GUIDANCE MATERIAL CONCERNING FLIGHT TIME AND FLIGHT DUTY TIME LIMITATIONS AND REST PERIODS

Transcription

1 GUIDANCE MATERIAL CONCERNING FLIGHT TIME AND FLIGHT DUTY TIME LIMITATIONS AND REST PERIODS PREAMBLE: Guidance material is provided for any regulation or standard when: (a) (b) The subject area is complex and in need of more detailed explanation so that there is a consistent understanding by all constituents, or Words are used that could have multiple definitions or could be construed differently when used in a different context. For ease of reference guidance material is numbered to correspond to the appropriate regulation or standard. Numbers preceded by the letter "R" refer to a regulation. Numbers preceded by the letter "S" refer to the appropriate standard and numbers preceded by both "R" and "S" amplify material contained in both the regulation and the standard. For example, guidance material numbered R would refer to guidance required by the regulation Similarly, a number of S would refer to guidance required for standard and RS would refer to guidance required by both the regulation and the standard. Where an air operator proposes a different means of conforming with a regulation or standard it will be assessed for acceptability against the following criteria: (a) (b) (c) (d) Does it provide an equivalent level of safety? Is it less or more restrictive than the "normal" means of compliance? Does it address the same intent and issues as the "normal" means of compliance? Does it utilize the most advanced or proven information available? While extensive, the above list may not be appropriate in some circumstances. Additional criteria will be considered as necessary. GUIDANCE MATERIAL R Monitoring System (1)In addition to the company monitoring system, CAR requires all persons who hold a licence to maintain a personal log of their flight time.

2 (2) Flight crew members are required to inform the air operator if any flight time or flight duty time assignment will cause him or her to exceed a flight time or flight duty time limitation. This applies to assignments from the air operator and to any flight time or flight duty time completed for another air operator, private operator or any private or military flying. R Flight Time Limitations The flight crew member s total flight time includes all flying whether private, military or commercial, including ferry, training and test flights or any other flying. For tracking flight time and for planning and scheduling purposes, a day is considered to be any period of 24 consecutive hours. An air operator may use midnight to midnight local time or UTC or any other starting time as a benchmark, as long as the method is used consistently. Where operations are conducted under more than one CAR Subpart, pilots that fly both types of aircraft are limited to flying only the aircraft that has the less restrictive flight time limits once the more restrictive limit has been reached. Take as an example, a pilot flying both the SA226 (Subpart 4) and the PA31 (Subpart 3). Once 40 hours within 7 consecutive days (Subpart 4 limit) has been reached in either the SA226 or the PA31 or a combination of both, the remaining flight time (up to the maximum of 60 hours in 7 consecutive days, the Subpart 3 limit) must be completed in the PA31. Where the flight crew member conducts single-pilot IFR flights, the flight crew member's total flight time, in all flights conducted by the flight crew member, will not exceed 8 hours in any 24 consecutive hours. In determining if this limitation applies to a given situation, this question must be asked did the flight crew member conduct single-pilot IFR flights? Yes or no. If the answer is yes, the flight crewmember is limited to 8 hours of flight time in any 24 consecutive hours. The length of time spent conducting single-pilot IFR flights is irrelevant. If the pilot flew a departure under IFR and then cancelled IFR and flew the rest of the day under VFR the answer is still yes and the 8- hour flight time limit applies. S Flight Time Limitations (1)&(2)The flight time limitations contained in CASS are not applicable to flight crew members on call. (1)&(2) If a flight crew member operates a DHC6 or helicopter in both scheduled passenger service and non-scheduled operations, or operates a helicopter conducting heli-logging in addition to other work, the flight crew member must fly only the type of operation that has the less restrictive flight time

3 limit once the more restrictive limit has been reached. Take as an example, a pilot flying a DHC6 on both scheduled and non-scheduled operations. The first 120 hours of the 150 hour limit for 30 consecutive days can be flown in either scheduled or non-scheduled operations, as per CAR (1)(c). All flight time after 120 hours has been completed up to 150 hours in the 30 consecutive days must be completed only in nonscheduled operations as per CASS (1)(c). (1) The 5 consecutive days free from all duty means the flight crew member will be free from all company-related duty. For example, travel time from a work site or base camp to the company base is not to be included in the 5 consecutive days, whereas travel from that company base to the location where the flight crew member spends their free time can be included in the 5 consecutive days. When an air operator is involved in Forest Fire fighting under the conditions of an exemption from the requirements of and , the air operator is expected to develop a Normal Operation Resumption Plan where by early rest will be assigned to a sufficient number of pilot towards the end of the emergency period, so as to ensure proper fire coverage within the first few days following the emergency period, to allow the other pilots to get their rest and become compliant with the CASS. The Normal Operation Resumption Plan shall be in accordance with the conditions of paragraph (1)(g) of the CASS. R Flight Duty Time Limitations and Rest Periods (3)The rest period does not start until the flight crew member is released from all duty required by the air operator. (3)&(4)Rest periods are a shared responsibility between the air operator and the flight crew member. Providing adequate rest periods is the responsibility of the air operator. Using those rest periods to obtain the required rest is the responsibility of the flight crew member. (4)Flight crew members are required to be adequately rested prior to reporting for flight duty. When a flight crew member commutes long distances, he or she should arrive with sufficient time to obtain adequate rest prior to reporting for flight duty. Flight crew members must consider the detrimental effects the additional time spent commuting may have on their ability to maintain alertness during the flight. (3)&(4)The minimum rest period requires that flight crew members are provided with an opportunity to obtain rest in suitable accommodation. The

