Our comments on draft Airworthiness Advisory Circular 3 of 2011 are as follows: BACKGROUND

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1 To, Shri Charan Das Joint Director General Office of The Director General Of Civil Aviation Opp Safdarjung Airport Aurobindo Marg, New Delhi Respected Sir, Our comments on draft Airworthiness Advisory Circular 3 of 2011 are as follows: BACKGROUND It is a well known and acknowledged fact across the industry that Aircraft Maintenance Engineers work under severe stress, challenging and difficult work conditions. The fatigue and stress level of Aircraft Maintenance Engineers have been consistently increasing with need to cater for the 24 hour society and increased focus on maximising aircraft utilisation, reduced ground / turnaround times in recent times. The fatigue and stress level are also adversely affected by the fact that the majority of the practical maintenance activities are performed under stressful conditions in mostly uncontrolled environment for long duration and while facing the hardships in adverse tropical weather conditions. Fatigue and stress levels are increased manifold because of inadequate or no break time while on duty, skipping of meals because of duty requirements, non-availability of basic human resources such as drinking water, transportation facility requiring movements on foot etc which causes rapid fatigue and deteriorated concentration level within a short time. Many times, Aircraft Maintenance Engineers involved in incident/ accident have officially reported loss of concentration/ desirable efficiencies because of fatigue and stress caused by inadequate rest between shifts/duty periods or longer than normal duty periods. Number of such unofficial reports from Aircraft Maintenance Engineers across the industry are much more high confirming the need for implementation of duty time limitations for Aircraft Maintenance Engineers and monitoring/ oversight of duty time limitations by national regulatory authority / DGCA to minimise human error contributed by fatigue and stress caused by long duty hours and/ or inadequate rest period keeping in view the safety of travelling public, aircraft and well being of Aircraft Maintenance Engineers. Both, Aircraft Maintenance Engineers and Flight Crew work in the same industry and encounter similar situations with regard to operational requirements such as break shift, positioning flights, standby duties, extended duties in case of unforeseen circumstances etc leading to in ordinarily long hours of duty coupled with insufficient and inadequate rest time before the next duty. 1

2 We have noted that The draft AAC 3 of 2011 and its recommendations are based on CAA Paper 2002/06 which does not fully cover all the aspects of work profile and duty patterns being followed by Aircraft Maintenance Engineers in India. We have further noted that DGCA mandate on flight and duty time limitation is laid down in CAR SECTION 7 FLIGHT CREW STANDARDS SERIES J, PART III for Flight Crew. These requirements have been mandated by DGCA after lengthy discussion, deliberations based on work environment and scientific studies. We have examined following documents namely: 1. CIVIL AVIATION REQUIREMENTS, SECTION 7 FLIGHT CREW STANDARDS SERIES J, PART III ISSUE II, 11TH AUGUST CAA Paper 2002/ National Legislations such as Factories Act 1948, Shop and establishment Act and other relevant legislations. Our review and examination have revealed that 1. A large number of the requirements laid down by DGCA relating to flight and duty time limitations for flight crew vide CIVIL AVIATION REQUIREMENTS, SECTION 7 FLIGHT CREW STANDARDS SERIES J, PART III ISSUE II, 11TH AUGUST 2011 are equally important for Aircraft Maintenance Engineers and non-inclusion of these requirements in AAC can be a contributory factor on increased risk caused by fatigue because of inadequate rest time adversely affecting safety of passengers, crew, aircraft and Aircraft Maintenance Engineers. 2. CAA Paper 2002/06 s recommendations needs to be harmonized with National legislations and International conventions. 3. All the aspects of work profile and duty patterns being followed by Aircraft Maintenance Engineers in India are not covered by CAA Paper 2002/2006. We would like to quote the last paragraph of draft AAC 3 of 2011 Quote: In the conclusion it is advisable that in line with pilot and Cabin crew every organization should frame policy for AME duty time limitations and adequate rest period. AME who are releasing the Aircraft to service after maintenance are practically ensuring the airworthiness and safety. Therefore, an AME performing duties whilst fatigued may become potential threat and safety hazard for operation of aircraft if the issue is not properly addressed. Unquote Therefore, Our comments have been prepared based on 1. CIVIL AVIATION REQUIREMENTS, SECTION 7 FLIGHT CREW STANDARDS SERIES J, PART III ISSUE II, 11TH AUGUST CAA Paper 2002/2006 s. 3. All the aspects of work profile and duty patterns being followed by Aircraft Maintenance Engineers in India which are not covered by. 4. The suggested comments are harmonized with relevant National Legislations and International conventions. 2

