FAA Fatigue Rules

[Number1atNumber2]

Re: New Pilot Time/Duty Limitations

Have not read any details about this yet. Is this going to be specific to just 121 ops, or does it include 135 ops as well?

 

[wheelsup]

Re: Proposed FAA Rest Regulations: Out Soon

What about now (proposed) where you can start at 0700 domicile time, and be legal to block 10 hours! If the van time needs to be 0600, that's wakeup for most people at 0500-0530 and be legal to block 10 hours and be on duty for 13. I really just don't think waking up at 5:00AM and being able to block 10 hours is a great idea, at all.

I don't think we should be on duty more than 4 hours, doesn't mean safety (fatigued) is compromised any.

(no I don't really think we should only have 4 hours of duty, hope you know where I am going)

Scenario 2:

Standup. 2155 report, the crew does not time out until the next morning at 0855. Many standup/high-speed overnight out-and-backs currently fit well within that timeframe. Even if the airline wants a buffer of 1.5-2 hours for possible MX issues or de-ice delays, the flight could still be scheduled to arrive at around 0700-0730 back at the hub, and we're back to having a crew doing a layover with five hours of sleep again. Right back to square one. Then we're also back to having van time included as rest again, too, although technically it's not even rest. WTF.[/quote

This doesn't make sense. Highspeeds aren't about rest at the "overnight". They are about rest when you get back in the morning till show the next evening. 12+ hours of rest.

Scenario 3:

A couple oceanic flights that would no longer require a third pilot:


So there's two complete trips that would go from 3 pilots, to 2, unless the pilot contract requires a third pilot due to the hours. That's going backwards in safety in my opinion.

From my understanding this study was actually based upon science and research and not opinion based. So while you might have an opinion that safety is compromised, apparently the research shows it is not.

I hope I just haven't read this thing enough yet. I think it will eliminate jobs while making some things safer, and other things not as safe as they already are. I'll be sure to comment in this 60 day window if I'm understanding this stuff correctly right now.

It'll probably be a give and take, my guess is with a net gain at least at the commuter level.

 

[Rocketman99]

Re: Proposed FAA Rest Regulations: Out Soon

Scenario 2:

Standup. 2155 report, the crew does not time out until the next morning at 0855. Many standup/high-speed overnight out-and-backs currently fit well within that timeframe. Even if the airline wants a buffer of 1.5-2 hours for possible MX issues or de-ice delays, the flight could still be scheduled to arrive at around 0700-0730 back at the hub, and we're back to having a crew doing a layover with five hours of sleep again. Right back to square one. Then we're also back to having van time included as rest again, too, although technically it's not even rest. WTF.

Perhaps you don't understand what a stand-up/highspeed/whatever name you like is? You are on duty the entire time. You should not and can not expect to actually get rest between legs on a stand up. You are supposed to get your rest before the trip started/when the trip is over. The idea is that the last flight of the night can slip as late as possible and still not worry about a crew timing out or that the first flight of the morning will be delayed.

 

[derg]

Re: New Pilot Time/Duty Limitations

It increases rest by a lot.... Stating that when you are in the hotel van to and from the hotel it is a DHD and counts towards the duty time.... Thus you no longer lose that time when going to and from a hotel.... It also says it is working to make sure you have the ability to SLEEP 8 hours. Right now on a RR overnight you are lucky to get 5-6 some nights.

Good angle. That's what a lot of folks don't understand is that an 8 hour layover is hardly more than a nap.

Especially in the winter time with delays, longer rides to the hotel and potentially delayed check-in time to the hotel.

 

[deadstick]

Re: Proposed FAA Rest Regulations: Out Soon

It said that the rest started when you arrive at the hotel.

p85
This proposal does not exactly mirror the ARC recommendation, because the FAA is proposing that transportation time to or from a duty station not be included in the minimum rest periods; nor would it be considered duty. Rather, the rest period would begin once the flightcrew members reach the hotel.

Also note there is a difference between "flight duty period" and "flight time." It looks like FDP is show to release and FT is block. So it looks like an 0430 show, you have to be released (rest not starting yet, though) NLT 1330 unless you do <=2 legs then it's 1430). Ref Table A and B Part 117.

 

[Nick]

Perhaps you don't understand what a stand-up/highspeed/whatever name you like is? You are on duty the entire time. You should not and can not expect to actually get rest between legs on a stand up. You are supposed to get your rest before the trip started/when the trip is over. The idea is that the last flight of the night can slip as late as possible and still not worry about a crew timing out or that the first flight of the morning will be delayed.

