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Whitlow Letter - 8 hours rest in 24 lookback

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Old 02-01-2010, 03:56 PM
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Default Whitlow Letter - 8 hours rest in 24 lookback

I am familiar with the FAA's Whitlow Letter, which basically says that time spent on reserve is not duty, but it's not rest either. In that, it says you have to be able to look back in any 24 hour period and find 8 consecutive hours of rest. There isn't anything that circumvents this when operating under Pt. 121 Supplemental (like FDX does), is there? Just curious, I'm trying to head something off before it starts...
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Old 02-01-2010, 04:29 PM
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The applicability of the Whitlow letter is isolated to Domestic only. Flag and Supplemental are not considered.

Actual flight determines when you can not continue, not duty time. If an opertor conducting operations under flag or supplemental alway kept the actual flight time under 8 hours in any floating 24 hour period, no rest would be required (for 2 pilot aircraft) until the 7th calendar day - when 24 hours free of duty would be required.

121.503
(a) A certificate holder conducting supplemental operations may schedule a pilot to fly in an airplane for eight hours or less during any 24 consecutive hours without a rest period during those eight hours.
(b) Each pilot who has flown more than eight hours during any 24 consecutive hours must be given at least 16 hours of rest before being assigned to any duty with the certificate holder

121.505 Flight time limitations: Two pilot crews: airplanes.
(a) If a certificate holder conducting supplemental operations schedules a pilot to fly more than eight hours during any 24 consecutive hours, it shall give him an intervening rest period at or before the end of eight scheduled hours of flight duty. This rest period must be at least twice the number of hours flown since the preceding rest period, but not less than eight hours. The certificate holder conducting supplemental operations shall relieve that pilot of all duty with it during that rest period
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Old 02-01-2010, 04:55 PM
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Here's what I am looking at. I start reserve at 1930z. Trip showtime is 0305z (not 8 hours between the two, not a legal rest period). End of duty for trip is 1215z. Looking back from 1215z, I don't have 8 hours of rest anywhere. Hopefully this helps...
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Old 02-01-2010, 05:14 PM
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Haz,

If your flight is domestic, it is not a legal pairing. You have to complete your duty within 4 hours after the end of your RP. In this case, your RP ends at 0730Z. Your trip needs to terminate by 1130z. If this trip is international, you're screwed. They could call you at 0729Z with a trip to Narita (not too likely unless you are flying the 777 or MD).
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Old 02-01-2010, 05:43 PM
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Originally Posted by golfandfly View Post
Haz,

If your flight is domestic, it is not a legal pairing. You have to complete your duty within 4 hours after the end of your RP. In this case, your RP ends at 0730Z. Your trip needs to terminate by 1130z. If this trip is international, you're screwed. They could call you at 0729Z with a trip to Narita (not too likely unless you are flying the 777 or MD).
Roger that, thanks.
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Old 02-01-2010, 06:05 PM
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Originally Posted by golfandfly View Post
Haz,

If your flight is domestic, it is not a legal pairing. You have to complete your duty within 4 hours after the end of your RP. In this case, your RP ends at 0730Z. Your trip needs to terminate by 1130z. If this trip is international, you're screwed. They could call you at 0729Z with a trip to Narita (not too likely unless you are flying the 777 or MD).
Also, the trip needs to land by 1100z so that you have 30 minutes to complete paperwork etc.
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Old 02-01-2010, 06:28 PM
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Is Canada and Mexico domestic or international in regard to this? By the way there was a Mem-Vancouver-Mem in 23 hours TAFB las night assigned to Reserve. Over 8 in 24 I guess 9 is OK and you rest after that on your own time?
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Old 02-01-2010, 07:16 PM
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Guess with 4a2b and Op Emergency all bets are off til called on it.
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Old 02-01-2010, 07:37 PM
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Originally Posted by viperdriver View Post
Is Canada and Mexico domestic or international in regard to this? By the way there was a Mem-Vancouver-Mem in 23 hours TAFB las night assigned to Reserve. Over 8 in 24 I guess 9 is OK and you rest after that on your own time?
It is considered International unless the carrier has applied for, and received, an op spec exemption to operate it under domestic duty rules.

Also, remember that "domestic" doesn't mean that it applies to a supplemental carrier flying domestically, it only applies to "Domestic" under the CFR, as opposed to Flag or Supplemental.
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Old 02-01-2010, 07:43 PM
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Originally Posted by viperdriver View Post
Is Canada and Mexico domestic or international in regard to this? By the way there was a Mem-Vancouver-Mem in 23 hours TAFB las night assigned to Reserve. Over 8 in 24 I guess 9 is OK and you rest after that on your own time?
You can be scheduled to fly over 8hrs in a 24hr period. You just need an intervening rest period.
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