EU plans to change Flight Time limitations
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Trouble is we’re in the wrong business, I want to be treated like cattle:
The Welfare of Animals (Transport) Order 1997 PART I
WATERING AND FEEDING INTERVALS, JOURNEY TIMES AND RESTING PERIODS FOR CATTLE, SHEEP, PIGS, GOATS AND FOR HORSES (EXCEPT REGISTERED HORSES)
1. Subject to the provisions of this Schedule, journey times shall not exceed 8 hours.
This is madness. The breathtaking hypocrisy in the philosophy behind alcohol and fatigue legislation is staggering.
Welcome to Blair’s Britain. All law and no justice.
Merry Christmas!, (while we’re still allowed to celebrate it.)
I’ll take on the opposition anyday. It’s my management I can’t beat!
The Welfare of Animals (Transport) Order 1997 PART I
WATERING AND FEEDING INTERVALS, JOURNEY TIMES AND RESTING PERIODS FOR CATTLE, SHEEP, PIGS, GOATS AND FOR HORSES (EXCEPT REGISTERED HORSES)
1. Subject to the provisions of this Schedule, journey times shall not exceed 8 hours.
This is madness. The breathtaking hypocrisy in the philosophy behind alcohol and fatigue legislation is staggering.
Welcome to Blair’s Britain. All law and no justice.
Merry Christmas!, (while we’re still allowed to celebrate it.)
I’ll take on the opposition anyday. It’s my management I can’t beat!
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Me too! I want to be a pig!
Why not increase working hours of pilots and therefore increase productivity whilst assisting with the pension crisis as writing off the odd aircraft (along with the pax and crew) will effectively reduce the number of pensioners!
Yes! Merry Christmas to everyone (unless you are offended by that - then you are free to ignore my wishes) and a Happy and Prosperous New Year 2005!!
Why not increase working hours of pilots and therefore increase productivity whilst assisting with the pension crisis as writing off the odd aircraft (along with the pax and crew) will effectively reduce the number of pensioners!
Yes! Merry Christmas to everyone (unless you are offended by that - then you are free to ignore my wishes) and a Happy and Prosperous New Year 2005!!
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What I would like to see is. How much support does BALPA get from ECA on this one?
And on a second note, where is the voice of the Association of UK AME.
Maybe its better that FTDT is the same all over Europe and for all operators.
The lesson behind all this; being shafted by Brussels is in no way any different than being shafted by the UK government.
But once you have a common European law, it will be easier to get it changed in all countries at the same time then in every state separately.
And on a second note, where is the voice of the Association of UK AME.
Maybe its better that FTDT is the same all over Europe and for all operators.
The lesson behind all this; being shafted by Brussels is in no way any different than being shafted by the UK government.
But once you have a common European law, it will be easier to get it changed in all countries at the same time then in every state separately.
Last edited by ARMGAT; 14th Dec 2004 at 11:03.
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Just to clarify some of the confusion over the two entities that are being quoted here.
The JAA (Joint Aviation Authorities) is just an organistaion formed from various European (as in georaphical) Aviation Authorities, who agreed to work to a set of standard requirements, as laid down in JAR-OPS1. It is not an EU organisation and therefore its requirements are NOT legally binding. Subpart Q of JAR-OPS1 was meant to be a standard FTL scheme but as was stated most of the countries with less restrictive FTL schemes would not agree to it. Not much choice for the JAA there. What do you do...scrap the whole idea because of one area of disagreement.
EASA (European Aviation Security Agency??) is an EU organisation and thereofre any requirements will be legally binding under European Law. That is the big differance.
Please dont forget that for many countries these proposals will increase their FTL schemes and therefore improve overall European safety. So we shoudn't just dissmiss this as typical EU bureaucracy.
What we do need to ensure is that a reasonable MINIMUM is put in place. Therefore there would be no reason why the UK should not stick with CAP371, After all it would comply with the European minimums.
