Time Free From Duty

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FISH-FLY
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Time Free From Duty

Post by FISH-FLY »

Quick question here about the new time free from duty requirements in reference to a 705 operation. A flight crew member requires:

a) One single day free from duty in any 168 consecutive hours; AND

b) Four single days free from duty in any 672 consecutive hours

For some reason I was of the belief that b) meant that we could count on at least one consecutive 4 day off stretch within any 28 days (672 hours). But, reading the reg more closely now, it doesn't state consecutive. However, what is the point of provision b) if it's not meant to be consecutive days off? Wouldn't having one single day free from duty in any 7 day (168 hour) period automatically satisfy having 4 single days free from duty in any 28 day (672 hour) period?

Is b) meant to be 4 consecutive days off in 28? If not, why does provision b) exist? Perhaps I'm missing something really simple here...

Thanks.
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flyinhigh
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Re: Time Free From Duty

Post by flyinhigh »

You’re correct. By satisfying a) and having 1 day off every seven days it will basically ensures satisfying b). If an operator was to provide you with consecutive days off during a week, that is fine, however you will than end up with more than the four days off in 28 as you still must satisfy the 60-7 requirements of one day day every seven.

Now if the operator chooses to follow the 70-7 requirements, the crew member is guaranteed at least five consecutive days off in 21 days.
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Outlaw58
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Re: Time Free From Duty

Post by Outlaw58 »

FISH-FLY wrote: Thu Jul 22, 2021 8:20 pm Quick question here about the new time free from duty requirements in reference to a 705 operation. A flight crew member requires:

a) One single day free from duty in any 168 consecutive hours; AND

b) Four single days free from duty in any 672 consecutive hours

For some reason I was of the belief that b) meant that we could count on at least one consecutive 4 day off stretch within any 28 days (672 hours). But, reading the reg more closely now, it doesn't state consecutive. However, what is the point of provision b) if it's not meant to be consecutive days off? Wouldn't having one single day free from duty in any 7 day (168 hour) period automatically satisfy having 4 single days free from duty in any 28 day (672 hour) period?

Is b) meant to be 4 consecutive days off in 28? If not, why does provision b) exist? Perhaps I'm missing something really simple here...

Thanks.
It is one OR the other and backward looking. In other word as long as looking backward you meet either a) or b) you are good to go. If however you happen to go 7 days or more in a row, you will NEED option b) to reset.

Makes sense?

58
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digits_
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Re: Time Free From Duty

Post by digits_ »

Outlaw58 wrote: Fri Jul 30, 2021 7:33 am
FISH-FLY wrote: Thu Jul 22, 2021 8:20 pm Quick question here about the new time free from duty requirements in reference to a 705 operation. A flight crew member requires:

a) One single day free from duty in any 168 consecutive hours; AND

b) Four single days free from duty in any 672 consecutive hours

For some reason I was of the belief that b) meant that we could count on at least one consecutive 4 day off stretch within any 28 days (672 hours). But, reading the reg more closely now, it doesn't state consecutive. However, what is the point of provision b) if it's not meant to be consecutive days off? Wouldn't having one single day free from duty in any 7 day (168 hour) period automatically satisfy having 4 single days free from duty in any 28 day (672 hour) period?

Is b) meant to be 4 consecutive days off in 28? If not, why does provision b) exist? Perhaps I'm missing something really simple here...

Thanks.
It is one OR the other and backward looking. In other word as long as looking backward you meet either a) or b) you are good to go. If however you happen to go 7 days or more in a row, you will NEED option b) to reset.

Makes sense?

58
It literally says 'AND' in his quote, and in the original CAR 700.29 (1)
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Outlaw58
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Re: Time Free From Duty

Post by Outlaw58 »

digits_ wrote: Fri Jul 30, 2021 7:58 am
Outlaw58 wrote: Fri Jul 30, 2021 7:33 am
FISH-FLY wrote: Thu Jul 22, 2021 8:20 pm Quick question here about the new time free from duty requirements in reference to a 705 operation. A flight crew member requires:

a) One single day free from duty in any 168 consecutive hours; AND

b) Four single days free from duty in any 672 consecutive hours

For some reason I was of the belief that b) meant that we could count on at least one consecutive 4 day off stretch within any 28 days (672 hours). But, reading the reg more closely now, it doesn't state consecutive. However, what is the point of provision b) if it's not meant to be consecutive days off? Wouldn't having one single day free from duty in any 7 day (168 hour) period automatically satisfy having 4 single days free from duty in any 28 day (672 hour) period?

Is b) meant to be 4 consecutive days off in 28? If not, why does provision b) exist? Perhaps I'm missing something really simple here...

Thanks.
It is one OR the other and backward looking. In other word as long as looking backward you meet either a) or b) you are good to go. If however you happen to go 7 days or more in a row, you will NEED option b) to reset.

Makes sense?

58
It literally says 'AND' in his quote, and in the original CAR 700.29 (1)
I may be mistaken. I went from memory from when we implemented it. I'll review.

