New crew rest laws!

They have to sign a statement saying they are fit for duty before every flight?

Come on, man
 
One summary I read said something about cargo being exempt?!

If you're flying cargo, you can go smear yourself all over the side of a mountain at night IMC because you haven't slept... no one will care.

Sends a really bad message from the FAA, if you ask me.

If it's about PILOT fatigue, it should be applied evenly.

Flying boxes of crap around is just as tiring and difficult as flying people around.

Safety. You haz it... if you're flying people. Otherwise, keep doing what you were doing...

Heh... I'll have to go read up and see if the summary was correct.
 
denverpilot said:
Sends a really bad message from the FAA, if you ask me.
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If you lobby hard enough, you can often get your way... *cough cough* UPS *cough cough*

Cargo was exempt citing reasons of excessive cost to implement the same rest requirements. Hrmm... cost vs. safety.
 
HPNPilot1200 said:
No more reduced rest is probably a step in the right direction.
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Just playing the devils advocate, How many steps do we take?
Is nine hours enough?
If you have ever flown that system then you know 8-9 hours block in to block out is nothing.
Unload passengers, postfight, walk to van that may or may not be there. Find something to eat , shower, hope you can fall asleep soon. :hairraise:


denverpilot said:
One summary I read said something about cargo being exempt?!

If you're flying cargo, you can go smear yourself all over the side of a mountain at night IMC because you haven't slept... no one will care.

Sends a really bad message from the FAA, if you ask me.

If it's about PILOT fatigue, it should be applied evenly.

Flying boxes of crap around is just as tiring and difficult as flying people around.

Safety. You haz it... if you're flying people. Otherwise, keep doing what you were doing...

Heh... I'll have to go read up and see if the summary was correct.
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I am not shur of the reasoning, but i would bet that it is because they don't use the same kind of schedules.
 
flyingmoose said:
Just playing the devils advocate, How many steps do we take?
Is nine hours enough?
If you have ever flown that system then you know 8-9 hours block in to block out is nothing.
Unload passengers, postfight, walk to van that may or may not be there. Find something to eat , shower, hope you can fall asleep soon. :hairraise:
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I see what you're getting at. 9 hours isn't enough. Arguably 10 hours isn't much either. I live an hour from where I work so after a 30 minute post flight and paperwork a 10 hour rest period looks closer to 8 and about 5 or 6 hours of sleep.

The new rule is certainly a step in the right direction but not nearly enough to provide a comprehensive solution to the problem. But at least rest periods won't keep getting reduced to 8 hours.
 
A 180-Club buddy flew for one of the regionals prior to getting on with UPS. When I asked, he said the biggest difference is that the boxes don't complain.
 
Greg Bockelman said:
No. It is because they don't haul PASSENGERS.
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Ok maybe, but can you show me that somewhere? I have flown boxes and crew rest issues are usually not a problem..you fly to the hub, you fly from the hub go back to work tomorrow. And yes I know there is exceptions. I used to have a 9a.m. to 5 p.m freight job.:thumbsup:

wabower said:
A 180-Club buddy flew for one of the regionals prior to getting on with UPS. When I asked, he said the biggest difference is that the boxes don't complain.
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Very true:yesnod:
 
Cargo exemption bought and paid for by the evil brown empire UPS
There are some downsides..
I'm actually thinking a 14 day line is now a 16 or worse...continuous duty overnights obliterated..so lots of efficiency lost..
 
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The final rule with accompanying excuses and rationalizations is 311 pages long. It's gonna take some time to digest it all before coming to the conclusion that it's all a variation of the same old **** sandwich.
 
Rotor&Wing said:
Until a 800,000 pound 747 full of cargo goes plowing through a subdivision.
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I see your point, but the fact is we have different levels of safety for the different types of operations. If we tried to have a single level of safety, we'd ban single engine planes, require two-person crew on all airplanes, and all fly under one set of rules.

Like everything else, it's a trade-off.
 
TMetzinger said:
I see your point, but the fact is we have different levels of safety for the different types of operations. If we tried to have a single level of safety, we'd ban single engine planes, require two-person crew on all airplanes, and all fly under one set of rules.