The JAA (Joint Aviation Authorities) is just an organistaion formed from various European (as in georaphical) Aviation Authorities, who agreed to work to a set of standard requirements, as laid down in JAR-OPS1. It is not an EU organisation and therefore its requirements are NOT legally binding. Subpart Q of JAR-OPS1 was meant to be a standard FTL scheme but as was stated most of the countries with less restrictive FTL schemes would not agree to it. Not much choice for the JAA there. What do you do...scrap the whole idea because of one area of disagreement.
EASA (European Aviation Security Agency??) is an EU organisation and thereofre any requirements will be legally binding under European Law. That is the big differance.
Please dont forget that for many countries these proposals will increase their FTL schemes and therefore improve overall European safety. So we shoudn't just dissmiss this as typical EU bureaucracy.
What we do need to ensure is that a reasonable MINIMUM is put in place. Therefore there would be no reason why the UK should not stick with CAP371, After all it would comply with the European minimums.
Alba Gu Brath
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The key point of the document is in one of the opening statements. I don't have it to hand but it basically states that member states have the autonomy to regulate above and beyond the limits imposed within Sub Part Q. For the UK there is nothing to stop the CAA overlaying Sub Part Q with CAP371, hence nothing in the UK changes. What will change is EU member states who have limits that are less than those imposed by Sub Part Q, in particular those member states that currently have no FTL limits for cabin crew!
In this case, surely the efforts should be directed to the CAA to ensure that they exercise their rights and impose the limits currently in place in the UK.
In this case, surely the efforts should be directed to the CAA to ensure that they exercise their rights and impose the limits currently in place in the UK.
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It is very important that we make these points not just on pprune but to our elected representatives, MP's MEP's and to the travelling public.
May I suggest that every pilot who reading or posting here also write to his/her Member of Parliament or equivalent if elsewhere in EU. If you don't know who he is it is in your phone book address is House of Commons, London, SW1A 0AA
May I suggest that every pilot who reading or posting here also write to his/her Member of Parliament or equivalent if elsewhere in EU. If you don't know who he is it is in your phone book address is House of Commons, London, SW1A 0AA
Alba Gu Brath
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Not sure whether the travelling public would be greatly sympathetic to the cause ShotOne. The general perception of pilots is one of highly paid salaries, luxuriating on far flung shores and a well regulated (albeit demanding) work environment. Trying to get sympathy from someone on £12,000 p.a. isn't going to be easy when they think that you are on 6 or 7 times that amount. (please note this is my comment on the publics perception, not reality).
I wouldn't hold out for much support from the elected MPs / MEPs either. Firstly they probably hold the same pre-conceptions about pilots lifestyles as Joe Public. Secondly there is a strong political will that the EU Parliament is seen to be an effective tool (sic) in European politics. Most MEP s (and MPs) would be reluctant to jeapardise that impression.
I wouldn't hold out for much support from the elected MPs / MEPs either. Firstly they probably hold the same pre-conceptions about pilots lifestyles as Joe Public. Secondly there is a strong political will that the EU Parliament is seen to be an effective tool (sic) in European politics. Most MEP s (and MPs) would be reluctant to jeapardise that impression.
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what it is?
sorry to be boring, but has anyone got a link to either a draft subpart Q, or the European initiative?
have found lots of debate about them, but not sure any of us can really comment until we have read them for ourselves.
would probably be the first question our elected representative will ask - "have you read the actual document".....
your help is much appreciated
have found lots of debate about them, but not sure any of us can really comment until we have read them for ourselves.
would probably be the first question our elected representative will ask - "have you read the actual document".....
your help is much appreciated
Alba Gu Brath
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I cannot open the link pasted by Big Tudor but as it links to the European Parliament website I suspect that it will not reflect the latest position as the Council has made a number of amendments to the Parliaments original proposal.
If this link works correctly you should be able to download a copy of the text of the proposal as it stood on 16 November from here. Click on PDF to the right of where it says content.
I understand that there may have been one or two minor amendments since 16 of November but this appears to be the latest text available at the moment.
Happy reading.
