New CAP 371: Avoidance Of Fatigue in Air Crews
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Avoidance Of Fatigue in Air Crews
The UK CAA has just published a new edition of CAP 371: Avoidance Of Fatigue in Air Crews.
"The regulations set a work pattern for flight crews and cabin staff designed to prevent the onset of fatigue, and yet allow an operator to pursue business interests."
Link to CAP 371
Version 4
Published yesterday.
Tudor Owen
"The regulations set a work pattern for flight crews and cabin staff designed to prevent the onset of fatigue, and yet allow an operator to pursue business interests."
Link to CAP 371
Version 4
Published yesterday.
Tudor Owen
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FODCOM 29/2003 says: "The CAA expects operators to revise their approved Flight Time Limitations Scheme when practicable, but no later than 1 April 2006, to take account of these revisions to CAP 371."
So plenty of time to digest the implications then.
So plenty of time to digest the implications then.
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Thanks, Flying Lawyer for taking the time to do this.
Big question is:
What if a company operates as in the ACMI business and have G registered aircraft and other aircraft registered in their home country. Such as the case with an Icelandic Airline.
For instance one day you may fly the G registered aircraft and the next day the TF registered. All on the same contract.
Do the new provisions only cover a crew member while he is operating on the G registration?
Big question is:
What if a company operates as in the ACMI business and have G registered aircraft and other aircraft registered in their home country. Such as the case with an Icelandic Airline.
For instance one day you may fly the G registered aircraft and the next day the TF registered. All on the same contract.
Do the new provisions only cover a crew member while he is operating on the G registration?
Last edited by Earl; 18th Jan 2004 at 05:01.
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Earl, I would have thought that you would need an Icelandic validation to fly to their FTL scheme or rules. Assuming you are employed on a UK contract, without such a validation then you are beholden to English law and CAP 371 only.
Have you asked your Company about this?
After all, if you have an accident or incident on a TF registered aircraft when operating outside CAP 371 can you be prosecuted in the UK?
Equally, would the company's insurance poilicy be valid if it could be proved you operated illegally?
Proceed carefully.
Have you asked your Company about this?
After all, if you have an accident or incident on a TF registered aircraft when operating outside CAP 371 can you be prosecuted in the UK?
Equally, would the company's insurance poilicy be valid if it could be proved you operated illegally?
Proceed carefully.
As I understand it the changes to CAP 371 are based on research by QinetiQ carried out in 2001 in response to concerns about fatigue in short haul operations. The airlines have until to 2006 to implement the changes in the CAP.
Of course, in the intervening years the problems which concerned the CAA (and pilots like myself) have remained.
The process is too slow.
I support the changes to CAP 371 but the ethos of the document is such that an airline can still write a truly awful roster and get away with it.
Of course, in the intervening years the problems which concerned the CAA (and pilots like myself) have remained.
The process is too slow.
I support the changes to CAP 371 but the ethos of the document is such that an airline can still write a truly awful roster and get away with it.
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FL:Thanks
Earl & ecj:Valid points
In Italy,from the recent light TV debate (post Flash) we noted the ENAC director mumbling about Italian FTL,how Italy shouldn't change because it could then be taken advantage of by others.In other words:another excuse to do (change) nothing.
Earl & ecj:Valid points
In Italy,from the recent light TV debate (post Flash) we noted the ENAC director mumbling about Italian FTL,how Italy shouldn't change because it could then be taken advantage of by others.In other words:another excuse to do (change) nothing.
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Just had a look at the new edition of the CAP 371, and although I admit it was a bit of a speed read there seems t be no major changes, apart from the rolling 7 day week.( which most companies are bringing in volentarily anyway!)
There seems to be no move the stopping the early start, late finish week, which over a couple of weeks is completely knackering. (there is a mention of training rostering staff into the effects of disruption of the circadian rythem, but no mention of stopping the practice anyway)
There is no mention of total duty hours per year ( meant to be reduced to 2000 duty hours under european law), although personally I worked about 750 block hours last year, the knackering bit was the 2300-2400 duty hours we were doing,( average 9 to 5'er is doing 1800-1900 hours a year)
that's my 2 bits worth, may be proved wrong ( hope so anyway!)
There seems to be no move the stopping the early start, late finish week, which over a couple of weeks is completely knackering. (there is a mention of training rostering staff into the effects of disruption of the circadian rythem, but no mention of stopping the practice anyway)
There is no mention of total duty hours per year ( meant to be reduced to 2000 duty hours under european law), although personally I worked about 750 block hours last year, the knackering bit was the 2300-2400 duty hours we were doing,( average 9 to 5'er is doing 1800-1900 hours a year)
that's my 2 bits worth, may be proved wrong ( hope so anyway!)
Moderate, Modest & Mild.
Although I am not yet affected by these CAO's, there will be the inevitable "flow on", because of the "global village" in which we all apparently work and reside.
At a glance, I find them a "crock" - wriiten by non-commercial flying bureaucrats sitting in an office. eg. the definitions of "Night" are distinctly poles apart, depending on whether it is being defined for the purpose of crew work/pay, or crew rest.
