Ryanair & Positioning Pilots
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There are a couple of questions: legality & convenience, plus, perhaps, integrity and respect both of employer & employee.
According to EASA FTL's the operator & crew member is responsible to abide by the FTL regulations and to keep a record of their duties for 24 months. The operator will assign each crew member a home base; note it does not say employee, but crew member. If the operator requires the crew member to report for duty away from home base then it is classified as positioning, and as such is duty at the very least. If a positioning crew member is listed as crew then it is FDP.
The maximum duty is 60hrs in 7 consecutive days. Here is a simple question for those involved.
A crew member (let's say contractor) is home based at A. They are rostered to report for duty at B which is outside driving distance and requires air travel. During their 5 day duty they will accumulate 50 hours FDP. To position A-B requires 1 or 2 sectors of company a/c travel and a total >6 hours. It is rostered as Day Off. Then follows 5 flying days. Travel home B-A >6 hours is the next day. It is rostered s Day Off.
Do pilots consider this to be 7 days consecutive duty and > 60hours? If they are rostered in such a way what is their reaction? Or do they have a different opinion? Or are their travelling days now rostered as duty days? Pray tell.
According to EASA FTL's the operator & crew member is responsible to abide by the FTL regulations and to keep a record of their duties for 24 months. The operator will assign each crew member a home base; note it does not say employee, but crew member. If the operator requires the crew member to report for duty away from home base then it is classified as positioning, and as such is duty at the very least. If a positioning crew member is listed as crew then it is FDP.
The maximum duty is 60hrs in 7 consecutive days. Here is a simple question for those involved.
A crew member (let's say contractor) is home based at A. They are rostered to report for duty at B which is outside driving distance and requires air travel. During their 5 day duty they will accumulate 50 hours FDP. To position A-B requires 1 or 2 sectors of company a/c travel and a total >6 hours. It is rostered as Day Off. Then follows 5 flying days. Travel home B-A >6 hours is the next day. It is rostered s Day Off.
Do pilots consider this to be 7 days consecutive duty and > 60hours? If they are rostered in such a way what is their reaction? Or do they have a different opinion? Or are their travelling days now rostered as duty days? Pray tell.
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The maximum duty is 60hrs in 7 consecutive days. Here is a simple question for those involved.
A crew member (let's say contractor) is home based at A. They are rostered to report for duty at B which is outside driving distance and requires air travel. During their 5 day duty they will accumulate 50 hours FDP. To position A-B requires 1 or 2 sectors of company a/c travel and a total >6 hours. It is rostered as Day Off. Then follows 5 flying days. Travel home B-A >6 hours is the next day. It is rostered s Day Off.
Do pilots consider this to be 7 days consecutive duty and > 60hours? If they are rostered in such a way what is their reaction? Or do they have a different opinion? Or are their travelling days now rostered as duty days? Pray tell.
A crew member (let's say contractor) is home based at A. They are rostered to report for duty at B which is outside driving distance and requires air travel. During their 5 day duty they will accumulate 50 hours FDP. To position A-B requires 1 or 2 sectors of company a/c travel and a total >6 hours. It is rostered as Day Off. Then follows 5 flying days. Travel home B-A >6 hours is the next day. It is rostered s Day Off.
Do pilots consider this to be 7 days consecutive duty and > 60hours? If they are rostered in such a way what is their reaction? Or do they have a different opinion? Or are their travelling days now rostered as duty days? Pray tell.
victorc10 wrote in this matter: It is counted as duty time, NOT flight duty time (as per the operations manual) and therefore you are on duty but not likely to affect your FTL's. Details are recorded and have been for a number of years, previously not. The new regulations will require some changes and are currently being negotiated with IAA.
I don't believe that for a second. My duty record still have me recorded as OFF on all those traveling days. As this is long gone for me know, I can honestly say I've probably busted the minimum rest on several occasions. Well I know I have, to avoid having to travel a day earlier losing yet another OFF day. So if details are recorded why have I not heard anything about it?
If this poster is a Ryanair employee, then he might be correct. I think on the rare occasions they are sent out of base it's put on the roster as a deadheading flight. For contractors, no.
Keeping Danny in Sandwiches
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It makes a mockery of Flight Time Limitations and the alleviation of fatigue.
In a proper airline monitored by a proper Aviation Authority this just wouldn't happen.
A pilot has a designated base and any travel away from that base is recorded as a duty period.
"Disney" airlines sums it up.
In a proper airline monitored by a proper Aviation Authority this just wouldn't happen.
A pilot has a designated base and any travel away from that base is recorded as a duty period.
"Disney" airlines sums it up.
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When Ryanair moved its entire operation from BGY to MXP in 2014 temporarily due to madatory runway works - all pilots and cabin crew got a memo officially changing their base to MXP to avoid any contractual obligation to provide accomodation or out of base allowances.