If this link works correctly you should be able to download a copy of the text of the proposal as it stood on 16 November from here. Click on PDF to the right of where it says content.
I understand that there may have been one or two minor amendments since 16 of November but this appears to be the latest text available at the moment.
Happy reading.
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I added several comments to the original post which appeared when Balpa started their campaign in earnest earlier this year. I wrote to all my MEPs and MP only to get a 'cut and paste' reply from those who even bothered to reply (approximately 2/3), which had obviously been supplied by Brian Simpson MEP who was at the time the EU Rapporteur (sp?) and who had put the proposals forward.
For those who don't know, he is an ex-school teacher here in the North West of the UK who jumped on the gravy train that is the EU. He was apparently sponsored by a cabin crew union (not sure which one and quite frankly couldn't be bothered to find out) which gave him his impetus to push for a harmonised set of FTLs (mainly for cabin crew), which may be admirable but is a totally seperate issue from harmonising FTL for flight deck to less limiting times.
I also went to see him in his constituency office with a senior captain from my airline who was about to retire but still had the wish to assist Balpa with their campaign. Simpson was bombastic and refused to listen to any argument we put. He dismissed all our concerns with the fact that the CAA could keep their more limiting FTLs therefore we had nothing to worry about. The simplistic view was astounding and he dismissed as 'not his problem' the fact that pressure would be brought to bear on the UK CAA to change to the less limiting FTLs of the rest of the EU. We even pointed out that our airline is part of a German owned group, so there may be an incentive to re-flag under a 'flag of convenience' to get round the issue. Again, 'not my problem'. His sole objective was to harmonise, at any cost otherwise he would have failed. Why was he given the job in the first place? It appears that he had a passing interest in civil aviation and word got round the office when they were looking for someone to take on the role. He has no aviation background or experience in the field other than in the role as rapporteur and refuses to take any of the concerns about lack of scientific evidence because, and I quote, 'for every report you quote that says it is unsafe, I have a desk full that say that it is safe'. I asked for sources so that I could read these reports, but he couldn't think of any at the time...........
He did indeed lose his seat in the recent EU elections, which was comforting to hear, but unfortunately the process had moved on from where he really mattered and was with the Council of Ministers, his proposals being complete.
It is a sad fact that not enough UK pilots are actively taking an interest in this subject, perhaps due to their misconception that we'll be alright with our get out clause. A colleague of mine attended the protest outside the EU parliament along with other pilots from throughout Europe. I know due to work commitments that not many would be able to attend, but only about 100 pilots were there and only 5 from the UK. Very sad indeed.
We must keep the pressure on and write to our MPs and MEPs and the Transport Minister to express our concerns. Balpa members can even get a template letter from the Balpa website. It couldn't be easier really, just half an hour on a day off. I personally think that the campaign must be pushed harder with the general public. OK they might have this image that we get paid too much and sit on beaches, but highlighting the differences mentioned above about bus and truck drivers and us with the associated effect on safety margins will eventually strike a chord. The public assume that we are highly protected and assume that we are never tired when sitting up front. They still assume that when we get to Tenerife we will be on the beach probably before them.............
PP
For those who don't know, he is an ex-school teacher here in the North West of the UK who jumped on the gravy train that is the EU. He was apparently sponsored by a cabin crew union (not sure which one and quite frankly couldn't be bothered to find out) which gave him his impetus to push for a harmonised set of FTLs (mainly for cabin crew), which may be admirable but is a totally seperate issue from harmonising FTL for flight deck to less limiting times.
