View Full Version : EASA Definition of Reporting for Duty
I’m sure this will have been touched on before but the search does not produce the result I’m looking for, so here goes:
Can anyone shed light on when a flight duty period starts, in terms of where you report? For example is it at Crew check in? Is it at the bag drop for the flight which just happens to be before security, thus taking about 30 mins before crew check in? Is it at the staff car park, etc etc?
Seem to remember a statement of ‘when you first carry out a duty required for the trip’, or words to that effect. Which could be argued staff car park, and certainly bag drop.
Have EASA provided an answer to this somewhere, or as usual, is this flight safety critical issue, along with much in the FTL section, open to interpretation?!
Intuitively it's tempting to say it's the moment you walk into the allocated crew room, or the rostered duty time, whichever later.
Bearing in mind that the crew room could be landside.
Imagine the case where you are rostered to take a taxi to a different base to then operate from there.
The FDP then would start as you turn up at the taxi rank (or at the time rostered to do so, whichever later etc).
All unless you had been on standby for at least 6 hrs prior.
Can of worms...
Also, the staff car park used to be a five minute walk, it’s now 30 mins on a bus. I haven’t moved house but my fatigue caused by issues like this, is steadily increasing!
B737900er
5th Nov 2019, 10:04
The company OMA will tell you. It will tell you where to report for duty and your roster will tell you the report time. If you are positioning then the airport itself or taxi rank is the reporting point.
back to Boeing
5th Nov 2019, 13:54
Unfortunately for us crew it is not defined.
some have it on entering the crew room. Some have it car park some have it from arriving at the queue for security if your crew room is airside. It just hasn’t been officially defined by the regulator so it’s up to the operator and their unions to come to an agreement.
I’m pretty certain in the not too distant future with electronic flight logs and briefings etc it’ll become on entering the aircraft unless we fight it
q400_driver
5th Nov 2019, 14:18
ORO.FTL.205 states it is the operator who has to define reporting times, in reality it should be in your OMA. There needs to be a set standard, you can't just walk in 5 hours before your flight in your briefing room only to announce that your duty period is over in the middle of your day..
Unfortunately, good old OMA is conveniently sparse of information, hence the search for an EASA definition. I’ve found a link to FTL questions to the CAA, so I’ll try that and report if any success.
q400_driver
5th Nov 2019, 14:41
Unfortunately, good old OMA is conveniently sparse of information, hence the search for an EASA definition. I’ve found a link to FTL questions to the CAA, so I’ll try that and report if any success.
another thing to remember is that, we pilots often get fixated on EASA regulations and OMA's completely forgetting that each country also have labor laws that also need to be adhered to. If the EASA/OMA is conveniently ambiguous to FTL, always worth checking with whoever is responsible for workforce/labor law protection in your specific country
Meester proach
5th Nov 2019, 21:58
At every airline I’ve worked, it’s when you get to where you report, which is normally the crewroom
ConwayBorders
6th Nov 2019, 10:06
To follow up on this question, if you leave the hotel and take a taxi for 30 minutes to the airport, when would your flight duty period start?
All our taxis are scheduled to arrive 60 minutes prior departure and that's the time crewing use to start the FDP. The actual check-out of the hotel can be a long time before that.
At every airline I’ve worked, it’s when you get to where you report, which is normally the crewroom
Normally, yes you are quite right.
It's the abnormal days when duty time starts to become a factor.
See the posts above about positioning.
Twiglet1
6th Nov 2019, 15:23
This is NNUTS- Nothing New Under The Sun.
God bless Monarch tried to have it out with the UK CAA on this issue - as when checking in for a long haul flight crews had to drop their cases at flight check in desks and their crew room was airside.
The CAA advised it was for AOC's to manage (wisely sitting on the fence)
I'm not sure if the issue was ever fixed - some Airlines like BMI increased their min rest at base to mitigate.
So imho it's open to interpretation and thus relies on the morale of the crew members e.g. if this is the only issue at your Airline then get a life. If not and multiple issues then any old small thing will pi$$ off the average Company minded Nigel.
Depending where the crew room is, you may already be airside through security. Or you may have that 30 mins balls ache to go through, so either way, your level of tiredness/fatigue will vary.
Good that they are happy to leave this area nicely in the grey! Shows that they don’t give a monkey’s about flight safety if there’s a cost to it!
Any old small thing it is then.
FlightDetent
6th Nov 2019, 17:02
The EASA regs are simple and functional. There shall be a reporting time defined in the OM and a designated reporting place. That's when it starts.
'm not claiming it's all unicorns and fluffy clouds, but there is no ambiguity. If the airline is making a mess of it, talk to them or the overseeing NAA.
Twiglet1
6th Nov 2019, 17:41
GM1 ORO.FTL.205(a)(1) Flight Duty Period (FDP)
REPORTING TIMES
The operator should specify reporting times taking into account the type of operation, the size and type of aircraft and the reporting airport conditions.
Absolutely that's why normal report is in the crew room and at 60 mins or thereabouts
Twiglet1
6th Nov 2019, 17:51
Depending where the crew room is, you may already be airside through security. Or you may have that 30 mins balls ache to go through, so either way, your level of tiredness/fatigue will vary.
Good that they are happy to leave this area nicely in the grey! Shows that they don’t give a monkey’s about flight safety if there’s a cost to it!
KYT - the CAA used to run a FTL working group where this sort of nif naf and trivia was discussed. The purposes of the group was for the CAA to use it as a sounding board. It was made up of AOC's such as scheduled, charter, low cost, night freight, Union FD/CC and Independent's. With EASA it's disbanded.
