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| ORO.FTL.200 | ORO.FTL.210 |
(1) define reporting times appropriate to each individual operation taking into account ORO.FTL.110(c);
GM1 ORO.FTL.205(a)(1) Flight Duty Period (FDP)
(2) establish procedures specifying how the commander shall, in case of special circumstances which could lead to severe fatigue, and after consultation with the crew members concerned, reduce the actual FDP and/or increase the rest period in order to eliminate any detrimental effect on flight safety.
(b) Basic maximum daily FDP.
(1) The maximum daily FDP without the use of extensions for acclimatised crew members shall be in accordance with the following table:
Table 2 Maximum daily FDP – Acclimatised crew members
|
Start of FDP at reference time |
Sectors |
||||||||
|
1 – 2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
|
|
06:00 – 13:29 |
13:00 |
12:30 |
12:00 |
11:30 |
11:00 |
10:30 |
10:00 |
9:30 |
9:00 |
|
13:30 – 13:59 |
12:45 |
12:15 |
11:45 |
11:15 |
10:45 |
10:15 |
9:45 |
9:15 |
9:00 |
|
14:00 – 14:29 |
12:30 |
12:00 |
11:30 |
11:00 |
10:30 |
10:00 |
9:30 |
9:00 |
9:00 |
|
14:30 – 14:59 |
12:15 |
11:45 |
11:15 |
10:45 |
10:15 |
9:45 |
9:15 |
9:00 |
9:00 |
|
15:00 – 15:29 |
12:00 |
11:30 |
11:00 |
10:30 |
10:00 |
9:30 |
9:00 |
9:00 |
9:00 |
|
15:30 – 15:59 |
11:45 |
11:15 |
10:45 |
10:15 |
9:45 |
9:15 |
9:00 |
9:00 |
9:00 |
|
16:00 – 16:29 |
11:30 |
11:00 |
10:30 |
10:00 |
9:30 |
9:00 |
9:00 |
9:00 |
9:00 |
|
16:30 – 16:59 |
11:15 |
10:45 |
10:15 |
9:45 |
9:15 |
9:00 |
9:00 |
9:00 |
9:00 |
|
17:00 – 04:59 |
11:00 |
10:30 |
10:00 |
9:30 |
9:00 |
9:00 |
9:00 |
9:00 |
9:00 |
|
05:00 – 05:14 |
12:00 |
11:30 |
11:00 |
10:30 |
10:00 |
9:30 |
9:00 |
9:00 |
9:00 |
|
05:15 – 05:29 |
12:15 |
11:45 |
11:15 |
10:45 |
10:15 |
9:45 |
9:15 |
9:00 |
9:00 |
|
05:30 – 05:44 |
12:30 |
12:00 |
11:30 |
11:00 |
10:30 |
10:00 |
9:30 |
9:00 |
9:00 |
|
05:45 – 05:59 |
12:45 |
12:15 |
11:45 |
11:15 |
10:45 |
10:15 |
9:45 |
9:15 |
9:00 |
(2) The maximum daily FDP when crew members are in an unknown state of acclimatisation shall be in accordance with the following table:
Table 3 Crew members in an unknown state of acclimatisation
|
Maximum Daily FDP according to number of Sectors |
||||||||
|
1 – 2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
|
11:00 |
10:30 |
10:00 |
9:30 |
9:00 |
9:00 |
9:00 |
Not Allowed |
|
(3) The maximum daily FDP when crew members are in an unknown state of acclimatisation and the operator has implemented a FRM, shall be in accordance with the following table:
Table 4 Crew members in an unknown state of acclimatisation under FRM
|
Maximum Daily FDP according to number of Sectors |
||||||||
|
1 – 2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
|
12:00 |
11:30 |
11:00 |
10:30 |
10:00 |
9:30 |
9:00 |
Not Allowed |
|
(c) FDP with different reporting time for flight crew and cabin crew.
Whenever cabin crew requires more time than the flight crew for their pre-flight briefing for the same sector or series of sectors, the FDP of the cabin crew may be extended by the difference in reporting time between the cabin crew and the flight crew. The difference shall not exceed 1 hour. The maximum daily FDP for cabin crew shall be based on the time at which the flight crew report for their FDP, but the FDP shall start at the reporting time of the cabin crew.
(d) Maximum daily FDP for acclimatised crew members with the use of extensions without in-flight rest.
(1) The maximum daily FDP may be extended by up to 1 hour not more than twice in any 7 consecutive days. In that case:
(i) the minimum pre-flight and post-flight rest periods shall be increased by 2 hours; or
(ii) the post-flight rest period shall be increased by 4 hours.
(2) When extensions are used for consecutive FDPs, the additional pre- and post- flight rest between the two extended FDPs required under subparagraph 1 shall be provided consecutively.
(3) The use of the extension shall be planned in advance, and shall be limited to a maximum of:
(i) 5 sectors when the WOCL is not encroached; or
(ii) 4 sectors, when the WOCL is encroached by 2 hours or less; or
(iii) 2 sectors, when the WOCL is encroached by more than 2 hours.
(4) Extension of the maximum basic daily FDP without in-flight rest shall not be combined with extensions due to in-flight rest or split duty in the same duty period.
(5) Flight time specification schemes shall specify the limits for extensions of the maximum basic daily FDP in accordance with the certification specifications applicable to the type of operation, taking into account:
(i) the number of sectors flown; and
(ii) WOCL encroachment.
(e) Maximum daily FDP with the use of extensions due to in-flight rest
Flight time specification schemes shall specify the conditions for extensions of the maximum basic daily FDP with in-flight rest in accordance with the certification specifications applicable to the type of operation, taking into account:
(i) the number of sectors flown;
(ii) the minimum in-flight rest allocated to each crew member;
(iii) the type of in-flight rest facilities; and
(iv) the augmentation of the basic flight crew.
