The European Aviation Safety Agency (EASA) may tighten some of the provisions for flight time limitations (FTL) contained in Sub- part Q of its existing EU OPS 1 rules covering commercial aircraft operations. The possible changes result from a recently concluded scientific and medical evaluation conducted on the agency’s behalf by an independent committee of fatigue experts.
EASA officially reported the findings of the European Committee for Aircraft Scheduling and Safety to the European Commission in late January. It has promised to complete a regulatory impact assessment before formally proposing any amendments to EU OPS. However, the prospect of further changes to FTLs drew rapid condemnation by the European Regions Airline Association, which viewed the move as “unjustified” because it would “provide no benefit to airlines or to the safety of passengers.”
The committee of experts addressed 18 aspects of EU OPS Subpart Q, which, at the time the operating rules were introduced, had been flagged by EASA as needing further research and consideration. In fact, most of these items are still subject to the discretion of the National Aviation Authorities (NAAs) from the EASA member states.
The main recommendations of the group are as follows:
• A reduction in the maximum number of hours worked in a period of 28 consecutive days from 190 to 180. Of these, no more than 100 hours should be permitted within 14 consecutive days and the 900 block hour total should apply over 12 consecutive calendar months rather than over a calendar year.
• The standard 13-hour limit for a flight duty period (FDP) should be kept but the provision to extend this to 14 hours should be abandoned. No more than 10 hours should be allowed for overnight FDPs. The maximum FDP should be reduced by 30 minutes for each sector after the first flown. The FDP limit might have to be further reduced to take account of acclimatization to local time (to accommodate jet lag), perhaps by a factor of one hour per day.
• In general, the same duty and rest rules should apply to both cabin and cockpit crews.
• Split duty periods should be used only outside the window of circadian low for crew. If split duty extends the total FDP then a break between sub duty periods should be for at least one third of the total FDP.
• Home base recovery days after time-zone crossings should be provided according to the number of time zones crossed and the duration of the layover.
• The format of rest periods should include provision for a “local night,” defined as 10 hours between 10 p.m. and 10 a.m. The present provision of a weekly rest period after 168 hours of duty “falls short of reasonable requirements.”
• Airport standby time carries approximately the same fatigue load as work and should count as FDP unless a fatigue risk management system is applied with proper rest facilities (such as crew sleeping rooms at an FBO).
Further details of the study and its recommendations can be found at: www.easa.europa.eu/ws_ prod/r/r_research.php.
Separately, EASA has launched a comment period for proposed implementing rules covering the regulation of air operators. The implementing rules will formalize the transfer of operational responsibility from NAAs to EASA and the comment period will end on May 30, 2009. Also covered by the notice of proposed amendment (NPA 2009-02) are acceptable means of compliance, guidance materials and certification specifications for FTLs.
The implementing rules are largely derived from the existing EU-OPS code (and the earlier JAR OPS rules) and will form the basis for certifying all commercial operators based in EASA member states. Draft rules covering non-commercial operators (such as corporate flight departments operating under Part 91-equivalent rules) will be based on the complexity of the aircraft being operated.
More details can be found at www.easa.europa.eu/flightstandards. EASA plans to host a workshop on the proposed rules at its Cologne, Germany headquarters on March 10 to 11.