I also went to see him in his constituency office with a senior captain from my airline who was about to retire but still had the wish to assist Balpa with their campaign. Simpson was bombastic and refused to listen to any argument we put. He dismissed all our concerns with the fact that the CAA could keep their more limiting FTLs therefore we had nothing to worry about. The simplistic view was astounding and he dismissed as 'not his problem' the fact that pressure would be brought to bear on the UK CAA to change to the less limiting FTLs of the rest of the EU. We even pointed out that our airline is part of a German owned group, so there may be an incentive to re-flag under a 'flag of convenience' to get round the issue. Again, 'not my problem'. His sole objective was to harmonise, at any cost otherwise he would have failed. Why was he given the job in the first place? It appears that he had a passing interest in civil aviation and word got round the office when they were looking for someone to take on the role. He has no aviation background or experience in the field other than in the role as rapporteur and refuses to take any of the concerns about lack of scientific evidence because, and I quote, 'for every report you quote that says it is unsafe, I have a desk full that say that it is safe'. I asked for sources so that I could read these reports, but he couldn't think of any at the time...........
He did indeed lose his seat in the recent EU elections, which was comforting to hear, but unfortunately the process had moved on from where he really mattered and was with the Council of Ministers, his proposals being complete.
It is a sad fact that not enough UK pilots are actively taking an interest in this subject, perhaps due to their misconception that we'll be alright with our get out clause. A colleague of mine attended the protest outside the EU parliament along with other pilots from throughout Europe. I know due to work commitments that not many would be able to attend, but only about 100 pilots were there and only 5 from the UK. Very sad indeed.
We must keep the pressure on and write to our MPs and MEPs and the Transport Minister to express our concerns. Balpa members can even get a template letter from the Balpa website. It couldn't be easier really, just half an hour on a day off. I personally think that the campaign must be pushed harder with the general public. OK they might have this image that we get paid too much and sit on beaches, but highlighting the differences mentioned above about bus and truck drivers and us with the associated effect on safety margins will eventually strike a chord. The public assume that we are highly protected and assume that we are never tired when sitting up front. They still assume that when we get to Tenerife we will be on the beach probably before them.............
PP
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The provisions of CAP 371 make perfect sense in an airline operation, but maybe one reason why some other countries don’t want to adopt it is that these regulations ignore the needs and conditions of a sizeable sector of professional aviation: daylight VFR-only ops, especially single-pilot.
I’ve worked for several operators outside the UK whose governing bodies used CAP 371 as their regulatory text, and for us these rules were only just shy of a disaster. In day VFR work there is no disruption of a sleep pattern – when it’s dark you rest, you only work when it’s light, so there should be no need for early or late shifts. The important factors to consider are maximum flying time per day, and sufficient days off. But under CAP 371 the maximum allowable duty period means that one pilot can’t cover a normal day’s flying, so the operator must hire somebody else to cover just the last 2 or 3 hours, or close up shop while there are still customers wanting to fly. For the small operators which engage in this kind of operation, either option is a severe financial burden.
In the USA, there are separate duty time regulations for unscheduled Part 135 operations, which allow an operator to crew an aircraft for one day with one pilot, but no such option exists in CAP 371. This lack of flexibility may just be the reason why other European countries don’t want to burden their GA operators with its consequences.
I’ve worked for several operators outside the UK whose governing bodies used CAP 371 as their regulatory text, and for us these rules were only just shy of a disaster. In day VFR work there is no disruption of a sleep pattern – when it’s dark you rest, you only work when it’s light, so there should be no need for early or late shifts. The important factors to consider are maximum flying time per day, and sufficient days off. But under CAP 371 the maximum allowable duty period means that one pilot can’t cover a normal day’s flying, so the operator must hire somebody else to cover just the last 2 or 3 hours, or close up shop while there are still customers wanting to fly. For the small operators which engage in this kind of operation, either option is a severe financial burden.
In the USA, there are separate duty time regulations for unscheduled Part 135 operations, which allow an operator to crew an aircraft for one day with one pilot, but no such option exists in CAP 371. This lack of flexibility may just be the reason why other European countries don’t want to burden their GA operators with its consequences.
ZbV
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Big Tudor and Cathar, Thank you for those links.
After reading the proposal there are very few changes to our national flight & duty time limitations. These seem to be very similar in all of the Nordic countries. So it will be ops normal to us.
JJ
After reading the proposal there are very few changes to our national flight & duty time limitations. These seem to be very similar in all of the Nordic countries. So it will be ops normal to us.
