On-call and Rest for Part 135

It won't change until somebody dies as a result. Pilots don't have the spines to stand up to it unfortunately.
 
They did say there will be no repercussions if you say no to a trip due to fatigue, which is a pleasant change.

This is such a weird thing. It really upsets me that companies do that. Don't put the responsibility on the pilot, just do the right thing...
 
This is such a weird thing. It really upsets me that companies do that. Don't put the responsibility on the pilot, just do the right thing...

I don't disagree with that, but the flip side is that if there truly are no repercussions to saying no to 14 hours of duty starting at 10pm when you've been up since 7am, that shows that they trust their pilots to make such decisions.
 
I don't disagree with that, but the flip side is that if there truly are no repercussions to saying no to 14 hours of duty starting at 10pm when you've been up since 7am, that shows that they trust their pilots to make such decisions.

But it is still indisputably 100% illegal. I love it if they truly mean that there are no repercussions for refusing a trip, but they will just keep making calls until somebody accepts. By virtue of having that policy, they are refusing to play by the rules, and are choosing to operate 24/7. The charter world and "unwritten rules" is just as bad as 24/7 on call. I am not picking on your company, more just venting because it really bugs me. I worked for a company that operated like this, and pilots were chastised for refusing trips.
 
But it is still indisputably 100% illegal. I love it if they truly mean that there are no repercussions for refusing a trip, but they will just keep making calls until somebody accepts. By virtue of having that policy, they are refusing to play by the rules, and are choosing to operate 24/7. The charter world and "unwritten rules" is just as bad as 24/7 on call. I am not picking on your company, more just venting because it really bugs me. I worked for a company that operated like this, and pilots were chastised for refusing trips.

I also worked for a company that gave us our rest in advance, and because of that I would spend 8 hours sitting in an FBO (many times starting at 0400) before having to fly. I flew fatigued far more times under the "rest first" system than I ever did previously.
 
Well rest in advance is the legal requirement, but there should also be a fatigue policy put in place, and consideration for off hour flying. Even the last charter company I worked for wouldn't schedule during circadian low, even if they could in advance. Certainly if you know your 10 hours in advance, and it is 230pm to 1230am, you can't sleep during that time frame well to be rested to fly 14 hours afterwards.
 
This is a good one, the author asks about enforcement and the blind eyes from many POIs, they don't offer a solution to that but it is nice that someone actually brought it up.

Saved this in the letters of investigations folder in DropBox.
 
I've quit jobs over this before, it's not legal, and remember, the impetus is on you the PIC to not accept trips that do not comply with rest rules.
No certificate holder may assign any flight crewmember, and no flight crewmember may accept an assignment

YOU cannot accept those flights either.
 
T
I've quit jobs over this before, it's not legal, and remember, the impetus is on you the PIC to not accept trips that do not comply with rest rules.

YOU cannot accept those flights either.

Correct. The problem is a lot of first time 135ers don't know about these interpretations. They go through indoc, read the regs and have the company explain it. The shady ones inevitably talk about a grey area and the newbie is none the wiser.

The Feds could solve this by putting the actual definition of rest in the front with all the other definitions. Or, you know, they could keep responding to letters asking for interpretation...
 
T


Correct. The problem is a lot of first time 135ers don't know about these interpretations. They go through indoc, read the regs and have the company explain it. The shady ones inevitably talk about a grey area and the newbie is none the wiser.

The Feds could solve this by putting the actual definition of rest in the front with all the other definitions. Or, you know, they could keep responding to letters asking for interpretation...
Those letters don't mean anything if they're not enforced.
 
It won't change until somebody dies as a result. Pilots don't have the spines to stand up to it unfortunately.

I'm sure people have already. It's not hard to read through some of the NTSB and read between the lines on some of the accidents - strangely, fatigue is rarely mentioned in . The truth is, the FAA and the general public don't give a damn about the occasional cargo plane crashing. In the eyes of the law, and the eyes of the feds, you are expendable. Cargo carve out proves it for 121 guys too. It's about making sure the amazon boxes get where they need to get on time.

I searched fatal accidents in 135 airplanes only with the key word "cargo." The results are tragic. Nearly every accident is the result of something preventable. Read through, it's pretty obvious that many could be related to fatigue.
 
I would love to see duty redefined to include "any time which a required crew member is required to answer flight requests" or something like that. That would nip this in the bud.

I like the "required to answer" bit you did there. My old shop got around the MSP FSDO by saying that we didn't have to accept flights if we didn't feel that we got 10 hours. Well, if you want me to answer my phone I'm obviously not on rest. I didn't realize how stressed I was on that schedule until I left that job.
 
I would love to see duty redefined to include "any time which a required crew member is required to answer flight requests" or something like that. That would nip this in the bud.

You mean like they do in 135.273? Strangely enough, they define it for flight attendants.

"§135.273 Duty period limitations and rest time requirements.
(a) For purposes of this section—

Calendar day means the period of elapsed time, using Coordinated Universal Time or local time, that begins at midnight and ends 24 hours later at the next midnight.

Duty period means the period of elapsed time between reporting for an assignment involving flight time and release from that assignment by the certificate holder. The time is calculated using either Coordinated Universal Time or local time to reflect the total elapsed time.

Flight attendant means an individual, other than a flight crewmember, who is assigned by the certificate holder, in accordance with the required minimum crew complement under the certificate holder's operations specifications or in addition to that minimum complement, to duty in an aircraft during flight time and whose duties include but are not necessarily limited to cabin-safety-related responsibilities.

Rest period means the period free of all responsibility for work or duty should the occasion arise."
 
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