Time off and being on call

I think you two are on the same page, and, fwiw I agree.

What baffles me (imagine that -- we're talking about the FARs after all) is that there is no compensatory rest requirement for exceeding a 14 hr duty day. That only kicks in after exceeding the flight time limit.

Oops you are correct on that one.
 
To heck with reduced rest. CAMTS wouldn't hear of it. ;) After doing 3 trips in 15 hrs of duty (finally leaving after all the i's are dotted etc), I'd sure like an extra hour or so before dragging my butt back into the hangar. Problem is that the base is out of service until we come back. Soooo 10 hrs it is.
There is no reduced rest in unscheduled, and all EMS is unscheduled, so yes CAMTS shouldn't be hearing any of it.
 
Well. The regs cover going over a normal duty day, if the flight was planned to be completed within a 14 hour duty day. So if it goes 15, you get extra required rest. It is not in place so you can land at 14 hours, and spend another 3 hours on paperwork.
I believe that is under scheduled ops?
 
I feel like there needs to be some regulatory recognition that "on call" is neither on duty nor on rest, especially for EMS. When I'm on call, I'm generally sitting around doing jack, but I can't really get too far into doing anything that's going to take along time to clean up and be flight ready for (sleep included) lest a call come in. What would really be nice is a reg that would say somthing to the effect of:

You can only be on call up to 12 hours in any 24 hour period, and those 12 hours must be contiguous (i.e. no "off call for the hour after you've landed so you can postflight" BS) and preceeded by at least a 10 hour rest period free from duty assignments or any obligation to accept a duty assignment,
You are eligible to accept any duty assigned within that 12 hour period provided you complete an operation covered by part 135 no later than 14 hours after the beginning of your assigned on call period, and
Your rest period does not begin until the aircraft has either returned to base and all flight-related duty is completed, or the flight crew determines that due to fatigue the airplane cannot safely be returned to base at which point no duty may be assigned or accepted until the completion of a 10 hour rest period. <-- This one would be hard, because I could see some of the more shady employers applying fatigue as a punitive circumstance.
If a rest away from base is required, the pilot may be considered "on call" upon returning to base until no later than twelve hours after the beginning of that flight duty period, and eligible to accept assignments provided the on-demand portion of the flight is completed no later than 14 hours after the beginning of the duty period
8 hour flight time rule would still be applicable.

I feel like you could still run a two pilot operation smoothly using these criteria because the 2nd pilot's on call would not begin until the flight returns to base, at which point they would be on call up to twelve hours but the other pilot would only need 10 hours rest. I can't imagine a scenario under normal EMS operations where neither pilots could accept the duty assignment, unless at like 9.5 hours into the first pilot's rest (and therefore 9.5 hours into the second pilot's on call) a stupid looooong call comes in, and even then in that scenario a delay of 0.5 would typically be tolerable.
 
F/W EMS is 135. Period. Can you safely and legally complete a flight from A to B with a given load? Start making it more than that and you run the risk of ending a day with more patients than with which you began.
 
I feel like there needs to be some regulatory recognition that "on call" is neither on duty nor on rest, especially for EMS. When I'm on call, I'm generally sitting around doing jack, but I can't really get too far into doing anything that's going to take along time to clean up and be flight ready for (sleep included) lest a call come in. What would really be nice is a reg that would say somthing to the effect of:

You can only be on call up to 12 hours in any 24 hour period, and those 12 hours must be contiguous (i.e. no "off call for the hour after you've landed so you can postflight" BS) and preceeded by at least a 10 hour rest period free from duty assignments or any obligation to accept a duty assignment,
You are eligible to accept any duty assigned within that 12 hour period provided you complete an operation covered by part 135 no later than 14 hours after the beginning of your assigned on call period, and
Your rest period does not begin until the aircraft has either returned to base and all flight-related duty is completed, or the flight crew determines that due to fatigue the airplane cannot safely be returned to base at which point no duty may be assigned or accepted until the completion of a 10 hour rest period. <-- This one would be hard, because I could see some of the more shady employers applying fatigue as a punitive circumstance.
If a rest away from base is required, the pilot may be considered "on call" upon returning to base until no later than twelve hours after the beginning of that flight duty period, and eligible to accept assignments provided the on-demand portion of the flight is completed no later than 14 hours after the beginning of the duty period
8 hour flight time rule would still be applicable.

I feel like you could still run a two pilot operation smoothly using these criteria because the 2nd pilot's on call would not begin until the flight returns to base, at which point they would be on call up to twelve hours but the other pilot would only need 10 hours rest. I can't imagine a scenario under normal EMS operations where neither pilots could accept the duty assignment, unless at like 9.5 hours into the first pilot's rest (and therefore 9.5 hours into the second pilot's on call) a stupid looooong call comes in, and even then in that scenario a delay of 0.5 would typically be tolerable.



