BALPA Non-members please read
stilljustanothernumber
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BALPA Non-members please read
BALPA is organising a campaign against the European Parliaments plans for flight time limitations. Against the advice of the scientific commmunity and the UKCAA, they seem set on introducing this new legislation. Please, go to www.balpa.org read, and then WRITE TO YOUR MP & YOUR MEP.
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Excellent news! Now would that be the same campaign that they started organising back - now let me think ah yes - 1994. That's seems an awful lot of organising to me so I expect the results wil be outstanding!
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I've no idea if it's the same campaign (though I doubt it) but the point is this: you need to join in and take action yourself, rather than leaving it to others. It's important for as many people as possible to respond.
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unwiseowl - you say 'against the advice of the UK CAA' and that is what the BALPA document says. Can you tell us where and how the CAA have given such contrary advice?
As far as I am aware the CAA can, effectively, veto anything it does not intend to adopt. It is one thing for them to tell us they do not agree but quite another for them to exercise their opinion in Europe - have they done that? I suspect CAA are far too concerned about gearing up to privatisation and potential share options and all the other 'goodies' to think about 'rocking any boats' on our behalf. Whilst they do, perhaps in many cases, did, have some very good people who were, essentially 'on the side' of aviation and aviators, I see and experience a very different CAA of late. Even the most obvious and basic muddles that we need answers to, they seem incapable, reluctant and too busy to do - preferring to farm as many cost centres as possible out to new quangos who don't know the answers either - as well as making us buy stuff that we really ought to be provided with - like JARs.,for example. Note that the French apply whichever of the JARs their aviation industry supports and veto those they don't - or, rather, just keep quiet and do what they want, anyway. I would like to see what CAA are actually doing to support 'their advice' on this topic. I rather suspect that airline operators will be delighted to see the new FTLs introduced - for obvious commercial reasons - are you sure CAA are not supporting the UK industry on this, rather than the workforce - viz: flight crew?
Actually, given age restrictions and a host of other issues where UK pilots lose out, I can't say on most other issues that CAA are supporting the UK industry/operators OR the flight crews. If CAA really do disagree with new FTLs., I am quite sure they have the brief to simply file an exception or difference, without us all writing to MEPs., etc who, I suspect, will neither understand or care what we are talking about. They will simply refer the matter back to the CAA - I suspect
As far as I am aware the CAA can, effectively, veto anything it does not intend to adopt. It is one thing for them to tell us they do not agree but quite another for them to exercise their opinion in Europe - have they done that? I suspect CAA are far too concerned about gearing up to privatisation and potential share options and all the other 'goodies' to think about 'rocking any boats' on our behalf. Whilst they do, perhaps in many cases, did, have some very good people who were, essentially 'on the side' of aviation and aviators, I see and experience a very different CAA of late. Even the most obvious and basic muddles that we need answers to, they seem incapable, reluctant and too busy to do - preferring to farm as many cost centres as possible out to new quangos who don't know the answers either - as well as making us buy stuff that we really ought to be provided with - like JARs.,for example. Note that the French apply whichever of the JARs their aviation industry supports and veto those they don't - or, rather, just keep quiet and do what they want, anyway. I would like to see what CAA are actually doing to support 'their advice' on this topic. I rather suspect that airline operators will be delighted to see the new FTLs introduced - for obvious commercial reasons - are you sure CAA are not supporting the UK industry on this, rather than the workforce - viz: flight crew?
Actually, given age restrictions and a host of other issues where UK pilots lose out, I can't say on most other issues that CAA are supporting the UK industry/operators OR the flight crews. If CAA really do disagree with new FTLs., I am quite sure they have the brief to simply file an exception or difference, without us all writing to MEPs., etc who, I suspect, will neither understand or care what we are talking about. They will simply refer the matter back to the CAA - I suspect
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Having worked for a Dublin based outfit and now a German airline I find the new proposals would actually result in my working potentially shorter shift patterns!
If the guys in the UK want to protect their jobs they must recognise the advantages from the company point of view of expansion using fewer crews. This may not be morally correct and there may be a valid arguement in terms of potential fatigue, however cost is a big factor.
The airline I work for is already moaning about possible increases in costs due this proposal. If anything this will put the UK back on an even footing with the rest of europe and maybe as Immelman suggests the CAA will go with the flow.