Like everything else, it's a trade-off.
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I can't buy that. The cargo guys are flying the same equipment, in the same airspace, at the same time as the passenger carriers are operating. The only difference is the type of cargo in the back.

At this moment the cargo guys are operating with the same duty/rest times as the passenger guys (Domestic, Flag and Supplemental). So essentially we have "one level of safety" for the Part 121's.

Now for the "fix" we're going to increase safety for one and not the other? :dunno:
 
Rotor&Wing said:
I can't buy that. The cargo guys are flying the same equipment, in the same airspace, at the same time as the passenger carriers are operating. The only difference is the type of cargo in the back.

At this moment the cargo guys are operating with the same duty/rest times as the passenger guys (Domestic, Flag and Supplemental). So essentially we have "one level of safety" for the Part 121's.

Now for the "fix" we're going to increase safety for one and not the other? :dunno:
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Do you think that what we had before was "Un-safe?"
 
flyingmoose said:
Do you think that what we had before was "Un-safe?"
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I believe the current rules could be easily manipulated and abused. I flew under all 3 (flag, domestic and supplemental) and had first hand experience of just how fatiguing it could become.

I believe in "one level of safety" for all operations.
 
Rotor&Wing said:
I believe the current rules could be easily manipulated and abused. I flew under all 3 (flag, domestic and supplemental) and had first hand experience of just how fatiguing it could become.

I believe in "one level of safety" for all operations.
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Doe you mean that there should be one level of safety for 121, and another for 91?

I'm not disagreeing with you on the exemption for cargo, necessarily. But there's always a cost/benefit tradeoff for regulations.

In 121 passenger ops you have the crew, the pax, and the people on the ground at risk.

In 121 cargo ops you arguably have fewer people at risk, since there are no pax.

Eventually, somebody has to look at the costs of changing the way things work versus the benefit/savings of changing the way things work. We could make cars more crashworthy but then they'd cost more and get worse mileage. We could make houses more fire-safe but then they'd cost more to buy and maintain.

I've watched the cost of operating one of our client's computer infrastructures go up by 25% or more last year due to increased requirements for computer security, which translates into more staff-hours to do the work. For some applications it's a reasonable thing to do. For this particular application, which is not available on the internet, it may not be. But it's easier to just apply the "highest" level of security to a system than it is to do the analysis and reach (and defend) the conclusion that it's not justified.

I'm playing Devil's advocate here, I don't understand why there's an exemption for cargo, but I'm assuming that somewhere there's a decision memorandum where somebody justified or rationalized it.
 
Rotor&Wing said:
I believe the current rules could be easily manipulated and abused. I flew under all 3 (flag, domestic and supplemental) and had first hand experience of just how fatiguing it could become.

I believe in "one level of safety" for all operations.
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Well, the industry does draw a distinction between a Catastrophic failure with many fatalities and a Severe-Major failure with possibly, say, one or two fatilities.

The safety requirements are pretty close, but there are differences.

Trying to apply the same level of safety to all systems and operations is unrealistic.

edit: I hope the fatigue issue is addressed by more than just adequate crew rest between shifts (e.g., allowing power naps on very long 15+ hour flights)
 
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Rotor&Wing said:
I believe the current rules could be easily manipulated and abused. I flew under all 3 (flag, domestic and supplemental) and had first hand experience of just how fatiguing it could become.

I believe in "one level of safety" for all operations.
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All rules are eventualy manipulated and abused I think.
The reason I posted this link was to start a discussion on the crew rest issues and the way we use the blanket of safety to get some feel good regulations. The people who wanted this after the buffalo crash are going to feel vindicated. We can change anything in any industry if we have enough people say "Its for safety!" While we know that crews are still gonna get tired and fatigued, its just the way it is. Trust me I would not be complaining about an extra hour.

They also sited that over 10 years this is going to prevent 1.5 fatal accidents?? Is this the average over the years of fatal accidents that were given the "Fatigue" label?

I don't know why cargo got an exemption, maybe they bought there way out and maybe the risk was the boxes and no one cares about them. Idk!
 
