I suspect all OMAs will state a flight duty period begins at report, (mine does).
Agreed, kind of self-evident, cue in the time-of-reporting-for-duty name
suspect none will specify where that is, (mine doesn’t). (Crew room, bag drop, security, car park, taxi rank etc - these are just examples to reinforce and illustrate the argument I am making, not that important in isolation but showing a more important lack of guidance.)
It is important. That part where you do not understand where is the place your employment duties commence. Who are the stakeholders and which responsibilities they have. Check with HR, it is useful to know. Luckily no need to take that with EASA, it's not aviation-related.
The EASA FTLs are standing on two feet
- 1 various numerical limits on activities
- 2 existence of effective fatigue management system
both of which are mandatory.
The 1) above are designed with the objective to allow for a great range of aviation activities and business models. For many if not most of them, the demands and practical restriction do not overlap. It is quite accurate to say that 1) was never intended to be exploited in all corners of its envelope in full by one individual or group and if that happens fatigue will ensue.
It is not breaking/extending beyond a certain limit that is reducing safety level below acceptable, working insufficiently alerted is. And indeed one could get fatigued when staying well clear of the boundaries, new rules and the old alike, even before we begin factoring the circumstances of personal and private life that do play a massive role by all means.
Hence the existence of 2). No matter if it's new teeth of your most beloved, or the EU devils who destroyed all that was good, a fatigue management system should contain the undesirable effects before the execution of duties is affected.
1) is not built water-tight to keep you at an acceptable state of alertness, 2) is. Feel free to quote me out of context whoever dares: The EASA FTL numerical limits are designed to enable fatigue (*). It is the mandatory FRMS that is put in place to ensure sufficient alertness levels of the crew on duty.
(*= as an unfortunate consequence of catering for a multitude of industry task patterns, in an all-encompassing manner)
This is not a defence of the EASA FTLs, but rather attempt to show how they are meant to work. A better understanding of which might help you handle the issues at hand with greater success. An anecdote from elsewhere, the regulator having sharper teeth:
a) extension in the planning stage (before the roster is approved and released) is not permitted
b) extension of FDP both before after commencing the duty is allowed up to 2 hours, but any extension beyond 30 minutes requires
- report to the NAA within 10 days by the Safety / Quality department suggesting measures to prevent re-occurrence
- after approval, those measures shall be implemented by the operator within 30 days.
c) there is a daily flight time limit, which is non-extendable (unless already airborne)