How many pilots will end up being effected by this anyway? most of us already come under the more flexible JAR limitations not the UK ones!
If the guys in the UK want to protect their jobs they must recognise the advantages from the company point of view of expansion using fewer crews. This may not be morally correct and there may be a valid arguement in terms of potential fatigue, however cost is a big factor.
The airline I work for is already moaning about possible increases in costs due this proposal. If anything this will put the UK back on an even footing with the rest of europe and maybe as Immelman suggests the CAA will go with the flow.
How many pilots will end up being effected by this anyway? most of us already come under the more flexible JAR limitations not the UK ones!
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Come on guys,
This is bigger than a 'them and us' argument, and as for CAA bashing this issue is bigger than that also. They have expressed their concerns about Brian Simpson's proposals to the Council of Members as have all 18 members of the European Cockpit Association and IFALPA. The concerns are not along protectionist lines or market share or any other such measure. They are concerned primarily with SAFETY and about the 'one case fits all' approach to a FTL scheme for Europe based on no scientific evidence of the effects of fatigue in airline pilots.
Simpson has the rather naive belief that setting the limits he suggests with the 'opt out' clause for individual member state authorities will be perfectly acceptable. The proposed EU regulation allows pilots to remain at the controls of aircraft whilst significantly above level 5 on the Samn-Perelli sleepiness scale as used by QinetiQ (formerly DERA)- leading experts in the field of sleep study and the effects of fatigue on the human body. (Level 5 equates to 'Moderate to severe fatigue' based on in-flight studies and where flying duty is permissible but not recommended)
ECASS - The European Committee for Aircrew Scheduling and Safety, is critical of the proposals. They conclude 'we would certainly consider it likely that this would lead to a significant reduction of airline safety operations. We would therefore recommend that this document (Simpson's proposal) is redrafted to reflect the scientific position more closely.'
I would urge you to read the ETSC (European Transport Safety Council) paper here prepared for the meeting 19/02/03 to discuss the role of the EU FTL legislation in reducing cumulative fatigue in civil aviation. It highlights the safety concerns too and demonstrates some of the flaws in the current proposals.
I have personally emailed all my Euro MPs to highlight my fears of these proposals being adopted and the inevitable safety detriment. One of these is Brian Simpson himself. This is his reply;
Dear Mr xxxx,
Thank you for your email. I am aware that the British Airline Pilots Association have publicly stated that the European Parliament's report on EU opps which contains flight duty time would force British pilots to work longer hours.
This is untrue.
The parliamentary report on this matter merely sets up a legal framework covering the whole of Europe in which a ceiling of maximum hours is set.
Member States such as the United Kingdom can still set flight and duty times for pilots at levels which they feel are appropriate to them and trade unions can negotiate with airlines flight and duty times for their pilots, providing that they do not exceed the maximum limits laid down. Therefore the present legal maximums set in the UK can continue, should the UK authorities so wish, and the present industrial agreements can be maintained.
An added bonus for a Europe wide regulation would be not only to set maximum limits in those countries were none exist at this moment but for the first time give legal recognition throughout Europe for cabin crew personnel. It should also be noted that the maximum flight and duty times contained within the Parliament's proposal is based on the present JAA rules which are operating in most member states at the moment.
In conclusion, I would remind you that the trade unions and airlines have been in negotiations on this issue for 15 years. Even when the Parliament was asked by the Commission to legislate in this area, its rapporteur gave the social partners a further two years to reach an agreement.
When this agreement failed (because the pilots alone would not agree) the Parliament felt it should go ahead and legislate, taking into account the views of all sides in reaching its decision.
I hope this clarifies the situation for you.
Yours sincerely
Brian Simpson MEP
European Parliament
13G209
rue Wiertz
1047 Brussels
Belgium
Tel: 0032 2 284 5293
This was my reply;
Dear Mr Simpson,
I would like to offer some further comments in response to your reply regarding your proposals to alter the FTL scheme Europe wide.
I feel the reply given, although factually correct appears, if I may be so bold, a little niave. I will respond in order.
