ORO.FTL.235 Rest Periods

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ORO.FTL.230

Reserve

ORO.FTL.240

Nutrition

(a)       Minimum rest period at home base.

(1)   The minimum rest period provided before undertaking an FDP starting at home base  shall be at  least as long  as the preceding  duty period,  or  12 hours, whichever is greater.

(2)   By way of derogation from point (1), the minimum rest provided under point (b) applies if the operator provides suitable accommodation to the crew member at home base.

GM1 ORO.FTL.235(a)(2) Rest Periods

(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.

AMC1 ORO.FTL.235(b) Rest Periods

(c)       Reduced rest

By derogation from points (a) and (b), flight time specification schemes may reduce the  minimum  rest  periods  in  accordance  with  the  certification  specifications applicable to the type of operation and taking into account the following elements:

(1)   the minimum reduced rest period;

(2)   the increase of the subsequent rest period; and

(3)   the reduction of the FDP following the reduced rest.

(d)       Recurrent extended recovery rest periods 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.

(e)       Flight time specification schemes shall specify additional rest periods in accordance with the applicable certification specifications to compensate for:

(1)   the effects of time zone differences and extensions of the FDP;

(2)   additional cumulative fatigue due to disruptive schedules; and

(3)   a change of home base.

CS FTL.1.235 Rest Periods

44 thoughts on “ORO.FTL.235 Rest Periods

  1. Can crew member be contacted by an operator, if the rest periot is during day time?
    For example:
    Crew have STBY from 0800-1400LT and after he should have rest. Can operator contact crew member at 1500LT to ask, if crew member is ready for operations at 0600LT next day?
    Thank you.

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    1. Janis,
      You asked the following:

      Can crew member be contacted by an operator, if the rest periot is during day time?
      For example:
      Crew have STBY from 0800-1400LT and after he should have rest. Can operator contact crew member at 1500LT to ask, if crew member is ready for operations at 0600LT next day?

      A crewmember assigned to STBY (Other than Airport Standby) must meet the following regulatory requirements:
      CS FTL.1.225(b) Standby.

      (b) Standby other than airport standby:

      (1) the maximum duration of standby other than airport standby is 16 hours;

      (2) The operator’s standby procedures are designed to ensure that the combination of standby and FDP do not lead to more than 18 hours awake time;

      (3) 25% of time spent on standby other than airport standby counts as duty time for the purpose of ORO.FTL.210;

      (4) standby is followed by a rest period in accordance with ORO.FTL.235;

      (5) standby ceases when the crew member reports at the designated reporting point;

      (6) if standby ceases within the first 6 hours, the maximum FDP counts from reporting;

      (7) if standby ceases after the first 6 hours, the maximum FDP is reduced by the amount of standby time exceeding 6 hours;

      (8) if the FDP is extended due to in-flight rest according to CS FTL.1.205(c), or to split duty according to CS FTL.1.220, the 6 hours of paragraph (6) and (7) are extended to 8 hours;

      (9) if standby starts between 23:00 and 07:00, the time between 23:00 and 07:00 does not count towards the reduction of the FDP under (6), (7) and (8) until the crew member is contacted by the operator; and

      (10) the response time between call and reporting time established by the operator allows the crew member to arrive from his/her place of rest to the designated reporting point within a reasonable time.

      In the situation presented, the STBY is in a questionable area.

      1) It is less than 16:00 in duration. Sub paragraph (1) above. So the duration of the STBY is legal.

      The rest period after the time the STBY ended, at the point of notification, is from 15 LT to 06 LT is 15:00 in duration. Under ORO.FTL.235 (a)(1) the minimum Rest at base is satisfied.

      ORO.FTL.235 Rest Periods

      (a) Minimum rest period at home base.

      (1) The minimum rest period provided before undertaking an FDP starting at home base shall be at least as long as the preceding duty period, or 12 hours, whichever is greater.

      However, if the crew member has already ended the STBY, there can be a problem with the airline attempting to contact the crew member, unless procedures for contacting the crew member when ‘off duty’ are established. Under the FAA rules, the airline may attempt to contact, but the crew member cannot be obligated to respond while on a designated off duty period. While the FAA rules are not part of the EASA rules, the basic principle is somewhat the same based upon the definition in the EASA rules:

      (20) “reserve” means a period of time during which a crew member is required by the operator to be available to receive an assignment for an FDP, positioning or other duty notified at least 10 hours in advance;

      (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;

      (25) “standby” means a pre-notified and defined period of time during which a crew member is required by the operator to be available to receive an assignment for a flight, positioning or other duty without an intervening rest period;

      As I stated before the Rest Period aspect seems to have been met, but the Standby aspect seems to be in a questionable area, as the contact has occurred after the Standby has ended, but within the 16 hour window from the start of the Standby. Further, by keeping the crew member contactable for an additional period of time, seems to circumvent the requirement in CS FTL.1.225(3) for that period while still contactable.

        My opinion, is that the airline is mixing the purpose of Standby with Reserve.

      My suggestion is that you have a discussion with your airline regarding this matter to help clear up the inconsistencies/understanding of the particulars that surround this issue.

