GCAA Subpart Q ULR vs. LRO

[lospilotos]

This might have changed some time ago but I happened to stumble upon the GCAA Subpart Q and noticed that it now does not mention ULR (16+ hours) anymore, instead it talks about LRO (Long Range Operations, 14+ hours). LRO also requires minimum 48 hours rest outstation, which I believe is not the case for EK flights to IAD, ORD etc...

Comments, thoughts?

[lospilotos]

Having had a closer look it looks like a lot of changes in Subpart Q...

I.e.

1. Requires two days off (3 local nights) prior any LRO
2. Requires two days off (3 local nights) following any LRO, irrespective if followed by another LRO or shorter flight
3. Maximum 2 LROs per calendar month

Looks like this will take effect 1 Jan 2016.

"AMC3 to 1.1120(d): for all operator conducting Long rangeoperations (LRO)
1. Operations Manual
The Operations Manual shouldcontain specific instructions to ensure that the flight meets the following requirements:
(a) LRO Pre-flight and In-flight Rest Planning
A scheme shouldbe established to provide guidance to the crew on the expected pre-flight preparations and in-flight rest to be taken. Flight crew are to be appropriately rested for the LRO flight.
(b) LRO pre-flight Rostering Requirements:
Prior to operating a LRO flight or a LRO Standby departing UAE, all crew members shouldbe scheduled for 02 days off including 03 local nights of rest in base.
(c) LRO Flight Rest Period Away from Base
In the LRO Rostered Duty Assignment, the scheduled period free of flying duties away from base shouldbe at least 48 hours.
(d) Post LRO Rostered Duty Assignment Rest At Base Before embarking on the Next Flight:
All crewmembers should be scheduled for a minimum of 2 days off including 03 local nights of rest in base upon completion of a LRO pairing followed by any other duty or a LRO pairing.
(e) Each crew member shouldnot be rostered more than 02 LRO Pairings/calendar month.
(f) Cabin crew shouldbe provided with a minimum in flight rest period of (3 1/2) hours for any LRO flight."

Have a look for yourself: Part IV, OPS 1 (https://www.gcaa.gov.ae/en/ePublication/_layouts/GCAA/ePublication/DownloadFile.aspx?Un=/en/epublication/admin/Library%20Pdf/Civil%20Aviation%20Regulations%20(CARs)/CAR%20PART%20IV%20-%20OPERATIONS%20REGULATIONS/AIRCRAFT%20OPERATIONS/CAR%20PART%20IV%20CAR-OPS%201%20-%20COMMERCIAL%20AND%20PRIVATE%20AIR%20TRANSPORTATION-AEROPLANES.pdf)

[glofish]

Good read and good news!

ORD definitely 48 hours now, eventually IAD.

[lospilotos]

Yeah, some good, perhaps not all though:

(b) LRO pre-flight Rostering Requirements:
Prior to operating a LRO flight or a LRO Standby departing UAE, all crew members should be scheduled for 02 days off including 03 local nights of rest in base.

This could be interpreted in two ways (and NB it does not mention acclimatization):

1. You have to be rostered for days off in DXB (for EK), you don't actually have to spend them there.

or

2. You have to spend your rostered off days in DXB, regardless of acclimatization.

[lowstandard]

The word "should" will be open to interpretation from EK. Standby for a new variation in the new FTL section.

[uplock]

Amigo, hate to rain on your parade however as the term SHALL has not been used then compliance is not required.

[lospilotos]

Amigo, hate to rain on your parade however as the term SHALL has not been used then compliance is not required.

You are soooo wrong, I wasn't parading, just taking a slow stroll, pointing out things as I pass. Also, it's not raining...

[Mach_Krit]

and that is why EK has the annex for ulr in the om-a. rubberstamped by the gcaa. dont expect anything to change.

[Monarch Man]

and that is why EK has the annex for ulr in the om-a. rubberstamped by the gcaa. dont expect anything to change.

And it will NEVER change so long as an ASR along with a fatigue report isn't submitted. Make a choice, either be part of the solution or part of the problem, state the facts and not opinion. The ORD flight and IAD flight if running as 24hr layovers reduces the safety margin too much IMHO.

[Mach_Krit]

couldnt agree more MM..especially the two local nights rest after ULR is farcical. so u have a rest day and a day off...followed by a cracking night flight to the subcontinent. get those ASRs and FR's in.

[lospilotos]

Well it was rubberstamped when there were no clear rules set out by GCAA. The current OM-A would violate at least three rules in the CAR-OPS...

[RainbowLorikeet]

Don't expect any changes unless ASRs keep coming.
Edit:
I should rephrase,
Don't expect any changes.

To cover the 24hr ULRs:

Note:
Any exsiting approved LRO flight shall remain in force until the time a re-assessment is required.

and...

The GCAA may grant variations to the FTL requirements contained in this Subpart provided the operator demonstrates to the GCAA, on the basis of a risk assessment, that an equivalent level of safety is ensured.

Godspeed

[fatbus]

Name at least three , I'm curious.

[nolimitholdem]

I'm on the side of the angels, believe me, I am.

But perhaps someone could specify just how many ASR's and fatigue reports will be enough to convince EK or the regulators that there is a fatigue problem with IAD/ORD/etc?

I mean how many hundreds of reports have been filed over the last few years? And how much has changed?

Not saying it's a reason to stop trying, but let's face it the reports haven't exactly improved anything. More like a bad joke.

But God help EK when inevitably someone prangs one and the ensuing investigation cites fatigue as a contributing cause...kinda hard to claim ignorance when your crews have been screaming at you for literally years.

[glofish]

Middle Eastern Lawmaking:

Under Blahblah law it shall not be allowed to beat your wife.
Exception is granted for existing couples where wives have been regularly beaten, until it is demonstrated on the basis of risk assessment by husbands that they might suffer some harm.

:ugh:

[Inside UAE]

24-Hour layovers on ULR should automatically be followed by an ASR and a FR. Anyone who has done any number of those knows exactly how it feels trying to stay awake at the controls.

[lospilotos]

Name at least three , I'm curious.

1. Two days off before (currently only 1)
2. Two days off after (currently only 1 if followed by non- ULR)
3. Maximum 2 ULR/LRO per calendar month (Currently max 3)

[puff m'call]

Inside UAE
"24-Hour layovers on ULR should automatically be followed by an ASR and a FR. Anyone who has done any number of those knows exactly how it feels trying to stay awake at the controls"

Couldn't agree with you more!!!

Every Pilot doing 24hr layovers on ULR flights should ASR it.

Come on Guys, grow some!!!!:ugh:

[TangoUniform]

Reality check. If factoring for ULR flights is allowed, and approved with the blessings of the GCAA, everything else is peanuts. How do you think so many 777 rosters are over 100 hours now? Thank you "Captain" TCAS.

[Buckshot16]

How many times or ways do we need to say this, MonarchMan 100% correct.

[Buckshot16]

AirbusChuck, ... there you go, "It's suspiciously vanished", my comment "I can't get it any clearer" wasn't directed at your post ( that's how I'm interpreting your comment ) ... what I am saying is what MonarchMan says " And it will NEVER change so long as an ASR along with a fatigue report isn't submitted. Make a choice, either be part of the solution or part of the problem, state the facts and not opinion." ..... and that said, thats what I do. And I meant what I said above ... "It's suspiciously vanished" or maybe I've just missed something also.