According to the FAR a three pilot crew can not be scheduled to fly more than 12 hours , but it does not say much about rest requirement after or before a long duty day .

I have emailed the FAA and asked this but I still yet to hear anything back .

I looked up the FAR 121.503,121.521,121.525 but it is not clear . Anyone can shed a light on this.

Thx.

 

I'm guessing that since you reference Subpart S you're asking about Supplemental rules. If you have three pilots (heavy crew), no one's supposed to spend more than 8 hours flying but there's an interpretation that says you get 16 off afterwards since you've been aloft more than 8.

 

Are you referring to the Whitlow Letter, where in 2000, Whitlow (FAA General Counsel at the time) responded to Capt. Rich Rubin's inquiries about crew rest? Capt. Rubin was a pilot with AMR so his scenarios were those common to passenger carriers. The FAA later did codify crew rest in 12 CFR 121.471 to apply to all flight crewmembers.

In the letter, Whitlow said that a pilot could not depart on a flight if it would end beyond the 16-hour duty day limit. The Air Transport Association (ATA), joined by the Regional Airlines Association (RAA), sued the FAA alleging that what Whitlow did amounted to new rulemaking. The US Court of Appeals, District of Columbia Circuit, denied the consolidated petitions for review.

One thing has always nagged me about the crew rest issue. It's easy to say that 8 hours of flying has been reached and therefore the crew gets a 16 hour rest, but this implies that waiting around for the airport van, checking in at the hotel, etc are included in the 16 hours. I do not believe that is what the law intended.

If any of this does not answer your question, please ask again. And congratulations for being the first to post a question in the new Aviation Law Forum!!

 

I suspect the rule made some assumptions about the quality of hotel accomodations and ground transport available to crews back in the day.

I think the current rest mins are probably OK, but need to be adjusted so that rest begins when the crew has access to their room (ie they have key in hand) and ends when you report for ground transport in the hotel lobby. I would probably also get rid of eight-hour reduced...no less than nine.

The airlines would then build in an extra 10-45 minutes on each end of the day, whatever is appropriate for the distance and responsiveness of the hotel. If delays exceeded the allotted time on a reduced overnight, the crew would call and inform their schedulers of the need to push the showtime.

This would not affect the vast majority of existing schedules, but would save the occasional crew from working eight hours, having van/hotels issues, getting four hours actual sleep, and then coming back for more...

 

Yes I am asking about the Supplemental rules , I know we can work up to 18 hours duty day and not to be scheduled above 12 block hours but how much rest should we have if we fly ( lets say 10 hours).

Thank for the responds

 

transportation that is local in nature ( to/from the hotel for example) is considered part of your rest time.

even though we all know that means that 8 hours free from duty equates to maybe 6 hours of sleep time.

the catch all is that every pilot has to determine whether the "rest" is sufficient to go flying. In other words, are you fit for duty or not. If the answer is no, or the story to the NTSB is I was soooo tired and guess I shouldn't have flown....then don't.

 

I don't think it's the Whitlow letter but another one (I don't have my books with me now.) Non sched ops in the US with 3 pilots sharing the flying should get you 16 off.

 

Is there a reference any where that it says 16 hours.

 

no, but there is a reference that says you must be able to show 8 hours of rest in the preceding 24 hours....thus, the 16 hour "duty" day is born

see
121.471c1
135.265c1
121.5031
121.505b


there are some exceptions for international (eg long range pacific type flying). But, the big consensus is that a 16 hour day is enough. And, if you look into the human factors issue, a 16 hour day is excessive and should be raising some major warning flags if you are working for that long

 

Trust me I know 16 hour duty day is more than enough . I have called in fatigue few times already but where I am working the company had tried few times to send me on a trip where I only had 8 hours of rest after an 11 hours of flying the day before ( since it is international and a three crew flying ) there are no specifics in the regs about rest requirements. I have emailed the FAA almost two weeks ago and they still yet to respond to me.

Thanks guys