Click here to close
New Message Alert
List Entire Thread
Msg ID: 2564921 FAA Rules with Union on Duty Period Issues +4/-0     
Author:Imagine That
4/9/2019 1:58:52 PM

FAA agress with the union that the previous rulings already address the issues presented and contested by amc meaning that the unions interpretation and guidance was correct. All that one-way flight non-sense is pointless now considering that all time under the direction of the certificate holder (getting to a hotel, driving back to base, closing out all shift duties) is part of your duty period and therefore part of your duty period planning for accepting a flight. Remember folks this about duty period, not flight time or whether its part 91 or part 135. It specifically involves when you report for a part 135 assignment and when you are released.

Great job!



Return-To-Index  
 
Msg ID: 2564927 Ah, the first sentence says it all: +0/-0     
Author:Anonymous
4/9/2019 2:45:38 PM

Reply to: 2564921


FAA agress with the union that the previous rulings already address the issues presented ..."

 

The faa has always said if you work for the company, you are on duty.   The question is, can you fly a part 91 leg after you drop the medical crewmembers and/or patient.   IOW, can you PLAN to end your Part 135 flying at or before the 14th hour of duty, and still fly back to the base under Part 91 without them?

 

That was the question that needed answering.   Not the ones the FAA has already addressed in long standing previous "rulings" (i.e., intepretations)



Return-To-Index  
 
Msg ID: 2564929 Ah, the first sentence says it all: +0/-0     
Author:NoMo
4/9/2019 3:02:26 PM

Reply to: 2564927

I think it was answered..............IF you WORK for a part 135 CERTIFICATE HOLDER, YOU HAVE A DUTY DAY.  If you or they cannot plan to complete the flight in that amount of time, you're spending the night...................somewhere.



Return-To-Index  
 
Msg ID: 2564930 Ah, the first sentence says it all: +5/-0     
Author:When
4/9/2019 3:06:32 PM

Reply to: 2564929
You reposition without the crew are you still working for the company? Of course you are. Would they let you fly that leg if your 135 ride had expired or if your class II medical had expired? Of course not. Don't keep asking the questions and hope for better answers.


Return-To-Index  
 
Msg ID: 2564936 Yes, and I'm not on rest....so what? I don't start +0/-0     
Author:my rest clock until I'm finished. But,
4/9/2019 3:21:25 PM

Reply to: 2564930

I am not limited to a 14 hour duty day under FAR 135.267(d), since I'm not operating under Part 135 any longer!



Return-To-Index  
 
Msg ID: 2564940 Yes, and I'm not on rest....so what? I don't start (NT) +1/-1     
Author:Wrong! In so many ways
4/9/2019 3:30:32 PM

Reply to: 2564936


Return-To-Index  
 
Msg ID: 2564941 Not wrong. For what you suggest the FAA has +0/-0     
Author:said to you to be true, it would have...
4/9/2019 3:44:03 PM

Reply to: 2564940

... required a NPRM, since what you think they are saying (now) is completely diffrent than what they have said all along, and including what they said in the Final Rule to Subpart L.  I have not seen a NPRM, or even a Notice of Draft Letter of Interpretation, which means the FAA isn't chaning the way they have enforced the regulation all this time.   And, according to the Final Rule for Subpart L, FAR 135.267 has not changed at all with the publishing of Subpart L.   All that changed was that a certificate holder was operating under Part 135 if the medical crewmember or patient was on board.   Nothing in the regs saying what you claim.  Nada!



