Check-out time
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Check-out time
A few weeks ago my employer decided to end our 15 minutes check-out time: the duty time after the park brake is set after the last sector of the day. It was done without any notice, without any explication.
In my opinion 15 minutes was quite a short time, where many companies have at least 30 minutes after their last flight.
Anyway, now when I set the brake, with all passengers on board and the doors still closed, waiting for the airbridge to connect, I am already in my rest period preceding the next day of duty.
Your opinions please. Any more pilots working without check-out time? Is it legal to be in your rest time with pax still on board?
Thanks!
In my opinion 15 minutes was quite a short time, where many companies have at least 30 minutes after their last flight.
Anyway, now when I set the brake, with all passengers on board and the doors still closed, waiting for the airbridge to connect, I am already in my rest period preceding the next day of duty.
Your opinions please. Any more pilots working without check-out time? Is it legal to be in your rest time with pax still on board?
Thanks!
Last edited by Liftdumper; 9th Sep 2009 at 06:40. Reason: typo
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It is one of those areas where EU-OPS subpart Q is not very clear. Some CAAs have the view that the checkout time is not flight duty time any more, but i haven't seen one yet that thinks it is not duty time. Duty time however is still used to calculate rest time and does not count into rest time, but there might be the odd employer that try to do it like that.
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From Sub-part Q:-
So would of thought you have a reasonable case to make that if the pax still on or even completing post flight duties before checking out that you are not "free from all duties". This is where a union is of value!
1.13. Rest period
An uninterrupted and defined period of time during which a crew member is free from all duties and airport
standby.
An uninterrupted and defined period of time during which a crew member is free from all duties and airport
standby.
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My company differentiates between flight duty time and duty time. Flight duty is report to block on, duty is report to block on plus 30 mins. Rest time is calculated based on duty and not flight duty as duty encompasses more than flying.
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From the UK CAP 371:
"13 Maximum FDP - Aeroplanes
13.1 Standard reporting times prior to flight must be specified by an operator. Pre-flight duties are part of the FDP. A period of duty must be allowed for post-flight activities:
the minimum for major operators is 30 minutes, 15 minutes for others. If this “period” for post FDP duties is routinely exceeded then the post FDP duty period stated in the scheme must be revised to better represent the actual time taken. The
time spent between reporting for a flight and the completion of post-flight tasksdetermines the length of the subsequent rest period."
If your employer is ending your duty time while you are sitting in the cockpit post-flight, they are violating the regulations. At least in the UK.
"13 Maximum FDP - Aeroplanes
13.1 Standard reporting times prior to flight must be specified by an operator. Pre-flight duties are part of the FDP. A period of duty must be allowed for post-flight activities:
the minimum for major operators is 30 minutes, 15 minutes for others. If this “period” for post FDP duties is routinely exceeded then the post FDP duty period stated in the scheme must be revised to better represent the actual time taken. The
time spent between reporting for a flight and the completion of post-flight tasksdetermines the length of the subsequent rest period."
If your employer is ending your duty time while you are sitting in the cockpit post-flight, they are violating the regulations. At least in the UK.
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AFAIK your rest time doesn't start until you are resting.
I always took it from when we hit the hotel or got home, etc.
I always took it from when we hit the hotel or got home, etc.
so in places like Bombay, (Mumbai) and Bangkok where the bus journey can take one to one and a half hours there wasn't a whole lot left if you were on minimum rest.
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There is a distinction in sub part Q between flight duty and duty. Rest is as stated above, free from all duty. The flight duty period ends at a standard time agreed with your operator's aviation authority, in our ops case 30 mins after on block time. This time should allow for all post flight duties. If you have extra duties not associated with the flight duty (a grey area) these are not counted as flight duty, but are still duty and cannot be rest. Rest starts in my log when I am free from all duties. If I have no other duties than flight duty it starts at the end of my FDP. Minimum rest is 12 hours at home base, 10 hrs away from home base. However the minimum rest must be at least as long as the preceding duty period if this is longer than the 10 or 12 hours mentioned.
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These times are standardised so that the company can plan and construct a rostered duty. That is distinct from what actually happens on a day to day basis. Obviously within this criteria there has to be an element of flexibility and common sense on both sides.
If post flight duties cannot be completed within the standard time allowed, then the reason should be written on the ops/flight paperwork, and the off duty time adjusted to reflect the actual situation, together with an explanation of the cause. The rest period would then be calculated from the actual off duty time. If a company is applying a constantly unrealistic standard off duty time, then it would seem to be self defeating, as it would be subject to constant disruption, with the knock on effect that would have to follow on duty report times.