      I caution you, I am not with the EASA or any local CAA/NAA, or any airline, or union so my opinions may be different.

      I hope this response helps to aide you in your understanding.

      /Garret

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  2. Let’s say you have had a 2 leg flight from Athens to Stockholm and back. Total duty time was 10 hours. It was 01:30L by the time you got back. Meaning it was locally the next day. Since a day is defined to start at 00:01 and end at 24:00, would it be against regulations to sign in the same day in the afternoon, lets say at 16:30, for your next flight or not. In short can we have two separate flight ops in the same day starting at our home base?

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    1. In short, yes it is legal.

      With a 10:00 duty time the minimum rest is 12:00 at base.

      ORO.FTL.235 Rest Periods
      (a) Minimum rest period at home base.
      (1) The minimum rest period provided before undertaking an FDP starting at home base shall be at least as long as the preceding duty period, or 12 hours, whichever is greater.

      No knowing how long the next duty is makes me wonder about it’s total validity.
      If the second duty is more than 10:00 it could be assumed to be a “Long Night Duty” whereby

      GM1 CS FTL.1.205(a)(2) Flight Duty Period (FDP)
      NIGHT DUTIES – APPROPRIATE FATIGUE RISK MANAGEMENT

      Should be examined.

      I suggest you have a word with your company to express your concerns.

      /Garret

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  3. Let’s say I’m flying my 2 Legs on medium haul and thereafter my operator requires me to start a recurrent training after only 8 hours of uninterrupted rest because, (that’s what’s they assume) I need the rest period of 12 Hrs only before undertaking the next FDP. Since I have to drive by car to and from the recurrent course, I am not flying and therefore not anymore subject to EASA FTL. Fact is my minimum rest period will be reduced and I need to know if I have to accept it or if I can insist to have my 12 hours after checkout before being assigned to any other duty.

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    1. Renzo,
      You asked the following:
      Let’s say I’m flying my 2 Legs on medium haul and thereafter my operator requires me to start a recurrent training after only 8 hours of uninterrupted rest because, (that’s what’s they assume) I need the rest period of 12 Hrs only before undertaking the next FDP. Since I have to drive by car to and from the recurrent course, I am not flying and therefore not anymore subject to EASA FTL. Fact is my minimum rest period will be reduced and I need to know if I have to accept it or if I can insist to have my 12 hours after checkout before being assigned to any other duty.
      EASA provides the following:
      ORO.FTL.105 Definitions
      (10) “duty” means any task that a crew member performs for the operator, including flight duty, administrative work, giving or receiving training and checking, positioning, and some elements of standby;
      (11) “duty period” means a period which starts when a crew member is required by an operator to report for or to commence a duty and ends when that person is free of all duties, including post-flight duty;
      (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;
      (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;

      ORO.FTL.235 Rest Periods
      (a) Minimum rest period at home base.
      (1) The minimum rest period provided before undertaking an FDP starting at home base shall be at least as long as the preceding duty period, or 12 hours, whichever is greater.
      (2) By way of derogation from point (1), the minimum rest provided under point (b) applies if the operator provides suitable accommodation to the crew member at home base.

      Looking at the situation you are presenting, the 8:00 period prior to beginning the recurrent training (RCT) would not qualify as rest, the minimum rest period without a suitable accommodation at home base is 12:00 or at least as long as the length of the preceding duty period. So in the case presented, the crew member is on continuous duty from the start of the 2-leg FDP until the conclusion of the RCT, thus depending upon how long the continuous duty period (including the 8:00 break in duty), the minimum rest following the RCT is 12:00 or the length of the continuous duty period.
      So lets say the FDP is 5:00, plus the 8:00 break plus the RCT of 4:00, the minimum rest period following the RCT would be 17:00.
      I would also question the effectiveness of the RCT with less than a full rest period.
      /Garret

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      1. Absolutely, the effectiveness is another important point. But according my roster I should check in at 14:00 UTC fly until 18:30 UTC (with checkout at 19:00), depart with a rental car the day after at 05:00 UTC return to Homebase at 19:00 UTC. After that, they give me 3 Day’s off. The point is, am I legal?
        Since I will not touch an Airplane except at the beginning, can the company pretend a duty, which at the end lasts 29 hours?

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      2. The FDP is 4:30 with a 5:00 Duty, the 10:00 (19:00 to 05:00) rest period (away from base), so the rest period meets the criteria in:
        ORO.FTL.235(b)
        (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.

        So the duty is not a continuous duty.

        The RTC is 14:00 of duty (05:00 to 19:00), thm minimum rest in base is 14:00, so the three day rest is legal.
        /Garret

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      3. Hi Renzo,
        We have the same problem in my airline. The fact is that before the recurrent training you do not need the 12 hours as it is not considered an FDP but just only a duty. The mínimum rest is only defined as “before undertaking an FDP”.
        When we perform ground duties we do not need to have 12hours.

        BR

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  4. The flight duty will start and finish AT and not away from my home base that’s why i will insist with having the course postponed.