3 5. The productivity of Aircraft Maintenance Engineers remains unaltered by maintaining limit of 48 hours per week while ensuring adequate rest time to reduce the fatigue and stress levels. We suggest following amendments along with our comments and reason for respective amendment for incorporation in the AAC 3 of 2011 so as to enhance the scope of AAC in order to meet the goals and objectives of the AAC 3 of APPLICABILITY AMENDEMENT NO 1: ADD: 1.1 The Duty Time Limitations and Rest Requirements contained in this AAC are applicable to Operators of and AIRCRAFT MAINTENANCE ENGINEERS engaged in scheduled/non-scheduled air transport and general aviation aeroplane maintenance. Comment and reason for amendment No.1: The applicability of AAC must be included for clarity of roles of Operator, Aircraft Maintenance Engineers to ensure compliance with duty time limitations. The above mentioned requirement(s) is/ are already laid down in case of flight crew and same must be adopted for Aircraft Maintenance Engineers as AAC does not specify the applicability, but The CIVIL AVIATION REQUIREMENTS, SECTION 7 FLIGHT CREW STANDARDS SERIES J, PART III ISSUE II, 11TH AUGUST 2011 specifies the applicability. AMENDMENT NO 2: ADD: 2.1 No Operator/ Aircraft Maintenance Engineer may require or perform duties beyond 31 st March 2012 unless the requirements contained in this CAR are complied with. Comment and reason for amendment No.2: Industry will require to time to comply with AAC 3of 2011, therefore, timeline must be specified for compliance of duty time limitations for Aircraft Maintenance Engineer. The above mentioned requirement(s) is/ are already laid down in case of flight crew and same must be adopted for Aircraft Maintenance Engineers and must be included in the AAC no.3 of 2011 to ensure compliance in a time bound manner. 3.1 DEFINITIONS AMENDMENT NO.3, 3.1 thru ADD 3

4 3.2 Duty. Any task that Aircraft Maintenance Engineer is required by the operator to perform, including, for example, flight duty, administrative work, training, positioning and standby when it is likely to induce fatigue. 3.3 Duty period. A period which starts when an Aircraft Maintenance Engineer is required by an operator to report for or to commence a duty that includes a flight or a series of flights and which finishes when the aeroplane finally comes to rest and the engines are shut down at the end of the last flight on which he/she is a crew member or performs the duties assigned by the operator and ends when that person is free from all duties. 3.4 Fatigue. A physiological state of reduced mental or physical performance capability resulting from sleep loss or extended wakefulness, circadian phase, or workload (mental and/or physical activity) that can impair An Aircraft Maintenance Engineer s alertness and ability to Perform safety related duties. 3.5 Flight time. The total time from the moment an aeroplane first moves for the purpose of taking off until the moment it finally comes to rest at the end of the flight. Note. Flight time as here defined is synonymous with the term block to block time or chock to chock time in general usage which is measured from the time an aeroplane first moves for the purpose of taking off until it finally stops at the end of the flight. 3.6 Home base. The location nominated by the operator to the Aircraft Maintenance Engineer from where the Aircraft Maintenance Engineer normally starts and ends a duty period or a series of duty periods. 3.7 Local night. A period of eight hours falling between and local time. 3.8 Neighbouring Countries. Countries whose standard times falls within a band of 3 hours (+1:30 hours on either side of India) i.e. countries covered in the standard time zone band of UTC+4 to UTC Positioning. The transferring of an Aircraft Maintenance Engineer from place to place as a passenger at the behest of the operator. Note. Positioning as here defined is synonymous with the term Deadheading. 3.9 Reporting time. The time at which an Aircraft Maintenance Engineer is required by an operator to report for duty Rest Period. An uninterrupted and defined period of time during which an Aircraft Maintenance Engineer is free from all duties and airport standby Split Duty (Break) means a period free of all duties, which counts as duty, being less than a rest period Standby. It is a defined period of time during which an Aircraft Maintenance Engineer is required by the operator to be available to receive an assignment for a specific duty without an intervening rest period. However, it shall not include any time during which an 4