After letters and complaints some rooms were provided for a part of the crew. Not sure but i think you even should have had a room partner and needed to register for it long in advance (lucky for some maybe
)
Most crew however chose to use a company provided bus at 3:30 AM that would leave at the BGY crewroom before the early shift or around 10:30 AM on lates to operate a full roster out of MXP. (The bus each way depending on the traffic jams near milan took around 1,5h . )
Offical duty time started at EOBT minus 45 in the crewroom at MXP and ended with time on blocks.
Ryanair at the same time kept saying that its up to the individual to turn up at base well rested.
Most pilots took hotels at their own cost and we were all concerned about fatigue levels of our cabin crew, which was under extreme pressure. I personally witnessed when *actual* (depending on how you want to define it) duty times were exceeded for days in a row and some captains were not happy to fly with some of the crew due to fatigue.
Besides internal critique I filed two confidential reports with the IAA on this matter and the response was this;
Just so you see how much the real world cares about your commuting - it happens to be possible cause it puts flexibility to Ryanairs planning and under Ry(IAA) their flexibilty is well protected by their associated authority.
Since we all now know that it was legal and there were no incidents / accidents during the period , it must follow that everything was safe!
win win for all relevant parties (where the word relevant does certainly not apply to crew)
After letters and complaints some rooms were provided for a part of the crew. Not sure but i think you even should have had a room partner and needed to register for it long in advance (lucky for some maybe
)Most crew however chose to use a company provided bus at 3:30 AM that would leave at the BGY crewroom before the early shift or around 10:30 AM on lates to operate a full roster out of MXP. (The bus each way depending on the traffic jams near milan took around 1,5h . )
Offical duty time started at EOBT minus 45 in the crewroom at MXP and ended with time on blocks.
Ryanair at the same time kept saying that its up to the individual to turn up at base well rested.
Most pilots took hotels at their own cost and we were all concerned about fatigue levels of our cabin crew, which was under extreme pressure. I personally witnessed when *actual* (depending on how you want to define it) duty times were exceeded for days in a row and some captains were not happy to fly with some of the crew due to fatigue.
Besides internal critique I filed two confidential reports with the IAA on this matter and the response was this;
Thank you for your communication regarding Ryanair’s plan to open a temporary Base in Malpensa while necessary works are being carried out in Bergamo. The Authority has reviewed Ryanair’s proposal and can confirm that they comply with the requirements of EU-OPS. The Authority would wish to point out that it does not have oversight responsibility for contractual issues.
Since we all now know that it was legal and there were no incidents / accidents during the period , it must follow that everything was safe!
win win for all relevant parties (where the word relevant does certainly not apply to crew)
Last edited by level_change; 18th Jan 2016 at 16:53. Reason: typos
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Thanks level change
Great post, great insight, I really hope this serves to illustrate the sort of issues that Ryanair pilots face and the total lack of regulation from the muppets ( IAA ) . Seriously, great thanks, really illustrates the attitude
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Perhaps it will be worth in the future raising the issue with more than one Authority; perhaps Publish the outcome, and some Customers may decide where it may not be safe to fly?
Agreed, if a similar issue occurs, it would do no harm to forward such reports to any and all aviation authorities in EASA where RYR operate, who may be able to pressure IAA.
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Level change
So FR did comply with the regulations but didn't give a toss about staff welfare - its all about the wonga to them. I think they had a similar situ in Brindisi ? when they changed crew base overnight due to the situ in Libya ?
So FR did comply with the regulations but didn't give a toss about staff welfare - its all about the wonga to them. I think they had a similar situ in Brindisi ? when they changed crew base overnight due to the situ in Libya ?
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It would be interesting to audit the % income of IAA from RYR. With >3000 pilots and increasing and the mandatory IAA licence required; with >330 a/c on Irish register and increasing; with what ever engineering licences under IAA regime; with EASA cabin crew licences being required and presumably IAA issued; with all other company regulations under IAA jurisdiction I wonder how much goes into the IAA coffers from RYR.
Note I asked %. UK CAA receives a huge amount from BA, but perhaps the % of total is not too great.
Not casting any aspersions, just curious.
Note I asked %. UK CAA receives a huge amount from BA, but perhaps the % of total is not too great.
Not casting any aspersions, just curious.
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Many other BIG carriers throughout the EU an beyond, carry EI- registrations! I often wonder why?
are we going to question Alitalias commuting also or any other people who use EI registered aircraft to get to work?
Trouble is, who is going to go looking? The Irish Government? Not bloody likely for much the same sort of reason. Nor any European "regulatory body" either - is there one with the "authority" to do that?
Regarding the IAA, it is worth noting that they recently upped the fee for ATPL issue to €600. Ryanair provide them with a captive audience of pilots. 600 cadets a year gives them €360k/year in ATPL upgrades. Add in licence conversions, type rating fees &DC and it's a nice little earner.
Worth noting that even the gold plated CAA only charge £240 (around €330) for the same service.
Worth noting that even the gold plated CAA only charge £240 (around €330) for the same service.
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A small sidestep:
Are we talking jump seats in the cabin, or do they use the cockpit seats as well?
