OBSERVATIONS/OBJECTIONS/Feedbacks on CAR Section 7 Series J Part III

3.1 “When the local time at the place where a flight duty commences differs by more
than 3 hours from the local time at the place where the next duty starts, the crew
member, for the calculation of the maximum daily flight duty period, is considered to
be acclimatised.”
The Line should read NOT acclimatised if time zone differs by more than 3 hours.
We also feel acclimatised definition should be based on 2 hours as is the International
standard.
Attached below is the EASA Definition
“acclimatised” means a state in which a crew member’s circadian biological clock is
synchronised to the time zone where the crew member is. A crew member is considered to
be acclimatised to a 2-hour wide time zone surrounding the local time at the point of
departure.

3.4.2 FLIGHT DUTY PERIOD

We feel the FDP definition must include at least 15 mts from Engine shut down to
complete post flight procedures, scans checklists and paperwork relevant to the flight.

3.12 NIGHT DUTY

We feel the definition of Night Duty must reflect its true meaning and intent and should
read as a DUTY PERIOD between 0000hrs and 0500hrs as opposed to Flight Duty.
By stating Flight Duty period, it leads to rosters which induce fatigue as a pilot can be
made to chocks on by 2355 and be clear of this definition, and then be asked to do
another duty thru the complete period of 0000-0500, effectively having no clear rest in
the two consecutive nights.
In these cases, the pilot never gets a clear and complete night rest. Since there is no late
finish early start protection.
We would request you to look into the same

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3.18 Reserve
The objective of an FDTL is to lay down prescriptive limits of Duty and rest and as such the
concept of Reserve seems not be applicable to any of the two.
The provision of Standby is sufficient for airlines to cover contingencies. A 24-hr reserve
day is effectively a 24 hr standby without any protection. Effectively an airline can make a
roster of 6 days
of Reserve which does not provide any planned rests or duty periods for a Crew to plan his
life around.
We disagree with this concept and feel it should NOT be included in the FDTL CAR.

3.27 WOCL
The WOCL shift definition should be across 2 or more time zone as acclimatised definitions
world wide including EASA are based on a 2-hr time zone change.

6 FDP and FT Limits

6.1 We find that the FDP limits for TWO pilot operation have been increased from the
earlier CAR, for flights up to 9 hrs from 12:30 to 13:00. Similarly, the limit of 13hrs FDP
and 10hrs FTL has been increased to 13:30 FDP.

We feel this will only encourage airlines to do more two crew operations.The very reason
the FDP was restricted was so that the fatigue level of the flight crew after a long
flight is not such that the safety of the flight is impacted adversely. Increasing the
FDP limits defeats this purpose and only serves to fit certain flights within the new
limits to avoid 3 crew operations. Any change made with operational convenience
as the sole reason for doing so will, in our opinion, have a negative impact on
Safety and should thus be avoided.

8 Max Flight time Limits

We would request that the 7 consecutive days max FTL be brought down to 30 hrs as this
will help to mitigate the daily multiple sector fatigue experienced by pilots. Also, we
would also suggest a weekly landing limit at 20.

10.1 Rest Period before flight

The very purpose of establishing the Rest Periods between flights is to ensure
schedules are planned in such a manner that any possibility of the flight crew
being fatigued.
Firstly, allowing the Rest to be reduced at the planning stage is an illogical concept
as it implies that planning is faulty to begin with and increase the possibility of
fatigue creeping in. Secondly, the idea of reducing rest prior to the occurrence of a
"exigent circumstance" is again a concept which defies logic.

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We disagree with this concept and in our opinion Reduced rest should only be allowed in
case of an unforeseen circumstance and NOT in the Planning stage. Also, its limit should
be 10% and not more than Once a Month
Even Europe does not permit reduced rest unless there is a strong FRMS in place and
regular safety and risk assessments are carried out to do the same.
For Note 2 shall the calculation for time zone be based on which acclimatised time zone?
For e.g. bom ams- ams yyz the flight to yyz the crew is still acclimatised to Bom time
zone. (as per acclimatised definition) Than does the crew need 36 hours pre-flight rest in
AMS

10.2 we feel the rest of 12 hrs should be followed even for all other duties for e.g. if a
Crew does 12 hours of office duty and then within 10 hrs turns up to operate a flight is not
ideal.
Similarly, a crew could have done 6 hours of simulator which has its own fatigue and then
in 10 hrs be asked to be operate a flight which is not ideal.

