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Old 03-03-2009, 01:36 PM
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Default Duty Time Limitations

I was just curious if someone could provide a reference to part 121 where if specifically states that there is maximum duty time of 16 hours. I can easily find it in my company ops manual-- it has a max of 14 scheduled and 16 for operational delays. The union contract has even tigheter restrictions.

I was having trouble finding a specific reference that applies to 121 domestic operations. Not flag ops.

Thanks.
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Old 03-03-2009, 02:19 PM
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It's implied by the fact that in any 24 hour period you have to have at least 8 continuous hours of rest. The Whitlow letter clarified the FAA's stance:

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Old 03-03-2009, 02:32 PM
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See the previous post, he is correct.

Since it was not explicitly spelled out in the FAR's some airlines tried to push the boundary on that, which prompted the whitlow letter's re-affirmation of the 16 hour limit.

Note that there is a common misconception that things like deadhead or other company duty cannot exceed 16 hours...that is not the case. The FAA does not care one iota about your beauty rest, health, or well-being, as long as all 121 flight operations are concluded NLT than the 16 hour mark, what you do after that is between you, the company, and your union. Of course you cannot return to 121 flight operations until all duty/rest requirements are met.
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Old 03-03-2009, 06:38 PM
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What you do after the flight the FAA could care less about? What you do prior, whole different situation/
Keep in mind, that a reposition flight for the company is "other" commercial flying and counts against the hours total.
Repositon before 121 and the FAA cares, after 121 and the FAA only kind of cares.
As always, the only one that can determine if you are fit to fly is YOU.

IF, God forbid, something should go awry, the company is going to swear up and down that you didn't have to take the flight and that they are very fatigue friendly. The only certificate you are risking is your own.
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Old 03-04-2009, 06:30 AM
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Originally Posted by kronan
What you do after the flight the FAA could care less about? What you do prior, whole different situation/
Keep in mind, that a reposition flight for the company is "other" commercial flying and counts against the hours total.
Repositon before 121 and the FAA cares, after 121 and the FAA only kind of cares.
As always, the only one that can determine if you are fit to fly is YOU.

IF, God forbid, something should go awry, the company is going to swear up and down that you didn't have to take the flight and that they are very fatigue friendly. The only certificate you are risking is your own.
True, 91 flight hours on a repo do count against your flight time limits.
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Old 03-22-2009, 05:01 AM
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Can someone define rest? On most international destinations everyone has to travel through customs and take a shuttle to the commercial side of the terminal or walk depending upon location before the airport authorities release you to enter the country. The same is true on the return in the morning. I am not counting the bus ride to the hotel since most guys do not want to stay at the airport location. As the computer scheduling now adds new stops even leaving Hong Kong which puts the lines routinely at 14+20 which makes it contract legal and now extendable to 16 hours--what is legal show time and release time per the FAR and not contractual stuff? Is it at the aircraft, in the lobby, at the airport or at customs? The current situation could (and does) put you well over 16 hours NOT counting the bus ride to and from the hotel.

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Old 03-22-2009, 08:48 AM
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Originally Posted by fishalaska
Can someone define rest? On most international destinations everyone has to travel through customs and take a shuttle to the commercial side of the terminal or walk depending upon location before the airport authorities release you to enter the country. The same is true on the return in the morning. I am not counting the bus ride to the hotel since most guys do not want to stay at the airport location. As the computer scheduling now adds new stops even leaving Hong Kong which puts the lines routinely at 14+20 which makes it contract legal and now extendable to 16 hours--what is legal show time and release time per the FAR and not contractual stuff? Is it at the aircraft, in the lobby, at the airport or at customs? The current situation could (and does) put you well over 16 hours NOT counting the bus ride to and from the hotel.

Fish
Generally it is the time you report to the "Operations Area" which is usually the airport. My company requires 45 minutes prior at the airport, except international airports we arrive one hour early for customs...we don't get paid for the extra 15 (unless we hit our 1:2 rig or over-12 rig) but it does count towards our duty day for rest purposes.

The FAR's allow "commuting of a local nature" to not count as duty, and this includes hotel van rides (although I have seen van rides of 45 minutes each way, which is probably pushing the intent).
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Old 03-22-2009, 08:48 AM
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Originally Posted by fishalaska
Can someone define rest? On most international destinations everyone has to travel through customs and take a shuttle to the commercial side of the terminal or walk depending upon location before the airport authorities release you to enter the country. The same is true on the return in the morning. I am not counting the bus ride to the hotel since most guys do not want to stay at the airport location. As the computer scheduling now adds new stops even leaving Hong Kong which puts the lines routinely at 14+20 which makes it contract legal and now extendable to 16 hours--what is legal show time and release time per the FAR and not contractual stuff? Is it at the aircraft, in the lobby, at the airport or at customs? The current situation could (and does) put you well over 16 hours NOT counting the bus ride to and from the hotel.

Fish
Read FAR 121.481, .483, and .485 closely. You will notice that a 1 or 2 pilot crew is required to have 24 hours free of duty every seven days. PROVIDED that you do not exceed 8 hours of actual flight time in any 24 hour period, you are legal to remain on duty for 24 hours a day for six days straight. (If you do exceed 8 hours actual flight time in a 24 hour periodfor a 1 or 2 pilot crew you are required to have a rest period of 18 hours.) You also may not exceed 32 hours in seven days.

A crew with two pilots and an additional crewmember may also remain on duty for six days straight, but requires 18 hours rest if actual flight time is 20 or more hours in 48 hours, or 24 or more hours in 72 hours.

Not until you get to FAR 121.485, which deals with a crew of three or more pilots and an additional crewmember, does the FAR say that the operator "...shall schedule it's flight hours to provide adequate rest periods on the ground for each pilot who is away from his base and who is a pilot on an airplane that has a crew of three or more pilots and an additional crewmember."

Bottom line, the Feds don't care, until you break an airplane or have a Nav deviation or bust some other reg. Then they will charge you with carless and reckless, or flying while medically unfit due to lack of rest.

Your only protection is your contract, and the only help you will get is from your union.

Joe
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Old 03-23-2009, 10:23 PM
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Originally Posted by rickair7777
See the previous post, he is correct.

Since it was not explicitly spelled out in the FAR's some airlines tried to push the boundary on that, which prompted the whitlow letter's re-affirmation of the 16 hour limit...
If you are scheduled and/or fly combined more than 9 hours in a 24 hour period domestically, you must have 9 hours of rest in your look-back as opposed to 8 hours . Therefore your duty day is 15 hours, not 16. (part 121.471(b)(3) and 121.471(c)(3)).

This happens often in regional (and even major) airline flying (I just did one on my last trip). And example would be starting a trip around noon on day 1, flying say 7.5 hours including some unforeseen delays, ending the day around 11pm, and then scheduled to show at 7:30am to fly scheduled 2.0 hours before noon on day 2. This would be illegal because you haven't had at least 9 hours rest (7.5 actual plus 2.0 scheduled is 9.5 hours of actual and scheduled flight time, and 11pm to 7:30am is 8:30 rest). Crew scheduling calling you at 6:30am telling you to delay your show to get to 9 hours rest doesn't work. If they blow it and don't inform you the night before, they need to either deadhead you on the last leg or re-crew.
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