I do understand it.

Realistically though, when you call a reserve who's been sitting around for days not flying and have them leave the hub at 10PM and be able to sleep from midnight to 4:30AM, they're getting a very short night of sleep.

 

[Seggy]

Re: Proposed FAA Rest Regulations: Out Soon

That's going backwards in safety in my opinion.

Nick, there is science behind these numbers that proves it is safer than we have now.

 

[Seggy]

Re: Proposed FAA Rest Regulations: Out Soon

From my understanding this study was actually based upon science and research and not opinion based. So while you might have an opinion that safety is compromised, apparently the research shows it is not.

:yeahthat:

 

[Nick]

Nick, there is science behind these numbers that proves it is safer than we have now.

Oh believe me, I don't doubt that there are pieces of the whole thing that will much improve safety. I am happy to see that.

Waiting for the hotel van to show up no longer counting as rest = excellent.

13 hour duty period limit = excellent.


All I'm saying though, is that there appears to be some loopholes that will allow operations to occur that already happen today, and we all consider them to be not the most safe ideas out there.

The standup overnight is an example. It appears as if they will still be permitted.

Increasing legal block hour maximums for crews waking up at 5AM is another example. I'm not in favor of that; 9AM okay...not 5AM.

 

[jtrain609]

Re: Proposed FAA Rest Regulations: Out Soon

It looks like CAL can't call a row of seats a rest facility anymore.

 

[ppragman]

Re: Proposed FAA Rest Regulations: Out Soon

Oh believe me, I don't doubt that there are pieces of the whole thing that will much improve safety. I am happy to see that.

Waiting for the hotel van to show up no longer counting as rest = excellent.

13 hour duty period limit = excellent.


All I'm saying though, is that there appears to be some loopholes that will allow operations to occur that already happen today, and we all consider them to be not the most safe ideas out there.

The standup overnight is an example. It appears as if they will still be permitted.

Increasing legal block hour maximums for crews waking up at 5AM is another example. I'm not in favor of that; 9AM okay...not 5AM.

Frankly, I like it, but I find it arbitrary, start your duty period at 5:00am have one set of rules, start at 4:59 have another. Frankly, if you're going to be arbitrary, limit the duty day to 12hrs for single pilot and two pilot crews with 8hrs of flying or less, and use some other schema to work out what to do with longer legs. This proposal seems overly complicated. 12hrs off duty (half of the day for god sakes) is more than enough time to be rested, even if you're on the wrong side of the clock. Even if I have an hour van ride both ways, and it takes me an hour to undress, and an hour to dress I have 8 hrs for sleep. That seems reasonable.

 

[jtrain609]

Re: Proposed FAA Rest Regulations: Out Soon

So here are the big things that I see in this:

117.9 - Schedule reliability. If system wide flight duty periods exceed the scheduled flight duty period more than 5 percent of the time and any scheduled flight duty period that is shown to actually exceeed the schedule 20 percent of the time, the company must adjust the duty times to a realistic number.

I.E. The company can't say "Oh yeah, it's an easy 8 hour duty day with 6 legs in and out of Newark!"

117.13 - Flight hour limits. There's a table; 8, 9 or 10 hours.

117.21 - Reserves can't be on short call more than 14 hours.

117.23 - Duty time limitations.

I love this.

No more than 60 hours of duty in 7 days.

No more than 190 hours of duty in 28 days.

If you work 13 hour days all month, that means you'll assured to have 15 days off in a 31 day month.

You can stretch this out a few hours if you're on a dead head or short call. If you're on a dead head, you need to be in a seat that is lie flat.

117.25 - Rest periods now give you 30 hours off in a row every 7 days. With the way many contracts work, this will likely mean 2 calendar days off in a row each week.

Oh, and 9 HOURS AT THE HOTEL! SUCK IT REDUCED REST OVERNIGHTS!!!!

 

[Nick]

Frankly, I like it, but I find it arbitrary, start your duty period at 5:00am have one set of rules, start at 4:59 have another. Frankly, if you're going to be arbitrary, limit the duty day to 12hrs for single pilot and two pilot crews with 8hrs of flying or less, and use some other schema to work out what to do with longer legs. This proposal seems overly complicated. 12hrs off duty (half of the day for god sakes) is more than enough time to be rested, even if you're on the wrong side of the clock. Even if I have an hour van ride both ways, and it takes me an hour to undress, and an hour to dress I have 8 hrs for sleep. That seems reasonable.