10.6 WEEKLY REST must be increased to 2 Local Days twice every month to provide an
extended Recovery period for flight crew.
Weekly Rest must be planned in the crews Home Base

10.7 REST AFTER RETURN TO HOME BASE

We feel the rest after return to home base should be irrespective of WOCL encroachment
as the definition of this paragraph itself states: -

“Operator shall ensure that effects on flight crew members of time zone differences
will be compensated by additional rest as specified below.”

Even the point on choosing that WOCL encroachment is only for return leg is
bewildering as a crew is as fatigued while flying out during a 100 % WOCL
encroachment and on reaching a different time zone. Here the lack of sleep and
having to recover by sleeping against his body clock and time zone difference has
similar negative effects.

The application of Time zone-based recovery should only be based on how many times
zones a crew has crossed and how long he has been away before he returns.

This will make it easier to track without any complicated formulas and understanding.

Also, the term Home base can be misinterpreted by airlines as Home base may be
Delhi and a crew brought back to Chennai and sent back to Europe does so on
minimum rest saying he did not return to home base.

This has happened with operators in the past.

Attached is the EASA table for easy reference for the same

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Something similar would make it easier for Airlines and crew to track and calculate and
maintain.

10.8.1 States WOCL encroachment up to 50%, this line can be misinterpreted as if there is
no encroachment than rest shall be minimum rest as laid in Pre-Flight Rest.
We feel that this would be inadequate and at least 2 Local nights must be maintained for
time zone recovery.

10.8.3 We feel the rest provided in this column is not sufficient and is less than as needed
for safe fatigue free operation.
For E.g. a Bom-ams -yyz-ams-bom pattern where a pilot crosses 09:30 time zones in
summer, (in winter it become 10:30) with 120 hrs away from home, will only get (48+24)/2
plus 36=72 hrs i.e. 3 days rest now on return. This rest is neither sufficient or equal to
what the earlier CAR provided (or EASA standard provides.)
And if the return flight has NO WOCL encroachment as listed than what is the rest?
This will make operators claim that there is no encroachment therefore no time zone rest
to be provided and minimum rest post this pattern will be provided
This is not only UNSAFE but will lead to extremely fatigued pilots returning to duty fully
disorientated.
We would once request that this table be reworked to only cater for Rest based on Time
Zone change as the header describes and as its intent is.

The same objection holds good for 10.8.4

Earlier while a crew would have got at least 5 local nights and 108 hrs of rest now a crew
gets only
(72+24)/2 plus 36= 84 hrs of rest that is only 3.5 days of rest to recover from time zone
effects.
We feel that all the rests laid down in this column neither provide enough recovery rest or
fatigue recovery for the Effects of Time Zone and must be increased for safety.

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We would once again like to reiterate that TIME zone Rest must be based on number of
Local Nights rest provided to recover from the effects of Jet lag and body clock disruption.
We would like to propose the following table in line with other FDTL and standards

REST AFTER RETURN TO HOME BASE

Operator shall ensure that effects on flight crew members of time zone differences
will be compensated by additional rest as specified below
10.8 Minimum rest including local nights shall be given according to the table given
below, to any flight crew member on returning to Home Base, who has been away
from Home base on a rotation of Flight Duty or Duties.

Time Zone Difference Rest in Hours Local Nights

More than 3 upto 6 36 2

More than 6 upto 9 48 3 Note2

More than 9 upto 12 72 4 Note2

Note 1 (Deleted)
Note 2 Flight crew covered by para 10.6 whose weekly rest is due after completion
of Flight duty or Duties, will be given ONE Local night in addition to the above
listed rest.
Note 3 (To be deleted as added into .3 and .4 column)
Note 4 (Deleted)

11.1.2 In case of exigencies when ‘Standby’ duty may go beyond the roster; Operator
shall ensure that concerned flight crew is notified in advance.

We object to this point as it gives a free hand to the operators to use this clause
for any duty outside the Standby or in a Pilots rest time.

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13 CONSECUTIVE NIGHT
As objected before the definition of Consecutive nights must be based on Duty period and
not FDP.
We object to the concept of Consecutive Night operations in its current format.

Thanking You

Capt Tej Sood

General Secretary
National Aviators Guild