. Because we only do MX in ALB and IAD, crews are flying 14 hour duty days then ferrying from PQI to ALB. It doesn't make much sense and if it's not safe, personally I WILL NOT fly it.

 

[kellwolf]

That's all good man because we can just drop the "F Bomb" (Fatigued) whenever we need to if we feel like calling it a day. People are no longer afraid to make that call. I have been activated three times in the past month for Fatigue calls.

If they try to get cute with you by extending you after even 10 hours, just drop the F Bomb and tell them to stick it. The new fatigue policy seems bulletproof...at least for now.

So, when you guys call in fatigued, is that it or is there more involved? When we call in fatigued on this side of the house we get the immediate "I can't believe you're doing this! Do you know how short we are?" from scheduling, followed by filling out a flight safety report and a "fact finding" meeting with the base manager. Now, we've got a couple of base managers (at most) where it's pretty much a no big deal type thing. Then we've got other base managers that you're looking for a union rep if you just see them walking down the hallway looking at you.

 

[L-16B]

We wouldn't have the amount of ferry flights if our MX was in a hub, not an outstation!!

Q400 and IAH guys- You don't ferry at all do you?

In the SAAB in the Northeast it is much different. Because we only do MX in ALB and IAD, crews are flying 14 hour duty days then ferrying from PQI to ALB. It doesn't make much sense and if it's not safe, personally I WILL NOT fly it.

Q400 guys do ferry - Heavy maintenance is in ALB, which they are shutting down as an outstation (which I like), so I think that we will have even more ferry flights there.

 

[Hernandezcfi]

So, when you guys call in fatigued, is that it or is there more involved? When we call in fatigued on this side of the house we get the immediate "I can't believe you're doing this! Do you know how short we are?" from scheduling, followed by filling out a flight safety report and a "fact finding" meeting with the base manager. Now, we've got a couple of base managers (at most) where it's pretty much a no big deal type thing. Then we've got other base managers that you're looking for a union rep if you just see them walking down the hallway looking at you.

We make the call and get released. I'm sure some might hear some wining in some cases but I havent heard of anyone hearing it. Within 24 hours we fax in the Fatigue Report. The last box in the report is the reason for calling Fatigued. Filling that last box out is optional. The report is forwarded to our Safety Department where someone will take a look and probably call at a later date to ask questions for their "Fatigue Study"

 

[zmiller4]

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.

Does any other airline do this? It's absolutely unbelievable.

 

[kellwolf]

We make the call and get released. I'm sure some might hear some wining in some cases but I havent heard of anyone hearing it. Within 24 hours we fax in the Fatigue Report. The last box in the report is the reason for calling Fatigued. Filling that last box out is optional. The report is forwarded to our Safety Department where someone will take a look and probably call at a later date to ask questions for their "Fatigue Study"

I know what I want in our new contract now.....That's way better than the carpet dance we're forced to do when we call in fatigued. "Don't fly fatigued.....but if you call in fatigued you have to talk to your base manager."

 

[USMCmech]

Part 91 flying is not subject to 121 Duty Time Rules. Part 91 is not subject to 8 hrs or 16 hour duty day.

Any "end of the day" pt 91 flights are suposed to be at your discretion, are they not?

If you don't want to fly it, tell dispatch you're too tired.



I've taken a few of these ferry flight, but only in situations where I was reasonably well rested, and it was to my advantage.

 

[BobDDuck]

Also, remember, a part 91 ferry (which, in my mind, per my FOM can't exists) may not count towards flight time THAT day but it counts in 30/7 100/30 and 1000/365 going forward.

 

[OldTownPilot]

That one thing for the contract.

All part 91 flying will be subject to any and all duty, rest and flight time regulations that apply to a flight operated under part 121.

I remember seeing that in the CAL contract that is kicking around the house somewhere.

 

[ctab5060X]

. "Don't fly fatigued.....but if you call in fatigued you have to talk to your base manager."

And get told by the base manager that "you had legal rest". :banghead:

Sure... whatever... 3 12 hour duty days separated by one reduced rest, one comp rest and just about 11 hours in base before a 9 hour ready reserve period where you give me an out and back that will have me right at (if not over) 15 hours of duty that day... No thanks!

 

[kellwolf]

No kidding. One guy had the BM say "But...but...you HAD enough rest. You were legal for the flight!" Riiiiight. 'Cause "legal" always means "safe."

 

[wheelsup]

It's funny the difference in corporate culture. AWAC voluntarily made all ferry flights to be operated under part 121 rules. Course, in our 45 year history we've only killed 26 people and we haven't killed anyone in almost 30 years.

 

[ctab5060X]

No kidding. One guy had the BM say "But...but...you HAD enough rest. You were legal for the flight!" Riiiiight. 'Cause "legal" always means "safe."

And that is when you pull out the cell phone, get to the record feature and say... "Could you please repeat that?"

 

[v1valarob]

It's funny the difference in corporate culture. AWAC voluntarily made all ferry flights to be operated under part 121 rules. Course, in our 45 year history we've only killed 26 people and we haven't killed anyone in almost 30 years.

That was a big discussion in my recurrent. Our safety/corporate culture is horrible. We are taking a new CRM class and in the end it just pissed most of us off.

 

[TUCKnTRUCK]

It's funny the difference in corporate culture. AWAC voluntarily made all ferry flights to be operated under part 121 rules. Course, in our 45 year history we've only killed 26 people and we haven't killed anyone in almost 30 years.

You know it is really kinda ironic, but, right before US air in the hudson, 3407, Air france, Yemen started... there was a Times article talking about how there had not been a single US air carrier fatality in 2 years... since Lex.

I think that happened 2 days before a couple of geese turned an A320 into a party boat. The day you say ,"look at how safe we are", is the day something happens.

I wonder how the news media would spin the fact that the 2 deadliest commercial aviation events, Tenerife and 9/11, were all "major" airlines. Heck, the KLM captain was one of the most experienced pilots KLM had.


I am by no means saying AWAC is unsafe, or that any of you are unsafe... just seems that Hunter Fate likes to aim for those who boast of beating her.