1 You state that the proposals will not force British pilots to work longer hours which is a concern of BALPA. Yes, I am sure that under the proposals member state aviation authorities will be allowed to continue to work to stricter, more limiting schemes. But, and this is where the viewpoint appears rather simplistic, if one state has a much more lax limit (the proposal) than the UK CAA CAP371 do you not think that UK airlines will seek to exploit this? Indeed if one airline does exploit it others may be forced to follow suit in order to remain competitive. This is exactly the kind of loop hole that your proposals will encourage, to the detriment of safety. Look to commercial shipping for evidence of lesser standards under flags of convenience. I do not believe that the UK CAA will be able to hold out under intense pressure from the airlines to increase the Flight Time Limitations to that of any Europe wide JAR OPS limit. The evidence is already there that the airlines, due to commercial pressures strive to roster to the limits laid down in law. CAP 371 was introduced to be a maximum limit and was not designed as a roster framework tool, which many airlines use it as. I have only a short time in the industry but after September 11th 2001 I was placed on contract with one of the UK's leading charter airlines who rostered me to the limits of CAP371 during summer 02 and I was fatigued by the end of it suffering from repeat bouts of conjunctivis due to a depressed immune system. The better uk airlines have Flight Duty Agreements that are more restrictive than CAP371 and offer better rostering practices and increased quality of life for their pilots, but primarily increased safety. The schemes have nearly all been negotiated by BALPA working with the employers. I fear these schemes could also be at risk if airlines are allowed to 'up sticks' and move their operation to a more 'convenient' member state.
2 You point out that an added bonus of the Europe wide regulation would be not only to set maximum limits in those countries were none exist at this moment but for the first time give legal recognition throughout Europe for cabin crew personnel. I agree that setting maximum limits in those countries where non exist presently is a good thing. But, surely this should not lead to the situation described in my first point where the largest aviation business outside the US (The UK) is allowed to 'flag out' to the detriment of safety in search of increased profitability? Do you not think that the limits for any scheme should be arrived at by scientific evidence about the human physiology and fatigue from an independent expert body such as QinetiQ? I must stress again that I would be more than happy to work under any FTL which had been devised under expert guidance which maintained safety levels by preventing fatigue. Your proposals will not ensure this, infact the opposite is true. If your proposals have been arrived at through independent scientific consultation please supply me with the references.
The fact that without exception all 18 pilot organisations representing 31,000 professional airline pilots in Europe condemn the proposals as unsafe speaks volumes to me and should strike a chord with you and your parliamentary colleagues. These are the people who currently work in the industry and understand the toll that repeated changing shift patterns and time zone changes have on their performance. These are the professionals whose primary concern is safety, your safety, the public's safety and their own safety, every time they go to work. You simply must listen to their concerns and not be responsible, even if inadvertently, for a decline in these safety standards. We rely on you to legislate to prevent inappropriate commercial gain at the expense of safety. Recognition of cabin crew throughout Europe is an important issue, again one which needs addressing, but it is too small a benefit to persuade me that these proposals should be adopted. I suggest you think again for a more convincing selling point for your ideas.
3 The fact that it has taken so long to reach agreement on this issue proves just what a difficult area it is to 'harmonise'. I take your word that it was the 'pilots' alone who would not agree, but perhaps they are the only ones trying to uphold the safety standards which this industry is rightly proud of. Just because something has taken a long time is no reason to pass ill advised legislation. If you truly are taking into account the views of both sides perhaps you could explain why no scientific evidence is being used to formulate the scheme, as requested by the 'pilots'?
I refer you to the ETSC paper prepared for the "Meeting to discuss the role of EU FTL legislation in reducing cumulative fatigue in civil aviation" in Brussels 19/02/03 by T. Akerstedt, R. Mollard, A. Samel, M. Simons and M. Spencer. This paper, and I quote, says 'It is therefore regretted that the propsal is so limited in its scope.' I have to agree this is harmonisation and a retrograde step at the expense of safety. I urge you to reconsider these proposals.
I thank you all once again for listening to my arguments and urge you to look deeply into the safety issues related to these proposals and come to the only conclusion that befits such proposals.
Yours sincerely
xxxx
And Immelman you are also incorrect in stating that Euro MPs
Here are the replies that I have received so far;
Dear xxxx
Thanks for your email about this matter. I am on the Regional Policy, Transport and Tourism Committee so I will be able to vote in accordance with your wishes at the appropriate time.