Return-To-Index  
 
Msg ID: 2564957 Not wrong. For what you suggest the FAA has +0/-0     
Author:11 Rulings since the Subpart L
4/9/2019 5:25:36 PM

Reply to: 2564941

Take a look at Jason Kidd (2017)



Return-To-Index  
 
Msg ID: 2564963 Where does Kidd say you can't fly Part 91? +0/-0     
Author:Anonymous
4/9/2019 5:37:32 PM

Reply to: 2564957

Kidd does not say anything about having to fly back to the base.  It answers the question about the flight segments being interrupted (failing to account for the previous intepretations of the Whitlow letter, btw).   The Kidd letter of interp has nothing to do witht he question here, and does not impose any obligation that the certificate holder MUST have the pilot fly back to the base at all.   Nor does it say the Part 135 segments can end at one location dropping of the paying customers, and return Part 91.

 

You are trying to insert a square peg into a round hole in hopes you can force your hand (as a union) upon the certificate holder to allow pilots to turn down a flight request becaue the planning is back to the base, and not to some other location or to operate Part 91 thereafter.   Yeah, the medical crew might get stuck for a while or overnight, but the pilot and aircraft are not bound by Part 135 limiations when they are no on board!

 

You need to get your glasses adjusted if you are trying to read Kidd to mean you MUST return to the base of operations under Part 135!   



Return-To-Index  
 
Msg ID: 2565064 RIDICULOUS  +0/-0     
Author:Anonymous
4/10/2019 9:11:52 AM

Reply to: 2564963

You can't just magically decide after accepting a flight to switch a leg to part 91 just because there isn't medical crew on board. 

If you decide you need fuel after dropping off a patient, the legs to and from the refueling point are still 135. They don't switch to 91 just because no medical crew is on board. 



Return-To-Index  
 
Msg ID: 2565114 Who said magically? I planned on doing so!! (NT) +0/-0     
Author:drop 'em off by the 14th hr & Pt 91 back
4/10/2019 11:14:49 AM

Reply to: 2565064


Return-To-Index  
 
Msg ID: 2565116 ...and sure you can!! Divert for wx. Trip cnx'ed  +0/-0     
Author:then 91 to where ever is next!
4/10/2019 11:18:19 AM

Reply to: 2565114

You are pretty arrogant to think once you start the day 135, you can never stop 135!   Suppose you clock on in the morning, and the company needs you to ferry an aircraft later in the day all of a sudden.   You must do it 135 because you started the day 135?   Hogwash!



Return-To-Index  
 
Msg ID: 2565134 If you plan to refuel, it's still 135 even if med crew aren't on board (NT) +0/-0     
Author:Anonymous
4/10/2019 12:18:48 PM

Reply to: 2565114


Return-To-Index  
 
Msg ID: 2565135 Not necessarily! If you are finished, dropped off +0/-0     
Author:you medcrew and patient , you can
4/10/2019 12:20:13 PM

Reply to: 2565134

refuel and finish the rest of your day Part 91 without those folks.



Return-To-Index  
 
Msg ID: 2565137 That is also incorrect. (NT) +0/-0     
Author:Anonymous
4/10/2019 12:20:59 PM

Reply to: 2565135


Return-To-Index  
 
Msg ID: 2565161 It was 100% accurate! (NT) +0/-0     
Author:Anonymous
4/10/2019 1:37:05 PM

Reply to: 2565137


Return-To-Index  
 
Msg ID: 2564935 Not quite right: +0/-0     
Author:Anonymous
4/9/2019 3:19:33 PM

Reply to: 2564929

Yes, if you work for a Part 135 Certificate holder, you have a duty day limitation TO FLY PART 135.   There is no duty day limitation to fly PART 91.   It isn't there.

So, you are correct to say what you do, but wrong to imply it limits your day to 14 hours under Part 91 operations!

 

You can operate aircraft Part 91 as you see fit with regards to duty time limitations!   Because, there are none limiting you.

 

FAA FAR 135 Subpart L Final Rule:

"Additionally, the FAA acknowledges that certificate holders may not be able to conduct certain operations because of the more stringent part 135 requirements. For example, the weather minimums may be below part 135 standards, but would have been acceptable for a part 91 operation. Similarly, additional part 135 flights may mean that a flightcrew member reaches flight time limitations more quickly. Nevertheless, the FAA has determined that these restrictions are appropriate given the increased safety of operations that are expected as a result of this regulation. However, the FAA is not extending this regulation to flights conducted without medical personnel onboard. The FAA has determined that such an extension would go beyond the stated rationale of providing additional protections to the medical personnel and passengers onboard the helicopter."



