First approval of materials.

Today, I received the pleasant news that Royal Brunei Airlines, has been granted permission to use the training materials for Understanding EASA FTL 2016 from the DCA Brunei Darussalam.

dca bn dca brunei

This is a significant achievement for my materials and should give confidence to the aviation community as to credibility of the materials being presented.

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EASA to expand FTL to other operations.

In a notice of proposed amendment, EASA would expand flight-time limitation (FTL) rules to cover air-taxi operations (ATXO); airplane and helicopter emergency medical service operations (AEMS and HEMS); and single-pilot operations for both scheduled and on-demand flights.

The proposed amendments are mainly expected to improve safety during night duties and where scientific principles to measure fatigue have not been used so far, as well as to ensure harmonization of requirements across the EU. All proposed amendments are fully aligned with ICAO standards and recommended practices, EASA said.

To a varying extent, current EASA FTL requirements apply to air taxis, single-pilot airplane operations and AEMs. An exception in this respect is the maximum daily flight duty period in single-pilot and AEMS since individual national rules apply. Also, HEMS flight and duty times vary considerably from state to state. Therefore, establishing EASA-mandated maximum daily flight duty periods for AEMS and FTL rules for HEMS constitutes a major element of this proposal.

Comments on the proposed rules must be submitted by Jan. 31, 2018. A decision on the proposal is expected to be made by next year’s third quarter.

New site format and added tools

In an effort to continue to improve the site usability for readers, I have aligned all the Family of FTL sites to use a more secure template.

An additional bonus is now the sites will have the capability to translate the pages using “Google Translate”.

While the materials will still be published and maintained in English, the new tool should aid users with a more limited use of English; by making the information more understandable.

Moving some print material

I have decided to move some of the training materials to Amazon.com.

In order to cover the costs of this site, users can now download the Understanding EASA FTL 2016 instructional document as a kindle readable document, or order a hard copy from Amazon.

/Garret

EASA issues Annex to Decision 2017/007/R

On 30-March-2017, the EASA issued Annex to Decision 2017/007/R.

The Annex includes the following Guidance Materials (GM):

GM1 ORO.FTL.105(1) Definitions (revised)

GM1 ORO.FTL.120 Fatigue risk management (FRM) (new)

GM1 ORO.FTL.120(b)(3) Fatigue risk management (FRM) (new)

GM2 CS FTL.1.235(b)(3) Additional rest to compensate for time zone differences (new)

I have updated the reference copy of the regulations.

The GM1 ORO.FTL.105(1) and GM2 CS FTL.1.235(b)(3) formalises the material presented by the EASA in the FAQ document from 31-Jul-2015, so no changes to the Understanding EASA FTL 2016 material will be required.

EASA combined FTL – 2017

Recurrent Extended Recovery Rest Period

The following question came in today, so I though I would share with everyone:

I have a question about recurrent extended recovery rest period. Minimum is one local day and two local nights. So the duty shall finish (not flight duty) latest 2200 local on day1 and start earliest on day3 at 0800 local time (actual reporting time). Total 36 hours of rest.

What if two local days off are assigned, when can be the earliest checkin on day4?
Assume FDP operates in the same time zone.

Thank you

The applicable regulation is:

ORO.FTL.235 Rest Periods

(d) Recurrent extended recovery rest periods (RERRP)

Flight time specification schemes shall specify recurrent extended recovery rest periods to compensate for cumulative fatigue. The minimum recurrent extended recovery rest period shall be 36 hours, including 2 local nights, and in any case the time between the end of one recurrent extended recovery rest period and the start of the next extended recovery rest period shall not be more than 168 hours. The recurrent extended recovery rest period shall be increased to 2 local days twice every month.

Since it is defined as a rest period it must meet the conditions of a rest:

ORO.FTL.105 Definitions

(16) “local night (LNR)” means a period of 8 hours falling between 22:00 and 08:00 local time;

(21) “rest period” means a continuous, uninterrupted and defined period of time, following duty or prior to duty, during which a crew member is free of all duties, standby and reserve;

So a rest period must be known in advance, and completely free of duty for the continuous period of time. Since it it a singular rest period no duty may intervene during the start and end of that period.

For a RERRP to exist it must meet certain conditions:

1. it is a single defined period of rest

2. it is no less than 36:00 in duration and it contains two LNR’s.

A LNR may start no later than 24:00, and it may end No earlier than 06:00.

