Originally Posted by Avroman

At my company, the extension language has been interpreted to mean that the 30 minute extension is automatic and requires a fatigue call to get out of. The 2 hour extension is at the pilot's discretion and can't be forced. But if you are deadheading at the back end of the trip, your 117 duty ended at block in and you can be scheduled to deadhead up to 14 hours after report, extendable to 15 hours for delays, no refusals allowed. Quite a gem for us reserves, to then get 10 hours before having to be back at the airport. I want to see duty end at the hotel on arrival, and start at van time so it's actually 10 hours AT the hotel.

Originally Posted by NoSidNoStar

The debrief time should count against the rest time, and it does not. There is a contradiction within 117 itself about this when it's said the rest it's free from any duty, but later it's said the rest start at the end of block time.

Originally Posted by Mesabah

The possible 18 hour duty period of a reserve is absolutely atrocious, and must stop. (4 hour call out + 14-12 hours duty)

Originally Posted by 404yxl

I agree that the 16 hour limit for 4 hours of short call plus FDP limit with an extension on top is bad, however, the reserve pilot should not be signing the fit for duty form if they are not fit for duty. The FAA has stated this. If they feel pressured they should be filling out an ASAP.

Originally Posted by Mesabah

They will be signing it, and they will be flying it, that's the whole point of it not being legal. Pilots fly what is legal, not what is safe, that's been going on in the industry forever, don't be naive. If we can police our own fatigue then why have 117 at all?

Originally Posted by 404yxl

Pilots can be unfit for duty under the FDP limits and the FAA has mandated that they shouldn't be signing the fit for duty statement if they are not fit for duty. How do you suggest regulating that beyond the fit for duty statement?

I don't disagree that the reserve limits are too long, but pilots also shouldn't be flying illegally. The company is just as responsible for making sure their pilots are fit for duty, but that doesn't mean the pilot can just use the excuse "I signed the fit for duty statement because 117 says I was legal" The FAA would answer that by saying, "You signed the fit for duty statement illegally knowing that you were in fact not fit for duty"

Again, if the pilots feel pressured into flying unfit for duty, then they should be filling out ASAP reports.

Originally Posted by NoSidNoStar

117 represents an improvement, but it needs to be fixed.
To name a few points that need adjusting:

The circadian rhythm it's not addressed properly, as it is legal for a pilot to fly very different times, one day from the other. For example you could start flying mid afternoon a day, and very early am the following day, and so on for more than five days. Reserve pilots could be especially exposed to that.

The debrief time should count against the rest time, and it does not. There is a contradiction within 117 itself about this when it's said the rest it's free from any duty, but later it's said the rest start at the end of block time.

The 8 hours opportunity to sleep it's not emphasize properly, and subject to interpretation, therefore 10 hours rest it's not enough in most cases.
12 hours would be more realistically appropriated.

117.21 allows reserve pilots to be on duty for 4 hours longer then line pilots, as the former would be safer to work for longer times. This is particularly concerning, given the fact that reserve pilots are already subjected to more disruption of the circadian rhythm.

The maximum amount of duty, or reserve + duty, should be max 14 hours.

When a pilot exceeds the maximum duty due to deadhead transportation, (compensatory) rest it's either 10 hours or double the deadhead time.
It's should be equivalent to the related flight duty period.

Under 117 if an extension it's required, the company must write an explanation to the FAA of the circumstances and the steps that will be taken to avoid such circumstances to happen in the future. So, if the extension is an exception that must be justified, the pilot should be free to refused it, without having to justify himself with a fatigue call. It is the other way around, it's the exception that must be documented, not the normal operation. This immunity for the pilot from any sort of report should be clearly stated in the regs.

Originally Posted by Mesabah

Yes, because a pilot would admit they wrongfully signed being fit for duty in lieu of an incident, come on. Of course pilots fly unfit for duty in the legal duty period. The FAA puts out a framework for rules they think are safe, and then hope for the best. The rules will always be stretched to their breaking point, no ASAPs will be filed. The only protection of safety is for the FAA to mandate a hard number.

Originally Posted by 404yxl

You didn't answer my question on how we should regulate pilots that are not fit for duty under the FDP limit.

Look, pilots aren't babies. It's their responsibility to not fly if they are not fit for duty. The reserve limits are too long in my opinion, but that doesn't mean the pilot is let off the hook for signing the fit for duty statement when they aren't.

Pilots complain about long duty days on reserve and how unfit for duty they are, yet they sign the release that they are fit for duty. And they are not to blame for part of that?

Originally Posted by Mesabah

How do you regulate a person's honesty? By using hard limits, that answers your question. The company is free to use a reserve pilot for 18 hours on reserve, they then throw the ball in the pilot's court whether he is fit for duty. Your answer to this problem, is to not sign the release, and file ASAP's. What does that accomplish, the company is well within its legal rights.

Originally Posted by 404yxl

Again, do you expect the pilot not to sign the fit for duty statement when they are not below FDP limits or do you think they should sign it? Do you still sign it because the regulations say you are still legal, even if you are not legal per the regulation that says you shouldn't be signing the fit for duty statement?

Just because the reserve limits aren't where they should be, doesn't let the pilot off the hook for signing the fit for duty statement when they are indeed not.

Originally Posted by Mesabah

I will give you a great example, contractually, we are limited to 14 hours at the airline. However, the company will provide financial incentives to go to the legal limit, if you're "fit for it". There is no proof you are breaking a regulation on something as subjective as fatigue. There is hard evidence that you went past a legal FDP. Also, what if you are getting on a 5 hour flight, as the last leg in an 18 hour duty period, and you feel great at the start of the flight?