I agree.

But, you have to draw the line somewhere.

The duty period times are adjusted gradually enough that I wouldn't think there's too much manipulation of schedules to be done.

It's the block hour limits where airlines will push a flight back a few minutes if it means getting another hour out of the crew and again, the line must be drawn somewhere, but 0500 start time and 9 hours block? Or 0700 start time and 10 hours block? They are a little early if you ask me. In order to get 8 hours of sleep for a 0500 report, you would need to go to bed around 2000-2030. That is very early.


Hopefully, there are lots of little details in the 145 pages that I haven't seen yet.

I did read something on another forum about if more than 4-5 time zones are crossed there is an automatic layover minimum of something like 24-30 hours. That could end up being much more restrictive than the basic flight time and duty limits, which is good.

 

[Nick]

So here are the big things that I see in this:

117.9 - Schedule reliability. If system wide flight duty periods exceed the scheduled flight duty period more than 5 percent of the time and any scheduled flight duty period that is shown to actually exceeed the schedule 20 percent of the time, the company must adjust the duty times to a realistic number.

I.E. The company can't say "Oh yeah, it's an easy 8 hour duty day with 6 legs in and out of Newark!"

117.13 - Flight hour limits. There's a table; 8, 9 or 10 hours.

117.21 - Reserves can't be on short call more than 14 hours.

117.23 - Duty time limitations.

I love this.

No more than 60 hours of duty in 7 days.

No more than 190 hours of duty in 28 days.

If you work 13 hour days all month, that means you'll assured to have 15 days off in a 31 day month.

You can stretch this out a few hours if you're on a dead head or short call. If you're on a dead head, you need to be in a seat that is lie flat.

117.25 - Rest periods now give you 30 hours off in a row every 7 days. With the way many contracts work, this will likely mean 2 calendar days off in a row each week.

Oh, and 9 HOURS AT THE HOTEL! SUCK IT REDUCED REST OVERNIGHTS!!!!

Yep, that is all very good stuff. I, too, immediately thought of those 12-13 hour scheduled workdays that would have a plane swap at EWR at 5PM before the last leg.

Hopefully that stuff will be targeted and fixed...I'm pretty sure the percentage of the time it ended up being a 14-16 hour day would clear that 20% hurdle by a wide margin!

 

[Seggy]

Re: Proposed FAA Rest Regulations: Out Soon

Scenario 3:

A couple oceanic flights that would no longer require a third pilot:

DL249
1440 AMS
1720 DTW
Block 8:40

~0700 report eastern time means the crew is legal for 13 hours of duty and 10 hours of block.

AA121
1750 CDG
2030 JFK
Block 8:40

~1030 report eastern time means the crew is legal for 13 hours of duty and 10 hours of block.

A friend of mine does Europe at lot with AA out of JFK. Like all the other airlines, they stay downtown in all cities there. The van ride for CDG and many others is 1 hour+. So this is an 8AM wakeup after flying all night the night before (so ZERO rest unless a relief pilot is in the contract), going into an airport that could easily turn 8:40 block into 9-10 if it's having a bad day. No breaks other than a few minutes at a time to use the lav. Again, I just think this is a very long workday with no sleep the night before do be doing with two pilots.


AA005
1335 DFW
1645 HNL
Block 8:10

~ Noon report central time means the crew is legal for 13 hours of duty and 10 hours of block.

Now, here's the return for those:

AA008
1650 HNL
0510 DFW
Block 7:20

~2030 report central time means the crew is legal for 11 hours of duty and 8 hours of block.


AA102
1930 HNL
0800 DFW
Block 7:30

~Same with this one.

So there's two complete trips that would go from 3 pilots, to 2, unless the pilot contract requires a third pilot due to the hours. That's going backwards in safety in my opinion.

I hope I just haven't read this thing enough yet. I think it will eliminate jobs while making some things safer, and other things not as safe as they already are. I'll be sure to comment in this 60 day window if I'm understanding this stuff correctly right now.

Nick, go back and look at the footnotes on page 43 and look at the chart of 44. There are two charts, one from industry, one from labor.

If you take a look at the footnotes on page 43 it explains why there are two charts there. Take a look at page 44, ALPA is proposing a maximum of 8 in some of the situations you described.