4 definition of "suitable accommodation" is contained in CAR Interpretation and refers to a single-occupancy bedroom with various conditions or, where such a bedroom is not available, an accommodation that is suitable for the site and season with various conditions. This second alternative refers to an accommodation that is typical for remote operations where the flight crew s rest facility could be a tent or bunkhouse. (5)The advance notice required in CAR (5)(a) means that the operator must notify the flight crew member of the extension of flight duty time at the start of the flight duty period. This will allow the flight crew member to modify their diet (eg. caffeine intake) during the flight(s) before the rest period and to use the rest period to obtain suitable rest based on the length of the flight duty extension. S Flight Duty Time Limitations and Rest Periods (2) For the flight duty time extension to 15 consecutive hours, the augmenting (additional) flight crew member must be fully qualified to enable all flight crew members the opportunity to obtain a rest period during the flights. Fully qualified means a fully qualified captain or first officer on that aircraft type. There is no requirement to be trained or checked out in the other seat in order to provide relief as an augmenting pilot during the cruise portion of flight. CASS (18) does require a captain to complete right seat conversion training in order to operate the aircraft from the right seat at times other than during cruise. For take off and landing, the Captain and First Officer shall be qualified to operate the aircraft from the seats that they are occupying. In the situation where an aircraft has a second officer or flight engineer, fully qualified means a fully qualified captain or first officer on that aircraft type who has been trained in the duties of the second officer or flight engineer as they pertain to cruise flight. Since the flight duty time extension to 15 hours does not include a sector limitation, the augmenting pilot must be qualified to operate during all phases of flight. During cruise if the augmenting flight crew member is a Captain (2nd Captain); Captain resting - The 2nd Captain would occupy the left seat and First Officer the right seat. The 2nd Captain could be the PF or the First Officer could be the PF (Captain's / 2nd Captain's choice).

5 First Officer resting - The Captain would decide which seats he/she and the 2nd Captain would occupy. The PF shall be qualified to fly the aircraft from the seat that he/she is occupying. If the Captain or 2nd Captain are right seat qualified, he/she may act as PF from the right seat (during any phase of flight). During cruise if the augmenting flight crew member is a First Officer (2nd First Officer); Captain resting - The First Officer is the PF in the right seat and the 2nd First Officer is the PNF in the left seat. First Officer resting - The Captain is the PF in left seat and the 2nd First Officer is the PNF in right seat. The Captain may designate the 2nd First Officer as PF. The augmenting flight crew member shall occupy a flight deck observer seat during take-offs and landings unless the observer seat is required by an air carrier inspector, in which case, a passenger seat must be available for the flight crew member. The subsequent minimum rest period shall be increased by at least 2 hours. (3)For the flight duty time extensions to 17 or 20 hours, a fully qualified flight crew member or a cruise relief pilot can be used as the augmenting pilot(s). (3)Bunks that are installed in aircraft when the CARs came into effect are considered to meet the requirement of the SAE Standard. S Unforeseen Operational Circumstances (1)Unforeseen operational circumstances (UOC) may be used to allow a pilot to complete a block or cycle with an extension to the flight time limitations for either the seven, 30 or 90 day periods. For example, a pilot on a 7-day block accumulates 3 additional flight hours during the first 6 days due to UOC. The pilot may still fly a trip on day 7 which takes him/her to a maximum of 43 hours in 7 days. In all cases, the maximum extension allowed is three consecutive hours. (2)Planning is considered to be unrealistic if the maximum flight duty time or flight time on a particular route is exceeded on more than 10% of occasions where 10 or more flights follow that route in a calendar year. The operator must take appropriate action to ensure that the planning is realistic and the flight or series of flights is completed within the