5 operator requires an Aircraft Maintenance Engineer to be contactable for the purpose of giving notification of a duty which is due to start 10 hours or more ahead Ultra Long Range (ULR) Operations. Continuous non-stop flights between the specific city pairs having a flight time of over 16 hours and duty periods between 18 and 22 hours Unforeseen operational circumstance. An unplanned event, such as unforecast weather, equipment malfunction, or air traffic delay that is beyond the control of the operator Window of Circadian Low (WOCL)is best estimated by the hours between 0200 and 0600 for individuals adapted to a usual day-wake/ night sleep schedule. This estimate of the window is calculated from scientific data on the circadian low of performance, alertness, subject report (i.e., peak fatigue), and body temperature. For flight duty periods that cross 3 or fewer time zones, the window of circadian low is estimated to be 0200 to 0600 home-base/ domicile. Comment and reason for amendment No.3,3.1 thru 3.15: These definitions have been rephrased and Definition must be included in the AAC 3 of 2011 for clarity and understanding of Aircraft Maintenance Engineer and Operators. It must be noted that Many a times, AMEs are transported on long flight/ ultra long flights and are required to perform maintenance on arrival without a rest period. Similar definitions are already laid down in CIVIL AVIATION REQUIREMENTS, Maintenance Engineers. 4. OPERATOR S RESPONSIBILITY AMENDMENT NO. 4&4.1 - ADD: 4.1 Every operator shall establish a scheme for complying with the limitations for duty periods and rest periods specified in this AAC in respect of Aircraft Maintenance Engineer Comment and reason for amendment No.4 & 4.1: Maintenance Engineers.AAC 3 of 2011 does not specify the operator s responsibility and the steps to be taken by the operator to ensure compliance with duty time limitations, therefore, the operator s responsibility to achieve and to ensure compliance with AAC 3 of 2011 must be included in the AAC 3 of

6 AMENDMENT NO. 4.2/ ADD 4.2 DGCA may approve, in exceptional circumstances, variations to these regulations on the basis of a risk assessment provided by the operator. Approved variations shall provide a level of safety equivalent to, or better than, that achieved through the prescriptive fatigue management regulations specified in this AAC. Comment and reason for amendment No.4.2: Maintenance Engineer. AMENDMENT NO. 4.3-ADD 4.3 The scheme along with any variations shall be submitted to the Director-General for approval and scheme shall be included in the MAINTENANCE ORGANISATION EXPOSITION. Comment and reason for amendment No.4.3 Maintenance Engineers.AAC 3 of 2011 does not specify the operator s responsibility, conditions, the means and the steps to be taken by the operator to ensure compliance with duty time limitations, therefore, the system to ensure implementation and compliance with AAC 3 of 2011 must be included in the AAC 3 of AMENDMENT NO. 4.4-ADD 4.4 The operator shall not require an AIRCRAFT MAINTENANCE ENGINEER to operate perform duties if it is known or suspected that the AIRCRAFT MAINTENANCE ENGINEER is fatigued to the extent that the safety of aircraft may be adversely affected. Comment and reason for amendment No.4.4 Maintenance Engineer. AAC 3 of 2011 does not specify the conditions and the means to control and effective implementation of the duty time limitations, however, The CIVIL AVIATION REQUIREMENTS, SECTION 7 FLIGHT CREW STANDARDS SERIES J, PART III ISSUE II, 11TH AUGUST 2011 specifies the operator s responsibility for compliance. 6

7 Therefore, the operator s and Aircraft Maintenance Engineer s duties to comply with duty time limitations must be defined/ specified and must be included in the AAC 3 of 2011 to prevent violation of duty time limitation to adversely affecting safety of the travelling public, crew, Aircraft Maintenance Engineers and others from such violations by operator / Aircraft Maintenance Engineer. AMENDMENT NO. 4.5-ADD 4.5 No operator shall schedule any AIRCRAFT MAINTENANCE ENGINEERS and no AIRCRAFT MAINTENANCE ENGINEERS may accept an assignment, which shall exceed the prescribed limitations. Comment and reason for amendment No.4.5 Maintenance Engineer. AAC 3 of 2011 does not specify the conditions and the means to control and effective implementation of the duty time limitations, however, The CIVIL AVIATION REQUIREMENTS, SECTION 7 FLIGHT CREW STANDARDS SERIES J, PART III ISSUE II, 11TH AUGUST 2011 similar requirements. Ttherefore, AAC 3 of 2011 must specify the operator s and Aircraft Maintenance Engineer s responsibility for compliance. Operator s and Aircraft Maintenance Engineer s duties to comply with duty time limitations must be defined/ specified and must be included in the AAC 3 of 2011 to prevent violation of duty time limitation to ensure safety of the aircraft from such violations by operator / Aircraft Maintenance Engineer. AMENDMENT NO.4.6- ADD 4.6 Operators shall ensure that persons concerned with the operations of aircraft are trained and educated regarding dangers of fatigue, the causes of sleepiness and importance of sleep and proper sleep habits. Comment and reason for amendment No.4.6 Maintenance Engineer for effective implementation. AAC 3 of 2011 does not specify the conditions and the means to control and effective implementation of the duty time limitations, however, The CIVIL AVIATION REQUIREMENTS, SECTION 7 FLIGHT CREW STANDARDS SERIES J, PART III ISSUE II, 11TH AUGUST 2011 specifies similar requirements as above, therefore, AAC 3 of 2011 must specify the operator s and Aircraft Maintenance Engineer s responsibility for compliance. 7