    Anyway thank you verry much for your help,

    Renzo

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  5. Let me present you with the following scenario:
    A standby duty starts at 0300LT. At 2325LT the preceding day I get a notification that I have changes to my roster to following day. The notification involves me to report at 0300LT. How is this scenario covered by EASE FTL’s, where the company interrupts my rest to invoke a change to my roster which they would not have been able to cover from my standby start? Thanks very much in advance.

    Kind Regards,
    Anthony F.

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    1. Anthony,
      While no specific requirements under ORO.FTL.225 CS FTL.1.225 with respect to rest periods before the start of a standby exist, carriers still must meet the objectives in ORO.FTL.110.
      An operator shall:
      (a) publish duty rosters sufficiently in advance to provide the opportunity for crew members to plan adequate rest;
      (b) ensure that flight duty periods are planned in a way that enables crew members to remain sufficiently free from fatigue so that they can operate to a satisfactory level of safety under all circumstances;

      As a general rule, contacting a crew member during the last 10 hours of a rest period, to notify him/her of a change seems to be contradict ORO.FTL.110.
      However, precedence for such actions is not totally out of the the airlines abilities.
      Under the FAA FAR 121 and 117, it has been understood, that an operator may attempt to contact a crew member to advise of a change, whereby it is also understood, that during a rest period, the crew member has no obligation to respond to such an attempt, also if the crew member does respond, they may decline a request until they have completed the rest period.

      Basically, if the individual believes that they will be sufficiently rested and fit for duty as outlined in your scenario, it may be legal, but the airline should understand that requesting such changes would/should be an extraordinary exception to the rule, not a general scheduling practice. Such exceptions to the general practice would best be included in an operation manual (OM), including crew members rights of refusal.

      I suggest you have a discussion with your airline over such matters.
      /Garret

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  6. EARLIEST PICK UP FROM HOTEL AFTER LOKAL NIGHT:

    What is the earliest pick up time after staying in a hotel (company accommodation) and after a require local night?
    Would you agree with 5:30 because of max 30 min traveling time local transport to the airport or is it 06:00?

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    1. Georg,
      you asked:

      What is the earliest pick up time after staying in a hotel (company accommodation) and after a require local night?
      Would you agree with 5:30 because of max 30 min traveling time local transport to the airport or is it 06:00?

      Not precisely.

      A Local Nights Rest must meet the conditions set in ORO.FTL.105:

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

      So, you are correct in identifying that the earliest report time is 06:00, thus the rest period period must have started no later than 22:00.

      The Absolute minimum rest period that is to be provided when a suitable accommodation is being provided is 10:00, however, that rest period is obligated to always be able to provide a sleep oppoutunity that is never less than 8:00 and 1:00 for physiological needs, hence a 9:00 period in the hotel. So 10:00 – 9:00 = 1:00, thereby the travel time should never less than 0:30 each way. If the travel time is greater than 0:30 each way the rest period should be increased so the 9:00 is still maintained.

      Examples:

      Expected Travel time is 0:30, then (0:30 * 2) + 9:00 = 10:00 minimum rest. The earliest pickup is 6:00 – 0:30 = 05:30 .

      Expected Travel time is 0:40, then (0:40 * 2) + 9:00 = 10:20 minimum rest. The earliest pickup is 6:00 – 0:40 = 05:20.

      Expected Travel time is 0:20, then (0:30 * 2) + 9:00 = 10:00 minimum rest. The earliest pickup is 6:00 – 0:20 = 05:40, the rest period uses a minimum travel time of 0:30.

      /Garret

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    1. No.
      The requirements are stipulated in:
      ORO.FTL 235 Rest Periods
      (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.
      (c) Reduced rest
      By derogation from points (a) and (b), flight time specification schemes may reduce the minimum rest periods in accordance with the certification specifications applicable to the type of operation and taking into account the following elements:
      (1) the minimum reduced rest period;
      (2) the increase of the subsequent rest period; and
      (3) the reduction of the FDP following the reduced rest.
      (e) Flight time specification schemes shall specify additional rest periods in accordance with the applicable certification specifications to compensate for:
      (1) the effects of time zone differences and extensions of the FDP;
      (2) additional cumulative fatigue due to disruptive schedules; and
      (3) a change of home base.

      CS FTL.1.235 Rest Periods
      (a) Disruptive schedules
      (1) If a transition from a late finish/night duty to an early start is planned at home base, the rest period between the 2 FDPs includes 1 local night.
      (b) Time zone differences
      (3) Time zone differences are compensated by additional rest, as follows:
      (ii) Away from home base, if an FDP involves a 4-hour time difference or more, the minimum rest following that FDP is at least as long as the preceding duty period, or 14 hours, whichever is greater. By way of derogation from point (b)(3)(i) and only once between 2 recurrent extended recovery rest periods as specified in ORO.FTL.235(d), the minimum rest provided under this point (b)(3)(ii) may also apply to home base if the operator provides suitable accommodation to the crew member.
      (c) Reduced rest
      (1) The minimum reduced rest periods under reduced rest arrangements are 12 hours at home base and 10 hours out of base.
      (2) Reduced rest is used under fatigue risk management.
      (3) The rest period following the reduced rest is extended by the difference between the minimum rest period specified in ORO.FTL.235(a) or (b) and the reduced rest.
      (4) The FDP following the reduced rest is reduced by the difference between the minimum rest period specified in ORO.FTL.235(a) or (b) as applicable and the reduced rest.
      (5) There is a maximum of 2 reduced rest periods between 2 recurrent extended recovery rest periods specified in accordance with ORO.FTL.235(d).

