Open Letter to GCAA
 

Dear PPrune EK members,

Please add below your griefs and comments in a letter I will send to the GCAA.
Flight, Duty period legality, Tiredness,.........

MasterYodaEK, Stef.

Getting to airport over 2 hours before STD and sitting in a/c 1h50 before is becoming the new norm, as station managers lobby for earlier pick ups in case it happens to be a bad traffic day. Also to mitigate Cabin Crew inability to get ready for boarding on time.

Likewise being at briefing just shy of 2 hours before STD in DXB

Not good - but be wary of the Airport Hotel being offered instead

3 Crew ULR's is hopefully high on the list?

More like the schedule being so tight that the second they get on board it's all 'Crew security checks' and yet mysteriously the call being made for said checks is often well before the allotted 12-15mins. It's the assertive ones insisting on doing them per the checklist (however long that may take) that hold up boarding.... and well done to them...

Perhaps better allocation of pre-flight duties should be on the list. Let the cleaning crew put the smelly sprays in the toilets and prep the towels (like they used to) and leave the cabin crew to do the actual important stuff...

Rest periods in between 18 - 30 hours.

I think it was NASA at their Ames Research Center in San Diego years ago that determined the most dangerous length of a layover in terms of fatigue when you come back to the airport was 24 hours. They concluded 18 hours was safer so the pilot was returning to work right on the heels of his sleep. Either that or 36 hours. But 24? That just means the guy is coming back to work when his body is telling him it's bedtime again.

The whole thing of arriving at work here in Dubai 2 hours before push when our official duty only starts one hour before has always bugged me. I mean, it's obviously a lie and I just always wondered how they got away with that...even with the airline's symbiotic relationship with the GCAA.

What IF , that every flight u show up at 1hr10 min at the briefing !? Are you breaking any law ??

Regulatory requirements not counting as part of duty hours (SEP, CRM etc.), and then SIM/PPC not counting as part of flight duty period unless they occur on the same say as an actual flight.

and that's it? nothing else?
I am quite disappointed, I thought more EK guys had things to point out, and it was here the right post to speak up!

Everyone's happy about the slavery conditions and some illegal operations?
Annex 1 reading: shall have a minimum of a local night rest IMMEDIATELY prior to the scheduled report time... look at MLE, BLR...

If you only send it to the GCAA it will never see the light of day, copy FAA,CAA etc.

Not many folk left at CAA!!

FACTORING!

Clarification of ULR ops.

Under GCAA CAAP 14, ULR is a flighttime that could exceed 16h any time during a calendar year taking into account the mean and seasonal wind changes.

In EK it is 14h. Can they then make up their own ULR rules as long as the flight time doesn't exceed 16h?

Main differences under GCAA CAAP 14 are:

Each ULR flight is to be operated by no less than four (4) pilots of whom two (2) must be pilot-in-command qualified.

Rest Period Away from Base shall be at least 48 hours.

All crew members (Flight and cabin crew) shall be scheduled for a minimum of 2 days off including 03 local nights of rest in base upon completion of a ULR pairing followed by any other duty or a ULR pairing. (Not sure if this is what the cabin crew are always getting)

Cabin crew shall be provided with a minimum in flight rest period of (3 1/2) hours for any ULR flight. (Again, not always the case. Specially on the 380)

There is no mentioning of 3 pilots ULR.

So whats the story?

Guys,
All these issues are not ever going to be addressed in this way. The variations from CAR OPS have all been approved by the GCAA. The OM-A and all the amending FSI's are all GCAA approved so if the company does not comply with it's own manuals, then it can be addressed by the GCAA who will issue a notification of non-compliance.
Every Airline I have worked for does the same. Going to the GCAA to complain about the airline variations that the GCAA has approved will simply end in what's your point they are doing as approved, or have I missed something here.
DD

Factoring will not have been approved!!

DD,

Not sure 3 pilot ULR has, just because there is a published rest plan I am certain it doesn't overide the following statement. The only mention of 3 crew ops is as follows:

"Where flight crew sickness occurs at short notice, which would impact the departure of the flight inbound to Dubai on an ULR flight sector only, the Commander may elect to complete the flight with only 3 flight crew"

Note "inbound" and "short-notice". More interestingly, the 22hrs rule is only based on 4 crew so if 3, non ULR rules apply and I would apply standard FTLs as you can't mix and match the regs.

Were one of these operations to go awry I would not want to have authorised this when the feds come knocking and see how it fits in with CAAP 14. Take your pick as to who would get it in the neck in management?

My comments were made trying to be constructive, in that the open letter may not be the best way to use the system to effect change. I would say that quality assurance or whatever is the appropriate title these days is the way to go. Question the potential non- compliance with them and let the system do the work.
Stay professional.
DD

Kingpost,
Factoring was approved based on a response to a non-compliance several years ago, the interpretation has often been subjective. Factoring is internationally recognised as a way to comply in principle as opposed to specific detail. So you can have standard reporting times or general approved timings. The interpretation comes that a flight engineers time counts as 25% towards license or ratings. So if he completes 4000hours as a FE he is credited with 1000 hours to his CPL/ATPL but he is still limited to 900 hours a year for absolute limits. This has been then interpreted that factoring can be used for absolute limits. In other words that FE would be able to fly 400 hours in 28 days or 3600 hours in the preceding 12 calendar months.
So factoring was approved but the interpretation has not been in the spirit of the rule, but GCAA did approve it.
DD

DD I agree. Whinging on PPrune won't get anywhere but I understand why the frustrations lead to it. I did a 3 man JFK recently, I have always enjoyed the trips in the past but this one was truly knackering and I won't be bidding for them again but what protections really are there? You just have to hope the operators within Flt Ops stand up to the bean counters. Judging by the SW there is little chance of that!