FAR 117 being re-worked?

SteveC said:
You guys really don't understand the difference between science and policy based on science???
Here's what I understand: some corporate pilot on the internet doesn't know jack compared to a panel of the foremost experts on fatigue in aviation and sleep science who put together these rules based entirely on the science.
 
As for the cargo cut-out, no offense, but you did know it was an all-nighter job when you signed up? It's like that NTSB grilling one of the UPS head honchos. Something along the lines of "Can you explain why your flight schedule seems to be majority at night back of the clock?" Answer was along the line of "Well, as you see our business model, we do a lot of next day delivery guarantees. That requires packages be collected at night and brought to a sorting hub, after the sort they are then flown to their final destination in the early morning hours so the package can be delivered that day."

What can you possibly hope for all night flying? There is no physical way to fix back-side of the clock flying. Humans were designed to work at day time and sleep at night. We evolved with better vision at day versus night (rod/cones balance). We are "meant" to sleep at night. To those fatigued pilots at UPS, I'm sorry you fly the backside of the cock. But at least your pay is high enough to offset that inconvenience. As for the BHM crash, lets not blame the lack of FAR 117 as if FAR 117 would have stopped that crash? My advice to any pilot approaching 60 who is complaining about constantly being fatigued is to just pull the trigger and retire. Nothing is stopping you and you'll actually extend your lifespan by getting proper rest and not working anymore at that phase in life.
 
I believe in the science for both climate change and the basis for the current rest rules.

I respectfully disagree that simply basing rules on science, even to the best of a committee's abilities, means that they are automatically the best possible rules and should not be questioned (i.e. other's opinions don't matter).

Implementation of guidelines based on proven science does not guarantee that the method of implementation is the best possible solution.
Can we agree that the 117 rest rules are not an aiming point but rather a floor?

I ask because I think I know where you are going with this but I want to make sure.
 
Look at the European rules (and how long they have been doing those rules) and then look at FAR 117.

Pretty damn similar.
I'm sure there are never fatigued European crews either. I mean, if it's based on science, it must be perfect. How about you Union guys actually listen to your constituents instead of mocking and ignoring them, us lowly corporate guys excluded. I mean, what would we know about them? I've only been flying under the European rules for 6 years...
 
What can you possibly hope for all night flying? There is no physical way to fix back-side of the clock flying. Humans were designed to work at day time and sleep at night. We evolved with better vision at day versus night (rod/cones balance). We are "meant" to sleep at night. To those fatigued pilots at UPS, I'm sorry you fly the backside of the cock. But at least your pay is high enough to offset that inconvenience. As for the BHM crash, lets not blame the lack of FAR 117 as if FAR 117 would have stopped that crash? My advice to any pilot approaching 60 who is complaining about constantly being fatigued is to just pull the trigger and retire. Nothing is stopping you and you'll actually extend your lifespan by getting proper rest and not working anymore at that phase in life.

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Because shutting up and just doing things the way they've always been done is a good solution?
 
Has anyone here exceeded the science-based table B limits? By 1 min? 30? 2 hours?

Those are just scheduling tools. No where does the science say that ever exceeding them is okay. The table is pretty clear. It's not fatigue past it, it's just not safe. Who wants to be the 91.13 guinea pig of the rule?
 
I believe in the science for both climate change and the basis for the current rest rules.

I respectfully disagree that simply basing rules on science, even to the best of a committee's abilities, means that they are automatically the best possible rules and should not be questioned (i.e. other's opinions don't matter).

Implementation of guidelines based on proven science does not guarantee that the method of implementation is the best possible solution.

I think in this case, Steve, you don't know what you speak of. As Andrew said, these rules are a floor, and whether the membership wants that floor lowered or not doesn't matter. It's a regulatory scheme designed to keep people safe, not an efficiency tool designed to make companies money by utilizing pilots to the maximum extent possible at any cost.

There are ALPA members who would happily fly trips with 5 hours of rest every night if it meant an extra half hour of productivity. These people are fools.
 
As for the cargo cut-out, no offense, but you did know it was an all-nighter job when you signed up? It's like that NTSB grilling one of the UPS head honchos. Something along the lines of "Can you explain why your flight schedule seems to be majority at night back of the clock?" Answer was along the line of "Well, as you see our business model, we do a lot of next day delivery guarantees. That requires packages be collected at night and brought to a sorting hub, after the sort they are then flown to their final destination in the early morning hours so the package can be delivered that day."

What can you possibly hope for all night flying? There is no physical way to fix back-side of the clock flying. Humans were designed to work at day time and sleep at night. We evolved with better vision at day versus night (rod/cones balance). We are "meant" to sleep at night. To those fatigued pilots at UPS, I'm sorry you fly the backside of the cock. But at least your pay is high enough to offset that inconvenience. As for the BHM crash, lets not blame the lack of FAR 117 as if FAR 117 would have stopped that crash? My advice to any pilot approaching 60 who is complaining about constantly being fatigued is to just pull the trigger and retire. Nothing is stopping you and you'll actually extend your lifespan by getting proper rest and not working anymore at that phase in life.

