NOTO has been made aware of new pilot fatigue regulations that are coming into effect. Here are highlights of some of the concerns brought forward so far:
New Maximum Total Flight Duty Times:
New maximum total flight duty times (“on duty”) are 2200 hours in 365 days, 192 hours in 28 days, based on rolling dates (not fixed calendar dates) and either:
- 60 hours in 7 days if 1 single day off in 168 hours (approximately 7 days) AND 4 single days off in 672 hours (approximately 28 days) with single days off requiring night’s rest on BOTH side; OR
- 70 hours in 7 days if 120 hours (approximately 5 days) free from duty including 5 local night’s rest in any 504 consecutive hours (approximately 21 days) if not assigned any early, late, or night duty, no shifts over 12 hours, and maximum number of work hours is 24 in any consecutive 48. If these hours/restrictions are exceeded, the pilot must receive 120 hours off and be put on the 60-hour rule instead.
While flight time stops being counted at engines off, flight “duty time” continues to accrue until the pilot is released from duty (for example, all post-flight duties such as paperwork, positioning aircraft, grooming, etc. are completed).
Time spent working, even if not flying, counts as duty time for the purpose of this calculation.
Unforeseen Operation Circumstances (UOC):
UOC includes adverse weather, equipment malfunction, air traffic control delay, or anything that is beyond the control of an air operator or private operator. In the event of UOC, the Captain must consult with all pilots and may then, at their discretion:
- Extend the maximum duty day by one hour for single pilot operations, two hours for two crew operations, or three hours for augment operations if only one flight is to be flown (two hours maximum if more than one flight);
- Increase the rest period after the duty day (minimum of at least the time of the extension); and/or
- Reduce the duty day. Pilots have a responsibility to respect fatigue considerations as they apply to each unique situation.
These options combined with the new “on-duty” definition has been brought forward as a concern.
NOTO would like to hear how these new regulations may impact you if you are a pilot, or operate an air service or if your business is dependent on air services. If you have any concerns or comments, please let us know.