Good points CP.
However, I think it is unconscionable to place a restriction on a pilot when that pilot has no reasonable way of knowing whether the restriction applies. Let me explain.
I realise that your excellent example is only for the 7 day rule. Got it. For the purposes of this paragraph however, imagine that the only rule is the 900hr / 365 day rule. Imagine we've expanded your hypothetical roster so it goes to 900 hrs in exactly 365 days. How would Ms Bloggs know what time of day she did that flight 366 days ago, so she knows when she can start flying again? Ms Bloggs can't consult the operator's records - he was working her too hard, so she quit, and now she is onto her second employer, and the first bloke won't even speak to her let alone let her examine his flight records. And Ms Bloggs can't possibly remember times of day or when rest periods started & stopped. So she's stuck with the only records that CASA require her to have and to use, which is her logbook. All she can do is use logbook dates to determine when she can fly again.
Note in this case, "logged" hours are the only ones available, even though you've rightly pointed out that the CAO doesn't mention that word. Similarly, her current operator can't help, as his records only go back three months to when employment began. Despite his legal responsibility to roster Ms Bloggs correctly, he is just as dependent on her logbook as she is.
The adjusting the times to seemingly get a free day, as you've done to provide an example, is not so weird. In the first case, I think there is no day off owing. In the second case (roster moved back 2hours 1minute) there is a day off owing according to my reasoning. However, you've gotten a day off on the 1st of the month in the second example. So in the long term it averages out exactly the same.
That's why I suggest using dates in the logbook to satisfy the FTL. However, I could be wrong - all the above is just my highly non-lawyer-like reasoning, I admit.
Good discussion.
O8
Last edited by Oktas8; 2nd Nov 2012 at 04:31.
Reason: Addressing weirdness