I am stricktly forbidden to carry anybody in the cockpit, who are not on duty, on flights to, from or over UK.
Doing so can put me (and my company) in serious trouble with the UK authorities.
Are we talking jump seats in the cabin, or do they use the cockpit seats as well?
I am stricktly forbidden to carry anybody in the cockpit, who are not on duty, on flights to, from or over UK.
Doing so can put me (and my company) in serious trouble with the UK authorities.
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Are we talking jump seats in the cabin, or do they use the cockpit seats as well?
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RAT 5
I remember this been mentioned a few years ago about revenue to them from Ryanair and it was about 0.5% of there budget or something. The main bulk is from airways charges.
This is all just guess work at this point with no real facts from me.
I remember this been mentioned a few years ago about revenue to them from Ryanair and it was about 0.5% of there budget or something. The main bulk is from airways charges.
This is all just guess work at this point with no real facts from me.
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positioning
Reading this thread it seems there is some confusion over the use of the word positioning.
If you are based in Bergamo but live in Luton then traveling to work is just that, it is not positioning, your not on duty,its not duty and you should be on board your employers aircraft (contractor or directly employed) as a ticketed passenger, that may be standby or firm.
What you cannot do in the UK is to turn up on a day off and use your airside pass to gain access to airside to turn up at the gate and ask the gate staff to put you on the flight, this would be in breech of the conditions of your airside pass. I do not doubt that this is going on, but that doesn't make it legal or right.
At Norwegian, also an Irish registered airline many pilots face the same situation of living in one country and working in another, Norwegian's solution is much simpler and transparent, all flight deck and some approved cabin crew can text their staff code and the flight on which they wish to travel and an automated system responds within about 10 seconds with a booking reference (called an S2 ticket) you then check in the same as any normal passenger, again this is not duty travel, you are not on duty and yes some use this then operate, but thats no different to catching the train to work and certainly less stressful than driving, you are allowed to occupy jumps seats both cabin and flight deck if the cabin is full. My understanding is that because this is NOT a leisure ticket and is to be used only for self positioning BEFORE OR AFTER DUTY then it does not attract APD
From time to time we also have to work from other than our home base, this is at the behest of the company and counts in full as duty time and must comply with FTL, the company rosters the positioning flight with a firm ticket,provides HOTAC, and all ground transport to from the hotel, the report time is STD - 1hour and counts in full as duty time, minimum rest normally 12 hours can be reduced to 10 hours in a hotel
So if people are turning up at the gate on days off having got there without a ticket by using staff ID channels, then i would suggest that they are in breech of many rules governing the issuance of airside passes, what they are doing is a crime and punishable as such.
Of course some will say its the last perk we have!! i disagree its black and white, it may allow people to have some sort of life whilst working in one country and living in another, but that does not make it right and your employer is complicit in allowing this practice to continue, clearly there are simple alternatives to achieve the same end as demonstrated by the Norwegian S2 ticket system, this keeps everyone legal and once set up the cost to the employer is close to zero.
If you are based in Bergamo but live in Luton then traveling to work is just that, it is not positioning, your not on duty,its not duty and you should be on board your employers aircraft (contractor or directly employed) as a ticketed passenger, that may be standby or firm.
What you cannot do in the UK is to turn up on a day off and use your airside pass to gain access to airside to turn up at the gate and ask the gate staff to put you on the flight, this would be in breech of the conditions of your airside pass. I do not doubt that this is going on, but that doesn't make it legal or right.
At Norwegian, also an Irish registered airline many pilots face the same situation of living in one country and working in another, Norwegian's solution is much simpler and transparent, all flight deck and some approved cabin crew can text their staff code and the flight on which they wish to travel and an automated system responds within about 10 seconds with a booking reference (called an S2 ticket) you then check in the same as any normal passenger, again this is not duty travel, you are not on duty and yes some use this then operate, but thats no different to catching the train to work and certainly less stressful than driving, you are allowed to occupy jumps seats both cabin and flight deck if the cabin is full. My understanding is that because this is NOT a leisure ticket and is to be used only for self positioning BEFORE OR AFTER DUTY then it does not attract APD
From time to time we also have to work from other than our home base, this is at the behest of the company and counts in full as duty time and must comply with FTL, the company rosters the positioning flight with a firm ticket,provides HOTAC, and all ground transport to from the hotel, the report time is STD - 1hour and counts in full as duty time, minimum rest normally 12 hours can be reduced to 10 hours in a hotel
So if people are turning up at the gate on days off having got there without a ticket by using staff ID channels, then i would suggest that they are in breech of many rules governing the issuance of airside passes, what they are doing is a crime and punishable as such.
Of course some will say its the last perk we have!! i disagree its black and white, it may allow people to have some sort of life whilst working in one country and living in another, but that does not make it right and your employer is complicit in allowing this practice to continue, clearly there are simple alternatives to achieve the same end as demonstrated by the Norwegian S2 ticket system, this keeps everyone legal and once set up the cost to the employer is close to zero.