ORO.FTL.215 Positioning

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ORO.FTL.210

Flight Times and Duty Periods

ORO.FTL.220

Split Duty

If an operator positions a crew member, the following shall apply:

(a)       positioning after reporting but prior to operating shall be counted as FDP but shall not count as a sector;

(b)       all time spent on positioning shall count as duty period.

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28 thoughts on “ORO.FTL.215 Positioning

  1. Accordinig to this definition, a flight crew can fly 12 hours and then be positioned back to home with 12 more flight hours in the same aircraft as passenger, with a total duty, let’s say 28 hrs ( including pre flight, transtit…)

    Is that correct?

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    1. Isidoro,
      Your observation is correct.

      You must remember, the time from start of duty to the conclusion of the positioning sector is one duty period, so the entire 28 hour period is still applied towards the cumulative duty time limits in ORO.FTL.210(b),60:00 in any 7 calendar days, 110:00 in any 14 calendar days, 110:00 in any 14 calendar days, and 190:00 in any 14 calendar days,

      The entire 28:00 period also is used to determine the required rest period under:
      ORO.FTL.235, CS.FTL.1.235, GM1 CS FTL.1.235(b)(3), GM1 ORO.FTL.235(a)(2), AMC1 ORO.FTL.235(b).

      Garret

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      1. For example i have a night duty which the limit is 11 hours. After that i have a positioning to layover station, which is additionally 2 hours long.
        So totally i made 13 hours at night. You mean positioning flight doesn’t counts for daily limit, but counts for weekly, monthly etc limits?

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      2. Correct.
        The time on positioning after FDP is not applied towards the daily FDP limits under ORO.FTL.205.

        It is applied towards the cumulative duty limitations in ORO.FTL(a).

        Additionally, the total time on duty (FDP + Positioning) must be considered when evaluating the rest requirements under ORO.FTL.235.

        /Garret

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  2. If the crew positioning take place 2 hours before the FDP and the positioning is made by car, should it be counted as FDP?’
    Thanks

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    1. Positioning is the transportation of a crew member at the behest of the airline, it is considered duty time and will be considered FDP as long as it precedes a flight where the crew member is expected to perform work.
      The form of transportation is irrelevant.
      See ORO.FTL.105 Definitions:
      (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;

      FDP in this situation, will begin when the crew member reports for the positioning.
      The FDP will end at the actual arrive time of the last operational (working) flight within the duty period.
      The Duty period will end when the crew member is released into a rest period.

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  3. Hello, I’d like to know how is defined “local transfer” outside of home base… is there any time or distance which need not be exceeded?

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    1. Adrian,
      You asked the following:

      I’d like to know how is defined “local transfer” outside of home base… is there any time or distance which need not be exceeded?

      With Respect to Positioning, which can be of any means available, car, bus, train and or aircraft, there is no limitation as to how long the positioning may last, however, positioning is considered duty. As such, the Cumulative Duty Limitations must still be observed:

      ORO.FTL.210 Flight Times and Duty Periods

      (a) The total duty periods to which a crew member may be assigned shall not exceed:

      60 duty hours in any 7 consecutive days;
      110 duty hours in any 14 consecutive days; and
      190 duty hours in any 28 consecutive days, spread as evenly as practicable throughout that period.

      And the Crew member must be given a rest period in accordance with:

      ORO.FTL.235 Rest Period

      (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.

      Meaning if the CM finishes a duty period with a positioning, and the total duty time including the time on positioning , in the duty period exceeds 10:00, then the rest period must be at least as long as the preceding duty period, even if it is all positioning..

      Now if you are discussing the travel time from release of a duty period to a hotel and from the hotel to report time, there are certain parameters that should be followed:

      AMC 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.

      For example, a CM is given a layover between two duties, the crew member requires 8:00 of sleep, in addition, 1:00 for physiological needs, so far the total time is 9:00, if the travel time is 0:45 in each direction this now brings the total time to 9:00 + 0:45 + 0:45 = 10:30. in this example 10:30 is the minimum time from release of one duty period to the start of the next duty period in the rotation.