8 The training is important to create awareness on Operator s and Aircraft Maintenance Engineer s duties to comply with duty time limitations must be defined/ specified and must be included in the AAC 3 of 2011 to prevent violation of duty time limitation to ensure safety of the aircraft from such violations by operator / Aircraft Maintenance Engineer. AMENDMENT NO ADD 4.7 Operator shall ensure that adequate restroom/ rest facility is provided considering the no. of Aircraft Maintenance Engineers in each shift. Comment and reason for amendment No.4.6 AAC specifies a break time after four hours of shift before a break but does not specify the requirement to comply. AMENDMENT NO ADD 4.8 Operator shall ensure that break shift duty of Aircraft Maintenance Engineers is limited to one in any work day and break shift duty should not affect the 11 hours rest period. Comment and reason for amendment No.4.6 Break shift duties are performed by AMEs and such break shift duties must be limited to one considering inadequate period for transportation etc if more than one break shift duty is performed. AMENDMENT NO.5 - ADD: 5. AIRCRAFT MAINTENACE ENGINEER S RESPONSIBILITY 5.1 An AIRCRAFT MAINTENANCE ENGINEER shall not perform duties on an aeroplane when he or she knows that he or she is fatigued or feels unfit to the extent that the safety of aircraft may be adversely affected. Comment and reason for amendment No.5 & 5.1 Maintenance Engineer. AAC 3 of 2011 does not specify the Aircraft Maintenance Engineer s responsibility as the means to control and effective implementation of the duty time limitations, however, The CIVIL AVIATION REQUIREMENTS, SECTION 7 FLIGHT CREW STANDARDS SERIES J, PART III ISSUE II, 11TH AUGUST 2011 specifies similar requirement, therefore, AAC 3 of 2011 must specify the Aircraft Maintenance Engineer s responsibility 8

9 for compliance to ensure and prevent violation of duty time limitations by Aircraft Maintenance Engineer,to ensure safety of passengers, crew and aircraft. AMENDEMNT NO.5.2- ADD 5.2 Aircraft Maintenance Engineer shall make best use of facilities and opportunities that are provided for rest and for the consumption of meals, and shall plan and use rest periods to ensure that they are fully rested. Comment and reason for amendment No.5.2 Maintenance Engineer. AAC 3 of 2011 does not specify the Aircraft Maintenance Engineer s responsibility as the means to control and effective implementation of the duty time limitations, however, The CIVIL AVIATION REQUIREMENTS, SECTION 7 FLIGHT CREW STANDARDS SERIES J, PART III ISSUE II, 11TH AUGUST 2011 specifies similar requirement, therefore, AAC 3 of 2011 must specify the Aircraft Maintenance Engineer s responsibility for compliance to ensure and prevent violation of duty time limitations by Aircraft Maintenance Engineer,to ensure safety of aircraft. 6. DUTY TIME: AMENDMENT NO.6/ ADD AND REPLACE RECOMMENDATION NO The scheduled duty time should not exceed 8 hours. Comment and reason for amendment No.5.2 Duty time for AMEs must be limited to 8 hours per day for following reasons. 1. AMEs work environment is severely affected by factors such as tropical weather, vigorous physical activities and other external factors such as noise, vibrations, exposure to fumes etc while performing the maintenance and for supervision of maintenance activity. 2. Most of maintenance activities take place in uncontrolled tropical weather conditions causing rapid fatigue. 3. Legislative provisions under shop and establishment act and factories act 1948 stipulates the duty time to 8 hours as well as other international conventions also stipulates the duty hours to 8 hours. 4. To reduce the risk factor as CAA paper 2002/2006 recognises that all other factors being equal, the risk on a 12-hour shift system is some 27.6% higher than that on an 8-hour system. 9