6 maximum allowable flight time and flight duty time. Flights on routes of less frequency than 10 per year should be dealt with on a case-to-case basis. (2)UOC relates solely to operational circumstances, which result in delays to a planned schedule. In other words, these circumstances must be crew, weather, aircraft mechanical, ATC or emergency related and must directly affect the operation of the aircraft. Delaying the departure of a flight to wait for a delayed passenger may have an operational effect on the schedule, but it is not an UOC. R Requirements for Time Free From Duty 1) The term consecutive days indicates that the requirement of the regulation must be satisfied throughout any of the period of consecutive days indicated. A moving or rolling window can be used to verify if the regulatory requirements are satisfied. For example, when verifying whether a flight crew member received a period of at least 3 consecutive calendar days free from duty within each 17 consecutive days, a 17 day window can be used. This sliding window can now be placed along the pilot s schedule one day at a time; however, this technique cannot be used when the beginning of the window moves inside a period of time free from duty. If the time free from duty is always satisfied within the 17 day window, the schedule meets the requirement of the regulations. (1) a) Where the operation is conducted under Subpart 4 or 5 using an aircraft other than a helicopter, the regulation states that an air operator shall provide each flight crew member, one period of at least 36 consecutive hours within each 7 consecutive days or one period of at least 3 consecutive calendar days within each 17 consecutive days. The above regulation allows the operator the opportunity to provide time free from duty to its pilots in either one of the two scheduling schemes; 36 consecutive hours within each 7 consecutive days, or 3 consecutive calendar days within each 17 consecutive days. The intent was to provide the flexibility of two scheduling schemes, but it was expected that each scheme would be used independently from the other in a more or less continuous state. The regulation is not meant to authorize a mix of the two schemes in an arrangement that will produce a working schedule conducive to fatigue. The only acceptable way to change from one scheme to the other is to provide the pilot 3 consecutive calendar days off.

7 Thus, the operator is allowed the opportunity to change a pilot s schedule from a scheme of 36 consecutive hours off in each 7 days, to a scheme of 3 consecutive calendar days off in each 17 days, provided that the 3 consecutive calendar days off are awarded to the pilot at the beginning of the 17 day period. Similarly, a schedule cannot revert from 3 consecutive days off in 17 days, to 36 consecutive hours off in 7 days without initially providing the pilot with 3 consecutive days off. A simple approach to evaluating a schedule is to use the concept of work period. For Subpart 4 or 5, a work period is defined as the period of time between two consecutive time off periods of duration of 36 hours or more. Thus, when operating under the scheme of 36 consecutive hours off within each 7 consecutive days, it also implies that a pilot cannot be scheduled for a work period longer than 5½ days. Conversely, when operating under 3 consecutive days off in 17 days, a pilot cannot be scheduled for more than 14 days without being awarded 3 consecutive days off. The work period need not be announced to the pilot. For example, if a pilot had 3 days off and then was initially scheduled for 5 days of work, implying a 36 in 7 work period, the air operator could still alter the schedule to a 3 days in 17 work period anytime prior to 5 ½ days of work. The following paragraphs provide a series of examples describing possible work schedules and an explanation for each of them as to why they meet the regulatory requirement or not. The examples show periods of 30 calendar days which could be taken at any point in time within the pilot s working schedule. Each X represents a period of 12 hours, two Xs within one day indicate that the pilot has the day off. The symbology was chosen to be able to adequately represent a period of 36 consecutive hours of rest. Example 1. The schedule shown at Figure 1. is unacceptable. The two scheduling schemes are mixed in an inappropriate fashion producing a working schedule conducive to excessive fatigue levels. The scheduling scheme is changed from 3 consecutive calendar days off in 17 days, to 36 continuous hours off in 7 days without providing 3 consecutive days off. Figure 2. Shows an acceptable schedule. Figure XX XX XX XX X XX X Figure XX XX XX XX XX XX X XX

8 Example 2. The schedule shown at Figure 3. is unacceptable because the pilot who had been working on a 36 hours off in 7 days schedule for the past few weeks is not allowed to work for 8 continuous days (days 11 to 18) without having been previously awarded 3 consecutive days off. Figure 4. Shows an acceptable schedule. Figure XX X XX X XX XX XX Figure XX X XX X XX XX XX Example 3. The schedule shown at Figure 5. has a rest period within each consecutive block of 7 days; days 4 to 10, days 11 to 17 and days 18 to 24 but there is a work period longer than 5½ days from days 16 to 22 which renders the schedule unacceptable. Figure 6 shows an acceptable schedule. Figure XX XX XX X XX X XX X XX X XX Figure XX XX XX X XX X XX X XX X XX Suggested scheduling methodology Following is a 2 step methodology which can be used by a scheduler to determine if a cycle can be assigned to a pilot in accordance with the regulation. The methodology uses the work period concept defined earlier. If the process is followed before each cycle allocation, the schedule will remain acceptable. This is assuming of course that the cycles are not