 

[ppragman]

Re: Proposed FAA Rest Regulations: Out Soon

So here are the big things that I see in this:

117.9 - Schedule reliability. If system wide flight duty periods exceed the scheduled flight duty period more than 5 percent of the time and any scheduled flight duty period that is shown to actually exceeed the schedule 20 percent of the time, the company must adjust the duty times to a realistic number.

I.E. The company can't say "Oh yeah, it's an easy 8 hour duty day with 6 legs in and out of Newark!"

117.13 - Flight hour limits. There's a table; 8, 9 or 10 hours.

117.21 - Reserves can't be on short call more than 14 hours.

117.23 - Duty time limitations.

I love this.

No more than 60 hours of duty in 7 days.

No more than 190 hours of duty in 28 days.
If you work 13 hour days all month, that means you'll assured to have 15 days off in a 31 day month.

You can stretch this out a few hours if you're on a dead head or short call. If you're on a dead head, you need to be in a seat that is lie flat.

117.25 - Rest periods now give you 30 hours off in a row every 7 days. With the way many contracts work, this will likely mean 2 calendar days off in a row each week.

Oh, and 9 HOURS AT THE HOTEL! SUCK IT REDUCED REST OVERNIGHTS!!!!

Me too, that's the best part of this whole thing. Fatigue is cumulative. Big time, and limiting the amount of duty hours in the week was smart.

I did 322hrs of duty in June, with 260legs, and 124.8hrs. I broke the 60hrs in 7 days every week that month and I was exhausted. That is the primary reason why I left the gig. There are guys there that are doing more after I left. It is and was ridiculous.

 

[jtrain609]

Re: Proposed FAA Rest Regulations: Out Soon

I agree.

But, you have to draw the line somewhere.

The duty period times are adjusted gradually enough that I wouldn't think there's too much manipulation of schedules to be done.

It's the block hour limits where airlines will push a flight back a few minutes if it means getting another hour out of the crew and again, the line must be drawn somewhere, but 0500 start time and 9 hours block? Or 0700 start time and 10 hours block? They are a little early if you ask me. In order to get 8 hours of sleep for a 0500 report, you would need to go to bed around 2000-2030. That is very early.


Hopefully, there are lots of little details in the 145 pages that I haven't seen yet.

I did read something on another forum about if more than 4-5 time zones are crossed there is an automatic layover minimum of something like 24-30 hours. That could end up being much more restrictive than the basic flight time and duty limits, which is good.

I'm not positive about that. This says that if you work more than 7 days in a row, which you can't do, then you need 3 days off.

§117.25 (b) (1)

(b) Before beginning any reserve or flight duty period, a flightcrew member must be given at least 30 consecutive hours free from duty in any 168 hour period, except that:

(1) If a flightcrew member crosses more than four time zones during a series of flight duty period that exceed 168 consecutive hours, the flightcrew member must be given a minimum of three physiological nights rest upon return to home base.
(2) A flightcrew member operating in a new theater must receive 36 hours of consecutive rest in any 168 consecutive hour period.

 

[Matt13C]

Re: Proposed FAA Rest Regulations: Out Soon

Whats the other side of this? Less duty time = less pay? So a 1st year FO on reserve is likely to see how much of a wage reduction?

Will this cause regionals to hire/bring back furloughs to account for the reduction in total flight time for each pilot? Could this destroy their slim profit margin and make it beneficial for mainline to bring flying back in house?

How long until this actually becomes law?

 

[RPM]

Re: Proposed FAA Rest Regulations: Out Soon

Pilots will also be given the right to decline any assignment if they feel fatigued without penalty.

... umm so now is the government going to cut me a check when I fatigue so I can still pay my mortgage or what.. because no pay is a HUGE FREAKIN PENALTY in my book..

 

[Nick]

Nick, go back and look at the footnotes on page 43 and look at the chart of 44. There are two charts, one from industry, one from labor.

If you take a look at the footnotes on page 43 it explains why there are two charts there. Take a look at page 44, ALPA is proposing a maximum of 8 in some of the situations you described.

Noted.

However, the final proposal looks like it starts on page 124 and is labeled section 117.

The Proposed Amendment
In consideration of the foregoing, the Federal Aviation Administration proposes
to amend Chapter I of Title 14, Code of Federal Regulations, as follows:
1. Part 117 is added to read as follows:
PART 117—FLIGHT AND DUTY LIMITATIONS AND REST

It is the three tables near the end of section 117 that I understand to be what the final FAA proposal is. Everything leading up to this section looks like a [good] summary of the discussion between the airlines and crewmember reps.