JJ
Last edited by JJflyer; 15th Dec 2004 at 09:14.
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Pilot Pete,
I too have been in touch with my MEP, Linda McAvan.
In the letter I got back, I quote, "I'm aware that BALPA have publicly stated that the European Parliament's report on civil aviation and specifically the element which covers flight duty time would force British pilots to work longer hours. This is untrue........"
There is then a page which attempts to explain why it's untrue, all of which seems to me to be misinformed twaddle.
It has always frightened and amazed me how stupid and not-so-bright people can end up having a bearing on other people's lives by getting themselves into posions of responsibilty, such as MPs and MEPs!
The MEP's fax number for anyone who is interested is 00322 284 9438
I too have been in touch with my MEP, Linda McAvan.
In the letter I got back, I quote, "I'm aware that BALPA have publicly stated that the European Parliament's report on civil aviation and specifically the element which covers flight duty time would force British pilots to work longer hours. This is untrue........"
There is then a page which attempts to explain why it's untrue, all of which seems to me to be misinformed twaddle.
It has always frightened and amazed me how stupid and not-so-bright people can end up having a bearing on other people's lives by getting themselves into posions of responsibilty, such as MPs and MEPs!
The MEP's fax number for anyone who is interested is 00322 284 9438
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When operating in busy airspace, packed in as tight as ATC can get, sliding down the glide 3 behind and 3 in front of another flight to land on a runway which the guy in front will have got off ASAP and there are others waiting at various holds to cross or line-up, not to mention the stream of VFR transit flights by PPLs traversing the overhead............................is itnot important that everyone is on top of their game?
If safety requires UK pilots to have adequate rest then it also dictates that every other flight in the same airspace should be operated by pilots who are as well rested.
Shame to be fully awake when the sleeping pilots spear your tin can!
Thus, if current European rest times are so bad that other countries could have fatigued and dangerous pilots.....is it not too dangerous for other people to fly there?
Perhaps BALPA are barking up the wrong tree (again).
Perhaps we need to look at the rest time of the refueler driver with 2 big tanks waiting to cross an active runway at 2200 in the dark!!!!
The lay person will simply see this as BALPA trying to protect their easy lifestyle.
Regards,
DFC
If safety requires UK pilots to have adequate rest then it also dictates that every other flight in the same airspace should be operated by pilots who are as well rested.
Shame to be fully awake when the sleeping pilots spear your tin can!
Thus, if current European rest times are so bad that other countries could have fatigued and dangerous pilots.....is it not too dangerous for other people to fly there?
Perhaps BALPA are barking up the wrong tree (again).
Perhaps we need to look at the rest time of the refueler driver with 2 big tanks waiting to cross an active runway at 2200 in the dark!!!!
The lay person will simply see this as BALPA trying to protect their easy lifestyle.
Regards,
DFC
Question - if the fatigue limitation is comparable to the drink/drive limit in effect, why do you never hear of Dramatic Fatigue Arrests! (Tired Pilot Torn From Cockpit of Airbus 737 By Cops Drama!)
Would it be that drinking alcohol is up to the individual employee - but hours are a question for the employer?
Would it be that drinking alcohol is up to the individual employee - but hours are a question for the employer?
I agree that pilots are widely seen by the public as highly paid. This is a PR problem. However the public is not stupid.
If pilot max work hours are compared with max permitted hours of other "drivers", or of other operators of critical machinary.
If (as I suspect) pilots can work much longer in comparison, the argument is, in part, won.
But I do not know the real numbers.
What are the max permitted working hours for truck drivers, (train drivers, bus drivers etc)?
What are the max permitted hours of Air Traffic controllers, nuclear power operators ...whatever.
This line of approach might bear fruit with the public.
If pilot max work hours are compared with max permitted hours of other "drivers", or of other operators of critical machinary.
If (as I suspect) pilots can work much longer in comparison, the argument is, in part, won.
But I do not know the real numbers.