      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.

      ORO.FTL.220 Split Duty
      The conditions for extending the basic maximum FDP due to a break on the ground shall be in accordance with the following:
      (c) split duty shall not follow a reduced rest.

      CS FTL.1.205 Flight Duty Period (FDP)
      (d) The extension of FDP with in-flight rest under the provisions of ORO.FTL.205(e)
      (6) The minimum rest at destination is at least as long as the preceding duty period, or 14 hours, whichever is greater.

      To summarize the conditions above when a rest period is not permitted to be reduced:
      1) If the operator does not have an approved FRM the rest is not permitted to be reduced (CS FTL.1.235(c)(3)).
      2) If the rest period is a transition from a late finish/night duty to an early start test rest period must include 2 local nights rest (CS FTL.1.235(a)(1)).
      3) If the FDP involves a time zone difference of 4 hours or more, the minimum rest is 14:00 (CS FTL.1.235(b)(3)(ii)).
      4) A rest period must include an 8 hour sleep opportunity, 1 hour physiological needs, and no less than 30 minutes travel time; whereby, if the travel time exceeds 30 minutes, twice the difference above 30 minutes must be added to the 10:00 minimum rest period. (AMC1 ORO.FTL.235(b)).
      5) If the next FDP is a split duty period, the rest period may not be reduced, (ORO.FTL.220(c)).
      6) If the preceding FDP has been extended, the minimum rest period is 14:00 (CS FTL.1.205(d)(6)).

      /Garret

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    1. Best practices have it that the RERRP should be at home base whenever possible, but it is not required under EASA ORO.FTL.
      1) It is less costly to the airline as a suitable accommodation is not required to be provided by the operator.
      2) Individuals generally reduce stress; a major contributor to fatigue; by having extended rests at home.

      Some national legislation within Europe requires transportation workers to have extended rest periods in the home environment, but it varies from country to country.

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  7. If the RERRP is not required to be at the Home Base would the following scenario be legal:
    1) Crew positioned at a XX destination;
    2) Operations from and to that destination for a period of 1 month;
    3) Recurrent extended recovery rest periods given in that destination;
    4) After 1 month return to home base
    Notes: How would you define the concepts of “Local Day”, “Local Night”, “Duty Period” and “Home Base” and the co-relation between them and being “forced” to spend your days off away from home and family?

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    1. Hello Miquel,
      You asked the following:
      If the RERRP is not required to be at the Home Base would the following scenario be legal:
      1) Crew positioned at a XX destination;
      2) Operations from and to that destination for a period of 1 month;
      3) Recurrent extended recovery rest periods given in that destination;
      4) After 1 month return to home base
      Notes: How would you define the concepts of “Local Day”, “Local Night”, “Duty Period” and “Home Base” and the co-relation between them and being “forced” to spend your days off away from home and family?
      Under the scenario you asked it seems to me that the crew member has been rebased, under certain conditions:
      I would believe that the crew member has been re-based when that individual will incure a normal ground travel time from home to the new airport where the normal ground travel time to from previous base to the new base will exceed 1:30 (90 minutes) AND the crew member will not be able to undertake a RERRP at the former base. Under such conditions the crew member should follow the guidance as provided in:
      ORO.FTL.200 Home Base
      An operator shall assign a home base to each crew member.
      CS FTL.1.200 Home Base
      (a) The home base is a single airport location assigned with a high degree of permanence.
      (b) In the case of a change of home base, the first recurrent extended recovery rest period prior to starting duty at the new home base is increased to 72 hours, including 3 local nights. Travelling time between the former home base and the new home base is positioning.
      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.
      So, if you meet the conditions as stated above, the calendar limitations for Cumulaitive Flight Time Limitations , Cumulaitive Duty time limitations set in ORO.210 should be based upon a local date/time of the new base. Further, the RERRP set in ORO.FTL.235(d) which requires 36:00 with 2 local nights increased to 2 local days twice every month will be based upon local time of the local time the new base, or the local time at the location where the RERRP is granted.
      Shuoud the crew membert not meet the conditions above in ORO.FTL.200, they woud not be eligible to to actually receive an assignemnt.

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      1. Thank you for the clarification.
        Just to finish… would you agree with the following statement: Minimum RERRPs (7 days in a month period) cannot be deferred.
        That is… may an operator roster a crew member for an extended operation and with his/her agreement assign the days off after returning to home base. This considering that the minimum 36 hours with 2 local nights were observed. This way a crew member could be placed for a period of 21 days

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      2. Miquel,
        You are welcome.