      I hope this helps.

      Garret

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      1. Hi Garret,

        I realise this is an old post but and like clarification if possible.

        The duty period ends at the end of the taxi ride to the hotel and begins at getting in the taxi from the hotel?

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      2. No.
        Duty ends at Release (Clear) (Start of taxi ride to hotel).
        Duty begins at Report Time (Sign on) at the designated location (Airport).

        A Rest Period (RP) is from Release to Report, within the rest period, the crew member must have 8:00 to sleep opportunity (SO), 1:00 to attend to physiological needs (PN) and a minimum of 0:30 travel time (TT) to from the hotel. The smallest RP is 10:00, so if we subtract the 8:00 SO and 1:00 PN we have 1:00 remaining for TT. Divide this number by 2 results in a TT one-way of 0:30. Should the scheduled TT exceed 0:30, the RP should like wise be extended.

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    1. This is from the EASA FAQ document:

      Positioning ORO.FTL.215 Shall a positioning between active sectors count as a sector for a pilot?

      No.
      According to ORO.FTL.215, positioning prior to operating should shall count as FDP but shall not count as sector.
      A positioning sector between in that respect is positioning after reporting and prior to operating.

      So, in the scenario you presented, the First Duty also contained FDP and is subject to FDP limits in ORO.FTL.205.
      The second duty is only DHD, so there are no FDP limits, however the time is duty, thereby it is not Rest, the rest period after such a duty period is still subject to the limitations in ORO.FTL.235.
      The third duty is just like the first duty.

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      1. So, you mean that if I report tomorrow at 10.30LT for HEL-ARL-HEL-OUL and ARL-HEL is positioning, I have to calculate the maximum daily FDP for 1-2 sector FDP and not for 3 sectors.
        Thanks.

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      2. It is then as anonymous says… you can do positioning as many sectors as the operator wants in between two duty sectors not counting as a sector.

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    2. Do you still require Min Rest away from home base (10 hours or duty whichever greater) if then you are positioning the following day? Listed as separate duties on roster which HOTAC provided.

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      1. A crew member (CM) must be provided rest periods that comply with:
        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.

        As we can see in the regulation, minimum rest period is 10:00, so unless a CM has been provided a prospectively defined continuous period of 10:00 or more ‘Free from duty’, the CM is still on duty.

        Example 1:
        9:00 FDP + post flight duty
        8:00 Free of duty
        4:00 Positioning

        The CM should be considered to be on duty for 21:00.

        At this point the CM is required to be provided a rest period of no less than 21:00.

        Example 2:
        11:00 FDP + post flight duty
        10:00 Free of duty
        4:00 Positioning

        The CM should be considered to have been given two duty periods, 11:00 and 4:00.

        At this point the CM is required to be provided a rest period of no less than 11:00.

        /Garret

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  4. When the FDP starts for a crew out of base?
    Directly after the briefing of the in-bound flight in the Hotel or 90mins prior the flight as written in the crew manual’s company?

    Is still effective the traveling with the new FTL of Feb 2017?

    Regards

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    1. Luca,
      You asked the following:

      When the FDP starts for a crew out of base?
      Directly after the briefing of the in-bound flight in the Hotel or 90mins prior the flight as written in the crew manual’s company?

      Is still effective the traveling with the new FTL of Feb 2017?

      My response is:

      FDP is definied under ORO.FTL.105:

      (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;

      Operators are required to define a report time:

      Under ORO.FTL.205 (a)(1)

      (a) The operator shall:

      (1) define reporting times appropriate to each individual operation taking into account ORO.FTL.110(c);

      Typically, Report time is at a specific location, (an airport), where once a crew member signs in, they begin the pre-flight duties to prepare for the flight(s) at hand.