I dont care how much mand. or comp rest you give me I still will sleep like crap and on the last day of a 4 day everyone is dog tired...commuting makes all of this worse
 
also who is really going to say "Ya I'm fatigued" more that a time or 2 before a carpet dance is in order
 
The Independent Pilots Assn. (IPA), representing about 2,700 United Parcel Service (UPS) pilots, petitioned a US federal court in Washington Thursday, challenging cargo carriers' exemption from new pilot flight time, duty and rest regulations finalized by FAA Wednesday.
G65_a2LowZ0


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Our company complies with 121 crew rest requirements even though we are a 135 cargo operator. I was very upset to see that cargo pilots are totally left out of this. Especially after we just had an incident at our company with a pilot falling asleep...
 
What effect, if any, will this have on the pilot labor market ?
 
Depends on if the passenger carrying 121 operators decide its cheaper to hire some folks or cancel flights more often due to lack of non-timed-out crews. ;)

There's going to be some interesting unintended consequences to this one, I suspect.

Some may use it as a way to dump routes while utilizing the new law as the scapegoat. I can see the Press Releases now... "Due to the new FAA crew rest requirements, XYZ airline will no longer be hiring ZYX RJ/turboprop operator airline to service Cities A, B, and C."

None will be able to play the opposite Marketing card of, "This change will not affect our operations because our airline was so committed to your safety that we were already exceeding the crew rest requirements."

A missed strategic competitive opportunity, really. They all knew it was coming. Margins are too thin these days for any of them to have played that PR card.
 
TMetzinger said:
Doe you mean that there should be one level of safety for 121, and another for 91?
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Comparing Part 91 ops to Part 121 ops is like comparing apples to pineapples.

TMetzinger said:
I'm not disagreeing with you on the exemption for cargo, necessarily. But there's always a cost/benefit tradeoff for regulations.
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I'm looking at this from the safety side. A tired fatigued crew is an accident waiting to happen.


TMetzinger said:
I'm playing Devil's advocate here, I don't understand why there's an exemption for cargo, but I'm assuming that somewhere there's a decision memorandum where somebody justified or rationalized it.
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Two big cargo operators, one with Purple airplanes and another with Brown airplanes lobbied hard for the "cargo cut out" as the proposed rules would have increased their crew cost.
 
TMetzinger said:
Does you mean that there should be one level of safety for 121, and another for 91?
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That has been the case for years. Look at the certification requirements for pilots. The higher up you go with certificates the tighter the standards. An ATP is held to a higher standard than a Private Pilot. Part 91 IS held to a different standard than 121. What this is essentially doing is creating TWO standards for part 121.

I'm not disagreeing with you on the exemption for cargo, necessarily. But there's always a cost/benefit tradeoff for regulations.
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I wonder how much of that is due to a lobbying effort on the part of the Cargo guys.
 
Rotor&Wing said:
Comparing Part 91 ops to Part 121 ops is like comparing apples to pineapples.

Yes, I know, but when you said "one level" I wasn't sure I understood what you meant.

I'm looking at this from the safety side. A tired fatigued crew is an accident waiting to happen.

No argument from me, but...


Two big cargo operators, one with Purple airplanes and another with Brown airplanes lobbied hard for the "cargo cut out" as the proposed rules would have increased their crew cost.
And who in the FAA bought their argument?
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Responses in bold. I'm not disagreeing with you, but I am trying to find out what the other side of the argument was, and why it was apparently persuasive to the regulators.

Edit: This is FAA rulemaking, not legislation, right? I can see where the Cargo guys could buy congressmen, but they aren't supposed to be able to buy the FAA guys (at least not as easily).
 
How is the safety record of the parcel haulers (as in the ones using big planes, not including the small fry in Barons and Navajos) ?
Is there any data to support that fatigue is as big of a problem in their operation as it is in the passenger business ?
 
http://www.ipapilot.org/petition_nprm/AdditionalPointsIPAFAAChallenge.pdf

FAA acknowledges the general concept that pilots working under the same conditions will feel the same level of fatigue regardless of the type of operation that he or she is participating in.” (e.g., Rule p. 259 (emphasis added)), but, incredibly excludes a whole category of operations – air cargo --from the scope of the rule.

...