Regards
Den Dover Conservative MEP for North West England
And;
Dear Mr xxxx
Thank you for your letter concerning airline pilot flying hours.
My colleague, Brian Simpson MEP, is following the report through parliament and I will certainly discuss your concerns with him. I will also discuss the proposals with my other North West colleagues.
Thank you for highlighting this issue and rightly pointing out the seriousness of it.
Yours sincerely,
Terry Wynn MEP
So there you have it. It IS serious and they WILL listen if you take the time to tell them your concerns. But it's no good just me doing it, the more people who do it the better as the more 'letters' they get about a subject the more they start to realise it is a SERIOUS set of concerns they are facing.
Best FTL practice should be what we are aiming for across Europe, to maintain and enhance safety, not some ill thought out proposal to give cabin crew recognition (Simpsons goal) at the expence of overall flight safety. CC recognition is a separate issue, and justified, but not the best selling point for me.
Think hard and take action or this industry's safety record is going to be set back years. Tell your MEPs that you are willing to work under any FTL that is scientifically proven to be best practice. Tell them to reject the proposals unless they are redrafted after scientific consultation.
PP
This is bigger than a 'them and us' argument, and as for CAA bashing this issue is bigger than that also. They have expressed their concerns about Brian Simpson's proposals to the Council of Members as have all 18 members of the European Cockpit Association and IFALPA. The concerns are not along protectionist lines or market share or any other such measure. They are concerned primarily with SAFETY and about the 'one case fits all' approach to a FTL scheme for Europe based on no scientific evidence of the effects of fatigue in airline pilots.
Simpson has the rather naive belief that setting the limits he suggests with the 'opt out' clause for individual member state authorities will be perfectly acceptable. The proposed EU regulation allows pilots to remain at the controls of aircraft whilst significantly above level 5 on the Samn-Perelli sleepiness scale as used by QinetiQ (formerly DERA)- leading experts in the field of sleep study and the effects of fatigue on the human body. (Level 5 equates to 'Moderate to severe fatigue' based on in-flight studies and where flying duty is permissible but not recommended)
ECASS - The European Committee for Aircrew Scheduling and Safety, is critical of the proposals. They conclude 'we would certainly consider it likely that this would lead to a significant reduction of airline safety operations. We would therefore recommend that this document (Simpson's proposal) is redrafted to reflect the scientific position more closely.'
I would urge you to read the ETSC (European Transport Safety Council) paper here prepared for the meeting 19/02/03 to discuss the role of the EU FTL legislation in reducing cumulative fatigue in civil aviation. It highlights the safety concerns too and demonstrates some of the flaws in the current proposals.
I have personally emailed all my Euro MPs to highlight my fears of these proposals being adopted and the inevitable safety detriment. One of these is Brian Simpson himself. This is his reply;
Dear Mr xxxx,
Thank you for your email. I am aware that the British Airline Pilots Association have publicly stated that the European Parliament's report on EU opps which contains flight duty time would force British pilots to work longer hours.
This is untrue.
The parliamentary report on this matter merely sets up a legal framework covering the whole of Europe in which a ceiling of maximum hours is set.
Member States such as the United Kingdom can still set flight and duty times for pilots at levels which they feel are appropriate to them and trade unions can negotiate with airlines flight and duty times for their pilots, providing that they do not exceed the maximum limits laid down. Therefore the present legal maximums set in the UK can continue, should the UK authorities so wish, and the present industrial agreements can be maintained.
An added bonus for a Europe wide regulation would be not only to set maximum limits in those countries were none exist at this moment but for the first time give legal recognition throughout Europe for cabin crew personnel. It should also be noted that the maximum flight and duty times contained within the Parliament's proposal is based on the present JAA rules which are operating in most member states at the moment.
In conclusion, I would remind you that the trade unions and airlines have been in negotiations on this issue for 15 years. Even when the Parliament was asked by the Commission to legislate in this area, its rapporteur gave the social partners a further two years to reach an agreement.
When this agreement failed (because the pilots alone would not agree) the Parliament felt it should go ahead and legislate, taking into account the views of all sides in reaching its decision.
I hope this clarifies the situation for you.
