Duty Time 135

I have been at several 135 outfits. All have had the same interpretation (different FSDO's): flight time limit has the wiggle room that triggers extended rest; 14 hrs is a hard limit and I could not take off if my ETA IN THE BLOCKS was > 14.00 hrs of duty. You can't plan for a 100 kt tail wind either. ;)

I had it happen one time. I've tweaked the profile on Fltplan.com fairly well, and it's pretty good. I was waiting and waiting and waiting....I knew my flight time was :45. When the GPS clock hit :47 'til pumpkin time, I had to taxi back to the FBO and get a hotel. Boss had zero issues. It is what it is.
 
Dugie8 said:
I couldn't find any interps that were on point, the reason I took that little snippet out of the one I did find was how the wording was done about being able to look back and not see that 10 hours of rest in 24 hours. Couple that with the Regs having no mention of duty periods, just flight times, I am of the opinino that the 14 hour duty day is unbreakable if you reasobably know that before departure.


I'd be throwing the fatigue flag long before that ever became issue though, I'm getting old.
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Lacking any other guidance, I will still say, and FLX and apparently FLX's POI, that if the FAA wanted 135 to be leg by leg, like the 121 world is, they would have used the same wording in the regulations.

As it is, we have no guidance other than our own interpretations, so we'll have to agree to disagree.
 
I'm working EMS now and both our POI and DO seem to think going over duty is no big issue at all.
 
Ok i am new to this world now that I am at a 135 operator!!! I am having a hard time grasping this duty day stuff!!! Please help!!

Okay say I duty off at 10pm and then duty on a 8am , at what time must my duty day end?
 
Nick2024 said:
Ok i am new to this world now that I am at a 135 operator!!! I am having a hard time grasping this duty day stuff!!! Please help!!

Okay say I duty off at 10pm and then duty on a 8am , at what time must my duty day end?
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A duty day is 14hrs. So, if you duty on at 08 then you would need to duty off at 2200.
 
Erik10 said:
A duty day is 14hrs. So, if you duty on at 08 then you would need to duty off at 2200.
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Well, to be entirely clear, you can't fly after 2200 and from whenever you duty off, you need 10 hours rest before you can be on duty and fly.
 
Functionally, it's what msms said. The verbiage all gets a bit tricky. There are some circumstances in which the difference matters, though. For example, if you "91 home" (which seems to be out of favor almost everywhere these days), or the company has you do some non-flying task at the end of your shift, you still need 10 hours before you can duty back on.
 
Boris Badenov said:
Functionally, it's what msms said. The verbiage all gets a bit tricky. There are some circumstances in which the difference matters, though. For example, if you "91 home" (which seems to be out of favor almost everywhere these days), or the company has you do some non-flying task at the end of your shift, you still need 10 hours before you can duty back on.
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I guess I should have said, "you can't fly a part 135 leg after 2200..." But yeah, the 91 home thing seems to be falling out of favor. Which I hate because I would always volunteer to be in my own bed.

Funny thing, I was offered that the company would rent a car for me to drive 45 minutes home, and that was off duty. They wouldn't have let me fly. As it was, the weather was the issue, but...
 
Just remember there will be days that after 8 hours you will be unsafe for flight. There are a few 135 operators that really push things. There are also a few that I would consider doing some magic math for to keep them and their customers happy. I'm at a small 135 outfit that goes way out of their way to take care of the pilots. In return I go way out of my way to provide excellent customer service.

Just wish more would figure out how that works.
 
Anyone have that letter from the Administrator regarding EMS flights that are delayed and what duty time rules apply?
 
I would say it's the same, but I imagine most companies err on the extreme conservative side with this. FLX is the only company I'm aware of at the moment that uses the same interpretation as that letter
 
The company I work for only operates one crew per plane at our current base, as each plane under our 135 certificate is of a different type here. The guy I fly with used to be Cheif/DO at his old company for years. According to him, his old POI specifically said under NO circumstances could they go over the 14 hour duty limit. It was even a question on his qualification test. Further, with current technologies, he argues that under the "circumstances beyond your control" clause, weather generally can be a grey area and you could get dinged for going over duty due to weather, being that we have so many different means of knowing a head of time of potential weather threats / issues during the scheduling process. Being that our current POI generally agrees with the above, we absolutely do not go over, and plan the required hour (minimum show up time) before departure, and a final 30 minutes after our last leg, into our duty schedule.
 
UAL747400 said:
I would say it's the same, but I imagine most companies err on the extreme conservative side with this. FLX is the only company I'm aware of at the moment that uses the same interpretation as that letter
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Well, that would mean there are no companies that you're aware of that use that interpretation. :)
 
Also, that NATA link I posted isn't found on the FAA's interpretation database anymore. One reason may be that the reg has obviously been re-written since the release of that 1992 interpretation. 135.267c states "no more than 14 hours." undefined
 
UAL747400 said:
I would say it's the same, but I imagine most companies err on the extreme conservative side with this. FLX is the only company I'm aware of at the moment that uses the same interpretation as that letter
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We use the interpretation that Calvin posted.

brian434 said:
Anyone have that letter from the Administrator regarding EMS flights that are delayed and what duty time rules apply?
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There is none that I am aware of. You cannot treat EMS flights as special. You follow ALL of the 135 rules and opspecs like anyone else. Just think of yourself as stupidly expensive charter, nothing more. Pushing beyond that is in no one's best interest.
 
z987k said:
We use the interpretation that Calvin posted.


There is none that I am aware of. You cannot treat EMS flights as special. You follow ALL of the 135 rules and opspecs like anyone else. Just think of yourself as stupidly expensive charter, nothing more. Pushing beyond that is in no one's best interest.
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Ah yes, I remember you asking me if I could find the letter that FLX handed out on this.
 
(Part 135 unscheduled) You have to plan each mission to finish by 14 hours of total duty time. However, if something truly unforseen occurs you can exceed 14 hours up to 16 hours according to the FARs so long as you get those hours back before you go back on duty the next day.

The book Everything Explained for the Professional Pilot has a pretty good section on duty times for 135 scheduled, nonscheduled, 1 or 2 pilots and 121.
 
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