(f) Unforeseen circumstances in flight operations — commander’s discretion
AMC1 ORO.FTL.205(f) Flight Duty Period (FDP)
(1) The conditions to modify the limits on flight duty, duty and rest periods by the commander in the case of unforeseen circumstances in flight operations, which start at or after the reporting time, shall comply with the following:
(i) the maximum daily FDP which results after applying points (b) and (e) of point ORO.FTL.205 or point ORO.FTL.220 may not be increased by more than 2 hours unless the flight crew has been augmented, in which case the maximum flight duty period may be increased by not more than 3 hours;
GM1 ORO.FTL.205(f)(1)(i) Flight Duty Period (FDP)
(ii) if on the final sector within an FDP the allowed increase is exceeded because of unforeseen circumstances after take-off, the flight may continue to the planned destination or alternate aerodrome; and
(iii) the rest period following the FDP may be reduced but can never be less than 10 hours.
(2) In case of unforeseen circumstances which could lead to severe fatigue, the commander shall reduce the actual flight duty period and/or increase the rest period in order to eliminate any detrimental effect on flight safety.
(3) The commander shall consult all crew members on their alertness levels before deciding the modifications under subparagraphs 1 and 2.
(4) The commander shall submit a report to the operator when an FDP is increased or a rest period is reduced at his or her discretion.
(5) Where the increase of an FDP or reduction of a rest period exceeds 1 hour, a copy of the report, to which the operator shall add its comments, shall be sent by the operator to the competent authority not later than 28 days after the event.
(6) The operator shall implement a non-punitive process for the use of the discretion described under this provision and shall describe it in the operations manual.
(g) Unforeseen circumstances in flight operations — delayed reporting
The operator shall establish procedures, in the operations manual, for delayed reporting in the event of unforeseen circumstances, in accordance with the certification specifications applicable to the type of operation.
Understanding EASA ORO.FTL 2016 
Hi, can you help me to understand if the traveling time between the place of rest (layover) is more than 30 minutes, when should the FDP start to be counted? In my airline the traveling time does not count for the FDP but only for the rest period.
Thanks very much
Alessandra
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Travel time To/From place of rest is not part of the FDP.
FDP starts at Report and ends upon the arrival of the last operating flight in the duty period.
Duty ends when the crew member is released into a rest period.
Travel time must be applied to ensure that the crew member will receive an 8 hour uninterrupted sleep opportunity.
AMC1 ORO.FTL.235(b) Rest Periods
MINIMUM REST PERIOD AWAY FROM HOME BASE
The time allowed for physiological needs should be 1 hour. Consequently, if the travelling time to the suitable accommodation is more than 30 minutes, the operator should increase the rest period by twice the amount of difference of travelling time above 30 minutes.
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Hi,
My airline is actually scheduling this rotation BCN-SDQ-LPA, 12CCM and 4FCM, more than 4-hour time difference and Class1 rest facility. We do not have our FRMS approved yet. Is it allowed to do such a rotation ? Thank you for your help.
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Hi,
Just a simple confirmation and clarification required,
If the operator planned an extention to ORO-FTL205(b) by inflight rest (d) can in unforeseen circumstances the commander uses discretion (f)
For example :
One sector non acclimatized state FRM
12 hours granted FDP
1:30 added in flight rest = total 13,30 min
Can commander discretion be applied to achieve 15hrs 30 min adding 2 hrs discretion?
Thank you for your support in advance
Regards
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My company contacted me at 2 pm to cancel my duty for the next day at 7pm and reschedule my roster with a stand-by starting at 6 am. Are they allowed to do that? With a so short time in advance?
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Hi
I’m not able to find any limits to single or daily duty period other than it shouldn’t exceed 60 hrs in 7 consecutive days. Would you know how much is the maximum for single DP or there is no limit. If that so than I can do positioning 60 hrs?
Thank you in advance
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You asked the following:
I’m not able to find any limits to single or daily duty period other than it shouldn’t exceed 60 hrs in 7 consecutive days. Would you know how much is the maximum for single DP or there is no limit. If that so than I can do positioning 60 hrs?
Your observation is correct, ORO.FTL does not specify any daily duty limits, ORO.FTL.205 requires the operators to establish in the certification scheme FDP limits. In all practically a crew member will not realistically be positioning over a 60 hour period, most likely some intervening rest periods will be provided.
Part of that is that under AMC1 ORO.FTL.110 Provides the following guidance:
(b) Schedules should allow for flights to be completed within the maximum permitted flight duty period
and flight rosters should take into account the time needed for pre- flight duties, taxiing, the flight and
turnaround times. Other factors to be considered when planning duty periods should include:
(1) the allocation of work patterns which avoid undesirable practices such as alternating day/night
duties, alternating eastward-westward or westward-eastward time zone transitions, positioning
of crew members so that a serious disruption of established sleep/work patterns occurs;
I believe you should review your operations manual and engage in a discussion with airline over this matter.
/Garret
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Garret,
A question regarding FDP with different reporting time for flight crew and cabin crew. Would it be OK to extend with the difference in reporting time even if cabin crew have a short positioning directly before the flight and the pilots do not? The rule says “same sector or sectors” and positioning before an FDP is not counted as a sector. So cabin crew and pilots are reporting for the same sector even if reporting at different bases. Still off course with maximum 1 hour difference in reporting time. Guess that he intention of the rule must be to limit the allowed extension and not where the duty starts. Is that in line with your understanding of the rule?