10 AMENDMENT NO.6.2/ ADD AND REPLECE RECOMMENDATION NO A minimum rest period of 11 hours should be allowed between the end of shift and the beginning of the next, and this should not be compromised by overtime and transportation time should be excluded from 11 hours of rest time. Comment and reason for amendment No.6.2 The transportation time must be considered and excluded from 11 hrs rest period so to ensure sufficient rest time before next duty. Similar requirement is already laid down in CIVIL AVIATION REQUIREMENTS, SECTION 7 FLIGHT CREW STANDARDS SERIES J, PART III ISSUE II, 11TH AUGUST 2011 in case of flight crew and same must be adopted in AAC 3 of 2011 for Aircraft Maintenance Engineer. AMENDMENT NO. 6.3/ ADD AND REPLACE RECOMMENDATION NO Scheduled work hours should not exceed 48 hours in any period of SIX successive days The overtime should not exceed four hours per day or total duty should not exceed 12 hours per work day Total work, including overtime, should not exceed 54 hours in SIX successive work days before a period of rest days The total no. of overtime hours over the period of consecutive 90 days must not exceed 50 hours. Comment and reason for amendment No.6.3,6.4,6.5,and 6.6 More stringent requirements are needed to ensure adequate rest period in the interest of public and personal safety of AMEs to meet the objectives of duty time limitations of Aircraft Maintenance Engineers and also to harmonize the duty time limitations with national legislations and international conventions. 1. Work week must comprise of six working days only as per world wide practice across all the industries including India as well as specified and laid down under Various National Legislations (Shop and establishment act and factories act 1948) and International Conventions. 2. Total work hours including overtime should not exceed 54 hours per week (maximum limit of four hour per day) as specified and laid down under national and international legislations (Shop and establishment act and factories act 1948). 3. Six work days before a period of rest days which is also mandated by national legislations (Shop and establishment act and factories act 1948)and International Conventions. 4. The total no of overtime hours over the period of consecutive 90 days must not exceed 50 hours to ensure A). Adequacy of man power with the organisation, B).To avoid undue work pressure causing fatigue, stress compromising safety. C). Same is mandated by Factories Act The risk factor is significantly increased beyond 12 hours of duty period. 10

11 7.Rest: 7.1 Minimum Rest: AMENDMENT NO.7- ADD The minimum rest, which must be provided before undertaking a duty period, shall be: At least as long as the preceding duty period, (a) 12 hours, OR (b) 14 hours on crossing 3 time zones, or (c) 36 hours on crossing 8 time zones whichever is the greater; Comment and reason for amendment No.7, 7.1 & Maintenance Engineer. AMEs in the airlines are required to travel on flights for coverage / performing duties on arrival station, therefore, rest period must be specified for Aircraft Maintenance Engineers on the lines of flight crew and this should be included in the AAC for AMEs duty time limitations. AMENDMENT NO ADD If the preceding duty period, which includes any time spent on positioning, exceeds 18 hours, then the ensuing rest period shall include a local night. Period of transportation to and from an airport shall neither be counted towards duty time nor rest period. The operator shall include in the Scheme the optimum time of transportation after taking into account various factors and on ensuring that the rest period does not get reduced below the minimum rest requirements. Comment and reason for amendment No Maintenance Engineer Aircraft Maintenance Engineer in the airlines are required to travel on flights for coverage / performing duties / positioning on arrival station, therefore, rest period must be 11

12 specified for Aircraft Maintenance Engineers on the lines of flight crew and this should be included in the AAC for AMEs duty time limitations. 7.2 Rest after return to base AMENDMENT NO.7.2, & ADD An operator shall ensure that effects on Aircraft Maintenance Engineers of time zone differences will be compensated by additional rest as specified below Minimum rest including local nights shall be given, according to the table below, when coming back to home base, to any Aircraft Maintenance Engineer who has been away from the home base in such a way that the WOCL had to be modified. Time zone difference Hours of rest Local nights More than 3 to Beyond Comment and reason for amendment No. 7.2, & Aircraft Maintenance Engineers are required to travel across network to attend to various operational and maintenance requirements of airlines and performing maintenance duties and may result in insufficient rest time therefore, minimum rest period must be included in the AAC for AMEs duty time limitations. Maintenance Engineers Split Duty (Break) AMENDMENT NO. 7.3-ADD Consecutive hours of break Maximum Extension of the DP 12