What?
 
What needs clarification?
I'm not sure what you're trying to say/get at.

Not being on duty nor calling it duty changes anything. As dpa noted this is a rest issue not a length of duty issue.

What operators want is the "flexibility" to cover that flight that is going to take 9 hours to complete but the first crew has been on duty (out of rest) 6 hours. The next crew isn't coming out of required rest for another 8 hours.


24/7/365 EMS ops need more than 2 crews a day. Not to mention covering sick/training/vacation/etc.
 
24/7/365 EMS ops need more than 2 crews a day. Not to mention covering sick/training/vacation/etc.

In our area I don't know if the activity is there to justify having more than two pilots. What I'm proposing is to give a little bit of flexibility in the duty period rules but still mandate a rest period every 24 hours free from obligation of flight duty.
 
What operators want is the "flexibility" to cover that flight that is going to take 9 hours to complete but the first crew has been on duty (out of rest) 6 hours. The next crew isn't coming out of required rest for another 8 hours.


24/7/365 EMS ops need more than 2 crews a day. Not to mention covering sick/training/vacation/etc.


They CAN come out of rest after another 4. "Hey, can you check weather for ABC to XYZ and come in early?" As long as the pilot has the 10 he or she is golden. When doing the community-based ops,most flights were 3 legs. We just needed to be able to make the first 2 and drop the patient. Then we head to the the hotel. Once we had some time, just not enough to get all the way home. I landed 2/3 of the way home and the relief pilot drove down to get the plane and med crew. I was within the 14 when we landed and got back to base at about the 16 hr mark. The pilot was already on normal duty and the company paid for mileage. We were out of service for 2 hrs when I came back on, but it was better than being out for 10+ if we had just stayed where we dropped the patient. All of these depend on the operation and coworkers.
 
In our area I don't know if the activity is there to justify having more than two pilots. What I'm proposing is to give a little bit of flexibility in the duty period rules but still mandate a rest period every 24 hours free from obligation of flight duty.


Ok, I see what you are saying now. Not exactly what "we" are complaining about: BUT, what you want is what most operators do, only they do it under the guise of "We didn't you call you so were in rest".

14 hours a day is enough. I could see longer duty day but a limit on total duty pulled in a 7 day period (168 hours) to something like 40 hours. Duty would have to be defined and enforced as on call, available, etc for that to work though.

EMS likes to play fast and loose with the rules under that guise of "saving lives". It's complete BS. If the area/base can't support staffing the operation properly to allow for the flight crews to have reasonable time off and consistent duty/rest rotations then so be it, the area doesn't get served 24/7.
 
If the area/base can't support staffing the operation properly to allow for the flight crews to have reasonable time off and consistent duty/rest rotations then so be it, the area doesn't get served 24/7.

Welp, hope you dont get plowed by a DUI driver at 3am.
 
Welp, hope you dont get plowed by a DUI driver at 3am.


That's a fine sentiment to have. But this job, EMS, isn't about that. The town I grew up in didn't have a hospital, airport or a local ambulance service. Populace simply couldn't support it.

Putting flight crews, that includes the medical folks, at a higher risk because you believe being fatigued and being beholden to the company for more than half the day just to try to fit into some altruistic idea of saving a life at 3am is a poor excuse for duty rule changes.
 
Medical flights are exactly why my old management company (Martinair, RIC) requires 24/7 out of the pilots. Owner trips and charters + Med flights at all hours of the day. Makes it really hard for the companies doing it legally to compete.
 
CAMTS would un accredite an operator very quickly for 24/7 on call. About 90% of our business required we maintain camts.
 
Medical flights are exactly why my old management company (Martinair, RIC) requires 24/7 out of the pilots. Owner trips and charters + Med flights at all hours of the day. Makes it really hard for the companies doing it legally to compete.

Yep, illegal operators make it really hard for legit companies to compete. BUT, I work for probably one of the best 135 charter outfits in the country outside of a fractional. They do it the right way and make money so it is hard to hear arguments from companies that say they would go out of business if they played by the rules. Sounds like they shouldn't be in business then.
 
Medical flights are exactly why my old management company (Martinair, RIC) requires 24/7 out of the pilots. Owner trips and charters + Med flights at all hours of the day. Makes it really hard for the companies doing it legally to compete.

Read this sentence in your head several times. I hope it seems as messed up to you as it does to me. I don't work in the EMS field, but I do work for a company that plays by the rules.

If you can't play by the rules, then you shouldn't be in business.
 
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