Not surprisingly, pilots may be rostered and flown during Winter months between the hours of (say) 6pm local time through until 02:45am and NOT have it counted as Night....."No honey, I'll be home at 0400, but it's all day flight."....according to the definitons:-
10) Local Night
A period of 8 hours falling between 1000 and 0800 hours local time.
11) Night duty
A duty is a Night Duty if any part of that duty falls within the period 0200 to 0459 hours local time.
"Dunno wot you lot are whinging about, you're all complainin' about bein' tired, but you're only rostered fer day flights!"
According to these CAO's, as long as a crew member finishes duty prior to 0100, there is NO restriction on the number of duties which may be assigned to him/her.
It's time that flight and duty times were looked at REALISTICALLY - from the SAFETY point of view, and in the TRUE light in which today's (desperate for a $) employers schedule crew.
NOT from the fanciful dreamings of some 9 to 5'er Walter Mitty!!
At a glance, I find them a "crock" - wriiten by non-commercial flying bureaucrats sitting in an office. eg. the definitions of "Night" are distinctly poles apart, depending on whether it is being defined for the purpose of crew work/pay, or crew rest.
Not surprisingly, pilots may be rostered and flown during Winter months between the hours of (say) 6pm local time through until 02:45am and NOT have it counted as Night....."No honey, I'll be home at 0400, but it's all day flight."....according to the definitons:-
10) Local Night
A period of 8 hours falling between 1000 and 0800 hours local time.
11) Night duty
A duty is a Night Duty if any part of that duty falls within the period 0200 to 0459 hours local time.
"Dunno wot you lot are whinging about, you're all complainin' about bein' tired, but you're only rostered fer day flights!"
According to these CAO's, as long as a crew member finishes duty prior to 0100, there is NO restriction on the number of duties which may be assigned to him/her.
It's time that flight and duty times were looked at REALISTICALLY - from the SAFETY point of view, and in the TRUE light in which today's (desperate for a $) employers schedule crew.
NOT from the fanciful dreamings of some 9 to 5'er Walter Mitty!!
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Kaptin M
Excellent post Kaptin M strongly agree with your remarks. The CAA are still working with windows 95. The curtains are draw and they can't see any need for a change based on safety.
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Kennedy
The 2000 Duty hours per year is mobile workers working time directive not CAP371. Dont compare your job with a 9-5er either as many of your fellows won't allow a 9-5er to be compared with your lifestyle.
If you didnt fly do you think you would get your high salary just doing a 9-5 job?, i doubt it. You'd have to do what i do, 24/7 on call / if i start at 0800 and end at 2200 do i get 14 hours rest or 10? / if i work at the weekend do i get a lieu day or payments for working like Nigels?. er no.
Be real
The 2000 Duty hours per year is mobile workers working time directive not CAP371. Dont compare your job with a 9-5er either as many of your fellows won't allow a 9-5er to be compared with your lifestyle.
If you didnt fly do you think you would get your high salary just doing a 9-5 job?, i doubt it. You'd have to do what i do, 24/7 on call / if i start at 0800 and end at 2200 do i get 14 hours rest or 10? / if i work at the weekend do i get a lieu day or payments for working like Nigels?. er no.
Be real
Perhaps we should remember that it took a major accident many decades ago to get ANY form of FTLs.
I once knew a colleague who said that if he left the house after his wife had gone to bed or returned when she was still in bed then, as far as he was concerned, that was a night flight! I cannot think of a more realistic definition.
It really is time that pilots as a body took some ACTION on this issue. The world has changed in so many respects, e.g. the journey to work takes twice as long as it did a few years ago and its no good companies saying oh well the FTL scheme/contract says you have to live within such and such travelling time from the airport - what about the time it takes to get from the car park to crew report etc etc. The bureaucrats need to get a dose of reality and shadow crew members for a couple of weeks to find out what is REALLY happening out there!
In the long term these rostering practices (and by the way I am not getting at the crewing officers who are trying their best give the resources) are only going to cost the companies a lot of extra money. Pilots are only going to start going elsewhere or, longer term, they might lose their medical due ill health or go sick due short term sickness.
I repeat that it is up to us as pilots to take concerted action and DO something before it is too late.
I once knew a colleague who said that if he left the house after his wife had gone to bed or returned when she was still in bed then, as far as he was concerned, that was a night flight! I cannot think of a more realistic definition.
It really is time that pilots as a body took some ACTION on this issue. The world has changed in so many respects, e.g. the journey to work takes twice as long as it did a few years ago and its no good companies saying oh well the FTL scheme/contract says you have to live within such and such travelling time from the airport - what about the time it takes to get from the car park to crew report etc etc. The bureaucrats need to get a dose of reality and shadow crew members for a couple of weeks to find out what is REALLY happening out there!
In the long term these rostering practices (and by the way I am not getting at the crewing officers who are trying their best give the resources) are only going to cost the companies a lot of extra money. Pilots are only going to start going elsewhere or, longer term, they might lose their medical due ill health or go sick due short term sickness.
I repeat that it is up to us as pilots to take concerted action and DO something before it is too late.