13 Less than 3H NIL Between 3H and 9H A period equal to half the consecutive hours break taken >9H No extension permitted Comment and reason for amendment No. 7.3, Aircraft Maintenance Engineers are required perform duties in split or break shift, therefore, the factor of fatigue caused by working in split shift break shift duties must be considered and adequate rest time be specified. Maintenance Engineer 7.4 STANDBY DUTY: 7.5 General AMENDMENT NO. 7.4, 7.4.1, 7.4.2,.7.4.3,.7.5.5,7.6.6,- ADD Operators shall include Standby as part of their regular rosters and concerned Aircraft Maintenance Engineer shall be kept notified In case of exigencies when Standby duty may go beyond the roster, Operator shall ensure that concerned Aircraft Maintenance Engineer is notified in advance Standby Period Standby period shall not extend beyond 12 hours. However, a maximum standby at airport (with or without sleeping quarters) shall not exceed 8 hours If the standby period is at the airport and Standby culminates into a duty then the total period (i.e. 100%) shall be counted towards the duty period and also towards cumulative duty period 13

14 Standby does not culminate into a duty then the total period (i.e. 100%) shall be counted only towards cumulative duty period If the standby period is at home or in a hotel and culminates into duty Within first 6 hours then no part of standby shall be considered as part of duty period or cumulative duty period At 6 hours or later then duty period shall be reduced by 50% of the standby time If standby period is at home or in a hotel does not culminate into a duty then, 25% of its time shall be considered under cumulative duty. Comment and reasons for amendment 7.4 Standby duties are also performed by AIRCRAFT MAINTENANCE ENGINEERS for e.g To provide coverage to the other AMEs with restricted scopes, ENGINE CHANGE/ SCHEDULED CHECKS etc which shall have impact on the fatigue and alertness of Aircraft Maintenace Engineer if not adequately rested and quality of maintenance performed by him may get adversely affected. Maintenance Engineers. 7.5 Rest period after Standby: AMENDMENT NO. 7.5, 7.5.1, ADD When any period of standby finishes, during which a call-out has not occurred, at least 10 hours rest shall follow prior to the next duty period When standby culminates in to a duty, then the rest period shall be decided based on total period of duty i.e. the duty plus the percentage of standby counted for duty. Comment and reason for amendment no. 7.5, 7.5.1, Standby duties are also performed by AIRCRAFT MAINTENANCE ENGINEERS for e.g To provide coverage to the other AMEs with restricted scopes at transit stationa, Scheduled checks, engine changes etc which shall have impact on the fatigue and alertness of Aircraft Maintenance Engineer if not adequately rested and quality of maintenance performed by him may get adversely affected. 14

15 Maintenance Engineer 7.6. POSITIONING AMENDMENT NO. 7.6, 7.6.1, 7.6.2,7.6.3,7.6.4,7.6.5-ADD All the time spent on positioning on the behest of the operator shall be counted as duty Positioning time shall be part of a duty period when it immediately precedes (i.e., without an intervening rest period) a duty period in which that person participates as an additional crew member Positioning after operating a flight duty period without an intervening rest period shall be counted for determining rest period Positioning shall not count as a duty for purposes of determining Duty Period if, after a positioning journey, the Aircraft Maintenance Engineer spends a minimum rest period at suitable accommodation provided by the operator Positioning shall be counted as a duty if, after a positioning journey, the Aircraft Maintenance Engineer spends less than a minimum rest period at suitable accommodation provided by the operator, and then extends duty period using Split Duty. Comment and reason for amendment no. 7.6, 7.6.1, 7.6.2,7.6.3,7.6.4,7.6.5 Maintenance Engineer Duties are performed by Aircraft Maintenance Engineers for positioning purpose in airlines and therefore, positioning must be accounted for duty period so as to ensure adequate rest time. AMENDMENT NO.8,8.1./ADD 8. UNFORESEEN OPERATIONAL CIRCUMSTANCES 8.1 For an unplanned event, such as unforecast weather, equipment malfunction, or air traffic delay that is beyond the control of the operator DUTY TIME and Duty Period may be extended as follows: (a) Duty Time by maximum of 4 hour and Duty Period by maximum of 50 hours in 90 consecutive days. 15