What are the max permitted working hours for truck drivers, (train drivers, bus drivers etc)?
What are the max permitted hours of Air Traffic controllers, nuclear power operators ...whatever.
This line of approach might bear fruit with the public.
Alba Gu Brath
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Lord Lucan,
Can't comment on any other than lorry drivers. There are no maximum duty hour rules, other than the EU Working Time Directive. The limits are set on driving time as follows:
Daily limit = Max 9 hours driving time (may be increased to 10 hours twice a week)
Fortnightly driving limit = 90 hours.
Max 6 daily driving periods between weekly rest periods.
1 x 45 hours rest period per week.
Drivers must take a 45 min break after 4 hrs 30 mins driving. No work may be undertaken during the break.
Min rest between daily driving tasks = 11 hours.
No early start / late finish rules. No reduction in driving hours for night work.
Can't comment on any other than lorry drivers. There are no maximum duty hour rules, other than the EU Working Time Directive. The limits are set on driving time as follows:
Daily limit = Max 9 hours driving time (may be increased to 10 hours twice a week)
Fortnightly driving limit = 90 hours.
Max 6 daily driving periods between weekly rest periods.
1 x 45 hours rest period per week.
Drivers must take a 45 min break after 4 hrs 30 mins driving. No work may be undertaken during the break.
Min rest between daily driving tasks = 11 hours.
No early start / late finish rules. No reduction in driving hours for night work.
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1.2 Cumulative Duty Hours
An operator shall ensure that the total duty periods to which a crew member is assigned do not exceed:
a) 190 duty hours in any 28 consecutive days,
b) 60 duty hours in any 7 consecutive days;
1.5 Duty period
A period which starts when a crew member is required by an operator to report for a duty and ends when the crew member is free from all duties;
1.6 Flight Duty Period
A Flight Duty Period (FDP) is any time during which a person operates in an aircraft as a member of its crew. The FDP starts when the crew member is required by an operator to report for a flight or a series of flights; it finishes at the end of the last flight on which he/she is an operating crew member or other time as specified by the responsible Civil Aviation Authority;
C. FLIGHT AND DUTY LIMITATIONS
1.1 Cumulative Limits on Flying Hours
An operator shall ensure that the total block times of the flights on which an individual crew member is assigned as an operating crew member does not exceed 900 block hours in a calendar year spread as evenly as practicable throughout the year;
So it appears that the referenced version at least has no weekly or monthly Flight Duty Period limits, only a 900 hour yearly limit (hopefully spread equally throughout the year), and a 190 hr Duty (Not FDP) limit per 28 days - all a bit goofy and reinforces that it was apparently all laid out by "amateurs" utilizing the standard EU consultative process (IE NONE - typical EU government by diktat).
An operator shall ensure that the total duty periods to which a crew member is assigned do not exceed:
a) 190 duty hours in any 28 consecutive days,
b) 60 duty hours in any 7 consecutive days;
1.5 Duty period
A period which starts when a crew member is required by an operator to report for a duty and ends when the crew member is free from all duties;
1.6 Flight Duty Period
A Flight Duty Period (FDP) is any time during which a person operates in an aircraft as a member of its crew. The FDP starts when the crew member is required by an operator to report for a flight or a series of flights; it finishes at the end of the last flight on which he/she is an operating crew member or other time as specified by the responsible Civil Aviation Authority;
C. FLIGHT AND DUTY LIMITATIONS
1.1 Cumulative Limits on Flying Hours
An operator shall ensure that the total block times of the flights on which an individual crew member is assigned as an operating crew member does not exceed 900 block hours in a calendar year spread as evenly as practicable throughout the year;
So it appears that the referenced version at least has no weekly or monthly Flight Duty Period limits, only a 900 hour yearly limit (hopefully spread equally throughout the year), and a 190 hr Duty (Not FDP) limit per 28 days - all a bit goofy and reinforces that it was apparently all laid out by "amateurs" utilizing the standard EU consultative process (IE NONE - typical EU government by diktat).