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Hi, you asked the Following:
A question regarding FDP with different reporting time for flight crew and cabin crew. Would it be OK to extend with the difference in reporting time even if cabin crew have a short positioning directly before the flight and the pilots do not? The rule says “same sector or sectors” and positioning before an FDP is not counted as a sector. So cabin crew and pilots are reporting for the same sector even if reporting at different bases. Still off course with maximum 1 hour difference in reporting time. Guess that he intention of the rule must be to limit the allowed extension and not where the duty starts. Is that in line with your understanding of the rule?
The specific provision you are discussing is ORO.FTL.205(c):
(c) FDP with different reporting time for flight crew and cabin crew.
Whenever cabin crew requires more time than the flight crew for their pre-flight briefing for the same sector or series of sectors, the FDP of the cabin crew may be extended by the difference in reporting time between the cabin crew and the flight crew. The difference shall not exceed 1 hour. The maximum daily FDP for cabin crew shall be based on the time at which the flight crew report for their FDP, but the FDP shall start at the reporting time of the cabin crew.
First off, it is very clear that FDP begins at the reporting time of the cabin crew.
I believe that the original intent of this rule was for when both flight and cabin crew report at the same location, but at different times.
For the calculation of the Basic FDP limit (Table 2) the Start of the FDP reference time is the report time of the flight crew member.
In the case when the cabin crew is required to report 1:15 before departure and the flight crew is required to report 1:00 before departure;
the FDP limit from Table 2 may be increased by 0:15. Using this process the most that the FDP limit may be increased is 1:00 as this also stipulated in the regulation.
When the difference in report time exceeds 1:00 or when the crew member reports at a different location, the entry into Table 2 will be to use the report time of the cabin crew member.
In either case, the derived limit from Table 2 is compared to the actual FDP calculated from the actual time of report.
Like wise, the required rest period required after a duty period as required in ORO.FTL.235 is based upon the actual time on duty from actual start of duty to the actual end of duty.
In the case you are presenting, let’s say a cabin crew member reports at 08:00 (0:30) before the start of a DHD flight (08:30) with a total duration of 0:45 (09:15) followed by a flight which commences 0:30 after arrival of the DHD (09:45), total time of 1:45. the flight crew is required to report at 08:45 (1:00) before the start of the flight. The difference in report time is 0:45, thus using the difference report time provisions, your contention is that the FDP limit may be extended by 0:45 … that is a possibility provided that the local CAA agrees. However in all cases where the difference report time exceeds 1:00, the actual report time for the cabin crew must be used.
I know my interpretation may be a bit conservative, so, please discuss with your Airline, Union and the local CAA, as they may have better guidance than I am providing.
/Garret
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HI, in a 2 sectors lh rotation do you think is it possible for a company to add a pilot after the first sector in order to extend fdp for the whole crew? Thanks for the answer
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No, The entire crew must be augmented for the entire FDP.
The requirements to extend an FDP due to in-flight rest are established in ORO.FTL.205(e).
These are further clarified in CS FTL.1.205(c)(2) which gives the maximum duration of extended FDPs with an
augmented crew.
The maximum duration of the FDP is established for the entire flight crew, not for individual crew members.
The crew is considered a unit for the calculation of the maximum FDP.
By having different individual flight crew members reporting at different times, those crew members are not acting as a unit and will have different FDP limitations, due to different FDP start times.
EASA answered a similar question in EASA FTL – FAQ July 2015 (see page 13).
/Garret
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Thanks, but I meant in case of 3 pilots joined by the 4th after the first sector max fdp for the entire crew is going to be 16 or 19 hrs? Thanks for tour reply
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Should the FDP start with 3 FCM’s and end with 4 FCM’s, the limitations is for 3 FCM’s (16:00 for class 1 facilities, 15:00 with class 2, 14:00 with class 3).
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Thanks as usual,but if true in this example:” A.flight starts from A with pilot 1 and pilot 2 to B ( 1:30 hr sector ). Arriving in B a third pilot join the crew and they fly to C ( 11 hr sector). The lenght of the flight from B to C allows all the pilots to have enough rest during cruise phase. In this example, extension of the fdp due to inflight rest is possible or not?
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Hi ,
lets say that a crew lands at 19:45 out of base and the hotel transfer is at 20:00. The crew misses the 20:00 transfer (15 min post flight duty’s plus 15 min to the bus stop. Keep in mind that the operator expects from the crew to take the hotel transfer bus that departs every hour on the hour for all the hotel customers no arrangement for the crew) The crew arrives at the hotel at 21:30 but the rostering ends the duty at 20:30 even thought the crew is out of base and waits for the transfer. When the duty stops ?
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Rostering is correct – Duty ends at 20:30 . Rest begins at 20:30.
The rest period that begins at 20:30 must be no less than 10:00, thus the next Duty period may not begin any earlier than 06:30 (next day).
Within that duty period, the CM must also be provided an 8:00 sleep period.
The sleep opportunity (SO) must consider all travel time to/from the airport and time for physiological needs (PN).
Generally PN is at least 1:00.
The travel time from the airport TVA is 1:00 = (21:30 – 20:30)
The travel time from hotel to Airport (TVH) is 0:45= (7:15- 6:30)
I assume that the shuttle leaves on every 0:30 of the hour to the airport, bus is 0:30 wih an additional 0:15 to get to the designated report location.
If we add up SO + PN + TVA + TVH this will provide the rest period provided (RPP), 8:00 + 1:00 + 1:00 + 0:45 = 10:45
With 10:45, the CM has met the minimum 10:00.
ORO.FTL.235
(b) Minimum rest period away from home base.