        Now to your second question:
        Just to finish… would you agree with the following statement:
        Minimum RERRPs (7 days in a month period) cannot be deferred.
        That is… may an operator roster a crew member for an extended operation and with his/her agreement assign the days off after returning to home base. This considering that the minimum 36 hours with 2 local nights were observed. This way a crew member could be placed for a period of 21 days.

        RERRPs are governed under:
        ORO.FTL.235(d) Recurrent extended recovery rest periods
        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.

        Under this provision, whether at or away from base, a crew member must be able to find in the 168:00 period preceding the release of any duty period, a RERRP that has ended within that span of time. The RERRP must always include 2 local nights rest and may never be less than 36:00 as a single continuous rest period. A RERRP may be taken while away from base.

        Given the conditions in your 21 days away from base, the crew member should have at least two RERRPs while away from base. 1 before the start of the 21 days, 1 at or before day 7, another at or before day 14 and 1 upon return to home base. The total RERRPs is 4 within a 24 days span.
        The situation concerning 7 days in a month, I believe involves a single day free of duty (SDFD), as defined in ORO.FTL.105.
        single day free of duty” means, for the purpose of complying with the provisions of Council Directive 2000/79/EC, a time free of all duties and standby consisting of one day and two local nights, which is notified in advance. A rest period may be included as part of the single day free of duty;

        EASA ORO.FTL, does not regulate SDFD, that is handled under 2000/79/EC and individual national government laws. Depending on the exact verbiage of the applicable laws, SDFD may or may not be required to be taken in the home base environment. So the 7 SDFD may possibly be deferred to after the 21 day period or granted to prior to the 21 day period.

        While SDFD may or may not be deferred, RERRP’s are technically not supposed to be deferred/delayed, to a point beyond the 168:00 between RERRP’s, The only exception I could possibly conceive, would be due to some unforeseen circumstance, and I am sure the local NAA’s would look very closely at those situations.

        I personally believe that the RERRP’s should be taken in the home environment to maximize the benefits of the rest, but that is my opinion.

        Please discuss further with your Airline, Union and local NAA, as my opinion may differ.
        /Garret

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  8. A question with reference to ORO FTL 235. The rule regulates rest before undertaking an FDP. So my understanding is that it is legal to have any other kind of duty with less rest.

    Ex.
    Day 1 FDP 11.30-00.30 (away from base). Total duty 11.30-.01.00 = 13 h 30 min

    Rest 01.00-13.30. = 12 h 30 h

    Day 2 Positioning duty 13.30-18.00 (to home base)

    This is as far as I understand legal. But if the following duty is an FDP?

    Day 3 FDP 06.00-16.00 (after 12 h rest at home base)

    Would this duty be legal? Or do the rest need to be min 13 h 30 min before the FDP on day 3 considering that the duty from day 1 was 13 h 30 min?

    //”Early Type”

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    1. Tommy, you asked the following:

      A question with reference to ORO FTL 235. The rule regulates rest before undertaking an FDP. So my understanding is that it is legal to have any other kind of duty with less rest.

      Ex.
      Day 1 FDP 11.30-00.30 (away from base). Total duty 11.30-.01.00 = 13 h 30 min

      Rest 01.00-13.30. = 12 h 30 h

      Day 2 Positioning duty 13.30-18.00 (to home base)

      This is as far as I understand legal. But if the following duty is an FDP?

      Day 3 FDP 06.00-16.00 (after 12 h rest at home base)

      Would this duty be legal? Or do the rest need to be min 13 h 30 min before the FDP on day 3 considering that the duty from day 1 was 13 h 30 min?

      //”Early Type”

      Your examples fall under:

      ORO.FTL.235 Rest Periods
      (a) Minimum rest period at home base.
      (1) The minimum rest period provided before undertaking an FDP starting at home base shall be at least as long as the preceding duty period, or 12 hours, whichever is greater.
      (2) By way of derogation from point (1), the minimum rest provided under point (b) applies if the operator provides suitable accommodation to the crew member at home base.

      (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.

      (c) Reduced rest
      By derogation from points (a) and (b), flight time specification schemes may reduce the minimum rest periods in accordance with the certification specifications applicable to the type of operation and taking into account the following elements:
      (1) the minimum reduced rest period;
      (2) the increase of the subsequent rest period; and
      (3) the reduction of the FDP following the reduced rest.

      The rest away from home base following duty 1 falls under ORO.FTL.235(b) and (c)

      The rest must be the length of the previous duty (13:30) or 10:00 which ever is greater (13:30). With only 12:30 rest provided, we now look at ORO.FTL.235(c).

      Under the reduced rest provisions, the rest may be reduced to as little as 10:00, in your case it was only reduced to 12:30, a 1:00 reduction. the next rest period must be increased by 1:00 and the FDP limits is reduced by 1:00.

      Duty period 2 is DHD only so no FDP reduction is required since it is at 0:00

      The rest at home base following duty period 2 falls under ORO.FTL.235(a)(1) and (2).

      The rest must be the length of the previous duty (5:30) or 12:00 which ever is greater (12:00). ORO.FTL.235(a)(1).

