121 Pilots! I have a Reg Q to discuss
#91
Line Holder
Joined APC: Aug 2005
Posts: 59
Do any of you non-duty day worried folks really want to be talking to the NTSB at this point? Anybody really want to be arguing to the FAA that it was part 91, and thus no restrictions on how long you work?
Or change the story slightly and make it an 0500 DH to work, with no intervening rest period.
Anyone really want to be making the argument that since I wasn't on the crew manifest, that I really wasn't working? Or that it was a part 91 DH and thus 121.471.f doesn't really apply?
Or that Free From a Present Requirement to Work.....means that the only work the FAA Chief Counsel was talking about was 121 work.....or does he mean a more liberal interpretation of work in that anything the company tells/compels you to do is working. e.g if the company tells you to show up at 0500 for a pilot safety meeting, are you working? or would you consider it "rest" since you're not at the controls of your plane
Or change the story slightly and make it an 0500 DH to work, with no intervening rest period.
Anyone really want to be making the argument that since I wasn't on the crew manifest, that I really wasn't working? Or that it was a part 91 DH and thus 121.471.f doesn't really apply?
Or that Free From a Present Requirement to Work.....means that the only work the FAA Chief Counsel was talking about was 121 work.....or does he mean a more liberal interpretation of work in that anything the company tells/compels you to do is working. e.g if the company tells you to show up at 0500 for a pilot safety meeting, are you working? or would you consider it "rest" since you're not at the controls of your plane
The rest of it - well words fail me - I just hope you're never actually get called on to APPLY any of these regulations, because you're going to fail miserably at it.
#92
Line Holder
Joined APC: Aug 2005
Posts: 59
Ok, its illegal period. To accept a deadhead flight that will violate your 8 hours of rest in a given 24 hr window is illegal. Dead heading is not rest, very clear. Does the company push you to do it yes. Does the FAA care apparently no. They get away with it because you’re going home to sleep or do whatever not fly a plane. (The FAA is concerned with accidents or incidents. They are not concerned with you’re over all wellbeing when you are not going to be flying the next day.)
Your company saves big money not giving you a hotel and paying you for the next day.
Your company saves big money not giving you a hotel and paying you for the next day.
There is no "8 hours of rest in a 24 hr window" regulation, there is a lookback requirement based upon Part 121 FLIGHT TIME, but deadhead is not flight time, or if it is my logbook needs a serious going over......
#93
Line Holder
Joined APC: Aug 2005
Posts: 59
Yes, once again I find myself agreeing ...Even Mesa's crap contract lets us go at 16, and anything over 15 is not reducable to less than 10 hours rest. This is one thing they actually stick to in the contract.
Don't forget guys you can always limit that work day with the mention of the F-word! ....and I don't mean F-off for you new guys either
Don't forget guys you can always limit that work day with the mention of the F-word! ....and I don't mean F-off for you new guys either
Good luck with your "not reducable to less then 10 hours of rest" argument, let us know how the conversation with the chief pilot goes......
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