muppet

Hello. Had a good look through the AICs but can't find anything on this one.

If employed full time by an airline does paid instruction below 1600Kgs count towards FTLs ?

The hours are not such an issue but day off rules are easily broken if your idea of a day off is sitting around on a grass strip on a summers day, but commit one hours flying....

Anyone point me towards the AIC ? WWW ? Beagle?

Whopity

FTLs are subject to the rules laid down in the approved Company Operations Manual ANO Art 82

Paid instruction, or unpaid instruction where the candidate hires the aircraft is aerial work, and counts towards your total hours as specified in Art 84.

Jumbo Driver

1.4 A flight crew member is required to inform anyone who employs his services as a flight crew member of all flight times and flying duty periods undertaken, whether professionally or privately, except for flying in aircraft not exceeding 1,600 kg maximum weight and not flying for the purpose of public transport or aerial work. Aerial work includes flying instruction for which the pilot is remunerated. It is also aerial work where valuable consideration is given specifically for flying instruction, even if the pilot receives no reward.

The above is extracted from Section A Introduction to CAP371.

Surely this indicates that such aerial work as you describe would need to be counted towards FTLs? Therefore, if you are just sitting around on a grass strip without flying that clearly would not count - but I would have thought in theory that the one hour of flying (if it was aerial work) would ...


JD



P.S. I can't find the AIC either ...

Keygrip

You appear to be talking about the UK CAA (with references to AIC's and your individual locations) in which case all the boks are irrelevant.

It's all a matter of who is doing it - and what the CAA want them to be able to do.

It varies from person to person. For some full time airline employees, the FTL is completely disregarded and the pilots encouraged to fly , for others the FTL will be specifically imposed to stop them doing stuff.

It doesn't matter what the books say.....and "THE" book that is quoted could be any one of various - depends how the CAA wants to make its case.

Jumbo Driver

What are you talking about, Keygrip?

UK ANO requires Operators to have a "Scheme" for regulating flight times, which must be approved by the CAA and be in accordance with the requirements of CAP371.

How precisely are you suggesting that such FTLs can be disregarded?


JD

muppet

Great JD, head nail etc,

Cheers

DFC

It is what is in the approved company opas manual that counts.

Generally the ops manual will comply with the appropriate CAP and/or EU ops.

I have not come across any commercial operators where instruction either in the aircraft (of any weight) or in the sim was not counted towards duty time limitations.

In some airlines, it is the weekly, monthly and annual hour restrictions that limit the hours available to instruct.

However, where those are not limiting, pilots still have to respect the requirements in respect of "days off" and they will find that their company requires that their outside activities do not restrict their availability for maximum duty times.

Pilots also have to respect the law in terms of turning up for work fully rested. It is unlikely that if you complete a busy series of days with an airline and are rostered on a series of rest days that you could claim to be fully rested when turning up at a flight school to work on your first day off.

It is also the case that if you work on your days off that you can not claim to be fully rested at your report time for the next series of days you work for an airline.

This simply means that usually the first 1 or 2 days off have to be just that -off and the 1 or 2 days prior to the next shift pattern have to be fully off also.

Your company also has to be aware of your duty times so that they can ensure compliance with the rules. This means that you have to tell them of the hours spent instructing.

Finally, EU Ops requirements have changed the way that rest is calculated. In the past rest started at the end of the duty period and provided that you had the required amount of rest you were available to work any time from the end of that rest.

Now the case is different in that rest ends at the start of the next duty period and starts an amount prior to that depending on the length of the previous duty.

Imagine you are expected to work for an airline starting at 0700 on Saturday. If you spend 12 hours involved in instructing on the friday then the company is responsible for ensuring that you were on rest from 1900 Friday night. How do they do that?

The only way that I can see a company letting you instruct on your days off is if you have enough duty free days between each period of "work" to allow the company maximum duty times at each end without reaching the 7 day limit. On a 5 on 4 off cycle, you basically can't do it because 12 hours duty 2 days before your airline working period starts reduces the airlines available hours by 12 in that 7 day period!!

I am sure that someone can find a way round the limits but I can't at the moment or at least not a proactical one.

No point is making onself availble next Tuesday to fly some IR students and then have to ring up Monday morning and cancel because the duty times you have done mean that flying Tuesday would put you over the limit!!

The only answer is to find an airline that gives you enough days off between working days so that what you do on your middle days off has no effect of their duty times. Having less duty hours for the same pay helps also!