As far as the rest time itself is concerned, how it is used is the responsibility of the individual. Where accomodation is provided by the company, the standard rest period is often reduced by one hour. This in turn is on the assumption that the travelling time between the airport and the accomodation is no greater than 30 minutes. Where this figure is exceeded then the rest time should be increased to reflect the additional travelling time. There is usually a stipulation that the hotel room must be available to the crewmember for a minimum period of time, in this case 10 hours. Rest is simply the period that is free of duty, it has nothing to do with "your head being on a pillow." If you use that time to watch TV, drive home, drive to work, meet up with friends, or anything else you choose, that is a matter for you. The actual rest or sleep you achieve is your responsibility, the company is only obliged to provide the time period.
To clarify, the rest period starts from when the duty period ends. The only travelling time that matters is when you are positioning as part of a duty for the company. When accomodation is provided by the company, and the travelling time between the airport and that accomodation exceeds 30 minutes, the rest period may need to be extended to ensure that a minimum of 10 hours in the accomodation is provided to the crewmember. The standard off duty time is a planning requirement and not an absolute. If the duty is extended for a valid reason, then the reported actual off duty time should reflect this. This time is then used to calculate the start time of the next available duty.
If post flight duties cannot be completed within the standard time allowed, then the reason should be written on the ops/flight paperwork, and the off duty time adjusted to reflect the actual situation, together with an explanation of the cause. The rest period would then be calculated from the actual off duty time. If a company is applying a constantly unrealistic standard off duty time, then it would seem to be self defeating, as it would be subject to constant disruption, with the knock on effect that would have to follow on duty report times.
As far as the rest time itself is concerned, how it is used is the responsibility of the individual. Where accomodation is provided by the company, the standard rest period is often reduced by one hour. This in turn is on the assumption that the travelling time between the airport and the accomodation is no greater than 30 minutes. Where this figure is exceeded then the rest time should be increased to reflect the additional travelling time. There is usually a stipulation that the hotel room must be available to the crewmember for a minimum period of time, in this case 10 hours. Rest is simply the period that is free of duty, it has nothing to do with "your head being on a pillow." If you use that time to watch TV, drive home, drive to work, meet up with friends, or anything else you choose, that is a matter for you. The actual rest or sleep you achieve is your responsibility, the company is only obliged to provide the time period.
To clarify, the rest period starts from when the duty period ends. The only travelling time that matters is when you are positioning as part of a duty for the company. When accomodation is provided by the company, and the travelling time between the airport and that accomodation exceeds 30 minutes, the rest period may need to be extended to ensure that a minimum of 10 hours in the accomodation is provided to the crewmember. The standard off duty time is a planning requirement and not an absolute. If the duty is extended for a valid reason, then the reported actual off duty time should reflect this. This time is then used to calculate the start time of the next available duty.
Last edited by Bealzebub; 9th Sep 2009 at 13:32.
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Unlike Denti, I think EU-OPS is quite clear - I wonder if you are mixing up FDP and Duty? One operator I worked for allowed 15 mins FDP after chox and then 15 after FDP end for Duty, two others said FDP ends on chox and duty at +30. Sub Part Q 1.1095 paras 1.4 and 1.13 is quite clear on the meaning of 'Duty' and 'Rest' and you cannot legally be 'at rest' if you are conducting duties for the company, which would include being in the cockpit after chox. The only 'get out' clause is 1.1090 para 5.1.1 but that requires the agreement of 'interested parties'.
What is of interest is that the CAP 371 '30 mins travelling time;' referred to by Beal has vanished with EU-OPs but time travelling from crew hotel to report is now 'Positioning' (1.1095 Para 1.12) and therefore 'Duty' (1.1195 Para 5.1) which could cause rostering havoc in some traffic jams!
What is of interest is that the CAP 371 '30 mins travelling time;' referred to by Beal has vanished with EU-OPs but time travelling from crew hotel to report is now 'Positioning' (1.1095 Para 1.12) and therefore 'Duty' (1.1195 Para 5.1) which could cause rostering havoc in some traffic jams!
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Well, the lack of clarity lies in the definition of flight duty time at least in the german version of the EU-OPS (which is applicable for me). The definition 1.5 in OPS 1.1095 says that the flight duty time ends with the end of the last flight of a duty period on which the crew member is on duty. However when the flight ends was a point of debate. The local CAA now clarified it and said the flight ends with on chocks. Everything you do after on chocks is not flight duty time anymore (except if your personal or union contract says anything different), but until all work pertaining the flight has finished it is still duty time which in turn is relevant for rest time calculation.
CAP 371 of course is only applicable to UK carriers and quite uninteresting for the rest of europe.
