CAP 371 Standby Duty Calculation

[ganga747]

Hi Everyone
I need some kind of interpretation here.
How does your organisation interpret this rule?
thanks

Standby Duty.

What is meant by "Total Duty Period" in CASE A & CASE B?
Does it mean that TDP is inclusive of post duty time of 30mins
OR
Does it mean TDP is exclusive of post duty time of 30 mins

Can an FDP be extended by commanders discretion in this case A and case B

CAP 371 cut and paste below
Case A
If a crew member is called out from standby to conduct an FDP before completing 6 hours standby duty then the total duty period allowed is the sum of the time spent on standby and the FDP allowable from paragraph 13, Tables A, B, C, or paragraph 23,Table D.

Case B
If a crew member is called out from standby to conduct an FDP after completing 6 or more hours standby duty, then the total duty period allowed is the sum of all the time spent on standby and the allowable FDP, reduced by the amount of standby worked
in excess of 6 hours.

NOTES:
1 The method of adding time spent on standby to cumulative totals is stated in paragraph 22.

2 The reference to 'total duty period' applies only to the sum of the standby time achieved + the allowable FDP obtained from paragraph 13.

On the day, for cumulative duty totals and for minimum rest purposes, the total duty achieved will be standby time achieved + FDP achieved + post flight duties + any positioning.

[BOAC]

EDIT: This is completely wrong so ignore please and I blame it on the hot weather.......... Thanks scrubba.

Gosh - I have not seen a reference to 371 for many a year. :eek: All it says is that your FDP is extended by the time on standby up to 6 hours and by the excess standby time over 6 hours where it exceeds 6 hours.

IE
On standby 4 hrs, Calculated basic FDP 12 hrs. New FDP 16 hrs

On standby 8 hrs, Calculated basic FDP 12 hrs. New FDP 14 hrs

[ganga747]

thanks and agreed

But what about the post duty time?
Q. Is it included or excluded from the TDP

Q. Can the FDP be extended by pilots discretion?

[scrubba]

BOAC,

Shouldn't the second calculated basic FDP of 12 hours be reduced by the two hours of standby over the 6 hour threshold, such that the total duty period allowed is 18 hours?

How did you calculate 14 hours?

[BOAC]

scrubba - apologies - I will have to bow out of this as I realise I am now totally confused and worked under 371 for many years as such!

I had in fact focussed on the FDP aspects and in doing so mixed up FDP and 'duty' (and got it wrong!) and ignored ganga's question - mea culpa. I have now edited my post to confess............. The problem highlighted by ganga is that I cannot recall any definition of total duty period apart from the limit of 12 hrs for standby duty, and thus as such I cannot fathom the answer to your or ganga's questions on the query on post chox duty. I had always assumed that the longer you spent on standby 'effectively' the less the FDP you could work, since 'rest' was not easy on standby as we know. I'm sure you are correct on 'total duty' since reducing FDP by the excess will reduce the 'total duty' available.

We (and 371) are mixing FDP and total duty period in a very confusing manner and my head now hurts.

As a 'supplementary', my filed copy of Part Q EU Ops makes no mention of duty time, FDP or other, from home/hotel standby. Has it been updated in EASA? All I have is:

2.1.4. Taking into account facilities available for the crew member to rest and other relevant factors, the relationship between the standby and any assigned flight duty resulting from the standby shall be defined.

which the UK has filed as '371'(still dated 2004) so full circle.

[ganga747]

TDP of 18 is correct
My Q. Is this 18 hrs inclusive of post duty period or exclusive
Look at the sentence below. The "total duty period" is in inverted coma and the word only bold. What is the CAP371 implying by doing this?
Can someone please explain as I am confused.
Quote:
Note 2
The reference to 'total duty period' applies only to the sum of the standby time achieved + the allowable FDP obtained from paragraph 13.

[BOAC]

Can someone please explain as I am confused. - join the club - I am secretary:)

EDIT: PLEASE IGNORE - THE ITALICS ARE WRONG I think the answer to 'post duty' is yes, since FDP normally includes a figure for this and since the 'TDP' calculation is based on 'FDP' I assume it must also.

I have no idea of the mental processes behind this bit of 371! In my time, there was never a real restriction on 'total duty' as we know, since the company can actually keep you going on and on and on, subject only to FDP and monthly limits..............

Yes, I reckon discretion is exercisable.