Yours sincerely
Brian Simpson MEP
European Parliament
13G209
rue Wiertz
1047 Brussels
Belgium
Tel: 0032 2 284 5293
This was my reply;
Dear Mr Simpson,
I would like to offer some further comments in response to your reply regarding your proposals to alter the FTL scheme Europe wide.
I feel the reply given, although factually correct appears, if I may be so bold, a little niave. I will respond in order.
1 You state that the proposals will not force British pilots to work longer hours which is a concern of BALPA. Yes, I am sure that under the proposals member state aviation authorities will be allowed to continue to work to stricter, more limiting schemes. But, and this is where the viewpoint appears rather simplistic, if one state has a much more lax limit (the proposal) than the UK CAA CAP371 do you not think that UK airlines will seek to exploit this? Indeed if one airline does exploit it others may be forced to follow suit in order to remain competitive. This is exactly the kind of loop hole that your proposals will encourage, to the detriment of safety. Look to commercial shipping for evidence of lesser standards under flags of convenience. I do not believe that the UK CAA will be able to hold out under intense pressure from the airlines to increase the Flight Time Limitations to that of any Europe wide JAR OPS limit. The evidence is already there that the airlines, due to commercial pressures strive to roster to the limits laid down in law. CAP 371 was introduced to be a maximum limit and was not designed as a roster framework tool, which many airlines use it as. I have only a short time in the industry but after September 11th 2001 I was placed on contract with one of the UK's leading charter airlines who rostered me to the limits of CAP371 during summer 02 and I was fatigued by the end of it suffering from repeat bouts of conjunctivis due to a depressed immune system. The better uk airlines have Flight Duty Agreements that are more restrictive than CAP371 and offer better rostering practices and increased quality of life for their pilots, but primarily increased safety. The schemes have nearly all been negotiated by BALPA working with the employers. I fear these schemes could also be at risk if airlines are allowed to 'up sticks' and move their operation to a more 'convenient' member state.
2 You point out that an added bonus of the Europe wide regulation would be not only to set maximum limits in those countries were none exist at this moment but for the first time give legal recognition throughout Europe for cabin crew personnel. I agree that setting maximum limits in those countries where non exist presently is a good thing. But, surely this should not lead to the situation described in my first point where the largest aviation business outside the US (The UK) is allowed to 'flag out' to the detriment of safety in search of increased profitability? Do you not think that the limits for any scheme should be arrived at by scientific evidence about the human physiology and fatigue from an independent expert body such as QinetiQ? I must stress again that I would be more than happy to work under any FTL which had been devised under expert guidance which maintained safety levels by preventing fatigue. Your proposals will not ensure this, infact the opposite is true. If your proposals have been arrived at through independent scientific consultation please supply me with the references.
The fact that without exception all 18 pilot organisations representing 31,000 professional airline pilots in Europe condemn the proposals as unsafe speaks volumes to me and should strike a chord with you and your parliamentary colleagues. These are the people who currently work in the industry and understand the toll that repeated changing shift patterns and time zone changes have on their performance. These are the professionals whose primary concern is safety, your safety, the public's safety and their own safety, every time they go to work. You simply must listen to their concerns and not be responsible, even if inadvertently, for a decline in these safety standards. We rely on you to legislate to prevent inappropriate commercial gain at the expense of safety. Recognition of cabin crew throughout Europe is an important issue, again one which needs addressing, but it is too small a benefit to persuade me that these proposals should be adopted. I suggest you think again for a more convincing selling point for your ideas.
3 The fact that it has taken so long to reach agreement on this issue proves just what a difficult area it is to 'harmonise'. I take your word that it was the 'pilots' alone who would not agree, but perhaps they are the only ones trying to uphold the safety standards which this industry is rightly proud of. Just because something has taken a long time is no reason to pass ill advised legislation. If you truly are taking into account the views of both sides perhaps you could explain why no scientific evidence is being used to formulate the scheme, as requested by the 'pilots'?
I refer you to the ETSC paper prepared for the "Meeting to discuss the role of EU FTL legislation in reducing cumulative fatigue in civil aviation" in Brussels 19/02/03 by T. Akerstedt, R. Mollard, A. Samel, M. Simons and M. Spencer. This paper, and I quote, says 'It is therefore regretted that the propsal is so limited in its scope.' I have to agree this is harmonisation and a retrograde step at the expense of safety. I urge you to reconsider these proposals.