      Since this rest also requires a 1:00 increase do to the previous rest period being reduced, the minimum rest at base now becomes 13:00 = ( 12:00 + 1:00 ). With it being a compensatory rest period, it is not permitted to be reduced to less than 13:00.

      You did not inform me if the company is providing the CM a suitable accommodation at base. Under those conditions the required rest would then be the greater of the duty following duty 2 (5:30) or 10:00, 10:00 plus the 1:00 compensatory rest penalty (11:00)

      This is basically re-stated in

      CS FTL.1.235 Rest Periods

      (c) Reduced rest
      (1) The minimum reduced rest periods under reduced rest arrangements are 12 hours at home base and 10 hours out of base.
      (2) Reduced rest is used under fatigue risk management.
      (3) The rest period following the reduced rest is extended by the difference between the minimum rest period specified in ORO.FTL.235(a) or (b) and the reduced rest.
      (4) The FDP following the reduced rest is reduced by the difference between the minimum rest period specified in ORO.FTL.235(a) or (b) as applicable and the reduced rest.
      (5) There is a maximum of 2 reduced rest periods between 2 recurrent extended recovery rest periods specified in accordance with ORO.FTL.235(d).

      In short the rest at base needs to be 13:00 and may not be reduced unless the airline provides a suitable accommodation, then the rest may be as little as 11:00.

      I hope that my answer meets your needs.

      Please review your OM as your company may have differing procedures. You may want to reach out to your local CAA as they are the best source for clarification, (the EASA is no longer answering questions concerning FTL and they are pushing it down to the CAA’s).

      /Garret

      Like

      1. Many thanks for prompt reply!
        Just so I do not misunderstand. Does the rest before the positioning duty on day 2 in the scenario above need to be at least as long as the previous duty (13h 30 min) not to fall under “reduced rest”? I was under the impression that ORO.FTL.235 only regulates rest period before undertaking an FDP. Or is the 13.30 h rest needed because of the FDP on day 3?

        Reduced rest is not applicable in this scenario since our company does not have an approved FRM.

        Regards
        “Early Type”

        Like

      2. Tommy,

        I understand no reduced rest cause you do not have FRM at your company so only ORO.FTL.235(a) and (b) will be applied.

        Many thanks for prompt reply!
        Just so I do not misunderstand. Does the rest before the positioning duty on day 2 in the scenario above need to be at least as long as the previous duty (13h 30 min) not to fall under “reduced rest”?

        Correct, most airlines under EASA FTL are providing the rest immediately after the duty period.

        Section (b) is applied under the following conditions:

        the rest period is away from base
        the rest period is preceding the next FDP
        The next FDP is begins away from base

        So a Duty period is completed away from base, before the start of the next FDP away from base, the rest is 10:00 or length of preceding duty. For any rest period away from base must meet this criteria or else the crew member (CM) has not been released into a legal rest period, so the CM will be considered to be still on duty. This is why most airlines are taking the rest as soon as possible.

        In your original situation the rest period of 13:30 between duty 1 and duty 2.

        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.

        I was under the impression that ORO.FTL.235 only regulates rest period before undertaking an FDP. Or is the 13.30 h rest needed because of the FDP on day 3?
        Reduced rest is not applicable in this scenario since our company does not have an approved FRM

        Let us assume that the rest between duty 1 and duty 2 is a legal rest period.

        The rest at home base between simply need to meet the conditions in ORO.FTL.235(a), 12:00.

        (a) Minimum rest period at home base.

        (1) The minimum rest period provided before undertaking an FDP starting at home base shall be at least as long as the preceding duty period, or 12 hours, whichever is greater.

        (2) By way of derogation from point (1), the minimum rest provided under point (b) applies if the operator provides suitable accommodation to the crew member at home base.

        In summary, rest 1 is illegal should be 13:30 not 12;30.

        Rest 2 is legal.

        Like

  9. Is here any clear statement for administrative time (office meetings after a flight)

    Imagine flight starting at 5:00 outstation arriving 9:00 homebase, followed by a 4h meeting until 13:00. how would i have to calculate my min. Legal rest after this?

    Like

    1. In short, yes,
      ORO.FTL.105 Definitions Provides:
      (11) “duty period” means a period which starts when a crew member is required by an operator to report for or to commence a duty and ends when that person is free of all duties, including post-flight duty;

      So unless the crew member has been released into a rest period, that crew member is still on duty.

      ORO.FTL.235 Rest Periods stipulates that the rest at base must be at least 12:00 unless a suitable accommodation is provided.
      (a) Minimum rest period at home base.

      (1) The minimum rest period provided before undertaking an FDP starting at home base shall be at least as long as the preceding duty period, or 12 hours, whichever is greater.

      (2) By way of derogation from point (1), the minimum rest provided under point (b) applies if the operator provides suitable accommodation to the crew member at home base.

      In the case you provided the crew member is on duty from 05:00 to 13:00 for a total of 8:00, the minimum rest is 12:00, (10:00 with a suitable accommodation).

      The FDP is only 4:00, so the FDP limits are fine.