The minimum rest period provided before undertaking an FDP starting away from home base shall be at least as long as the preceding duty period, or 10 hours, whichever is greater. This period shall include an 8-hour sleep opportunity in addition to the time for travelling and physiological needs.
Things get very complicated with such a rigid hotel shuttle schedule.
I hope this helps.
/Garret
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As you said if we add SO+PN+TVA+TVH =10:45 so the earliest the crew must depart from the hotel is 07:15 and no 06:30 correct?
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Ok you are right duty starts at 06:30 the TVH is duty. Thank you for your help
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Good, you got it.
Rest is from end of duty to start of the next duty (20:30 to 07:15)
ORO.FTL.105
(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;
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Another question to complete the previous topic. Let’s assume that take off time is at 07:30 with one hour before reporting time according to the company’s regulation the hotel bus is living every 0:30 of the hour that means at 05:30 is this ok or not ?
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Correct,
The time from Release to Report is 10:00 (Actual Rest (AR)), which may seem fine, but we can determine whether 8:00 of SO has been provided.
With TVA of 0:45 a hotel pickup at 5:30 will get you to the gate at 6:15, thereby you have a 0:15 wait time (WT) at the airport until 6:30.
AR – (PN + TVA + TVH + WT) will yield Actual SO (ASO), 10:00 – (1:00 + 1:00 + 0:45 + 0:15) = 10:00 – 3:00 = 7:00, so the ASO is less than 8:00 which fails the Rest Requirement.
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The airline scheduled a two day home WBT PBN training . This count as duty ? and is it necessary to be published in the monthly roster?
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I have the following question and I can’t seem to find an answer anywhere..
What happens when there is a scheduled admin or training duty before a flight duty??
For example: The PIC of a flight has admin duties at 08:00 and a flight at 12:00.
The basic maximum duty period shall be calculated based on the reporting time for the flight at the airport or on the time he starts his admin duties?
I realize that if he is allowed to work 12 hours the countdown will begin at the start of the admin, but I am confused whether I should calculate the basic allowed fdp from the admin time or from the reporting time.
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Hi Garret,
A question regarding extended flights ORO.FTL 205 (d)(1). The maximum daily FDP may be extended by up to 1 hour not more than twice in any 7 consecutive days.
Do the number of extended flights count from reporting time of first exteded flight to reporting time for next extended flight? Or does any part of the extended FDP count if within the seven days? And the seven days is a rolling 168 hour period (hour by hour) or is it seven fixed 24 hour periods (midnight to midnight)?
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This provisions ORO.FTL.205(d) and CS FTL.205(b) deals with a planned extension of the FDP.
The rule is applied to a FDP that operates with an un-augmented crew and the FDP does not operate under ORO.FTL.220 split duty.
The look back is for 7 calendar days (base time) using a fixed 24:00 period midnight to midnight, and is based upon the report time for the FDP being evaluated.
So a FDP that starts at 10:00 Time will need too look back 154:00 ( midnight day 1 to 10:00 day 7 ).
Any FDP that ENDS within that time frame that has been extended above the scheduled limitation is included in the count.
If the count of the previously extended FDPs is two or more, a planned extension is not permitted.
/Garret
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Hi, my operator claims that Commander’s discretion is available for use for issues not known at the point of report for the entire rotation i.e. in the case of a six day trip, they can knowingly send an aircraft down route without class 1 rest facilities, requiring discretion to be used for the sector but because they’ve only known about the issue after report on day one, it’s permissible…. is this correct as it seems an abuse of the intent of the legislation?
Thanks.
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You asked the following:
Hi, my operator claims that Commander’s discretion is available for use for issues not known at the point of report for the entire rotation i.e. in the case of a six day trip, they can knowingly send an aircraft down route without class 1 rest facilities, requiring discretion to be used for the sector but because they’ve only known about the issue after report on day one, it’s permissible…. is this correct as it seems an abuse of the intent of the legislation?
Commander’s Discretion, may be applied at anytime during the operation of a rotation.
While ORO.FTL contains no specific definition of Unforeseen Operational Circumstance; ICAO (ICAO – ANNEX 6 — PART I ATT A-1) has supplied the following:
Unforeseen Operational Circumstances are events that could not reasonably have been predicted and accommodated, such as adverse weather, equipment malfunction or air traffic delay, which may result in necessary on-the-day operational adjustments.
Further, AMC1 ORO.FTL.205(f); provides that “as general guidance when developing a commander’s discretion policy”.
If I interpret the AMC properly, the Operations Manual should contain such guidance/policy statements for the proper application of commander’s discretion.
If we look at your specific question; an aircraft assigned to operate without an operating class 1 facility to a FDP that requires inflight rest using a class 1 facility, before report; seems to not fit squarely as an Unforeseen Operational Circumstance, as the operator should have had sufficient time to correct the problem.
The operator should have other options:
Assign an aircraft with a working class 1 facility
Modify the flight to operate under the scheduled limits that will not require a class 1
Delay the flight to correct the problem
Cancel the flight
My suggestion is to review the “commander’s discretion policy” and then ask questions to your supervisors at the airline.
/Garret
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I have a question. There’s a table (7.1F and G /page 07.1/12) which states the extensions of FDP with in-flight rest. However, this table doesn’t state if the crew are acclimatized or not. It says only “(b) Extension of FDP with in-flight rest:”
The previous chart (7.1 E page 07.01/9) clearly states “(a) Maximum daily FDP for acclimatized crewmembers with the use of extensions without in-flight rest shall be:”
All this having in mind that on page 07.1/9 it clearly states that the maximum daily FDP in an unknown state (let’s say 1-2 sectors) is of 11:00.