I thank you all once again for listening to my arguments and urge you to look deeply into the safety issues related to these proposals and come to the only conclusion that befits such proposals.
Yours sincerely
xxxx
And Immelman you are also incorrect in stating that Euro MPs
will neither understand or care what we are talking about
Dear xxxx
Thanks for your email about this matter. I am on the Regional Policy, Transport and Tourism Committee so I will be able to vote in accordance with your wishes at the appropriate time.
Regards
Den Dover Conservative MEP for North West England
And;
Dear Mr xxxx
Thank you for your letter concerning airline pilot flying hours.
My colleague, Brian Simpson MEP, is following the report through parliament and I will certainly discuss your concerns with him. I will also discuss the proposals with my other North West colleagues.
Thank you for highlighting this issue and rightly pointing out the seriousness of it.
Yours sincerely,
Terry Wynn MEP
So there you have it. It IS serious and they WILL listen if you take the time to tell them your concerns. But it's no good just me doing it, the more people who do it the better as the more 'letters' they get about a subject the more they start to realise it is a SERIOUS set of concerns they are facing.
Best FTL practice should be what we are aiming for across Europe, to maintain and enhance safety, not some ill thought out proposal to give cabin crew recognition (Simpsons goal) at the expence of overall flight safety. CC recognition is a separate issue, and justified, but not the best selling point for me.
Think hard and take action or this industry's safety record is going to be set back years. Tell your MEPs that you are willing to work under any FTL that is scientifically proven to be best practice. Tell them to reject the proposals unless they are redrafted after scientific consultation.
PP
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So is he listening or does he just read the first line and then pump out his standard reply?
The more who write to him, and more importantly to all the other MEPs with less of a 'vested' interest, the more chance there is of influencing their viewpoints with a realisation of just what will happen should his proposals be adopted.
PP
The more who write to him, and more importantly to all the other MEPs with less of a 'vested' interest, the more chance there is of influencing their viewpoints with a realisation of just what will happen should his proposals be adopted.
PP
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I think you guy`s lost the plot! BALPA and their inability to do ANYTHING was the thread........
Quite were we go from here i don`t know, yes our world is now constantly changing for the worse less pay more sectors [ 118 on my last roster] etc etc.
The problem is whilst you guys are to be congratulated for taking the bull by the horns and writing to MEP`s and the like, what we really need is a new British Pilot`s Association who live in 2003 and not on in 1953 who are able to fight for our new modern cause..................
Quite were we go from here i don`t know, yes our world is now constantly changing for the worse less pay more sectors [ 118 on my last roster] etc etc.
The problem is whilst you guys are to be congratulated for taking the bull by the horns and writing to MEP`s and the like, what we really need is a new British Pilot`s Association who live in 2003 and not on in 1953 who are able to fight for our new modern cause..................
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Flaps8 the whole point of this thread is that BALPA is fighting this, on behalf of all UK pilots. As unwiseowl (the originator of this thread) says, it is important that all UK pilots read and understand the Simpson proposals, set out at www.balpa.org and then lobby their MPs and MEPs to get this misguided proposal defeated.
BALPA has already written to all members with a comprehensive package describing the proposals and where they conflict with the scientific arguments, and inviting members to enter the argument by directly contacting their representatives in the UK and EU parliaments. It is precisely because this campaign is too important to be an issue between BALPA and non-BALPA pilots that unwiseowl has tried to bring this to the attention of non-BALPA members.
This is not the time or the place to bring up historical dissatisfactions with BALPA. If you want to avoid crew duty days up to 3 hours longer than you may work at present, do something about it now.
BALPA has already written to all members with a comprehensive package describing the proposals and where they conflict with the scientific arguments, and inviting members to enter the argument by directly contacting their representatives in the UK and EU parliaments. It is precisely because this campaign is too important to be an issue between BALPA and non-BALPA pilots that unwiseowl has tried to bring this to the attention of non-BALPA members.
This is not the time or the place to bring up historical dissatisfactions with BALPA. If you want to avoid crew duty days up to 3 hours longer than you may work at present, do something about it now.