Return-To-Index  
 
Msg ID: 2566222 Ah, the first sentence says it all: +0/-0     
Author:STL206
4/15/2019 2:44:28 PM

Reply to: 2564927

The Air Methods GOM in the Applicabilty section states that all Air Methods Flights shall be considered FAR Part 135 except maintenance flights and training flights.  Those are the only two exceptions that the section lists.  



Return-To-Index  
 
Msg ID: 2564939 FAA Rules with Union on Duty Period Issues +2/-1     
Author:Duty Day NOT Flight Time
4/9/2019 3:30:08 PM

Reply to: 2564921

Bottom line:

1) No part 91 reposition legs per the FAA legal interpretations. That’s black and white. Starts 135, ends 135.

2) No one way flights. If you cannot plan to complete the flight with a return to base (hub rule similar to 121 operators) you can not legally except the flight.

3) if you accept a legal flight under part 135, then you can complete the flight with an RTB (hub rule) even if it exceeds 14 hours after you initiated the flight. Again, no need to drop off crew because you can legally RTB under part 135. Also, no need for RON.

4) All part 135 duty assignments will be used to calculate duty period compliance. That means ALL duties. Post flight, etc. you are on and within your duty period whether part 91 or part 135 until you are relieved if ALL directives by the Certificate holder For the assignment you reported for. A 12-14 hour shift, that can be extended.

5) rest period starts when relieved of duty, not at the end of the part 135 patient drop off leg.

end of story. 



Return-To-Index  
 
Msg ID: 2564942 FAA Rules with Union on Duty Period Issues +2/-1     
Author:Anonymous
4/9/2019 3:52:13 PM

Reply to: 2564939

Bottom line:

1) No part 91 reposition legs per the FAA legal interpretations. That’s black and white. Starts 135, ends 135.  With medical crewmembers on board!

2) No one way flights. If you cannot plan to complete the flight with a return to base (hub rule similar to 121 operators) you can not legally except the flight.  With medical crewmembers on board!

3) if you accept a legal flight under part 135, then you can complete the flight with an RTB (hub rule) even if it exceeds 14 hours after you initiated the flight. Again, no need to drop off crew because you can legally RTB under part 135. Also, no need for RON.  A legal flight could end at an away location, with medical crewmembers on board!

4) All part 135 duty assignments will be used to calculate duty period compliance. That means ALL duties. Post flight, etc. you are on and within your duty period whether part 91 or part 135 until you are relieved if ALL directives by the Certificate holder For the assignment you reported for. A 12-14 hour shift, that can be extended.  With medical crewmembers on board.  

5) rest period starts when relieved of duty, not at the end of the part 135 patient drop off leg.  Always been the case, even for the Part 91 leg back to base afterwards without medical crewmembers on board!

 

Your 'story' is not the whole story

 

 



Return-To-Index  
 
Msg ID: 2564948 HILARIOUS HOW YOU ARE "FINDING WAYS TO SAY YES" +1/-1     
Author:Anonymous
4/9/2019 4:40:27 PM

Reply to: 2564942

You keep pushing this on your pilots. SAD!