9 extended. When a cycle is extended, the extension should be treated as a separate cycle and then the same methodology applies. Step 1. Determine under which scheduling scheme the pilot is presently operating. Depending on the schedule of the last 17 days a pilot may be under a 36 in 7 scheme or a 3 in 17 scheme or have the option of either. The either situation can be illustrated by day 16 of Figure 6. Because of the history of time off, the pilot may work for 2 days followed by 3 consecutive calendar days off to remain on a 3 in 17 cycle or work for up to 5½ days and transition to a basic 36 in 7 cycle. To determine the scheduling scheme, proceed as follows: Within the last 17 calendar days, did the pilot get 3 consecutive days off? YES Since the end of the 3 consecutive days off period, did any work period exceed 5½ days? NO NO YES Pilot is operating under a basic 3 consecutive days off for each 17 days. Pilot may operate under either scheduling scheme. Pilot is operating under a basic 36 consecutive hours off for each 7 days. Step 2. Determine if the proposed cycle will respect the regulation. Depending on the scheduling scheme the pilot is presently operating, investigate as follows: - when operating under a basic 36 hours in 7 days, if the pairing creates a work period longer than 5½ days, it is not acceptable, - when operating under a basic 3 days off in 17 days, if the pairing extends past 14 calendar days since the end of the last 3 days off period, it is not acceptable, - when the pilot can operate under either scheme, if the pairing creates a work period longer than 5½ days and extends past 14 calendar days since the end of the last 3 days off period, it is not acceptable.

10 (1) The intent of time free from duty is to provide a flight crew member with a specified period of time during which he or she is free from all company assigned duties. Notwithstanding, some flight crew members may chose to carry a beeper or cellular phone while on time free from duty in order to be accessible to the air operator or others. At times, air operators do contact flight crew members by various means during a period of time free from duty for administrative or operational reasons. If a flight crew member is to be considered still on time free from duty when an air operator contacts or attempts to contact the member, then two conditions must be met as follows: 1.There is no requirement for the member to be available to be contacted by the air operator. For example, the member is not obliged to be available by phone or some other means; and 2.If the member is contacted by the air operator, the member is not obliged to respond to any request the air operator may have which would interfere with the members time free from duty. Contacts for routine administrative or operational reasons, the content of which does not infringe on the time free from duty period, are acceptable. For example, a call to inform the member of a schedule change for a flight assignment which follows the time free from duty period does not infringe on the period. Any call which requires further action on the part of the member during the period of time free from duty means that period can no longer be considered as time free from duty. In general, operator contact with a flight crew member on time free from duty should be kept to a minimum. S Requirements for Time Free from Duty (1) Days off (one day equals at least 24 consecutive hours) for weather or mechanical problems, etc. taken throughout the 42 consecutive days do not reduce the requirement for 5 consecutive days off. However, these days off can be applied towards the 90-day requirement. R Flight Crew Members on Reserve Time spent on reserve is not considered as duty time nor can it be considered as time free from duty. Therefore, when scheduling time free from duty in accordance with and , reserve time must be considered as counting as duty time. S Flight Crew Members on Reserve

11 (1)When a flight crew member is on reserve, an air operator must provide the flight crew member with the opportunity to obtain at least 8 consecutive hours sleep in any 24 hours by one of the 3 methods indicated in the standard. When that flight crew member is contacted and required to report for duty during the period of reserve duty, the flight crew member is no longer considered to be on reserve but on duty, and therefore the requirements of no longer apply. This means that at anytime during the reserve period, a flight crew member can be required to start a 14 hour duty period (or longer depending on the applicability of those sections of and which permit extended flight duty times). A flight crew member therefore must remain rested while on reserve such that they are able to cope with a full duty day if called. (2)Anytime a flight crew member returns to reserve status following a flight duty assignment and the rest period required for that assignment, the reserve clock is set to zero. This means that a flight crew member who was originally on early reserve can be placed on late reserve following the flight and rest period. Should an operator wish to shift a flight crew member s schedule from an early reserve to a late reserve (or late to early) without an intervening flight duty assignment and rest period, the flight crew member must receive 24 hours off before commencing the late reserve. (3)The phrase where an air operator is unable to provide a flight crew member with a rest period required by subsection (1) and the flight crew member is notified to report for duty means that the flight crew member is required to report for duty during a scheduled reserve period and/or during the subsequent rest period. Subsection (2) does not apply to a flight duty assignment which begins during the reserve period and infringes on what was a scheduled rest period if the rest period that preceded the flight duty assignment was scheduled in accordance with subparagraph (1). S Controlled Rest on the Flight Deck (1)Controlled rest on the flight deck was developed as a result of a NASA research program. The NASA Ames Fatigue Countermeasures Program provides a training module in alertness management in flight operations that covers sleep, circadian rhythms, alertness management, fatigue countermeasures and controlled rest on the flight deck. The module can be modified to include company-specific information. Information on the module can be obtained at the following address: Fatigue Countermeasures Program, NASA Ames Research Center, MS 262-4, Moffett Field, California