Originally Posted by
Car RAMROD
You do realise that many management teams use the hard limits as "targets" and that you can still become extremely fatigued even when staying within "hard limits", don't you?
Nothing wrong with an FRMS. Nothing wrong with hard limits. It's the managerial support and culture that makes a rostering/limiting system, whatever it is, good or bad.
This is precisely why the original CAO48.1 brief, aligning Australian regulation with ICAO Annex 6 sought clarity and established clearly mandated limits which among other things saw rest periods in accommodation, not in transport. In the case of one high capacity RPT operator in Australia, 'rest period' was usually when still in the aircraft..
- TOD duty extension outside 12 hours were only to be granted where an unforeseen operational circumstances.
Unforeseen Operational Circumstances were defined as those in which the OPERATOR could not have anticipated the occurrence,
as it had only been observed in 5% or less of cases previously. Unfortunately for management, seasonal thunderstorms or peak hour holding were not likely to be grounds for an extension to be granted. Practically speaking this necessitated operators reducing roster TOD to say, 11 hours, with 95% of delays allowing the duty (as planned) was completed by 12 hours.
Is it any wonder such 'draconian' regulatory oversight was viciously opposed by airline management? Dare we say it, but at least one aviation union was happy to continue with the status quo....
Pilots collectively ought realise that the maximum roster limit offers protection for the operating crew. Stepping outside statutory protection (no matter what company manuals tell pilots) is not for the faint hearted. If something goes wrong (beyond say a hard 12 hour limit) the operator has a plausible defence that the pilot 'elected' to extend the duty. This is where
strict liability is a term that aircraft commanders and their 'offsider' will come to understand intimately.