Return-To-Index  
 
Msg ID: 2564950 even more HILARIOUS how you are trying to (NT) +1/-1     
Author:use regs that don't apply!
4/9/2019 4:42:07 PM

Reply to: 2564948


Return-To-Index  
 
Msg ID: 2565061 That provably false. YOU FAIL. (NT) +0/-0     
Author:GOOD DAY
4/10/2019 9:05:26 AM

Reply to: 2564950


Return-To-Index  
 
Msg ID: 2564958 FAA Rules with Union on Duty Period Issues +0/-0     
Author:Just the FACTS Though
4/9/2019 5:26:33 PM

Reply to: 2564942

Sorry to burst your bubble AMC manager



Return-To-Index  
 
Msg ID: 2564944 why wouldn't you be able to close out all that (NT) +0/-0     
Author:paperwork before you drove back?
4/9/2019 4:27:24 PM

Reply to: 2564921


Return-To-Index  
 
Msg ID: 2564945 you have to have ten hours rest within 24, so (NT) +0/-1     
Author:10 + 14 = 24
4/9/2019 4:36:57 PM

Reply to: 2564944


Return-To-Index  
 
Msg ID: 2564947 if you are flying. The FAA does not regulate (NT) +0/-0     
Author:driving a car!
4/9/2019 4:39:16 PM

Reply to: 2564945


Return-To-Index  
 
Msg ID: 2564960 if you are flying. The FAA does not regulate +2/-0     
Author:Nope BUT
4/9/2019 5:28:38 PM

Reply to: 2564947

they do clearly say ALL directives adn have stated that if you are REQUIRED or ACTING (driving a car) as a directive from the certificate holder that is still part of your duty day. STOP trying to mix flying and hours with duty period and tasks.



Return-To-Index  
 
Msg ID: 2564975 Yes, part of your unrestricted duty day (NT) +0/-0     
Author:(since your Part 135 work is finished)
4/9/2019 6:57:01 PM

Reply to: 2564960


Return-To-Index  
 
Msg ID: 2564956 you have to have ten hours rest within 24, so  +1/-0     
Author:OOS Time
4/9/2019 5:23:44 PM

Reply to: 2564945

So put your base OOS until you get your full 10 hours of rest.  Plus, the pilot on your opposite shift has his full 14 hours if needed.  Not to hard to make it work.



Return-To-Index  
 
Msg ID: 2564959 why wouldn't you be able to close out all that +0/-0     
Author:Still not on rest and not
4/9/2019 5:27:22 PM

Reply to: 2564944

relieved from all directives or control of the certificate holder...Still part of your duty period. Sorry



Return-To-Index  
 
Msg ID: 2564977 Yes, again, so what? You are not restricted by +0/-0     
Author:Part 91 or by deadheading!
4/9/2019 7:10:51 PM

Reply to: 2564959

You can be on duty for 24 hrs, or longer...  just not conducting any further Part 135 operations



Return-To-Index  
 
Msg ID: 2564955 Did the FAA just change their Final Rule without +0/-0     
Author:a NPRM ??
4/9/2019 5:21:41 PM

Reply to: 2564921

In the final rule published for Subpart L, the FAA wrote the following:

 

RELATIONSHIP BETWEEN PARTS 91 AND 135

AMOA, Air Evac EMS Inc. (Air Evac EMS), AAMS, NEMSPA, and PHI were among commenters that said that applying part 135 regulations to operations traditionally considered to be under part 91 is inconsistent with the current regulatory framework and could introduce confusion. Instead, these commenters said changes to enhance safety requirements for these operations should be made by amending part 91, not part 135. This would ensure the continuity and applicability of the current rules.

The NTSB supported the proposal and stated that it would likely meet the intent of Safety Recommendation A-06-12. However, it also stated that the list of flights conducted under part 135 must be as complete as possible and should include maintenance flights, training flights, helicopter positioning flights performed without medical crewmembers on board, and other operations that would not be required to be conducted under part 135 under this rule.

The commenters are correct that, as discussed in the NPRM, currently non-patient-carrying legs of helicopter air ambulance operations may be conducted under part 91. The FAA, through this rule, is requiring legs with medical personnel onboard to be conducted under part 135. The primary reason for this change is to protect medical personnel by ensuring that those flights are conducted under the more stringent operating rules of part 135. As noted by the NTSB, medical personnel “cannot be expected to meaningfully participate in the decision-making process to enhance flight safety or to significantly contribute to operational control of the flight.” Accordingly, the FAA determined that medical personnel deserve the same safety protections that part 135 provides to patients on helicopter air ambulance flights.

