For you good folks of the SLF community here is a precis of the proposed EASA limits that could be forced on us. We presently work to the scientifically based CAP 371, but these new proposals would appear to come from a combination of MEPs and accountants.
1. Reducing rest has always been at the behest of the aircraft commander, after he has taken consideration of the state of his crew. Under EASA it will be at the behest of the operator, maybe even just before report.
2. The max number of duty hours worked in 7 days will increase by 5 hours, but 'nothing' is being said about 14 days!!
3. The number of early starts will be almost unregulated and the 'window' defining an early start closes to only one specific hour - 0500 to 0559, from 0500 to 0659 at present.
4. The max flying duty period would be increased. The early morning allowabel FDPs show a huge increase in those in CAP 371.
5. The flying hour limit would increase to 1000 hours per '12 consecutive months' - up from 900 hours.
6. Minimum rest away from base could be cut to 7.5 hours from the existing 10 hours.
7. The present 2 days off together in any 14 days ensures that the body gets 3 nights to recover. There is no mention at all of 2 in 14 in EASA!!!
8. EASA makes no comment regarding doing a standby at home and then being called to carry out a flying duty period. There is therefore no protection about doing a standby followed by a long flying duty period.
9. Airport standby rules would be 'watered down'.
10. The definition of 'home base' would mean that you would be expected to report directly to that home base, but not get credit for the journey in any flying duty period.
11. A lot of the definitions and interpretations that are clearly defined in CAP 371 are not even mentioned in EASA.
12. EASA make no mention at all on several critical areas, such as: restrictions around late finishes and early starts, restrictions around what constitutes a night duty and options related to night operations, control if delayed at the start of a flying duty period.
As is usually the case, BALPA recognised the unsound review process of EASA and then did a thorough study of the document. All BALPA members were then advised of the problems and encouraged to look at the proposals. We have then been encouraged to contact MPs, who were briefed at Westminster, and the next step is to put carefully considered 'arguments' against some of the draconian measures being proposed.