16 (b) Subject to the maximum limit of extension of duty period of 4 hour on individual event and, extension shall be decided between AIRCRAFT MAINTENANCE ENGINEERS and Head of Maintenance/ Designated post holder of operator. (c) AIRCRAFT MAINTENANCE ENGINEER will convey their willingness (or consent) to the Head of maintenance/ Designated post holder. The AIRCRAFT MAINTENANCE ENGINEER will submit the report to QUALITY MANAGER who will file to DGCA along with his comments. Comment and reason for amendment no.8 &8.1: Extensions of duty due to unforeseen circumstances are necessitated an unplanned event such as unforecast weather, equipment malfunction, or air traffic delays and operational requirement resulting reduced rest time faced by Aircraft Maintenance Engineers. Maintenance Engineer AMENDMENT NO ADD 8.3 Whenever the duty period gets extended, the rest period shall be pro-rata increased by twice the amount of extended time of duty period. Comment and reason for amendment no.8 &8.1: Extensions of duty time due to unforeseen circumstances and resulting reduced rest time are faced by Aircraft Maintenance Engineers as well. Therefore, AAC 3 of 2011 must specify for adequate rest after extension of duty period. Maintenance Engineer AMENDMENT NO.9,9.1,9.2,9.3,&9.4- ADD 9. CONSECUTIVE NIGHT OPERATIONS 9.1 No operator operating passenger flights shall deploy An Aircraft Maintenance Engineer nor an Aircraft Maintenance Engineer shall undertake any duty between period embracing 0000 to 0500 hours local time if during the previous day he/she performed flight duty between the period embracing 0000 to 0500 hours local time; 9.2 Cargo operations shall be permitted during period embracing 0000 to 0500 hours for two consecutive nights provided: 16

17 9.3 The minimum rest period before the start of such a series of duties is 24 hours. 9.4 The duty shall not exceed 8 hours. Comment and reason for amendment no. 9,9.1,9.2,9.3,&9.4 Maintenance Engineer to ensure adequate rest time. AMENDMENT NO. 9.5-ADD 9.5 At the finish of such a series of duties AIRCRAFT MAINTENANCE ENGINEER shall have a minimum of 54 hours free from all duties. Comment and reason for amendment no. 9.5 Maintenance Engineer to ensure adequate rest time. AMENDMENT NO. 9.6-ADD 9.6 There shall not be 4 such duties in any 7 consecutive days. Comment and reason for amendment no. 9.6 Maintenance Engineer to ensure adequate rest time. AMENDMENT NO.9.7-ADD 9.7 AIRCRAFT MAINTENANCE ENGINEER shall be free from all duties by 2100 hours local time before covering the block of consecutive night duties, such that they may take a rest period during a local night. Comment and reason for amendment no. 9.7 Maintenance Engineer to ensure adequate rest time. 17

18 10. RECORDS AMENDMENT NO. 10,10.1 thru ADD: 10.1 To enable the operator to ascertain that the fatigue management system is functioning, as intended and as approved, records shall be kept for 18 months of the duties performed and rest periods provided so as to facilitate inspection by the operator s authorized personnel and surveillance/audit by DGCA officers The operator shall ensure that these records include for each AIRCRAFT MAINTENANCE ENGINEER, at least: (a) the start, duration and end of each duty time; (b) the start, duration and end of each duty period; (c) rest periods; (d) flight time The operator shall also keep records of occasions when discretion was used by the AIRCRAFT MAINTENANCE ENGINEER to extend the prescribed limits If discretion was used for similar reasons on more than 20 percent of occasions when a particular route/ station or station/ route pattern is flown, then the operator shall review and change the schedule or the AIRCRAFT MAINTENANCE ENGINEER S scheduling arrangements so as to reduce the frequency at which such events occur In addition, DGCA may require submission of copies and analysis of records in the manner deemed fit AIRCRAFT MAINTENANCE ENGINEERS shall maintain a personal record of their daily flight time, duty period, flight duty period and rest periods Above may be achieved through a foolproof, transparent, computerised system, for which there will be an online system with a link for DGCA to monitor. The operator shall evolve a system so that only designated officers of the operator and DGCA have access to the system. Further, the system shall have provision of audit trail so that any change made in the data may be tracked down to its source The operator through the computerised system shall be able to ensure that AIRCRAFT MAINTENANCE ENGINEER is well within the duty time, duty period and rest period requirements before permitting him to perform the duties No operator shall keep such records only on paper. Any violation of this provision shall attract penalties as laid down in relevant law including action against persons. 18

