Far 117
 

I've started the petition "FAA: Change FAR 117" and need your help to get it off the ground.

Will you take 30 seconds to sign it right now? Here's the link:

http://www.change.org/p/faa-change-far-117

Here's why it's important:

FAR 117 was written to promote safety issues concerning fatigue in commercial flying. FAR 117 did bring about some significant changes but fell well short of changes that need to be made.
Please voice your opinion, tell the FAA why FAR 117 needs to be or should be changed.

Lets not wait for another crash to bring about changes.

Look up FAR 117 at change.org

What specific changes would you recommend? In my opinion, 117 is light years better than the previous duty regs. Company can't adjust show times, duty period is based on critical factors such as acclimated start time and number of segments, and no reduced rest just to name a few.

The only thing I'd change would be the 10-hour rest. All rest should be 12 hours minimum. Other than that, 117 is light-years ahead of the old regs.

For starters, get rid of the bull**** 2 hour extension and the fact that the duty period ends at block in instead of 30 minutes after like the old rules. When I first saw FAR 117, I thought to myself they got it right. Then I realized I had to add 30 minutes to the times to compare it to the old way. Then I realized there was a 2 hour extension. Then I realized it was possible to do a 16:30 hour dutt day compared to 16 before. Wait, we can actually do a longer duty day under FAR 117? YES YOU CAN.

I work at a respectable major. My company expects you to extend. The only way not to is to go out of your way which to my company equates to a fatigue call. I know if my company treats it like that, then most other companies are also.

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.

Change #1 needs to be the inclusion of cargo pilots under 117. The other change that I have haven't seen mentioned above is the disruption of circadian rhythm within a trip. For example, using a combination of very long and very short layovers to move you from a night schedule to a day schedule, or the opposite. We don't need to eliminate it, but limiting the amount of movement per day help.

Any of the extensions are only allowed if the pilot agrees to it. I have never felt pressured to accept an extension. If the company is pressuring you into accepting a 2 hour extension, that sounds like an issue that needs to be brought to the attention of the FAA.

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.

You never have to accept an extension. I had one of the crafters of 117 on my JS a while back. He said the airlines are purposely misinterpreting the reg for their own gain.
Also ALPA, at least at my airline has done a miserable job of making pilots aware of this. Same with the rest rules. The reg states "8 hours of uninterupted sleep opportunity". Unless you sleep in your uniform, don't brush your teeth or shave and can fall asleep on command that means about 9 hours behind the door. I have several times used this and told the company I'll be at pickup at this time because of it. Never been questioned on it, but if they did give me grief I feel confident the reg would back me up.

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