Regards,

DFC

Jumbo Driver

Further to my earlier post, I have just come across FODCOM 16/2005, which (although now cancelled) contains the following FAQ:

4.1 Accountability of Flying and Duty Hours

Q. When a pilot undertakes secondary employment what is the requirement to maintain a record of flying?

A. CAP 371 states that pilots operating on a freelance basis are required to maintain a record of flying and duty hours which must be presented to an operator before undertaking a duty period. Similarly, when a pilot undertakes secondary employment, whether paid, unpaid, instructional or reserve flying in aircraft having a Maximum Take-off Mass greater than 1600 kg, the same requirement applies in order that they meet their personal responsibility, not to be in breach of their company FTL scheme.

This seems to carry the implication that below 1600Kg accountability may not be (so) relevant but offers nothing explicit.


Also, there is FODCOM 10/2009 (issued 6 April 2009), which contains the following three relevant paragraphs:

3.5 Secondary Employment

3.5.1 Commercial Air Transport (Public Transport) flights or flights operated by an air transport undertaking must be conducted by crews adhering to the requirements of an approved FTL Scheme. These Schemes specify the accountability of all flight and duty times of crew members. Some additional work-related activities, undertaken during assigned Days Off, could significantly impact on a crew member’s ability to sufficiently recover from both transient and cumulative fatigue. Certain activities, therefore, need to be recorded so that a crew member’s duty records adequately represent the overall potential for fatigue.

3.5.2 An example of when these activities need to be recorded is where a pilot undertakes secondary employment for which he has received the authority of the CAA and/or according to the privileges of a professional pilot’s licence, for example, duties undertaken in a flight simulator. The time engaged on these duties must be recorded and the crew member is required to provide this information to their primary employer (see Article 82(3) of the ANO 2005). The primary employer’s responsibility is to ensure that the minimum rest periods and Days Off requirements contained in their approved FTL Scheme are met.

3.5.3 Attempting to control other secondary and recreational activity through a similar process would create a significant administrative burden for both operators and crew members. In particular, it would be very difficult to define and account for ‘relevant activities’. Operators should therefore ensure that crew members are aware of the need to act in a professional manner in discharging their legal responsibilities under Article 83 of the ANO, by ensuring that effective use is made of all planned rest periods.

I'm not sure either of these help you much, muppet - perhaps you should re-direct the question to SRG ... ?


JD

Steak&Kidney_Pie

As an instructor and Corporate Public Transport pilot, having dealt with this one before, as long as the aircraft is below 1600kgs, it does not count towards CAP371 and a company FTL scheme.

Regards

SKP

DFC

How does that tie-in with the quote from Jumbo Driver above?

Does your main company's FTL specify that weight limit. It is what the ops manual says that is the requirement. The CAP only comes into it if you want to argue that the approved company FTL is incorrect.

I think that it would be reasonable of a company to require one of their pilots who was operating on a second job as a flight instructor to ask that pilot for their flight time limitation scheme showing how duty time while on the second job is calculated, how start time for duty was determined and how end time for duty was determined etc etc and most importantly of all how the second operation will through it's FTL scheme ensure that the company is protected.

Otherwise, you could have an instructor who is "on duty" at the school from 0900 to 1800, does 1 flight from 1200 to 1400 and records the duty time as 2 hours!!.

The whole area is a minefield for both sides!

The all excompasing quote from EU ops is;

Crew members should make optimum use of the opportunities and facilities for rest provided and plan and use their rest periods properly.

EU ops defines Rest Period as:

An uninterrupted and defined period of time during which a crew member is free from all duties and airport standby.

So instructing on days off only works when the employer provides more than the minimum rest.

Regards,

DFC

Keygrip

JD - I didn't expect you/anyone to agree or understand.

All I'm saying is that the question *appears* to be UK derived and therefore the CAA.....so it all comes down to which individual is trying to do what.

I've known flight instructors who have been grounded from all flight duties because they reached over 900 hours in one year - yet the CAA have deliberately scheduled airline guys to conduct paid aerial work on their rest days and standby days. Deliberate, intentional, disregard for any FTL.

So, a scheduled rest day from the airline could easily involve five hours of driving and six to eight hours of on-site duty (paperwork and flying). Possible 13 hours of duty on a scheduled rest day - and not just on one occassion.

Paid aerial work conducted at their base aerodrome, in airline uniform, so that they can meet the company 2hr standby rule to conduct a long haul flight if called upon.

There are numerous manuals on numerous subjects - many of which conflict with each other. The CAA will pull out and quote the relevant paragraph of which ever manual they WANT to use in order to support their position on any particular question.

A sort of flexible database.

Whopity

Then why does Art 84 State:
If what you say is true, it would be pointless exempting private flights!

Jumbo Driver

You are absolutely right, keygrip, I didn't understand - and I have to say I still don't ...

Instead of just apocryphal stories, can you specify which manuals you are talking about? FTL are very specific and are laid down in either CAP371 or Company Schemes - so, specifically, which of other "numerous manuals" are you talking about?


JD