[XFR8]

Duty limits end on blocks. The 30 mins only total duty period / calculating next rest and for cumulative duty totals

[BOAC]

You are right, I was wrong (again!) - FDP normally ends on chox and 'duty' at +30, so the ?correct? answer to ganga is I don't think there is an answer the way 371 is worded. I expect most companies follow that - FDP ending on chox - but I once flew for a company where chox+10 was allocated to FDP and +20 to 'duty'.

I reckon the only way to get an answer is via your Flt Ops inspector, in writing.

Again I have corrected my post............

[ganga747]

"Total Duty Period" is referenced to the statement in Note 2.

ie TDP= All time on stby + allowed FDP.

The max limit for the duty period now is the TDP. Since it is a duty period, then the post duty is included as post duty is part of duty period.( by definition of duty)

confusing /????.

If the limit is the TDP, then there is no room for FDP extension as it will exceed the TDP.

confused /???

[BOAC]

One would have hoped we could have had more input on this query than just the three of us!

Why, I ask, is there some 'limit' on TDP imposed on Standby rosters? I am not aware of any 'limit' on TDP on any other duties. I once met a co-pilot who had been 'on duty' for well over 24 hrs as he was being shuffled around the world positioning to chase a problem aircraft, sleeping fitfully in each pax cabin amongst the kids and chavs.:mad:

I disagree with the 'extension' point you make, since surely once 'up and running', discretion over-rules all rostering?

Yes, confused.

[ganga747]

There are few people that understand the CAP371 as it is written. Where are they?? I was hoping the CAP371 "guru" would have enlightened me and saved my frustration.
With EASA involved its going to get more interesting interpreting it.

BOAC, point taken on extension.
Ultimately the pilot has the final authority to extend FDP, whether it is from a standby call up or from a normal rostered duty.

[Don Coyote]

The sentence is missing the word "flight" i.e. it should read "then the total flight duty period allowed is the sum of the time spent on
standby and the FDP obtained from paragraph 13."

You can then add the time spent on post flight duties (e.g. positioning by taxi, tidying up the aircraft etc) to the Flight Duty Period to then calculate the period of rest required.

With regard to the FDP, you may add discretion to the calculated FDP (including standby periods) if you deem it suitable to do so.

[BOAC]

Don - as you can see from my miserable attempts to 'understand' this (at post #5?) there is a confusing mix between FDP and DP indeed. If that word is 'missing' it is a serious error which needs immediate correction. HOWEVER (remember I am way past being 'bothered' by that call from crewing, so memories are vague:)) but there is a problem with your calculations too.

If I recall correctly in 371, FDP (off standby) begins at report, not at standby start and standby ceases at report? SO, if we take a nominal 12 hr FDP, and work 12 (minus the 1:30 'get in' time = 10:30) on standby when the dreaded call comes, reporting after 12 hrs standby, your figures say FDP = 12+12-6 = 18 hrs FROM REPORT? I don't think so.

Returning to my 'instinctive' post #1, FDP FROM REPORT would be 6 hrs. Sounds better?

All this now raises the spectre of what happens if I am called after 11:59 standby time, and report 1:30 later - I have effectively worked 13:29 standby with a 'limit' of 12 hrs EXCEPT this 'Case B' in 371 now adjusts the 'max duty period for standby' to 13:29 - 7:29 + FDP(12) = 18hrs from start of standby. Is that all that this section is about? In which case why? As I said earlier, 'total duty time' is totally flexible anyway and there is no way a rosterer/crewer could take this into account on a random call out, except it will always be 'legal'. This now, of course, raises the question of allowable FDP - is that reduced after standby or not? I think not, except, of course, for airport standby.

I think someone who is directly affected by this - ie current crew - needs to clarify this with the CAA.

[Don Coyote]

BOAC, it is only if "standby is undertaken at home, or in suitable accommodation provided by the operator, during the period 2200 to 0800 hours local time and a crew member is given 2 hours or less notice of a report time, the allowable FDP starts at the report time for the designated reporting place."

Otherwise the FDP starts at the start of the standby i.e. the total 18 hours would start counting from the start of the standby. The travelling time from place of standby to place of report is included in that total which is why operators normally stipulate that crews must be within 1.30 of the reporting place (union agreements may allow different). There is the other proviso that if the report (usually 1 hour before scheduled departure) falls in a more limited time band than the standby starts in, then the more limiting time applies. That defines when you should arrive on chocks assuming that discretion is not used. Once on chocks then post flight duties of 30 min plus any other duty (positioning etc) may be carried out. The total time i.e.start of standby to on chocks plus subsequent duty defines the length of rest period required if it is over 12 hours.