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Three points.
1. BALPA seem to have changed tack to the degree that they are now, according to their current publications, affirming the strengths of CAP371. Sure, these limitations ARE the maximum, however, should they be used as the rostering maximums, because of the vagaries of schedules, these maximums are rarely actual maxima. Commercially, (and that is not neccesarily a dirty word!), there have to be finite maximum FDPs and, currently, perhaps in order to make the point, BALPA seem to accept that the current CAP371 IS based on scientifically assessed data. Some of us can, however, point to (CAA approved) so called alleviations to CAP371 and these should certainly be addressed by BALPA on the grounds of Flight Safety.
2. A feature of some operations is "flagging out" and I suggest that BALPA would be well-advised to project a much stronger policy against this abberation rather than their tacit approval that can be read into the status quo. This may be a stronger weapon against the taking of commercial advantage by the more unscrupulous operators, who may hide behind the more lax FTL schemes of other (European, even) jurisdictions.
3. Having seen the operation of the Brussels Gravy Train at first hand, (When licece harmonisation was first projected, I was an "expert witness"), I am not a bit surprised that these FTL proposals have been introduced in such an obviously flawed form. I am also confident that they will not survive, simply because, when all the potential dangers are exposed, arse-covering will go into overdrive and the likes of Simpson will retreat so rapidly, you won't see them.
1. BALPA seem to have changed tack to the degree that they are now, according to their current publications, affirming the strengths of CAP371. Sure, these limitations ARE the maximum, however, should they be used as the rostering maximums, because of the vagaries of schedules, these maximums are rarely actual maxima. Commercially, (and that is not neccesarily a dirty word!), there have to be finite maximum FDPs and, currently, perhaps in order to make the point, BALPA seem to accept that the current CAP371 IS based on scientifically assessed data. Some of us can, however, point to (CAA approved) so called alleviations to CAP371 and these should certainly be addressed by BALPA on the grounds of Flight Safety.
2. A feature of some operations is "flagging out" and I suggest that BALPA would be well-advised to project a much stronger policy against this abberation rather than their tacit approval that can be read into the status quo. This may be a stronger weapon against the taking of commercial advantage by the more unscrupulous operators, who may hide behind the more lax FTL schemes of other (European, even) jurisdictions.
3. Having seen the operation of the Brussels Gravy Train at first hand, (When licece harmonisation was first projected, I was an "expert witness"), I am not a bit surprised that these FTL proposals have been introduced in such an obviously flawed form. I am also confident that they will not survive, simply because, when all the potential dangers are exposed, arse-covering will go into overdrive and the likes of Simpson will retreat so rapidly, you won't see them.
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Your points are all relevant and have some merit IMHO Boris.
But, regarding your last point the greatest danger is that the potential dangers are not exposed. BALPA is trying it's best to raise it's concerns. I personally had an 'audience' with Brian Simpson MEP yesterday to discuss these matters and he 'was not for turning'. He disputes that his proposals are unsafe on the grounds that no scientist will state this fact and go public with it. The fact is that the most respected scientists in the field (ECASS, whom he dismisses)have deep concerns but are not prepared to enter into the political argument about it. This is fair enough as it is outside theirmodus operandi being completely impartial and reporting only what they conclude. They have put their concerns into print but Simpson dismisses this as, and I quote " for every scientist that says the proposals are unsafe I have another disputing this." He believes that because BALPA commissioned QinetiQ to appraise his proposals they will come up with a result that fits BALPA's position as regards the proposals. He also states that the AEA (the airlines) commissioned experts come up with a view that fits their position. He is naive in this belief and unwilling, when challenged to give details of ANY scientific evidence that he took into account when formulating his proposals, other than stating that he has a pile 9" deep of scientific evidence on his desk that is contradictory and he has taken it into consideration. The fact is he is horse-trading politically to reach an 'harmonisation' position and is not looking at best practice when coming up with an FTL that primarily takes into account safety and then looks at the other issues.