I believe this is an important issue, as acclimatization is an important matter in aviation. It should be clear whether the same table and respective flight extensions should be used or not for both acclimatized and unknown state of acclimatization crewmembers.
Thanks in advance for your feedback
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Pedro,
I believe that extension of a FDP without the use of in-flight rest is not permitted when the crew member is in an unknown state of acclimiatisation.
The main rule is fount in ORO.FTL.205(d):
(d) Maximum daily FDP for acclimatised crew members with the use of extensions without in-flight rest.
(1) The maximum daily FDP may be extended by up to 1 hour not more than twice in any 7 consecutive days. In that case:
(i) the minimum pre-flight and post-flight rest periods shall be increased by 2 hours; or
(ii) the post-flight rest period shall be increased by 4 hours.
(2) When extensions are used for consecutive FDPs, the additional pre- and post- flight rest between the two extended FDPs required under subparagraph 1 shall be provided consecutively.
(3) The use of the extension shall be planned in advance, and shall be limited to a maximum of:
(i) 5 sectors when the WOCL is not encroached; or
(ii) 4 sectors, when the WOCL is encroached by 2 hours or less; or
(iii) 2 sectors, when the WOCL is encroached by more than 2 hours.
(4) Extension of the maximum basic daily FDP without in-flight rest shall not be combined with extensions due to in-flight rest or split duty in the same duty period.
(5) Flight time specification schemes shall specify the limits for extensions of the maximum basic daily FDP in accordance with the certification specifications applicable to the type of operation, taking into account:
(i) the number of sectors flown; and
(ii) WOCL encroachment.
When a crew member is in an unknown state of acclimatisation, the WOCL cannot be determined, so the ENTIRE FDP is assumed to operate during the WOCL.
Under ORO.FTL.205(d)(3)(iii) the limit for 1-2 sector FDP is a maximum of 2:00 encroachment upon the WOCL.
You should also review ORO.FTL.105 Definitions, (1) Acclimatisation.
A crew member is considered to be acclimatised for the first 48:00 to the location where they were last acclimated to.
/Garret
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Hi there, I have a question about delaying a report time for a crew called out of SBY and how this applies regarding the allowable FDP: crew on SBY from 07:00LT is called out to report at 10:30LT and operate a 4-sectors pairing; allowable FDP = 12:00HS. Shortly after, crew is contacted again and assigned a new reporting time at 13:30LT. By definition, a SBY ceases at time of reporting time so this crew had a total SBY time of 6:30HS (07:00 – 13:30). Please confirm that it´s correct to deduct 30min from the allowable FDP, e.g: 12:00HS – 0:30HS = 11:30HS.
Many thanks!
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Hello
On the surface I believe that your interpretation is correct.
First off, I assume the the FDP is not extended by in-flight rest or split-duty.
A 4 sector FDP starting at 10:30LT is permitted to be scheduled for 12:00 FDP,
thus requiring a scheduled of the last operation sector at 22:30 LT of FDP start.
While 4 sector FDP starting at 13:30LT is permitted to be scheduled for 11:45 FDP,
thus requiring a scheduled of the last operation sector at 01:15 (next day) LT of FDP start.
The FDP Delay provisions in CS FTL.1.205(e)(iii) state that the with delays of less than 4:00:
the original FDP limit (12:00) may be applied using the Revised FDP start time (13:30LT);
thereby, the FDP must be expected to be completed at 01:30 (next day) LT of FDP start.
You are correct that time on SBY ends at time of report (13:30 LT) CS FT.1.225(b)(5),
and that the FDP is reduced by the amount of time that the CM is on SBY above 6:00 (0:30) CS FT.1.225(b)(5);
thus the FDP limit is 11:30 (12:00 – 0:30); requiring that the FDP must be scheduled to be completed by 01:00 (next day) LT of FDP start.
Another aspect you need to keep in mind is the 18:00 awake (CS FTL.1.225(b)(2));
this is normally interpreted as a hard time limit, so if the CM begins the SBY at 07:00 LT (awake),
they must end the FDP by 01:00 (next day) LT SBY start scheduled or extended due to unforeseen delays after report.
/Garret
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Hi
A question regarding ORO 205.
(d) Maximum daily FDP for acclimatised crew members with the use of extensions without in-flight rest.
(3) The use of the extension shall be planned, and shall be limited to a maximum of:………………
How is it possible to call a Standby CM to an extension duty, when it shall be planned? (Either on Airport Standby or other then Airport Standby). Specially in context of EASA FAQ 47593.
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A FDP Extended without in-flight rest or split duty may be extended in accordance to ORO.FTL.205(d) and CS FTL.1.205(b), so the limits under
ORO.FTL.205(b) maybe planned to be extended up to 1:00.
A FDP that begins at 09:00 with 2 sectors has a normal limit of 13:00, thus a planned FDP of 13:30 may apply this rule.
I believe you need to look at this coming from the perspective of a CM assigned to Other Standby (OSB) first.
For example:
A CM is assigned to a OSB that begins at 06:00. The maximum duration a CM may be assigned to a OSB and FDP is 18:00 CS FTL.1.225(b)(2). So a CM further assigned to a FDP must be scheduled to end the FDP by 24:00 = 6:00 + 18:00.
With OSB, FDP begins when a CM reports for the FDP. so if a CM is notified at 06:30 to report at 09:00 for an Extended FDP with 2 sectors, the FDP is scheduled to end no later than 23:00 = 09:00 + 14:00.
If we look at an Airport Standby (ASB). FDP begins when a CM starts the ASB. The nature of ASB is to have the CM already in place and available to work a FDP. a CM may begin an ASB at 08:30 and be assigned to the 13:30 FDP that begins at 09:00. The Total ASB & FDP is 14:00 which is in compliance with CS FTL.1.205(b).