And i do disagree with your view of 1.12 as it says that positioning is the time spend during a transport from one point to another, however the time spend travelling between your place of residence and your reporting point (usually the crew room) and the local transport between airport and hotel is not positioning time but "travelling time". Travelling time however is part of your rest time and accounts for the 2 hour higher minimum rest time at your home base vs. on the road (2 hours travelling time, one hour after and one before duty). Travelling time is accounted for in OPS 1.1110 1.2 which says that you have to have a possibility of at least 8 hours uninterrupted sleep time plus time for physiological needs and travelling time. Physiological needs is often defined as one hour before and one hour after your sleep time period. However physiological needs is another one of those gray areas as there is no definition in the EU-OPS.
As someone who works actively in the union on matters like that is often quite distressing how many gray areas are there, especially when you count in the differing views of your employer, the local CAA, the ministry and of course your union. It is not an easy field by far and quite often we wish we had CAP 371 which seems in many cases quite a bit clearer than our local regulations.
CAP 371 of course is only applicable to UK carriers and quite uninteresting for the rest of europe.
And i do disagree with your view of 1.12 as it says that positioning is the time spend during a transport from one point to another, however the time spend travelling between your place of residence and your reporting point (usually the crew room) and the local transport between airport and hotel is not positioning time but "travelling time". Travelling time however is part of your rest time and accounts for the 2 hour higher minimum rest time at your home base vs. on the road (2 hours travelling time, one hour after and one before duty). Travelling time is accounted for in OPS 1.1110 1.2 which says that you have to have a possibility of at least 8 hours uninterrupted sleep time plus time for physiological needs and travelling time. Physiological needs is often defined as one hour before and one hour after your sleep time period. However physiological needs is another one of those gray areas as there is no definition in the EU-OPS.
As someone who works actively in the union on matters like that is often quite distressing how many gray areas are there, especially when you count in the differing views of your employer, the local CAA, the ministry and of course your union. It is not an easy field by far and quite often we wish we had CAP 371 which seems in many cases quite a bit clearer than our local regulations.
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Denti - my apologies - I did not read 1.12 fully. I see that hotel to report is not 'duty', so the 30 min 'max allowance' the UK had in CAP371 has gone. Presumably therefore you can sit in traffic in the bus from the hotel for 1hr+ and not be 'on duty'.
Regarding FDP, it has always, in my experience in the UK, ended either at on chox or +15 as above, and has never been 'grey', but I see it can be in EU-OPS.
Incidentally, is 371 still applicable to UK ops or is the whole of Europe fully 'signed-up' to EU-OPS?
Regarding FDP, it has always, in my experience in the UK, ended either at on chox or +15 as above, and has never been 'grey', but I see it can be in EU-OPS.
Incidentally, is 371 still applicable to UK ops or is the whole of Europe fully 'signed-up' to EU-OPS?
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The minimum across europe is EU-OPS, each state can have its own regulation if it is better (for the employee) than EU-OPS. As far as i know CAP 371 is not revoked and therefore still valid, but i'm afraid i do not know exactly how much of that is better than EU-OPS and which parts are not.
So yes, everyone has signed up to EU-OPS, however if some regulations in your local laws and regulations are better they may still be valid. I think many UK carriers were whining quite a bit to be more regulated than EU-OPS only.
We used to have that on blocks plus 15 minutes regulation as flight duty time as well (minimum in our local ops prior EU-OPS and still valid where EU-OPS is not applicable) and it is still in most union contracts for unionized airlines over here, some have 30 minutes which in my opinion fits better into reality than 15 minutes. However some do not want to lose 15 or 30 minutes of their yearly allowance of flight duty time each duty period and do not use it anymore, however it is still duty time (which has the higher 2000 hour limit) and not rest time.
By the way, if you sit for hours in the crewbus on the way to the hotel it might eat into your core sleep time which is "sacred" and therefore you must use a longer rest period to be able to get at least eight hours of uninterrupted core sleeping time.
So yes, everyone has signed up to EU-OPS, however if some regulations in your local laws and regulations are better they may still be valid. I think many UK carriers were whining quite a bit to be more regulated than EU-OPS only.
We used to have that on blocks plus 15 minutes regulation as flight duty time as well (minimum in our local ops prior EU-OPS and still valid where EU-OPS is not applicable) and it is still in most union contracts for unionized airlines over here, some have 30 minutes which in my opinion fits better into reality than 15 minutes. However some do not want to lose 15 or 30 minutes of their yearly allowance of flight duty time each duty period and do not use it anymore, however it is still duty time (which has the higher 2000 hour limit) and not rest time.
By the way, if you sit for hours in the crewbus on the way to the hotel it might eat into your core sleep time which is "sacred" and therefore you must use a longer rest period to be able to get at least eight hours of uninterrupted core sleeping time.
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Re last para - happy with that - it is the 'Hey Boac - we've brought your hotel pick-up forward 1 hr due to rush-hour traffic' I am thinking about! You still have 'nominal' rest, but are actually being dragged through the streets on company business!
You still have 'nominal' rest, but are actually being dragged through the streets on company business!
