I think the biggest problem in the existing guidelines is that only 'earlies' are defined.
It is legal under the current definition to effectively do seven early starts in a row.
An example of a recent roster of mine...
Day one: Airport Sby. Rpt 06.00z (07.00L UK - NOT an 'early' by one minute).
Day two: 3 Sectors. Rpt 06.25z (07.25L UK - NOT an 'early' by 26 minutes).
Day three: 3 Sectors. Rpt 04.00z (06.00L Mainland Europe (AMS) - An 'early' under CAP371).
Day four: 3 Sectors. Rpt 04:30z (05.30L UK - Another 'early' under CAP371).
Day five: 3 Sectors. Rpt 04:30z (05.30L UK - Another 'early' under CAP371).
Day six: Airport Sby. Rpt 06.00z (07.00L UK - NOT an 'early' by one minute).
Day seven: 2 Sectors. Rpt 06.25z (07.25L UK - NOT an 'early' by 26 minutes).
Now I'm not in any way complaining about the amount of work here... Rough with the smooth and all that (I don't complain when I occasionally get 3 in a row off, 4 on then another 3 off - mind you it is rare).
The problem for me is that all seven involve me getting out of bed at or before the crack of sparrows. And yet four of the above duties are NOT 'earlies' - two by one minute and two by 26 minutes. This is actually not even rostering up to the CAP371 limits as one of these four could have been earlier as you're actually allowed to do four 'earlies' in seven days subject to a maximum of three in a row.
Surely what was intended by those who first worked on CAP371 was to allow one to 'recover' on days that are not defined as 'earlies'?
Such recovery, involves (at the very least, IMHO) being allowed to have a lie in.
And that's where the current regulations fall down. What would be more useful in avoiding the fatigue caused by early starts would be to make sure that once your quota of 'earlies' are used up in a given period, that any remaining duties should actually be 'LATES' and defined as such (i.e. not starting BEFORE 11.00L or similar) rather than simply not being 'earlies' (i.e. must start later than 07.00L).
I consider that the seven days work I was rostered above is simply a reprehensible and immoral abuse of the 'spirit' of CAP371. Unfortunately the spirit of what was intended does not feature in most companies' views on the subject of FTLs. Until changes are made to CAP 371 itself we will always hear those over-used words from crewing/rostering departments... "well, it's legal - so you'll have to do it".
What I have difficulty understanding is that if more than four 'earlies' in a seven day period could have had me so dangerously fatigued that it has to be leglislated against... how does the extra 54 minutes in bed that the above roster gives me (against all seven being made 'earlies') relieve this potential fatigue?
Are there any scientists out there who can explain it?
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Climbing at an R.A.T.E. of 1.53 vertical seconds per foot of thrust!