The next stage is the Council of Ministers giving their opinion on these matters, as the vote in the European Parliament has already passed and they have not rejected the proposals. The Council of Ministers have the power to reject them, send them back for ammendment/ reassessment or to accept them. Simpson is of the belief that his proposals are the best thing since sliced bread because some ststes don't have any FTL currently and therefore these states have given him the nod. The fact is that these states have taken no studies of pilot fatigue into consideration whatsover and can hardly be considered if you are looking at best practice in harmonisation. I agreed with him that his proposals are a step forward for these states, but at what expense? The fact is that the nations who have lead the field in Europe with regard to best practice in FTL planning have all taken on board the fatigue studies of organisations such as QinetiQ in the UK and the Karolinska Institute in Sweden. His proposals will set back the current 'best practice', which is not ideal (CAP371 in the UK) years. Pilots will be flying a/c with a performance detriment due to fatigue greater than someone who is just over the (fairly common European) drink drive limit. This is the danger.
We all need to, and I speak about ALL EUROPEAN PILOTS, stand up and be counted as regards this issue. Even if you come from a state that will benefit from his proposals you must write to your MP, your MEP and the Council of Ministers. They must demand that the proposals be sent for independent scientific study. You must pressure them to demand this. If the proposals get passed the Council of Ministers we are all scuppered. Fly fatigued or face your pilot management. Simpson says that member states can keep their FTL with his proposals forming an absolute maximum. He said, and I quote, if airlines exploit loopholes or less restrictive FTLs elsewhere in Europe "that's not my problem'. His brief is to formulate a framework for harmonisation, it appears at any cost.
Don't let this happen.
PP
But, regarding your last point the greatest danger is that the potential dangers are not exposed. BALPA is trying it's best to raise it's concerns. I personally had an 'audience' with Brian Simpson MEP yesterday to discuss these matters and he 'was not for turning'. He disputes that his proposals are unsafe on the grounds that no scientist will state this fact and go public with it. The fact is that the most respected scientists in the field (ECASS, whom he dismisses)have deep concerns but are not prepared to enter into the political argument about it. This is fair enough as it is outside theirmodus operandi being completely impartial and reporting only what they conclude. They have put their concerns into print but Simpson dismisses this as, and I quote " for every scientist that says the proposals are unsafe I have another disputing this." He believes that because BALPA commissioned QinetiQ to appraise his proposals they will come up with a result that fits BALPA's position as regards the proposals. He also states that the AEA (the airlines) commissioned experts come up with a view that fits their position. He is naive in this belief and unwilling, when challenged to give details of ANY scientific evidence that he took into account when formulating his proposals, other than stating that he has a pile 9" deep of scientific evidence on his desk that is contradictory and he has taken it into consideration. The fact is he is horse-trading politically to reach an 'harmonisation' position and is not looking at best practice when coming up with an FTL that primarily takes into account safety and then looks at the other issues.
The next stage is the Council of Ministers giving their opinion on these matters, as the vote in the European Parliament has already passed and they have not rejected the proposals. The Council of Ministers have the power to reject them, send them back for ammendment/ reassessment or to accept them. Simpson is of the belief that his proposals are the best thing since sliced bread because some ststes don't have any FTL currently and therefore these states have given him the nod. The fact is that these states have taken no studies of pilot fatigue into consideration whatsover and can hardly be considered if you are looking at best practice in harmonisation. I agreed with him that his proposals are a step forward for these states, but at what expense? The fact is that the nations who have lead the field in Europe with regard to best practice in FTL planning have all taken on board the fatigue studies of organisations such as QinetiQ in the UK and the Karolinska Institute in Sweden. His proposals will set back the current 'best practice', which is not ideal (CAP371 in the UK) years. Pilots will be flying a/c with a performance detriment due to fatigue greater than someone who is just over the (fairly common European) drink drive limit. This is the danger.
We all need to, and I speak about ALL EUROPEAN PILOTS, stand up and be counted as regards this issue. Even if you come from a state that will benefit from his proposals you must write to your MP, your MEP and the Council of Ministers. They must demand that the proposals be sent for independent scientific study. You must pressure them to demand this. If the proposals get passed the Council of Ministers we are all scuppered. Fly fatigued or face your pilot management. Simpson says that member states can keep their FTL with his proposals forming an absolute maximum. He said, and I quote, if airlines exploit loopholes or less restrictive FTLs elsewhere in Europe "that's not my problem'. His brief is to formulate a framework for harmonisation, it appears at any cost.
Don't let this happen.
PP