So planning Extended FDP upto the maximum limits is not recommended and it would be better to plan using some buffer especially when there is a high probability of the need to utilize ASB crew members. (My opinion).
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Hi, i have an inquiry regarding whether to apply discretion or not in below case:
SCHEDULED/PLANNED BLOCK HOURS ARE 09:01 HRS WITH 3 PILOTS WITH IN-FLIGHT REST CLASS 1 CREW ALLOWABLE WILL BE 17:00HRS
AFTER THEIR REPORTING BLOCK HOURS HAS BEEN DECREASED TO LESS THAN 9HRS,
IN THIS CASE CREW SHOULD MAINTAIN THEIR FDP AS 17HRS OR WILL HAVE TO CALCULATE AS 16HRS?
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Hello,
If the flight is “normally scheduled” to be greater than or equal to 9:00; I believe that 17:00 would still be the scheduled FDP limit.
The additional extension of 1:00 under CS FTL.1.205 (c)(4) is optional; and may only be applied provided only 2 sectors are scheduled in the FDP.
I would suspect that your approved Operations Manual should include under what conditions the additional 1:00 may be applied.
/Garret
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Dear WxMan,
Can you help me on the following as I can’t seem to find an answer anywhere.
One CM has a back-to-back:
– Flight 1: D2 LGG 1100Z – 1930Z JFK – Back on D4 JFK 2130Z – 0430Z(+1)
– Flight 2: D6 LGG 0530Z – 1500Z ATL – Back on D1
My enquiry is: how much FDP this CM has for flight 2 LGG-ATL? Since he’s between 48h and 71h59 in JFK, he is in an unknown state of acclimatisation. Then, he returns to LGG and has minimum rest (+ some) at the hotel. For me, he should have only 11h of FDP for the LGG-ATL but for the program we use, which respect all the FTL limitations, he’s entitled to 13h.
I can’t find any answer to that anywhere in the rules, would you happen to have an answer for me?
Thank you!
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Hello,
I agree 11:00 is correct.
Let’s first determine the appropriate acclimatization status at the start of each FDP.
Use Tables 1 and 2.
The first FDP starts in a acclimated state, so the reference time zone (TZ) is LGG (UTC+1:00).
The Basic FDP limit is based upon 12:00 Local (LGG), with 1 sector, 13:00.
The second FDP begins at JFK (UTC -5:00).
The TZ difference is 6:00, so we need to examine Table 1. Use Row 2.
The elapsed time at JFK is 50:00, so column 2 is used. the Crewmember is in an acclimated state for JFK.
The Basic FDP limit is based upon 16:30 Local (JFK), with 1 sector, 11:15.
The third FDP begins at LGG (UTC +1:00).
The TZ difference is 6:00, so we need to examine Table 1. Use Row 2.
The elapsed time since departure from JFK is 32:00, so column 1 is used. the Crewmember is STILL in an acclimated state for JFK.
The Basic FDP limit is based upon 00:30 Local (JFK), with 1 sector, 11:00.
The Basic FDP limits in ORO.FTL.205(b) may be extended using the provisions under ORO.FTL.205(d) to 12:00.
The FDP may be extended under commander’s discretion to 13:00 – ORO.FTL.205(f).
Garret
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Hello,
I had an airport sby of 4 hours. During 3rd hour of my asby i was notified of a change, it was added one more hour of sby, total 5, but without adding any flight duty.
In our OM-A asby is a sby at the airport that “will not be more than 4 hours. Timings and duration may be adjusted to suit roster needs.” which i understand as it can be 2,35 or 3,45, depending on actual flight plan. Whenever there is a possibility of extension, word extend is used and it is precisely definied under which circumstances, but here word adjusted is used with no further explanation of possible extension.
Should I consider this change being legal?
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I believe it is legal.
Most likely the 4:00 limit in your OM-A stems from CS FTL.1.225 Standby:
The modification of limits on flight duty, duty and rest periods under the provisions of ORO.FTL.225 complies
with the following:
(a) Airport standby
(1) If not leading to the assignment of an FDP, airport standby is followed by a rest period as
specified in ORO.FTL.235.
(2) If an assigned FDP starts during airport standby, the following applies:
(i) the FDP counts from the start of the FDP. The maximum FDP is reduced by any time spent
on standby in excess of 4 hours;
(ii) the maximum combined duration of airport standby and assigned FDP as specified in
ORO.FTL.205(b) and (d) is 16 hours.
In particular (a)(2)(i), when in the cases a FDP is assigned during a ASBY there will be no required reduction to the FDP as the ASBY is limited to 4:00.
In the situation you presented, the ASBY remained less than 16:00, I assume you have been released into a rest period of at least 12:00.
Had you been assigned a FDP, after 4:00 of ASBY (4:30), the Basic FDP limit would be required to be reduced by the amount of ASBY in excess of 4:00 (0:30).
Not sure, why you had your ASBY extended, but reasonable causes for the extension can be thought of:
1) a CM is required for a FDP that commences at 5:00, and
2) it is more cost effective than calling a CM on home standby (SBY) with a 2:30 show time (contact time to FDP report time)
etc, etc, etc.
The operator will still need to ensure that the actual time on ASBY is applied to the Cumulative Duty limits in ORO.FTL.210.
I suggest, you have a respectful cooperative discussion with crew scheduling. If you have found a ‘hole’ in the OM-A where the wording is not precise it would be advisable to improve the language to better cover situations similar to this.
/Garret
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Ok, thank you for the answer.
However, I’m still confused of how can it be legal.