I am on an iPad at the moment so it is a bit difficult to flick between your post and 371 to clarify the details at the end of your post.

Remember that an operators FTL scheme may be slightly different from CAP371 and it is your operators FTL scheme that defines what you should work to. As mentioned above, union agreements may be more restrictive but a crew member may chose to ignore that if they wish to.

[BOAC]

Yes, I misread the commas! What you are saying is that "Otherwise the allowable FDP starts at the start of the standby" - this brings us back to a mis-write of 371, does it not, where it references 'Total Duty Period" not 'FDP" in Cases A and B which was ganga's OQ?

[Don Coyote]

Indeed and I apologise for not answering the OP's questions directly; answers in colour below.

What is meant by "Total Duty Period" in CASE A & CASE B?
Does it mean that TDP is inclusive of post duty time of 30mins
OR
Does it mean TDP is exclusive of post duty time of 30 mins
Exclusive, add post duty time of 30 minutes to calculate duty period for rest purposes

Can an FDP be extended by commanders discretion in this case A and case B
Yes

[BOAC]

Sorry, Don, but we are not there yet. Ganga asked "What is meant by (allowable) "Total Duty Period" in CASE A & CASE B?" and we appear to suggest it is actually 'allowable' FDP, so really an amendment to 371 is called for to correct the mis-wording, since 'Duty' and 'FDP' have such different meanings in flying.

I also think there should be a clearer definition as to when FDP begins in the non 22-08 standby bracket, ie as you say, at standby start, except this does not equate to 'FDP' according to 'definitions' (8) (my colouring)

8) 'Flying Duty Period (FDP)'
Any time during which a person operates in an aircraft as a member of its crew. It
starts when the crew member is required by an operator to report for a flight, and
finishes at on-chocks or engines off, or rotors stopped, on the final sector.

Am I alone in seeing this discrepancy?

[ganga747]

Hi Don, thank you for joining in the discussion.

I am in agreement that the word total "flight" duty period would have been a better statement. But sadly it is not. So we have to live with it and now the problem of correct interpretation.

BOAC - I agree that 'Duty' and 'FDP' have such different meanings in flying.
Then, is that the reason why, in Note 2 the words "Total Duty Period" is in inverted coma and the word "only" in bold?

quote
"2 The reference to 'total duty period' applies only to the sum of the standby time achieved + the allowable FDP obtained from paragraph 13."
unquote
Are they (writers of CAP 371) trying to tell us something here?

OK. The reason I feel it is in inverted coma, is to differentiate the meaning of the word "DUTY". as in

Definition of Duty
6) 'Duty' Any continuous period during which a crew member is required to carry out any task associated with the business of an aircraft operator.

and "Duty" meaning 'Flight Duty Period'

In this case the word duty in "Total Duty Period" actually means total FDP and it ONLY applies in this case. ie the meaning of the word "duty" in TDP.
That is my interpretation though it may not be the correct interpretation.

This is in alignment with DON interpretation as well.

[Don Coyote]

BOAC, if you look at Section B page 6 there is a reference to mixed duties. That is meant to apply to staff who do office duty before flying but the principle applies to standby whereby you are effectively "report for duty in advance of the stipulated report time for a scheduled flight" as standby is duty.

Ganga747, I would concur

[Don Coyote]

BOAC, looking at your comment:

"All this now raises the spectre of what happens if I am called after 11:59 standby time, and report 1:30 later - I have effectively worked 13:29 standby with a 'limit' of 12 hrs EXCEPT this 'Case B' in 371 now adjusts the 'max duty period for standby' to 13:29 - 7:29 + FDP(12) = 18hrs from start of standby. Is that all that this section is about? In which case why? As I said earlier, 'total duty time' is totally flexible anyway and there is no way a rosterer/crewer could take this into account on a random call out, except it will always be 'legal'. This now, of course, raises the question of allowable FDP - is that reduced after standby or not? I think not, except, of course, for airport standby."