So here's the question for you. Increase report time to 90 minutes. Put's the 2 crew out of hours so maybe in-flight rest and a 3rd Pilot needed. Tour Operator says um I might as well get European Company X in to do it for half the price. I can name medium sizedUK AOC's on my two hands now.
My experience of the CAA is they do absolutely care about Flight Safety, in the big scheme of things pitching up 30 minutes earlier to drop your bag - um let's talk about commuting if you want to be serious.
Hey Twiglet, this issue wasn’t an issue for me until EASA got involved increasing flight duty periods, such that fatigue is now an issue, thanks to Airlines exploiting the new crazy work practices. Dumbing down safe operating practices while the US were becoming more concerned with the same issue, (crazy commuting), thanks to Capt Sully’s efforts. Did you ask your MEP to vote against them? Did the CAA campaign against them?
The new EASA regs are less safe, and Companies are happy not to define things and keep everything woolly, it’s down to money. The reason for this post was to try and find a straightforward definition, the fact that appears not to be one, should ring alarm bells for everyone, not that it’s about 30 mins, (or an hour.)
If legislation was introduced to mandate a maximum commute period, people and Companies may ignore them, that’s up to them. Again, the fact that there isn’t speaks volumes. ANO states you must be fit for duty, yet I have heard of duties where tiredness leads to sleeping crews being intercepted. Without us getting on with the job sometimes, certain schedules would never take place. On these tough rotations, every moments rest is vital, as clearly not everyone falls asleep. So perhaps that extra 30 mins or an hour becomes more important. I’m a little surprised you think it’s nifty naff and trivia, suspect you don’t get tired much, you must be a real Company man!
Oh and your other point about 2 man crew running out of duty so Operator goes for cheap European X option......
Well hopefully that would be against employment law, but it won’t stop them doing it......
So once again, nowt to do with safety....just money.
FlightDetent
7th Nov 2019, 07:54
Your trouble seems to be with the employer not following the regs(*), and not with the EASA rules. SmallCog's post #16 refers. Post the paragraph from off the OM-A which serves to satisfy those, and we'll help you find the answers.
(* = more explicitly, the lack of understanding on how your employer follows or pretends to satisfy those regulations).
My problem is with the EASA regs, they are more fatiguing than the old regs. Also, some areas I think are important for fatigue mitigation are conveniently vague.
I suspect all OMAs will state a flight duty period begins at report, (mine does). I suspect none will specify where that is, (mine doesn’t). (Crew room, bag drop, security, car park, taxi rank etc - these are just examples to reinforce and illustrate the argument I am making, not that important in isolation but showing a more important lack of guidance.)
I do not have an issue if the rules were to state crew room, but as the time taken to get to the crew room has markedly increased over the years, and now coupled with more tiring EASA regs, I am concerned about the effect this MUST be having on fatigue. All left conveniently in a grey area by the authorities!
FlightDetent
7th Nov 2019, 12:09
I suspect all OMAs will state a flight duty period begins at report, (mine does). Agreed, kind of self-evident, cue in the time-of-reporting-for-duty name
suspect none will specify where that is, (mine doesn’t). (Crew room, bag drop, security, car park, taxi rank etc - these are just examples to reinforce and illustrate the argument I am making, not that important in isolation but showing a more important lack of guidance.) It is important. That part where you do not understand where is the place your employment duties commence. Who are the stakeholders and which responsibilities they have. Check with HR, it is useful to know. Luckily no need to take that with EASA, it's not aviation-related.
The EASA FTLs are standing on two feet
- 1 various numerical limits on activities
- 2 existence of effective fatigue management system
both of which are mandatory.
The 1) above are designed with the objective to allow for a great range of aviation activities and business models. For many if not most of them, the demands and practical restriction do not overlap. It is quite accurate to say that 1) was never intended to be exploited in all corners of its envelope in full by one individual or group and if that happens fatigue will ensue.
It is not breaking/extending beyond a certain limit that is reducing safety level below acceptable, working insufficiently alerted is. And indeed one could get fatigued when staying well clear of the boundaries, new rules and the old alike, even before we begin factoring the circumstances of personal and private life that do play a massive role by all means.
Hence the existence of 2). No matter if it's new teeth of your most beloved, or the EU devils who destroyed all that was good, a fatigue management system should contain the undesirable effects before the execution of duties is affected.
1) is not built water-tight to keep you at an acceptable state of alertness, 2) is. Feel free to quote me out of context whoever dares: The EASA FTL numerical limits are designed to enable fatigue (*). It is the mandatory FRMS that is put in place to ensure sufficient alertness levels of the crew on duty.
(*= as an unfortunate consequence of catering for a multitude of industry task patterns, in an all-encompassing manner)
This is not a defence of the EASA FTLs, but rather attempt to show how they are meant to work. A better understanding of which might help you handle the issues at hand with greater success. An anecdote from elsewhere, the regulator having sharper teeth:
a) extension in the planning stage (before the roster is approved and released) is not permitted
b) extension of FDP both before after commencing the duty is allowed up to 2 hours, but any extension beyond 30 minutes requires
- report to the NAA within 10 days by the Safety / Quality department suggesting measures to prevent re-occurrence
- after approval, those measures shall be implemented by the operator within 30 days.
c) there is a daily flight time limit, which is non-extendable (unless already airborne)
FlightDetent, I see what you mean about the range of operations using 1, and the monitoring responsibilities of 2. Suppose with the complexities faced, that is as good as we will ever get. Thanks for providing the reply, very much appreciated.