First of all, asby is definied as given in advance, beginning and the end should be assigned. On the other side, regarding changes, it is written that all changes should be performed until 18pm of the previous day.
Regarding extensions, i found only those planned in advance and captain’s discretion. There is no word in our OM-A nor any ORO.FTL about sby extension in actual duration.
I was not given any flight duty. The aircraft was returning back due to malfunction and they did not know when and whether it was going to be fixed, so they just extended my asby to keep me more on the a/p, just in case, to consider further options.
Thank you so much.
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Ok, so if I understand the 18:00 previous day issue, I believe that is for BEFORE reporting for the ASBY, basically a Planning/Scheduling/Re-Scheduling issue, so a CM will know when to REPORT and plan rest his/her rest for the ASBY to be assigned.
The extension from 4:00 to 5:00 after starting the ASBY is a day of operations issue to adjust for an unplanned event.
In the case you illustrated, it seems appropriate to just keep you on ASBY for an extra hour rather than call in a Home Standby (SBY), since at that time I assume they only anticipated a 1:00 turn.
If they had anticipated a 2:00 or 3:00 turn, they reasonably, would have called in the SBY and released the ASBY at the originally designated time.
Further clarification with Crew Scheduling is your best way to approach this, I am sure they would willing to answer your questions. My opinions may differ from the airline, so I would not want to lead you in the wrong direction.
Your very welcome.
Garret
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Dear WxMan,
Could you please clearify this sub paragraph:
(d)(2) When extensions are used for consecutive FDPs, the additional pre- and post- flight rest between the two extended FDPs required under subparagraph 1 shall be provided consecutively.
In case we have 2 consecutive FDPs, should crew member have additional 4 hours of rest after first FDP and 4 hours of rest before second FDP (total 8 consecutive hours of additional rest between FDPs) or rest periods can/should be extended before first and after second FDPs as well (i.e. 2 hours before 1 FDP + 2 hours after 1 FDP + 2 hours before 2 FDP + 2 hours after 2 FDP)?
Thanks in advance
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So your question concerns ORO.FTL.205(d):
(d) Maximum daily FDP for acclimatised crew members with the use of extensions without in-flight rest.
(1) The maximum daily FDP may be extended by up to 1 hour not more than twice in any 7 consecutive days. In that case:
(i) the minimum pre-flight and post-flight rest periods shall be increased by 2 hours; or
(ii) the post-flight rest period shall be increased by 4 hours.
(2) When extensions are used for consecutive FDPs, the additional pre- and post- flight rest between the two extended
FDPs required under subparagraph 1 shall be provided consecutively.
The first aspect to consider is whether the additional rest is being properly applied to the FDP.
A FDP maybe extended up to 1:00 without inflight rest, provided the rest period before/after the FDP meet the criteria in (d)(1)(i) or (ii). So a FDP of 13:30 (13:45 duty time) will require 2:00 additional rest before the FDP and 2:00 after the FDP for a minimum rest period after the FDP of 15:45 = 13:45 + 2:00 under (d)(1)(i). Alternatively, the rest period after the FDP
may be increased by 4:00 for 17:45 = 13:45 + 4:00 under (d)(1)(ii).
With respect to (d)(2), the additional rest periods applied to each FDP under (d)(1) must be applied distinctly.
The only situation this may be a problem is when the additional rest for the 2nd FDP is applied under (d)(1)(i).
If we apply the example of the 13:45 duty time in two consecutive FDP’s the smallest rest periods are:
2:00 before FDP 1
17:45 = 2:00 + 13:45 + 2:00 between FDP 1 & FDP 2
15:45 = 13:45 + 2:00 after FDP 2
If (d)(1)(ii) is applied to FDP 1 then we have:
19:45 = 4:00 + 13:45 + 2:00 between FDP 1 & FDP 2
15:45 = 13:45 + 2:00 after FDP 2
Lastly if (d)(1)(i) is applied to FDP 1 and (d)(1)(ii) is applied to FDP 2:
2:00 before FDP 1
15:45 = 2:00 + 13:45 between FDP 1 & FDP 2
17:45 = 13:45 + 4:00 after FDP 2
I hope this aides you in your understanding.
/Garret
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Many thanks for your answer!
However one thing is still not clear to me. In case of 2 consecutive FDPs with extentions, you listed 3 examples of additional rest:
1. 2 hours before & after 1st FDP, 2 hours before & after 2nd FDP
2. 4 hours after 1st FDP, 2 hours before & after 2nd FDP
3. 2 hours before & after 1st FDP, 4 hours after 2nd FDP
Does it mean, that variant “4 hours after 1st FDP and 4 hours after 2nd FDP” is not acceptable?
If not acceptable: why so? Is there any explanation?
If acceptable: what is the idea of subparagraph d(2)? I mean, in this case, it seems, there are no any specific rules of additional rest for situation with 2 consecutive FDPs, so why does this subparagraph exist?
Thanks in advance!
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4:00 after FDP 1 and 4:00 after FDP 2, IS ACCEPTABLE.
The 3 examples I gave you illustrated when the additional rest would occur during the rest period between FDP 1 & FDP 2.
Basically, each FDP must have 4:00 additional rest in total, of which 2:00 may occur before the FDP and 2:00 after the FDP (d)(1)(i) or 4:00 after the FDP (d)(1)(ii).
Essentially, the requirement in (d)(2) establishes that when two consecutive FDP’s are extended without inflight rest, the additional rests must be clear and distinct.
Sorry, if I was not totally clear.
/Garret
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Hello WxMan. Are flight crews in the obligation to perform a flight with max FDP extended under ORO.FTL.205(d) max FDP with extension without in-flight rest or they can refuse it? I don’t find the response in the documentation. Thanks in advance.