      If the crew is “reporting” at the hotel, there seems to be a conflict with the definition of positioning (ORO.FTL.105)

      (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;

      As the local transfer from place of rest to the airport is purposely excluded from “positioning” which is excluded, therefore it is not duty.

      The defined report time (90 minutes) should be occurring at the airport 90 minutes prior to the scheduled departure, no less

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  5. Hello

    I have a real situation here and I need some advice.

    After finishing with my last flight from YPPH to NZAA and 12 hours of rest they have me positioning direct to my home base LGAV
    with a total of 35 hours of duty and 3 sectors. AKL LAX LHR ATH. Is this possible? My thought is that since position regulations are under the daily FDP chapter and there are only 24 hours in a day it should be impossible to exceed this without a rest period in between.

    Thank you for your time

    Dino

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    1. You asked the following:

      I have a real situation here and I need some advice.

      After finishing with my last flight from YPPH to NZAA and 12 hours of rest they have me positioning direct to my home base LGAV with a total of 35 hours of duty and 3 sectors. AKL LAX LHR ATH. Is this possible?

      My thought is that since position regulations are under the daily FDP chapter and there are only 24 hours in a day it should be impossible to exceed this without a rest period in between.

      If I understand your situation correctly permit me to make a few assumptions.

      1) The FDP which ends with the YPPH-NZAA sector began with a location within 4 hours of NZZA, and the crew member is in an acclimated state.

      2) The Positioning (DHD) Duty Period was 35 hours continuous duration and included 3 flights – NZAA-KLAX, KLAX-EGLL, EGLL-LGAV

      First-off, let us look at the rest period following the YPPH-NZAA sector:

      1) The rest period is legal as long as the duty time is less than or equal to 12:00 and the FDP meets the first conditon in my assumptions.

      Now lets turn to DHD duty period.

      1) A duty period that is all DHD is not FDP, thereby it is not governed by ORO.FTL.205.

      2) However, the same all DHD Duty period, is Duty as defined in ORO.FTL.215, it is not Rest since an individual cannot be at rest while on duty.

      3) Upon return to Base, the crew member will require a rest period of no less than 35:00 (ORO.FTL.235 (a)(1)),

      a) Since the return to home base will also involve a change in time zones greater than or equal to 4:00 the rest upon return to home base must meet the requirements in

      CS FTL.1.235 (b)(3)(i). This depends upon the duration of time away from base, but at first glance I can safely state that the minimum continuous rest at base will require no

      less than 3 local nights rest.

      Now, not knowing what is stated in your Operations Manual (OM) or the Union Agreement, I cannot state that the DHD only Duty Period must not be limited, but based upon

      ORO.FTL I cannot see a duty limit.

      Please discuss with your Airline and or Union, they should be able to give you better insight as to whether this rotation / crew member’s rostered schedule is legal.

      /Garret

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    1. Based upon your question, I assume you are asking whether the time in local transportation after the completion of a duty period, or before starting a duty period is to be considered duty time.

      ORO.FTL 105 Definitions, provides:

      (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;

      So, once a crew member is released from a duty period, that individual is in a rest period until the crew member reports for a duty period at a designated location.

      However, the time in transportation must be considered when the airline is providing a suitable accommodations for a rest period. During a rest period, the crew member must be able to have at least 8:00 minimum sleep opportunity. To accomplish that, the total time in travel to/from the accommodation must be accounted for as well a time for physiological needs.

      AMC1 ORO.FTL.235(b) Rest Periods, provides:

      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.

      For, example:

      A FDP with a 5:00 duty period is followed by a 10:00 rest period away from base;

      With a travel time each way of 0:20, this is legal, 8:00 (Sleep Opp.) + 0:20 (Travel To) + 0:20 (Travel From) + 1:00 (Phys. Needs) = 9:40, which is less than the required 10:00 Rest period requirement.

      If the Travel time each way were to be 0:35, then the
      8:00 (Sleep Opp.) + 0:35(Travel To) + 0:35(Travel From) + 1:00 (Phys. Needs) = 10:10, which is less than the required rest of 10:00.

