Cujo665

It says released from duty, otherwise they’d start the rest when the brake is set. This actually works in our favor.

All this section means is the minimum rest between FDP’s is 10 hours. The 10 hours starts when you go off duty, not when the FDP ends.
THEN
The rest of the rule kicks in. It says that the minimum 10 hour rest period must end immediately prior to starting the FDP. So, if you have a 20 overnight, yes, your rest period starts once you’re off duty, but it’s the 10 hours before the FDP that counts.

You have to have a 10/8 immediately prior to the FDP (or reserve period). On a minimum rest overnight that 10 hours starts when you go off duty and finishes when you report 10 later. It establishes 10 hours as the minimum overnight (time between FDP). You can have more time off in between... you can even have your prospective 30 hours... you still need 10/8 immediately prior to starting a new FDP.

It’s dont ask, don’t tell.

Cujo665

That is written to establish a 10 hour minimum. If you have more than 10, then the only portion effecting you is the part about 10/8 immediately prior to the new FDP. You can have more rest measured from when duty ended, you just can’t have less than 10 measured from when duty ended.
If you do have more, it’s the 10/8 immediately prior to the new FDP that counts. This is clear, even in the interpretations cited elsewhere in this thread.

Baradium

Nowhere does it say what you are asserting. What interpretations concur with your assertion? There is nothing that says that only the 10 hours prior to your next FDP counts. It also does not say anywhere that it uses a 10 hour look-back, only that the minimum is 10 hours with 8 inside it. You can have 20 hours with 8 inside it as well.

This is not "clear" in the regulations because you are the only one who even thinks this. Why don't you send an e-mail off to the FAA and see what they say to you about it. Just because you think something would make sense in a regulation doesn't mean you get to add it in on your own and require everyone else to abide by it.

Flyhayes

Jeeezus Murray and Joseppi....

Also for what it's worth, you're not necessarily considered a crewmember when occupying the jump seat. That's a function of airline policy. So no, the FAA will not pop you for that either.

vessbot

This is incorrect. 117.25 does not say this.

Cujo665

§117.25 Rest period.

(a) No certificate holder may assign and no flightcrew member may accept assignment to any reserve or duty with the certificate holder during any required rest period.

(b) Before beginning any reserve or flight duty period a flightcrew member must be given at least 30 consecutive hours free from all duty within the past 168 consecutive hour period.

(c) If a flightcrew member operating in a new theater has received 36 consecutive hours of rest, that flightcrew member is acclimated and the rest period meets the requirements of paragraph (b) of this section.

(d) A flightcrew member must be given a minimum of 56 consecutive hours rest upon return to home base if the flightcrew member: (e) No certificate holder may schedule and no flightcrew member may accept an assignment for any reserve or flight duty period unless the flightcrew member is given a rest period of at least 10 consecutive hours immediately before beginning the reserve or flight duty period measured from the time the flightcrew member is released from duty. The 10 hour rest period must provide the flightcrew member with a minimum of 8 uninterrupted hours of sleep opportunity.

(f) If a flightcrew member determines that a rest period under paragraph (e) of this section will not provide eight uninterrupted hours of sleep opportunity, the flightcrew member must notify the certificate holder. The flightcrew member cannot report for the assigned flight duty period until he or she receives a rest period specified in paragraph (e) of this section.

(g) If a flightcrew member engaged in deadhead transportation exceeds the applicable flight duty period in Table B of this part, the flightcrew member must be given a rest period equal to the length of the deadhead transportation but not less than the required rest in paragraph (e) of this section before beginning a flight duty period.

https://www.ecfr.gov/cgi-bin/text-id...7_125&rgn=div8

end copy

Per E; you must have a rest period that begins being measured when the duty period ends. This rest period must allow at least 10 hours, with an 8 hour rest opportunity, immediately prior to starting a new FDP or reserve.

Per E; you must have an 8 hour uninterrupted sleep opportunity in the 10 hours immediately preceding the FDP. Explain how you had that driving more than 2 hours to work, or how you had 8 hours uninterrupted jumpseating.

Per F; you can not report for duty without having the rest required under E. If you didn't get it, you are supposed to notify the certificate holder..... which is what everybody does on days 2,3,4,5..... so, where's the exception for day 1?

The Airlines know this, the FAA knows this, the Unions know this....
it's all Don't ask & Don't tell.

Carry on.

Flyhayes

Bravo! You can copy and paste! And even highlight!

But it still doesn't mean what you think it means. You are still conveniently not highlighting the "at least" in under paragraph e). That "at least" changes the entire meaning of the paragraph. In legalese, every word is weighed carefully.

If you're still have problems wrapping your mind around this I highly encourage you to reach out to the FAA and obtain a legal interpretation. Although, those of us who enjoy studying LOI's will probably get a good chuckle at your expense for your waste of the FAA's resources.

This is where you go: https://www.faa.gov/about/office_org...s_offices/agc/

teddy3412

The rules clearly read that the rest period has to be AT LEAST 10 hours and contain the 8 hour sleep opportunity in there somewhere. To clarify a rest period is defined as:

"The FAA has said that for a “rest period” to be legal it must be: 1) continuous, 2) determined prospectively (i.e. known in advance) and 3) free from all restraint from the certificate holder, including freedom from work or freedom from the present responsibility for work should
the occasion arise."

Also the fact that the reg clearly states it must be AT LEAST 10 hours prior to the fdp means it can be 10 hours or months for all they care as long as it touches the beginning of your fdp (which is why they use the word immediately). The 8 hour sleep opportunity also has to occur within this AT LEAST 10 hour sequence.

If you were to receive 48 hours off from work and then had an fdp after that time was up, would you have not received at least 10 hours of rest period (defined above) containing 8 hours of sleep opportunity immediately prior to the fdp? 48 hours is well above 10 and it all occurred immediately prior to beginning your fdp and you would have had 8 hours in 48 to have a sleep opportunity.

You really should just contact the faa or someone in your company because they will repeat exactly what everyone here has been saying.

Flyhayes

Denser than Osmium....

vessbot

If you take out the subordinate clause "of at least 10 consecutive hours" the sentence reads:

"No certificate holder may schedule and no flightcrew member may accept an assignment for any reserve or flight duty period unless the flightcrew member is given a rest period immediately before beginning the reserve or flight duty period measured from the time the flightcrew member is released from duty."

Without it, the sentence is fully grammatical and carries out the gist of its content: You need a rest period, and the rest period itself must be immediately before beginning the reserve/FDP, and is measured from release from the previous duty.

"Of at least 10 consecutive hours" is a quality of the rest period, which may as well be 500 hours. Nothing about the clause, or its relation to the rest of the sentence, implies that the 8 hour sleep opportunity must be contained in the last 10 hours of the rest period.