      All time on duty (8:00) will need to be applied towards the cumulative duty limits in ORO.FTL.205 Flight Times and Duty Periods.

      /Garret

      Like

  10. Hallo, I am flight attendant in a VIP airline. Recently, I had a POS flight from ATH to DBX and as soon as I landed at 5:00am my company asked me to make a flight to Moscow which was 10hours flight time. When I said that this exceed a lot my duty limitations, company replied that I am not a FA but an escort on board. But in GENDEC they have me as crew. What rules stands for vip flight attendants that are not considered as CREW on board?

    Like

  11. Dear Garret,

    I had a 2 sectors day finishing at 10am at home base.
    I was under the impression i was entitled to a 12 hour rest (free from phone calls from the compagnie)
    I got called at 16H to inform me of a roster change for the next day.

    Is this allowed ? Is the 12h rest only preceding a duty ?

    Thank you !

    Like

    1. Barb,
      You aked the following:

      I had a 2 sectors day finishing at 10am at home base.
      I was under the impression i was entitled to a 12 hour rest (free from phone calls from the compagnie)
      I got called at 16H to inform me of a roster change for the next day.

      Is this allowed ? Is the 12h rest only preceding a duty?

      It is allowed, but under exceptional circumstances.

      A rest perioud is defined under 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;

        An Operator may attempt to contact a crew member (CM) during a rest period, but the CM is under no obligation to answer/respond to the airline during a rest period. Should a CM volunteer to respond and the CM feels that they will be sufficiently rested the change in schedule may proceed. Should the CM feel that they will not be properly rested before commencing the next duty, the CM should decline the assignment based upon the potential of fatigue and advise the airline when they feel they will be ready to accept a new assignment.

        If the Airline is rescheduling to start the next FDP at or after 04H the next day, the improper rest argument may not be valid as a 12:00 rest period is being provided.

        An airline also has to understand that contacting a CM during a rest period may have an adverse and may disrupt the sleep a CM is attempting attain especially when a rest period includes the hours during normal waking hours (Day time) and make cause further disruption. This should be under ORO.FTL 110 Operator Responsibilities.

        While the EASA has no policy, the FAA dose have a 1-phone call rule. The Airline may try once during any rest to period to contact the CM, the CM may cite that the rest period has now been broken and the they will attempt to get back to rest for the required amount. An airline calling more than once during the rest period may be construed as harassment.

        /Garret

        Like

  12. Dear Garett,

    Does 1 in 7 exist with EASA ?
    Meaning one local day off per seven days.
    I have had a mix of flying duties and stand by since the 29th of april and tomorrow on my seventh day i will have another flying duty starting at 15h and finishing on my 8th day at 00:05

    Thank you in advance !

    Like

    1. Barb,
      You asked the following:

      Does 1 in 7 exist with EASA ?
      Meaning one local day off per seven days.
      I have had a mix of flying duties and stand by since the 29th of april and tomorrow on my seventh day i will have another flying duty starting at 15h and finishing on my 8th day at 00:05

      Tecnically NO.
      ORO.FTL has rest requirements which are defined in ORO.FTL.235.

      Part of provision is that a Crew member must be provided a Recurrent Extended Recovery Rest Period (RERRP).
      A RERRP must be at least 36:00 in duration, and it must include 2 Local Nights Rest.
      A RERRP may be given at or away from base. The maximum amount of time from the end of the preceding RERRP to the start of the next RERRP may not be more than 168:00.
      A RERRP must also be increased twice every month to include two full calendar days free from duty.

      A crew member assigned to Standby or Reserve (even if not called) is not on an RERRP and cannot be retroactively considered to have been given a RERRP as the crew member is free from all duty as they must me contactable and available to be assigned a duty.

      Best practices: generally will place the crew member on RERRP when at base.

      Do not confuse a RERRP withe a “single day free of duty” (SDFD), while similar, ORO.FTL does not actually enforce this, it merely defines it. a SDFD is controlloed by national/local labor laws,; not by EASA.

      /Garret

      Like

  13. Is it allowed to contact a crew member less than 12 hours before the scheduled flight duty / standby, or in other words does one not need 12 hours of UNINTERRUPTED rest time before duty start?

    Like

    1. A crew member on Standby may be contacted with less than 12:00 notice.
      CS FTL.1.225(b)

      A crew member on Reserve must first be given the required rest period before starting any FDP or duty.
      ORO.FTL.230 CS FTL.1.230,
      GM2 CS FTL.1.230 requires as little as 10 hours notification.

      A crew member may be contacted during a required rest period to be notified of a delayed reporting ORO.FTL.205(g), CS FTL.1.205(d)

      Like

  14. Dear Garett,

    does the rest period away from home base end at the time of pick up from the hotel or at the time of check-in (one hour before the flight) for the succeeding FDP?

    Thanks!

    Like

  15. Say you have a local day flying from base. The next day you only have a positioning flight away from base, no active legs. What is the minimum rest period at home base, before reporting for the positioning flight the day after, considering there will be no active FDP that day?

