It certainly is an issue with SAR operators as most FTL schemes are close to the 2000h limit if standby duty is counted in full. The Department of Transport has issued the following recommendation:
http://http://www.dft.gov.uk/stellen...on_611444.hcsp
At the moment it looks as though standby duty is fully accountable towards the 2000h yearly total. The recommendation however is to align the directive with CAP371 which in certain circumstances will half duty spent on standby.
Woolf