19 10.10 Operator shall evolve a mechanism by which personal records maintained by individual AIRCRAFT MAINTENANCE ENGINEERS are reconciled with the operator s records from time to time. Comment and reason for amendment no. 10,10.1 thru Records are important to ensure effective compliance and monitoring of duty time limitations, therefore, it is imperative to specify maintenance of records for effective implementation, control and monitoring/ oversight by DGCA. Maintenance Engineer. 11. ULTRA LONG FLIGHTS 11.1 Definitions: AMENDMENT NO.11./ ADD (A) In-flight Rest Period means a period of time within a flying duty time, which is to give a Aircraft Maintenance Engineer an opportunity to rest before commencing or recommencing duty. (B) Rostered Duty Assignment (RDA) means a sequence of Duty Periods, off-duty periods, standby duty periods, positioning duties and rest periods for which an Aircraft Maintenance Engineer is rostered when assigned to operate a ULR flight Designated rest facilities shall be provided on board aircraft. These rest facilities shall comprise not less than two independent rest areas with horizontal bunks and shall provide an environment that is conducive to rest/sleep in cases if Aircraft Maintenance Engineer is to perform duty on arrival at destination airport. The rest facilities shall be subject to the prior approval of the DGCA ULR Pre-flight Rostering Requirements (a) The Aircraft Maintenance Engineer shall be acclimatised at base before undertaking a ULR RDA. Immediately prior to commencing the ULR RDA, the Aircraft Maintenance Engineer shall be rostered for a rest period of no less than 48 hours, which shall include two (2) local nights, free from duties ULR Flight Rest Period Away from Base (a) In the ULR RDA, the scheduled period free of flying duties away from base shall be at least 48 hours, with at least two (2) local nights. 19

20 Post ULR RDA Rest At Base Before Embarking on the Next Flight (a) The Aircraft Maintenance Engineer after an ULR flight shall be provided with four (4) consecutive local nights of rest free of duty on completion of the ULR RDA, before the Aircraft Maintenance Engineer may be rostered for another ULR flight or other flights. Comment and reason for amendment no. 10,10.1 thru Aircraft Maintenance Engineers are required to travel on ULR flights, often to perform maintenance immediately after the flight and mostly under AOG situations requiring maintenance on critical system or critical tasks. Therefore, adequate rest through proper resting facilities in flight must be ensured to minimise the fatigue before undertaking such tasks. Rest period after ULR flight and AOG handling is needed to ensure alertness while performing subsequent duties Maintenance Engineer. It is also suggested that DGCA should specify the requirements for duty time limitations of Aircraft Maintenance Engineers through CAR in near future Section 4A, 5A of Aircraft Act 1934 And under Rules 29D - Part III, Rule 133A - Part XII-A of The Aircraft Rules, 1937 and incorporate these amendments in the Draft CAR with following objectives. 1. To ensure implementation of effective system of duty time limitation for Aircraft Maintenance Engineers to enhance and contribute to the aviation safety. 2. To clarify the roles / responsibility of Aircraft Maintenance Engineer and operator under the oversight and monitoring of DGCA for effective implementation of duty time limitation. Further, we also take this opportunity to inform you that: 1. DGCA has mandated and prescribed age limit for flying crew for commercial operations, similar age limit of 60 years should also be imposed for certification of maintenance in case of scheduled airlines as AMEs are required to perform rigorous maintenance activity under challenging weather conditions. 2. DGCA has mandated in case flight crew and cabin crew for operating similar type of airplanes, AMEs maintenance certification must also be limited to two types of aircraft on any workday and exercising the privileges to three aircraft in case of large transport category aircraft/ scheduled airlines. 20

21 We request you to kindly review our comments / information and take suitable action in this regard. Yours Faithfully VIVEK SHINDE GENERAL SECREATARY For and On behalf of JET AIRCRAFT MAINTENANCE ENGINEERS WEFARE ASSOCIATION REGN. NO. : MAHARASHTRA STATE, MUMBAI 1270/19/2000GBDS REGISTERED ADDRESS: 17, AMINA MANJIL, JUHU TARA, MUMBAI MAHARASHTARA INDIA jamewa2000@yahoo.co.in -:END :- 21

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