The pilot fatigue that was a factor in one of the air crashes cited by NTSB and FAA as spurring the need for the new rule was brought about by “a demanding round trip flight to Europe that crossed multiple time zones . . . [and] involved multiple legs flown a night following daytime rest periods that caused the flightcrew to experience circadian rhythm disruption” (Rule at p. 21). In fact, this was “a regular cargo flight from Germany.” NTSB Aircraft Accident Report PB95-910406 p. 2 (emphasis added).

...

Yet the NTSB Chair stated that “we are extremely disappointed that the new rule is limited to Part 121 carriers. A tired pilot is a tired pilot, . . . whether the payload is passengers or pallets. As the FAA said in its draft, „Fatigue threatens aviation safety because it increases the risk of pilot error that could lead to an accident.‟ This is particularly a concern for crews that fly „on the back side of the clock.‟” NTSB Press release 12-21-11.
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Just look at the cargo pushes, FedEx for example. You could be looking at a duty period beginning at 0300 or so. I'm not saying that part 121 airlines don't have duty periods that start around the same time, but the cargo outfits operate a majority of movements at odd hours of the night which can interrupt your circadian rhythm.

I had an 0400 show this past summer... I live an hour from the airport so I had to get up at 0130-0200 to get ready. It was part 91 so we didn't have a hard "max duty day" but when we returned at 1600 we were both exhausted. I didn't get home until 1730 after post flight and paperwork. In retrospect I probably shouldn't have driven home.
 
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On the other hand, Jason, I've worked 3rd shift and after getting used to it (about a week) I was fine.

What really sucks is when you can't get into a steady cycle. When I was in the CG I'd sometimes have watch cycles that varied and I would be a zombie after a couple of days.

Put another way - going to work at 0100 isn't bad if you do it regularly. But from what I've seen of the schedules both pax and cargo pilots fly, it's practically the opposite of "regular".
 
TMetzinger said:
On the other hand, Jason, I've worked 3rd shift and after getting used to it (about a week) I was fine.
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Most of the time the schedule isn't consistent though. It is usually all over the place with a few early starts thrown in there.

TMetzinger said:
Put another way - going to work at 0100 isn't bad if you do it regularly. But from what I've seen of the schedules both pax and cargo pilots fly, it's practically the opposite of "regular".
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Exactly.

I thought this was interesting and worth sharing:

LOUISVILLE, December 21, 2011 – The following statement is from Captain
Robert Travis, President of the Independent Pilots Association (UPS pilots):

"Giving air cargo carriers the choice to opt-in to new pilot rest rules makes as much sense as allowing truckers to 'opt-out' of drunk driving laws.
To potentially allow fatigued cargo pilots to share the same skies with properly rested passenger pilots creates an unnecessary threat to public safety. We can do better.

Congress directed the FAA to create new science-based flight and duty rules to establish one level of aviation safety to protect the public. Today, under intense pressure from the cargo industry lobby, the FAA has failed to carry out this basic congressional mandate.

At the same time we work to reverse the ‘opt-in’ provision, we will ask UPS to voluntarily operate under these new science-based safety rules. UPS is a premier company and our expectation is that UPS will honor their longstanding pledge to operate the world’s safest airline.”
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My point in all of this is that someone in rulemaking in the FAA felt that he could defend excluding the cargo operators from the new rule.

It will be interesting to learn who that person is (or who they are), and what their reasoning is.
 
TMetzinger said:
My point in all of this is that someone in rulemaking in the FAA felt that he could defend excluding the cargo operators from the new rule.

It will be interesting to learn who that person is (or who they are), and what their reasoning is.
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I suspect part of the justification can be found in the distinction between Catastrophic hazards and Severe-Major hazards.
 
Rotor&Wing said:
I can't buy that. The cargo guys are flying the same equipment, in the same airspace, at the same time as the passenger carriers are operating. The only difference is the type of cargo in the back.

At this moment the cargo guys are operating with the same duty/rest times as the passenger guys (Domestic, Flag and Supplemental). So essentially we have "one level of safety" for the Part 121's.

Now for the "fix" we're going to increase safety for one and not the other? :dunno:
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Boxes don't vote.
 
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