Agreed 100% Dan,
And why does CX need to use terms which are not in CAD371. It would be a lot more transparent to the regulator and to the pilots what that document says if there was consistency between the AFTLs and CAT371.
The AFTLs refer to terms throughout which are not even defined.
Every definition in the AFTLs should be clearly defined in the front of the document, and every use of a definition should have a Capital Letter at the start or each word and in italics.
Every reference to schedule needs to be updated to reflect if it is a Aircraft Schedule or Crew Schedule. The CAD 371 document is there for the prevention of fatigue for crew, however many of the "interpretations" CC use resolve around the Aircraft Schedule which does not require inflight relief, or commanders discretion to fly longer.
If an aircraft diverts to an offline port, the additional sector is not an Aircraft Schedule or Crew Schedule, there is no prior plan for that sector.
Crew Schedule should mean published roster, none of these 8929 changes, reserve callouts, or changes made at dispatch. That is unplanned.
Aircraft Schedule mean the CX published timetable, and a fixed timetable made for the freighter. Not on that Aircraft Schedule means its unplanned.
Should means must/will, no crew control discretion.
Normally means must/will, unless the crew member whom fatigue is being prevented by the AFTLs agrees, , no crew control discretion.
Service disruption means the following events A,B, C, D, which are published in real time by the following means and reported to the CAD on a quarterly basis. Service disruption does not include a change in the Aircraft Schedule to uplift or offload passengers or freight.
The other issue is what happens when an AFTL limit is exceeded ? When we exceed a limit on an aircraft it has to undergo an inspection. Exceed a limit on a crew member there is no consequence. The should be a mandatory 72 hours off or similar so that when CC send crew on on reserve with a duty that lands withing 10 minutes of max FDP based upon Aircraft Schedule that no aircraft has actually landed on the Aircraft Schedule for weeks is complicit to knowingly busting AFTLS. Reserve callouts are unplanned, actual duty start and stop times are required to be considered.
"O" days, day of reserve.
Calling crew out for reserve duties that have an Aircraft Schedule just landing just prior to midnight knowing full well that is one of the busiest times in HKIA. Crew members duty goes part midnight into the G, no penalty.