In the spirit of SCRATCOH?
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In the spirit of SCRATCOH?
Hi All - beg to consider the opinion of the good and the wise here...
At a certain 'airport' ATCO's are currently covering ATSA shifts as part of their regular cycle, due to ongoing ATSA training and the need for leave/sickness cover.
A recent change in airport operating hours has meant that fatigue breaks are now being eroded, in that in some instances there is not 12 hours between shifts, though we are told by 'unit management' that 'it's okay - it's only an Assistant's duty (i.e. not subject to SCRATCOH).
Whilst we appreciate ATSA's arent' subject to SCRATCOH - we ATCO's are...so here's the question...
Should an ATCO covering an ATSA duty still be subject to SCRATCOH?
All opinions gratefully received.
At a certain 'airport' ATCO's are currently covering ATSA shifts as part of their regular cycle, due to ongoing ATSA training and the need for leave/sickness cover.
A recent change in airport operating hours has meant that fatigue breaks are now being eroded, in that in some instances there is not 12 hours between shifts, though we are told by 'unit management' that 'it's okay - it's only an Assistant's duty (i.e. not subject to SCRATCOH).
Whilst we appreciate ATSA's arent' subject to SCRATCOH - we ATCO's are...so here's the question...
Should an ATCO covering an ATSA duty still be subject to SCRATCOH?
All opinions gratefully received.
Join Date: Sep 2004
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From CAP670 Part D section 2 page 1
2.1 Period of Duty
The period between the actual commencement of and the actual end of a shift during
which an air traffic controller whose licence contains a rating valid at the unit
exercises, or could be called upon to exercise, the privileges of the licence at that unit,
and includes prescribed breaks, time spent on other duties such as training, airfield
inspection, meteorological observations, collection of landing fees, administration and
any extension of duty.
2.1.1 Maximum Period of Duty
Except where other limits are defined within these regulations no period of duty shall
exceed 10 hours. Within 720 consecutive hours (30 days) the aggregate of periods of
duty and on call duties shall not exceed 300 hours provided that periods of duty do
not exceed 200 hours.
2.1.2 Intervals Between Periods of Duty
There shall be an interval of not less than 12 hours between the conclusion of one
period of duty and the commencement of the next period of duty. This interval may
only be reduced (and only by a maximum of 1 hour) with the approval of the controller
concerned and in any individual case such a reduction will be permitted no more than
once in a period of 720 consecutive hours (30 days).
So I would say that you can only do it once in 30 days, and only by 1 hour.
For info CAP670 can be found online here http://www.caa.co.uk/docs/33/cap670.pdf
2.1 Period of Duty
The period between the actual commencement of and the actual end of a shift during
which an air traffic controller whose licence contains a rating valid at the unit
exercises, or could be called upon to exercise, the privileges of the licence at that unit,
and includes prescribed breaks, time spent on other duties such as training, airfield
inspection, meteorological observations, collection of landing fees, administration and
any extension of duty.
2.1.1 Maximum Period of Duty
Except where other limits are defined within these regulations no period of duty shall
exceed 10 hours. Within 720 consecutive hours (30 days) the aggregate of periods of
duty and on call duties shall not exceed 300 hours provided that periods of duty do
not exceed 200 hours.
2.1.2 Intervals Between Periods of Duty
There shall be an interval of not less than 12 hours between the conclusion of one
period of duty and the commencement of the next period of duty. This interval may
only be reduced (and only by a maximum of 1 hour) with the approval of the controller
concerned and in any individual case such a reduction will be permitted no more than
once in a period of 720 consecutive hours (30 days).
So I would say that you can only do it once in 30 days, and only by 1 hour.
For info CAP670 can be found online here http://www.caa.co.uk/docs/33/cap670.pdf
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I think there's another part of the rules that are relevant here....
4.2 Modification of Limitations by the Provider of Air Traffic Control Services
In exceptional circumstances the Provider of Air Traffic Control Services at a unit may in its discretion modify any Limitation through persons exercising its authority. Such modifications may only be made to overcome short-term, temporary and unforeseen difficulties at the unit and, having regard to the Scheme of Regulation, may only be made if the safety and effectiveness of Air Traffic Control will be maintained. The CAA will require to review the circumstances of each such modification and for this purpose a report and full details of the modification shall be notified in writing, using the form shown in Annex A to Part D, to Air Traffic Standards Department within 24 hours of the modification taking effect.
I'd be inclined to ask whether you could have a copy of the reports for your extended working hours and any response from the CAA. If it's a serious issue for you or your colleagues on the unit - and you can't get sense out of your management - a quick call to the inspectors at SRG might not go amiss.
4.2 Modification of Limitations by the Provider of Air Traffic Control Services
In exceptional circumstances the Provider of Air Traffic Control Services at a unit may in its discretion modify any Limitation through persons exercising its authority. Such modifications may only be made to overcome short-term, temporary and unforeseen difficulties at the unit and, having regard to the Scheme of Regulation, may only be made if the safety and effectiveness of Air Traffic Control will be maintained. The CAA will require to review the circumstances of each such modification and for this purpose a report and full details of the modification shall be notified in writing, using the form shown in Annex A to Part D, to Air Traffic Standards Department within 24 hours of the modification taking effect.
I'd be inclined to ask whether you could have a copy of the reports for your extended working hours and any response from the CAA. If it's a serious issue for you or your colleagues on the unit - and you can't get sense out of your management - a quick call to the inspectors at SRG might not go amiss.
StandupfortheUlstermen
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mmm, yes, always was a nice 'get out' clause for employers that one.
File an MOR when you come back on shift about how tired you are cos you're not getting proper rest periods, and keep doing it until this stops.
Sickness can be described as 'short term, temporary and unforeseen'. ATSA training or leave cover cannot.
But then show me an ATC employer who has enough ATSAs these days, other than at the centres, natch.
File an MOR when you come back on shift about how tired you are cos you're not getting proper rest periods, and keep doing it until this stops.
Sickness can be described as 'short term, temporary and unforeseen'. ATSA training or leave cover cannot.
But then show me an ATC employer who has enough ATSAs these days, other than at the centres, natch.