    Regards JP

    Like

  16. Hi Garret!

    When a crew member is scheduled a consecutive of 10 days OFF without an additional rest period applying to the requirements of RERRP of 2 local nights, does this accommodate the requirement of the following rule:

    AMC1 ORO.FTL.235(b) Rest Periods
    (d) ……….. The recurrent extended recovery rest period shall be increased to 2 local days twice every month.

    Appreciate your answer!

    George

    Like

    1. George,
      I believe the 10 days off would satisfy the 2 local days off, twice in the month rule.
      Each occurrence of the 2 local days off, must be contained within the month being evaluated.
      So if the 10 days off was split as the last 5 days off in Feb. and the first 5 days off in Mar. Both Feb and Mar are met this requirement.
      If the days off were split as 8 days in Feb and 2 days in Mar, Feb meets the Requirement, while Mar will need another 2 days off consecutively within Mar.
      Likewise with 2 days off in Feb and 8 days in Mar, the requirement is met for Mar, but Feb must have had an additional 2 days off consecutively within Feb.

      Under all circumstances, the calendar day/month measurement uses Home Base Time, and should have been scheduled in advance to the crew member. RERRP are permitted to be provided concurrently with other rest requirements in ORO.FTL.235 and they may be provided at or away from home base, (Best practices will have the RERRP provided in the home environment).

      /Garret

      Like

  17. Hello there
    I have a random question about AMC1 ORO.FTL.235(b).
    If the travel time is greater than one hour when away from base but I still get an 8 hour sleep opportunity, is this okay?
    For example, if my duty is 11.5 hours long, technically, I would need 11.5 hours rest. But what if the travel time to and from the hotel is 1 hr and 20 mins? Does the rest have to be increased by 40 minutes or is it okay because I still have an 8 hour sleep opportunity?
    Any help would be great!

    Like

    1. Gary,
      With respect to your question concerning rest requirements:
      ORO.FTL 105 Definitions
      (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;

      When a crew member is away from base the minimum rest period is 10:00, (ORO.FTL 235(b))
      (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.

      These requirements are further clarified by: AMC1 ORO.FTL.235(b)
      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.

      To address you example:
      Duty period of 11:30 in duration, with a total travel time to/from suitable accommodation 1:20 (0:40 to/from).
      If we add 8:00 (sleep opportunity) + 1:00 (physiological needs) + 1:20 (total travel time) = 10:20 (minimum rest period); however, under the regulations the rest period must be at least the length of previous duty period (11:20).

      If we adjust your example:
      Duty period of 9:30 in duration, with a total travel time to/from suitable accommodation 1:20 (0:40 to/from).
      If we add 8:00 (sleep opportunity) + 1:00 (physiological needs) + 1:20 (total travel time) = 10:20 (minimum rest period); this will exceed the requirement under the regulations where the rest period must be at least the length of previous duty period (9:30) but no less than 10:00.

      Like

  18. Hello,
    Your flight arrival has been delayed and you have only 11.30 rest before the next rostered flight.
    Can the operator call you before the Check in time to tell you that the flight has been delayed by 30 mins in order for you to have the minimum 12hrs.?
    I believe that you should not be contacted during your minimum legal rest period because you are being Interrupted ie not a continuous 12 hrs..
    What is your opinion.?
    Thanks

    Like

    1. Robert,
      Sounds more like a Delayed Reporting Time problem.
      CS FTL.1.205(d) provides
      (d) Unforeseen circumstances in flight operations — delayed reporting

      (1) The operator may delay the reporting time in the event of unforeseen circumstances, if procedures for delayed reporting are established in the operations manual. The operator keeps records of delayed reporting. Delayed reporting procedures establish a notification time allowing a crew member to remain in his/her suitable accommodation when the delayed reporting procedure is activated. In such a case, if the crew member is informed of the delayed reporting time, the FDP is calculated as follows:

      (i) one notification of a delay leads to the calculation of the maximum FDP according to (iii) or (iv);

      (ii) if the reporting time is further amended, the FDP starts counting 1 hour after the second notification or at the original delayed reporting time if this is earlier;

      (iii) when the delay is less than 4 hours, the maximum FDP is calculated based on the original reporting time and the FDP starts counting at the delayed reporting time;

      (iv) when the delay is 4 hours or more, the maximum FDP is calculated based on the more limiting of the original or the delayed reporting time and the FDP starts counting at the delayed reporting time;

      (v) as an exception to (i) and (ii), when the operator informs the crew member of a delay of 10 hours or more in reporting time and the crew member is not further disturbed by the operator, such delay of 10 hours or more counts as a rest period.

      In the case you provided, paragraphs (i) & (iii) would apply. The FDP limit is based upon the original FDP start time and FDP begins at the revised report time.

      The question comes up as to when the notification is provided. During a rest period, contacting the crew member (CM) is permissible, however, the CM is not obligated to “answer”, the CM may be asleep, so some common sense must be used by scheduling to understand when the CM is awake/asleep; a notification at the time a CM would be expected to begin preparing to depart the suitable accommodation (last 1:00) seems reasonable (my opinion).

      /Garret

      Like

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