I have a couple of comments as as follows:

1. As per table 12.4 in 371, the max length of standby is 12 hours and the standby ceases when the individual reports at the designated reporting point (para 12.3) so the 1:30 drive to your place of report is technically part of the standby period.

2. Case B applied so length of standby (12 hours) + FDP from table 13.3 (12 hours in your example) less time spent in excess of 6 hours on standby (6) gives an allowable FDP of 18 hours. This FDP would have started at the time your standby started which would only allow 6 hours from report to on chocks.

3. Once on chocks you would complete post flight duties and could then position to somewhere and could then carry out any other non flying duty as required by the company. Lets say that the total period from start of standby to completion of non flying duties totals 36 hours. This would dictate that you would require 36 hours rest period even though you had only completed 6 hours from report to on chocks.

I hope that all makes sense!

[BOAC]

That is meant to apply to staff who do office duty before flying - yes, I can see that interpretation, but I had always taken that section 'literally' for office duties etc. I think it could have been made clearer.

[Mr Angry from Purley]

Dear 3 of you!
Am on hols, sorry for delay
The answer to the question is total duty In effect this therefore becomes the limiting factor depending on you're off duty times in you're scheme particularly if the Cabin Crew have different off duty times than the FD, or if as previously stated som post flight paxing involved
I have used this "understanding" only once in 30+ years in a previous life (charter). If my memory servs me right i did speak to a IO (subtle difference to FOI) and they agreed with my interpretation although a similiar discussion to yours took place, the issue being that the CC could be the more limiting factor, and was discretion allowed. I think the answer was yes to both but this was only a casual convrsation (so deliberatly left "grey")
Hope it helps :\
Angry

[BOAC]

Mr A - hope you enjoyed the hols. The problem with what you say is that I am not aware of ANY limit on 'total duty' on a daily basis so it cannot be a 'limiting factor' as you say. As I posted, you could be 'on duty' for more than 24hrs - I met that zombie. It is down to the actual words used in 371 - they need changing to reflect 'FDP'..I think c/crew are best left out of the discussion, as once you start mixing duty starts etc inter-crew...................I know - been there in BA a few times.

[Don Coyote]

Cabin crew duty would not affect the rest required by pilots or create any limits as the cabin crew and pilots could operate different flights the following day, assuming that the operator had a number of flights departing. What would be limiting is if, for example, the cabin crew had a different report time or had operated different number of sectors and required e.g. 14 hours rest compared to the pilots 12 hours. If there was only one aircraft at that particular location then the pilots would have to wait until the cabin crew were rested; consequently all crew would have 14 hours rest although only the cabin crew needed 14 hours.

Captain can always dictate that discretion is undertaken if he is satisfied that it is safe and sensible to do so.

Mr A, with regard to the phrase duty used in the context of allowable standby followed by operating, please see my previous comments.

[Mr Angry from Purley]

Don
Apologies, here's the relevant extract from CAP371
"The reference to 'total duty period' applies only to the sum of the standby time achieved + the allowable FDP obtained from paragraph 13. On the day, for cumulative duty totals and for minimum rest purposes, the total duty achieved will be standby time achieved + FDP achieved + post flight duties + any positioning."

An example
SBY 0800-1600LT
Callout 1530LT
2 sectors

Sum of time spent on sby 0730hrs
Allowable FDP 12.15 (More restrictive time band)

So 0730hrs + 1215 = 1945 hrs, reduced by time over 6 hrs sby = 1hr 30mins = 1815hrs.

0800 start of sby + 1815hrs = 0215 last land.

Interesting given all the spin by BALPA over the proposed EASA FTL with my 30 years in Crewing I don't know the rules because i've only gone to the max about twice in my career (and without the knowledge of the above from CAP371 i worked to a last off duty as previosuly mentioned)

[Don Coyote]

Mr A,

Your figures are correct and give the figure for max FDP to last landing. Post flight duties and positioning could then be added to that figure.

Using your example then adding post flight duties and positioning:

18:15 to on chocks, 30 min post flight duties, 2 hours positioning gives a total duty period of 20:45 with an off duty of 04:45. Rest period of 20:45 required which gives a next available for duty of 01:30 the following day.

If I had bothered/remembered to read the note that you quoted we could have saved ourselves a number of posts!!

[Mr Angry from Purley]

Don
Thanks for the cross check. With the duty being over 18hrs a local nights rest would be required so 0600 back on duty!

[Don Coyote]

Good spot!