58
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FISH-FLY
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Re: Time Free From Duty

Post by FISH-FLY »

Thanks for the replies. I still don't see why requiring 4 off in 28 is necessary, if 1 off in 7 is already required. The 1 off in 7 will ALWAYS satisfy the 4 off in 28, right? Why not require 5 off in 35, and 6 off in 42 while they're at it? Hence I always assumed that the 4 in 28 was intended to be consecutive. In other words, a pilot would need at least one single day free from duty each week, and at least one 4 day stretch off every 28 days. Seems reasonable from a baseline fatigue perspective. I guess I'm wrong, but still can't figure out the need for the two specific prescribed regulations then, attached with an AND.
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acpaleaks
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Re: Time Free From Duty

Post by acpaleaks »

FISH-FLY wrote: Fri Jul 30, 2021 9:14 pm Hence I always assumed
Your first mistake was assuming anything TC does actually improves pilot fatigue and safety.
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flyinhigh
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Re: Time Free From Duty

Post by flyinhigh »

FISH-FLY wrote: Fri Jul 30, 2021 9:14 pm Thanks for the replies. I still don't see why requiring 4 off in 28 is necessary, if 1 off in 7 is already required. The 1 off in 7 will ALWAYS satisfy the 4 off in 28, right? Why not require 5 off in 35, and 6 off in 42 while they're at it? Hence I always assumed that the 4 in 28 was intended to be consecutive. In other words, a pilot would need at least one single day free from duty each week, and at least one 4 day stretch off every 28 days. Seems reasonable from a baseline fatigue perspective. I guess I'm wrong, but still can't figure out the need for the two specific prescribed regulations then, attached with an AND.
I do agree as it is somewhat odd. That being said, there is other aspects of the new regs that leave one wondering just what they are trying to achieve that is more convoluted that 700.29. I wouldn't waste to much energy wondering why they wrote this one this way, rather spend the time ensuring you don't violate 700.28, in consultation with 700.29d).
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digits_
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Re: Time Free From Duty

Post by digits_ »

It might have an effect if you just got hired from a busy 703 job, or if you are working under multiple subparts. Still pretty rare cases when it would make a difference though.
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FISH-FLY
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Re: Time Free From Duty

Post by FISH-FLY »

Good point on the multiple sub-parts scenario, however, I still find it unlikely that it would be written for that rare situation, or for the one-off job transition scenario. Most going to a 705 from a 703 will have a long (>28 day) course to do before even touching an airplane.

Not intending to waste my time worrying about it, but was just hoping to be entitled to 4 consecutive days off somewhere in 28.

After seeing the world operate for the time that I have, it genuinely wouldn't surprise me if 4 consecutive off in 28 was the original intention of the regs, but the wording was F'd up and it instead came out as a redundant requirement in the favour of the airlines.
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TailwheelPilot
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Re: Time Free From Duty

Post by TailwheelPilot »

On single-pilot aircraft, TCCA does not recommend that the pilot-in-command take a break from operating the aircraft in flight, for a nutrition break.
I am very surprised this is not prohibited...who is going to operate a single-pilot aircraft in flight if the PIC is taking a nutrition break :lol:
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Re: Time Free From Duty

Post by C-GGGQ »

TailwheelPilot wrote: Wed Aug 04, 2021 4:04 am
On single-pilot aircraft, TCCA does not recommend that the pilot-in-command take a break from operating the aircraft in flight, for a nutrition break.
I am very surprised this is not prohibited...who is going to operate a single-pilot aircraft in flight if the PIC is taking a nutrition break :lol:
I mean…. If its single pilot it’s not like they’re leaving their seat. Just eating a Sandwhich while George is flying
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Outlaw58
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Re: Time Free From Duty

Post by Outlaw58 »

C-GGGQ wrote: Wed Aug 04, 2021 7:52 am
TailwheelPilot wrote: Wed Aug 04, 2021 4:04 am
On single-pilot aircraft, TCCA does not recommend that the pilot-in-command take a break from operating the aircraft in flight, for a nutrition break.
I am very surprised this is not prohibited...who is going to operate a single-pilot aircraft in flight if the PIC is taking a nutrition break :lol:
I mean…. If its single pilot it’s not like they’re leaving their seat. Just eating a Sandwhich while George is flying
You can, but it's not recommended :wink:

58
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Outlaw58
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Re: Time Free From Duty

Post by Outlaw58 »

Outlaw58 wrote: Fri Jul 30, 2021 10:45 am
digits_ wrote: Fri Jul 30, 2021 7:58 am
Outlaw58 wrote: Fri Jul 30, 2021 7:33 am

It is one OR the other and backward looking. In other word as long as looking backward you meet either a) or b) you are good to go. If however you happen to go 7 days or more in a row, you will NEED option b) to reset.

Makes sense?

58
It literally says 'AND' in his quote, and in the original CAR 700.29 (1)
I may be mistaken. I went from memory from when we implemented it. I'll review.

58
Had a chance to go back on the rules and yeah I was mistaken. The reset I was referring to is CAR 700.29 (2)

An air operator who has assigned to a flight crew member a flight duty
period that will result in the member’s number of hours of work
exceeding those referred to in paragraph (1)(d) shall ensure that the
member has 120 consecutive hours free from duty, including 5
consecutive local nights’ rest, before assigning a flight duty period that
will result in the member’s number of hours of work exceeding those
referred to in paragraph (1)(c).


What I did get right is that it is backward looking. Looking back on your schedule, you need to be able to satisfy CAR 700.29 (1) (a) AND (b) AND ((c) OR (d)). If you don't then it's the 5 day reset above.

58

PS.: It's a nightmare to track these hours by hand and my hat's off to those who do. Here we use computer program (Sabre) to track and alert us if a duty / flight time period is exceeded.
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