      In the case when the airline is not providing a suitable accommodation (rest at base), the EASA provided the following guidance:

      GM1 CS FTL.1.200 Home Base

      TRAVELLING TIME

      Crew members should consider making arrangements for temporary accommodation closer to their home base if the travelling time from their residence to their home base usually exceeds 90 minutes.

      Here, it is clearly the crew members responsibility.

      With the minimum rest at base of 12:00, the 8:00 sleep oppourunity still needs to be considered, as well as the travel time and physiological needs.

      With a 1:20 (80 minutes) commute each way, so we can apply the same formulas:

      8:00 (Sleep Opp.) + 1:20(Travel To) + 1:20(Travel From) + 1:00 (Phys. Needs) = 11:40, which is less than the required rest of 12:00.

      With a 1:35(95 minutes) commute each way, so we can apply the same formulas:

      8:00 (Sleep Opp.) + 1:35(Travel To) + 1:35(Travel From) + 1:00 (Phys. Needs) = 12:10, which is greater than the required rest of 12:00 (so the crew member should consider reducing the travel time).

      In short, No travel time, local in nature is not part of a duty period.

      I hope this helps you in your understanding.

      Please discuss with your airline and union, as they should be able to provide better guidance.

      /Garret

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      1. Just a small clarification. I’m asking about the transport from aircraft to base not from base to place of rest. Ie does the duty end when duties are done at the aircraft or only when crew member has been transported back to the base?

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      2. It is Duty.

        ORO.FTL.215 Positioning
        If an operator positions a crew member, the following shall apply:
        (a) positioning after reporting but prior to operating shall be counted as FDP but shall not count as a sector;
        (b) all time spent on positioning shall count as duty period.

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  6. Just a quick question :

    If on Monday you operate a long duty period for example 19h (long haul + positioning to another point of departure).
    On Tuesday, after only 17h of rest time (Monday start of rest – Tuesday begin of dp) you go on a positioning and the FTL235 says rest time = the previous DP before begining another FDP.
    Monday to Tuesday rest in the hotel, Tuesday 19h Long haul flight in function return to base.
    A Positioning is not a FDP , only DP
    How do you calculate the rest time between Monday and Tuesday?

    thank you in advance,

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    1. The Rest period before the next FDP must be able to satisfy the rest requirements in ORO.FTL.235
      I will assume that rest periods being provided are away from base.

      So under 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.

      The first Duty Period is 19:00, so a rest period of the greater of the length of the preceding duty period (19:00), or 10:00; must be provided before starting another FDP.
      The 17:00 between DP #1 and the DP #2 (DHD) is insufficient to qualify under this condition, but since the DP is only a DHD DP you are still legal. The 17:00 just ensures that you have been given at least a minimum rest period so the CM is not on a continuous DP/FDP.
      DP #3 is a FDP, the rest period that precedes it must be at least 10:00, length of DP #2 or 19:00 (the rest following DP #1 still needs to be satisfied); whichever is greater.

      /Garret

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  7. Hello, small question:

    I am landing at an airport and then I am supposed to take a shuttle which will take me to some seaport. From there, I will take a boat that will take me to another seaport in a different island. From that seaport, I will take another shuttle (55m ride) to go to my hotel (place of rest). That last shuttle ride is not taken into account in my schedule and my duty period. Is that normal? I consider it as POSITIONING according to the FTL definitions.

    Thank you

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    1. If the crew member is to REVERSE the TRAVEL to continue the assignment after the rest period from the previous AIRPORT, it would most likely be considered as just TRAVEL time to/from the place of rest.

      If the assignment is to be continued from a different airport, then time (Shuttle-Ferry) would be considered as POSITIONING.

      The idea of local travel is generally considered as a time frame less than 2 hours (my opinion), but that varies from airline to airline/ regulator to regulator.

      The total travel time should include all time waiting for the shuttles or ferry.

      Like

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