To satisfy condition 1 look at the start time of your RERRP and add 36:00,

a RERRP starting at 18:00 (day 1) + 36:00 = 54:00 (06:00 day 3)

a RERRP starting at 20:00 (day 1) + 36:00 = 56:00 (08:00 day 3),

a RERRP starting at 22:00 (day 1) + 36:00 = 58:00 (10:00 day 3)

a RERRP starting at 23:59 (day 1) + 36:00 = 59:59 (11:59 day 3)

To satisfy the second condition you must have two LNR’s,
To have a LNR, it must contain 8:00 continuous rest.
A LNR that starts at 21:00 must not end earlier 06:00, since a LNR cannot start earlier than 22:00 we add 8:00 22:00 + 8:00 = 30:00 (06:00 the next day), a LNR may start after 22:00 but no later than 24:00, so a LNR that starts at 23:00 + 8:00 = 31:00 (07:00 next day), and a LNR that starts at 24:00 + 8:00 = (32:00 (08:00) the next day.

The second of the LNR in a RERRP would be expected to start no later than 22:00, so it must always include the time and end no earlier than 06:00 day 3.

Knowing the start time of your RERRP you must find the difference from 06:00 day 3 – so a RERRP that starts at 16:00 day 1 to 06:00 day 3 is 38:00, which is greater than 36:00 so the cm must be off for at least 38:00.

The easiest way to figure this out is if your RERRP starts before 18:00, the minimum rest = (18:00 – RERRP start) + 36:00.
So a RERRP that starts at 02:30 is (18:00 – 02:30) + 36:00 = 15:30 + 36:00 = 51:30

If your RERRP starts at 18:00 up to 24:00, it is just 36:00.

Lastly, the RERRP must be extended to included two full local days off, 2 times per month, meaning a 48:00 period starting at midnight and ending no earlier than midnight 48:00 later, So a RERRP starting at 23:00 must be no less than 49:00, and a RERRP starting at 22:00 must be no less than 50:00, to satisfy this condition.

A RERRP starting at 23:00 day 1 and ending at 03:00 day 4 for a duration of 52:00 is legal.

Here is a small excel spread sheet you can use.
RERRP.xlsx

The first year of EASA FTLs

The first year of EASA FTLs

28 February 2017

Simon Roberts
Scheduling Specialist
Copyright BALPA 2017
Aside from speaking to pilots from across the industry about their experiences flying under the new EASA Flight Time Limitations, we’ve also looked at what key issues have been raised with the BALPA Scheduling Team since the new rules became mandatory in February last year.

The 18-hour rule

Early last year, we were made aware by a number of Company Councils that the rule designed to avoid an individual being awake for more than 18 hours when a standby and FDP were combined was not working [CS FTL.1.225 (b) (2)]. We were led to believe that some operators saw the rule as ‘soft’ so decided not to adhere to it. The CAA were contacted, and confirmed our view that it was NOT a ‘soft’ rule, and that operators needed to create procedures to ensure that the 18-hour rule could not be broken. The regulator went on to highlight the fact that each UK operator will have included procedures in this area when they submitted their new EASA FTL documentation for ratification, so the processes should still be relatively fresh in their minds.

We have also observed that some operators have seemingly been better than others at designing and implementing processes that do not lead to more than 18 hours awake. As an example, we have noticed a trend towards utilising a single standby to cover both the early and late-wave departures. The standby allocated on its own is unlikely to cause any significant problems until such a time when a late duty is assigned from an early standby, at which point the 18 hours could rapidly be approaching. Disappointingly, we have been made aware of this happening on a far too frequent basis over the summer, which means we will need to continue to push for the pressure testing of frequent offenders’ procedures by the regulator.

Transition between late (night) and early duties

During the summer, one BALPA Company Council reported an issue that seemed to show their operator endeavouring to redefine the ‘early start’ definition which is a hard law, implementing rule.

Rosters were being planned with no local nights rest between FDPs that transitioned from a night duty – a duty that encroaches any period between the hours of 02:00 – 04:59, and an early start duty which starts between the hours 05:00 – 06:59. This is a requirement under rule CS FTL.1.235 (a) (1).

In effect, the operator had extended the early start definition by including a period of time prior to 05:00 which essentially made a night duty a ‘deep early start’ thereby avoiding the need (in the operator’s opinion) for a local nights rest. This was raised with the regulator who agreed with BALPA that the practice was not in line with the EASA FTL rules or the operator’s own FTL scheme. The operator swiftly stopped the practice and are now assessing their commercial plan for summer 2018.

