ORD 27 hr layover

[ima birdbrain]

MR8 The company response to that ASR was incorrect.
Show me the reference to the variation...there is none.
CH 7 OMA is long over due for a re write, and I would suspect this has been ongoing for some time however yet to see the light of day.

GCAA CAR regulation 1.1040b requires any variation to CARs to be listed at the front of the OMA , its located at the start of the OMA.
Otherwise an approval must be issued by the GCAA, these letters are not a blanket approval and there is a process that should be followed.

Given the numerous non compliance issues with our OMA section 7 ULR and the GCAA CARs, I doubt very much that approval was given as it would have required virtually ignoring all of CAR 1.1130 (FTLs ULR) and not one but many separate approval letters from the GCAA.
Instead it was much easier for the company to write at the start of the OMA Annex 7 C ULR Operational Plan "This document is raised in compliance with the UAE GCAA Regulations "

At that time the definition of Extended Long Range Operations was not in the CARs or our OMA as was the addition of FRMS policy which is now in place ( CARs). FRMS definition has also changed.
You will gradually hear the company referring to ELR rather than ULR and will be a way they can become compliant.

CAR-OPS 1 Subpart Q
CAR-OPS 1.1110 Terminologies
Long Range Operation:
Any operation that involves a sector with planned flight time between 7 and 14 hours, and conducted under the prescriptive limits of the applicable regulation
Extended Long Range Operations
Any augmented (two set of flight crew) operation that involves a sector with planned flight time between 14:01 hours and 16:00 hours, and conducted under a specific variation approved by GCAA on the basis of a risk assessment provided by the operator, that provide a level of safety equivalent to, or better than, that achieved through the prescriptive fatigue management regulations.
FRMS
A data-driven means of continuously monitoring and managing fatigue-related safety risks, based upon scientific principles and knowledge as well as operational experience that aims to ensure relevant personnel are performing at adequate levels of alertness
FRMS Policy
A required component of an FRMS. THE FRMS Policy must: identify the elements of the FRMS and its scope; reflect the shared responsibility of all stakeholders in the FRMS; state the safety objectives of the FRMS; be signed by the accountable executive of the organisation; be communicated throughout the organisation; declares management commitment to effective safety reporting, to providing adequate resourcing for the FRMS, and to continuous improvement of the FRMS; identify clear lines of accountability for the functioning of the FRMS; and require periodic reviews of the FRMS.