Duty/rest and EMS

[deadstick]

Looks like 7Bar asked some questions nobody really wanted answered. Took them 2 years, but an LOI is out on 135.267(c).

https://www.faa.gov/about/office_or...ar Aviation - (2017) Legal Interpretation.pdf


I've heard some crazy points of view over the years, but I've always said that we're still on-demand pax 135. There's no "*" or footnote that exempts EMS operations.

 

[gotWXdagain]

Somehow the only thing I'm getting out of that letter is that 24 hour on-calls are legal again?

Well, part (d) does address that, the only way to practically operate under part (b) is "Long Call" I guess.

Although this does seem pretty odd that unscheduled duty periods (and there probably more fatigue-vulnerable) are granted more leeway than people who operate on a regular duty period.


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[z987k]

Somehow the only thing I'm getting out of that letter is that 24 hour on-calls are legal again?

I can't figure out where you picked that up from the letter.

 

[gotWXdagain]

I can't figure out where you picked that up from the letter.

I brain farted, when the letter referenced part (b) of the reg as a "rolling 24 hour duty period" I forgot about part (d).


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[Inverted25]

Link not working

 

[Roger Roger]

So wait...if you go home after 8 hours of your 14 hour assigned duty period that's not ok? That's one of the side effects I gathered from reading this.

 

[gotWXdagain]

So wait...if you go home after 8 hours of your 14 hour assigned duty period that's not ok? That's one of the side effects I gathered from reading this.

Right? Or if your duty period is assigned as 12 hours but you don't get back until hour 13.


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[deadstick]

So wait...if you go home after 8 hours of your 14 hour assigned duty period that's not ok? That's one of the side effects I gathered from reading this.

I agree. I'd think that it starting at the same time is more important because you're done no more than 14 hrs later. BUT, that's not what the FAA wrote.

Also, the way this DO wrote it, their pilots only work a day shift or a night shift. There are other letters which specify that a schedule isn't a "schedule" IAW 267(c) until it's been in place for 4 weeks. Swapping days/nights every other weeks defeats that.

 

[Roger Roger]

I agree. I'd think that it starting at the same time is more important because you're done no more than 14 hrs later. BUT, that's not what the FAA wrote.

Also, the way this DO wrote it, their pilots only work a day shift or a night shift. There are other letters which specify that a schedule isn't a "schedule" IAW 267(c) until it's been in place for 4 weeks. Swapping days/nights every other weeks defeats that.

At this point, that's the point in an operator like that using a scheduled duty day? Just go unassigned.

 

[deadstick]

At this point, that's the point in an operator like that using a scheduled duty day? Just go unassigned.

For bases that fly a ton, the daily 8 hr flight time reset is good, but that the only thing I can see.

 

[Roger Roger]

For bases that fly a ton, the daily 8 hr flight time reset is good, but that the only thing I can see.

Do those exist in EMS? Most of the EMS guys I know would average that in a week not a shift.

 

[deadstick]

Do those exist in EMS? Most of the EMS guys I know would average that in a week not a shift.

We have some bases that average over 90 flights per month. So they are out there.

It's the problem with walking into a flight at the beginning of a shift after flying a lot at the end of the day before.

 

[Roger Roger]

We have some that average over 90 flights per month. So they are out there.

It's the problem with walking into a flight at the beginning of a shift after flying a lot at the end of the day before.

Yeah, we deal with the same thing doing 135 commuter ops. We do assigned duty periods for most of our folks for that reason.