Didn't you sign up to fly under the old rules, too? What makes you get the rule changes, and not us? Also, you're aware that many passenger flights are flown on the backside of the clock each night too, right?

But I get it... Since I have freight in the back vs. people, I can fly this leg without a rest facility, and it's okay? 11.5 hours, and much of it done in the daytime (leading up to a fun 0200L landing). By the way, you're only looking at domestic freight schedules, which is only the tip of the iceberg of the freight that's actually flown around the world. What you see, and what you're referring to in your post, is merely the end of the assembly line.

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@amorris311 and @jtrain609, I don't think that you are addressing the point of my discussion. I am not opining on whether or not the rules are good, bad, indifferent, nor whether or not they should be changed. All of my posts have been responding to one point only. That point is
The new rules are science based so everyone's opinion really doesn't matter.

My contention was, and continues to be, that just because rules are based on science does not mean that they should not/cannot be questioned.

I have never stated an opinion on the 117 rules themselves.
 
The new rules are science based so everyone's opinion really doesn't matter.

I think in this case you and SteveC are talking past each other. All he is saying is that there may be room for improvement, even for a policy based on science.


A policy based on science is still a policy, and policies are rarely (if ever) perfect. There was probably some horse trading that went on during the writing of that policy, and I highly doubt it purely sticks to the science. I'd love to hear Dr. Steve Hursh's, gasp..."opinion"...on the perfection of FAR 117.

Are you seriously saying that FAR 117 is perfect? Beyond reproach? Hold it folks! FAR 117 has reached the pinnacle of policy making and is perfect!


SteveC, having a conceptual argument with Seggy and ATN is not fun.
 
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@amorris311 and @jtrain609, I don't think that you are addressing the point of my discussion. I am not opining on whether or not the rules are good, bad, indifferent, nor whether or not they should be changed. All of my posts have been responding to one point only. That point is


My contention was, and continues to be, that just because rules are based on science does not mean that they should not/cannot be questioned.

I have never stated an opinion on the 117 rules themselves.

I'm with ya. He won't be able to see your point.
 
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The policy isn't the science. The science is: People need sleep and rest between work schedules (gasp, the concept!!!!). The policy is, since you greedy pilots need sleep and rest we are only going to work you to the science based maximum and then with your coerced concurence we will extend you beyond that science based maximum in the name of productivity (see 4+ hour airport appreciation sits).
 
The policy isn't the science. The science is: People need sleep and rest between work schedules (gasp, the concept!!!!). The policy is, since you greedy pilots need sleep and rest we are only going to work you to the science based maximum and then with your coerced concurence we will extend you beyond that science based maximum in the name of productivity (see 4+ hour airport appreciation sits).

Our mgmt sure doesn't grasp the concept of "concurrence." They see a FDP extension as automatic, and if you refuse, you're one of "those guys."
 
I think in this case you and SteveC are talking past each other. All he is saying is that there may be room for improvement, even for a policy based on science.


A policy based on science is still a policy, and policies are rarely (if ever) perfect. There was probably some horse trading that went on during the writing of that policy, and I highly doubt it purely sticks to the science. I'd love to hear Dr. Steve Hursh's, gasp..."opinion"...on the perfection of FAR 117.

Are you seriously saying that FAR 117 is perfect? Beyond reproach? Hold it folks! FAR 117 has reached the pinnacle of policy making and is perfect!


SteveC, having a conceptual argument with Seggy and ATN is not fun.

Your reading comprehension is horrific.
 
The new rules are science based so everyone's opinion really doesn't matter.

Haven't you been watching the news lately? Science is up for debate. I prefer our previous faith based rest rules...as in "I'm so tired I need someone to watch over me so I don't screw up."
 
My contention was, and continues to be, that just because rules are based on science does not mean that they should not/cannot be questioned.

Of course they can be questioned....by people who are qualified to do so. That ain't you. Opinions of laymen are irrelevant in a system based on science. And if we look in this thread, we can see what most of the "opinions" revolve around: "efficiency" and how people like their schedules for pay and day off purposes; not safety.
 
I believe in the science for both climate change and the basis for the current rest rules.

I respectfully disagree that simply basing rules on science, even to the best of a committee's abilities, means that they are automatically the best possible rules and should not be questioned (i.e. other's opinions don't matter).

Implementation of guidelines based on proven science does not guarantee that the method of implementation is the best possible solution.

I get what you're saying. Extreme example would be 48 hour minimum overnights and 3 hour duty days. We would be well rested, even the science would agree on that. However that doesn't mean it's the most practical solution.

That being said, I think 117 IS a pretty good solution. At least as a regional pilot it is the answer to a lot of problems. I feel a lot more alert for the entire trip. Under the previous rules I would have to take my first day off from a trip to just catch up on sleep, now I don't need to do that because I'm not working 16 hour days with 6 hours of sleep in between.

I'm going to go out on a limb too and say that my sick calls have gone down because I'm much better rested. Yesterday was the first time I've called in sick since January. (Protip: when you are drinking from a water bottle in the crew lounge, make sure it's yours)
 
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