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Amine,
you asked the following:
Are flight crews in the obligation to perform a flight with max FDP extended under ORO.FTL.205(d) max FDP with extension without in-flight rest or they can refuse it? I don’t find the response in the documentation.
As long as ALL of the subsections contained within ORO.FTL.205(d) as well CS FTL.1.205(b) the operator is technically meeting the obligations under the regulations.
However, crew members (CM) need to reasonably expect to be able to perform the tasks required for the flights(s) in a safe manner at proper level of alertness. Should a CM feel that fatigue may become a factor he/she should alert the operator about the problem at the earliest possible moment.
A refusal with a valid justification is reasonable. It must be dealt with on a case by case basis.
If many CMs are alerting the operator about concerns with fatigue for a certain series of flights scheduled under ORO.FTL.205(d), the operator is obligated to address those concerns as required under ORO.FTL.110(b).
Please discuss your concerns with your operator./Garret
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What is the official definition of “unforeseen circumstances in flight operations”?
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Ivan this is from EASA FAQ 2019 (Question 27)
Considering the ICAO definition of ‘unexpected conditions’, unforeseen circumstances in flight operations for the purpose of ORO.FTL.205(f) are events that could not reasonably have been predicted and accommodated, such as adverse weather, equipment malfunction or air traffic delay, which may result in necessary on-the-day operational adjustments.
Garret
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Hello
Is there any limitation in Duty Period in case of a positioning following a FDP (wich is considered as DP) other than duty period limitation (ORO.FTL.210). In other words after operating how long my company can affect me a positionning?
Thanks
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There is no limit to Duty Time, like there is for FDP.
So, a Positioning sector followed by operating flights would be limited FDP limits in ORO.FTL.205.
In the case where a FDP is followed by Positioning, the FDP is limited, but the Duty has no expressed limit under ORO.FTL.
In either case, the entire duty time is to be applied towards the rest requirements under ORO.FTL.235.
So a FDP of 10:00 (Duty of 10:30) would require no less than 10:30 Rest.
A FDP of 10:00 followed by 3:00 Positioning (13:00 duty) would require no less than 13:00 Rest.
Unless, your Operations Manual or CBA has different requirements with respect to Positioning; you are pretty much at the mercy of ORO.FTL.
I suggest you have a discussion with crew scheduling to address your concerns.
/Garret
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Hello! Acc. to ORO.FTL.205 it is possible to reduce the rest period to 10h following an FDP where commander’s discretion was used. Is it legal to do so in a company that does not have the FRM approved?
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Hello!
If a delay outstation occurs by 30min, we are all notified about delayed reporting time and acknowledge it in the system by ourselves. However, hotel does not amend wake up/transport time and we take it. Transport becomes 1h30min instead of normal 1h.
When does FDP starts counting in this case – at delayed reporting time or original time (30min earlier)? Counting into consideration, that rest provided before FDP was more than minimum.
Should FDP here start earlier because we arrived earlier or should longer taxi time just extend rest time before FDP?
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Interesting case here.
My opinion is:
So the rest period is not extended since the crew reported at the original time.
Likewise the FDP begins at the time of report (original report time).
In such a case, it may be necessary for the crew to determine if the FDP will be extended beyond the basic limits using the original reporting time, thus commanders discretion must be invoked under ORO.FTL.205(f).
It seems like an isolated case that bears discussion with management, as issues I have not considered may have been impacted.
/Garret
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What is the maximum FDP extension allowed
under commander’s discretion without in flight rest ( no plan extend)?
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Short answer: 2 hours.
ORO.FTL.205 (f) Unforeseen circumstances in flight operations — commander’s discretion
(1) The conditions to modify the limits on flight duty, duty and rest periods by the commander in the case of unforeseen circumstances in flight operations, which start at or after the reporting time, shall comply with the following:
(i) the maximum daily FDP which results after applying points (b) and (e) of point ORO.FTL.205 or point ORO.FTL.220 may not be increased by more than 2 hours unless the flight crew has been augmented, in which case the maximum flight duty period may be increased by not more than 3 hours;
(ii) if on the final sector within an FDP the allowed increase is exceeded because of unforeseen circumstances after take-off, the flight may continue to the planned destination or alternate aerodrome; and
(iii) the rest period following the FDP may be reduced but can never be less than 10 hours.
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How would commander’s discretion apply when the FDP of a non-augmented crew has already been extended as plan extension (without in flight rest)?
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Very good question.
Perhaps if I give you an example:
Suppose the FDP starts at 07:00, with 2 sectors with 2 Flight Crew Members (FCM).
Table B contains a limit of 13:00. (ORO.FTL.205(b)).
Under provisions under ORO.FTL.205 (d), the scheduled extension may be 14:00.
Let’s say that the FDP is initially scheduled for 13:30.
An unforeseen delay occurs after report.
The maximum extension provisions are found in ORO.FTL.205 (f).
Since the FDP only has 2 FCM, the maximum extension is 2:00 above the Table B limit, in this case 15:00.
the reference provision is as follows:
(f) Unforeseen circumstances in flight operations — commander’s discretion
(1) The conditions to modify the limits on flight duty, duty and rest periods by the commander in
the case of unforeseen circumstances in flight operations, which start at or after the reporting
time, shall comply with the following:
(i) the maximum daily FDP which results after applying points (b) and (e) of point
ORO.FTL.205 or point ORO.FTL.220 may not be increased by more than 2 hours unless the
flight crew has been augmented, in which case the maximum flight duty period may be
increased by not more than 3 hours;
You airline may a have different understanding of these provisions so check the OM and ask them.
/Garret
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