Commander’s discretion

Under the EASA FTL rules, commander’s discretion should only be used in exceptional circumstances when unforeseen circumstances ‘start at or after the reporting time’. However, we were made aware through the summer period that some operators were ignoring these words and delivering a request for the use of commander’s discretion to the pilot at report time.

Rule clarity was sought from the CAA who stated that a crew member should not be arriving for a duty to find the operator requesting the use of discretion at report time; and that if a significant delay was known about in advance, the operator should consider delaying the crew member at home.

Whilst the regulator clarified the intent of this section of the rule, we are now seeing pressure being exerted on the ICAO definition of ‘unforeseen circumstances’. As far as we are concerned, there seems to be little reason for an operator to do this other than to seek additional flexibility from their crews. We have highlighted this to the regulator and will continue to monitor closely.

All of these three issues above came about during the first full summer of EASA FTLs, but we expect further pressure to be placed on the prescriptive rules in the future, so if you see something that doesn’t seem right or you feel is pushing the intent of the rules, BALPA members can raise any issue with your Company Council pilot reps or liaise with your Scheduling Team at BALPA House

Tail End Ferry Flights

The following question came in yesterday, and I felt it would be helpful to all if I shared my response.

You asked the following question:
Do you have any link to regulation for considering Ferry flights as FDP when ending a series of flights?

ORO.FTL.105 provides the following definitions:

(12) “flight duty period (FDP)” means a period that commences when a crew member is required to report for duty, which includes a sector or a series of sectors, and finishes when the aircraft finally comes to rest and the engines are shut down, at the end of the last sector on which the crew member acts as an operating crew member;

(17) “operating crew member (OCM)” means a crew member carrying out duties in an aircraft during a sector;

(18) “positioning” means the transferring of a non-operating crew member from one place to another, at the behest of the operator, excluding:

(i) the time of travel from a private place of rest to the designated reporting place at home base and vice versa, and
(ii) the time for local transfer from a place of rest to the commencement of duty and vice versa;

(24) “sector” means the segment of an FDP between an aircraft first moving for the purpose of taking off until it comes to rest after landing on the designated parking position;

My interpretation:

There is no distinction between “Ferry Flight” and “Commercial Operation”, for the aircraft to have flown, the Flight Crew Member (FCM) is considered an OCM, as per definition (17), thus the ferry flight is considered to be part of the FDP.

With respect to Cabin Crew Members (CCM), those individuals could be considered to be positioning/non-operating crew members, Dependant upon company policies as documented and approved, If the CCM is responsible for performing duties pertinent to the safety of individuals onboard
eg. evacuation protocols, I would imagine that such a CCM would also be considered an OCM, and the ferry flight would be considered to be part of the FDP.

Reference info from the EASA:

The EASA issued a document with FAQ’s in July 2015. (see page 14 of attached document).

Question 1:
How should ferry flights performed by crew members of a given operator be accounted for? DP or FDP?

  • Case 1: CAT flight then ferry flight
  • Case 2: Ferry flight then CAT flight.

Response 1:
Annex I to Reg. 965/2012 does not define ‘ferry flight’. Crew members performing any activity within the scope of the BR (as opposed to private flying for leisure/fun) are subject to Subpart FTL when they conduct activities within the scope of an AOC.

Question 2:
Complementary question: when a ferry flight counts as FDP, does it count as a sector?

Response 2:
Crew members performing any activity within the scope of the BR (as opposed to private flying for leisure/fun) are subject to Subpart FTL when they conduct activities within the scope of an AOC. If a ‘ferry flight’ is conducted within the scope of an AOC, it counts as FDP and sector.

FAQ_FTL 2015

Acclimatisation Under EASA FTL

I have prepared a presentation regarding acclimatisation under EASA FTL.

EASA FTL 2016 Module 6 V1.1 (Acclimatisation Examples)

EASA_FTL_2016_Module_6_V1.1 (PDF version)

Acclimatisation with practical examples (Link to full page)

Within are many examples  following the processes detailed in the FAQ document from the EASA from 31-July-2015.

 

ORO.FTL Operator Responsibilities

I have prepared an example of ORO.FTL Operator responsibilities.

The examples illustrate some of the concepts an operator may consider necessary for their operation. Not all examples have been considered, and not all examples will apply to all operations.

Example ORO.FTL Operator Responsibilities