Additionally, the FAA is not changing the rule language to provide a more extensive list of flights that must be conducted under part 135. As discussed above, the rule is clear that if medical personnel or a patient are on board the aircraft and the flight is conducted for medical transportation, then it must be conducted under part 135. The non-exclusive list is intended to emphasize that the traditional three-legged helicopter air ambulance flight (base to pick-up site, pick-up site to drop-off site, drop-off site to base) must now be conducted under part 135.

Further, the FAA does not anticipate that the placement of these rules in part 135 rather than in part 91 will cause confusion for certificate holders. It is clear that these rules only apply to part 119 certificate holders authorized to conduct helicopter air ambulance operations under part 135. Part 135 is a logical place for the regulations affecting this population.

 

The FAA is not requiring a certificate holder fly all the way back to the base under Part 136.267.   Not in the least.   I'll bet the FAA answered the union's question as it was asked, but that the question asked was not what the union thought they were asking.   Yes, if a medical crew is aboard the flight, it must be Part 135.  But, at the same time, if the medical crewmember is not on the flight, it can be operated under Part 91.

 

Thus, you can plan to fly to where you drop off the patient and medical crewmembers prior to the 14th duty hour, and still plan to fly back to the base without them under Part 91 beyond the 14 hrs.   Your rest will not start until you are completely free of all duty (postflight, etc), but there is not limitation on the lenght of the duty period any longer since it is not Part 135!

 

Imagine if what the union says to be true, then EVERY Part 135 operator will have to fly their aircraft back to the base everyday, and within 14 hours!   Preposterous!   Or, they can't ever have a pilot fly an aircraft anywhere and plan to deadhead him back to his domicile unless it is within the 14-hours from him starting.  Inane!   All those NetJet pilots will have to give up yet another day off now!



Return-To-Index  
 
Msg ID: 2564961 Did the FAA just change their Final Rule without +1/-0     
Author:Jason Kidd 2017 Lega Interpretation
4/9/2019 5:30:17 PM

Reply to: 2564955

Was just one of 11 legal interpretations following the release and publication of subpart L to further explain this very issue. Do a simple google search or dig a little. Its amazing what you would find.

Thanks Union. Great Job!



Return-To-Index  
 
Msg ID: 2564967 the other 10 don't support your assertion (NT) +0/-0     
Author:either
4/9/2019 6:09:26 PM

Reply to: 2564961


Return-To-Index  
 
Msg ID: 2565062 Nothing supports your assumption. (NT) +0/-0     
Author:Anonymous
4/10/2019 9:06:51 AM

Reply to: 2564967


Return-To-Index  
 
Msg ID: 2564978 What I've found does not say anything about  +0/-0     
Author:Part 91 without medical crew/pax
4/9/2019 7:14:29 PM

Reply to: 2564961

Try again!   Point out in the "Kidd" interp, or any of the other 10 you mention were it denies the certificate holder and/or pilot the ability to operate Part 91 past 14 hrs of duty.

Should be simple, since you are saying there are so many references!



Return-To-Index  
 
Msg ID: 2564979 Hey OP. If there is a new FAA letter of interp to +0/-0     
Author:the Union, post it since it affect all!
4/9/2019 7:18:38 PM

Reply to: 2564921

There isn't anything on the FAA Chief Council's website about it:

 

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/Interpretations/

 

Nothing!



Return-To-Index  
 
Msg ID: 2564988 Wow, this is great news. this means a pilot can't +0/-0     
Author:plan to stay for a pilot meeting after
4/9/2019 8:26:57 PM

Reply to: 2564921

his shift ends.  Cool!

 



Return-To-Index  
 
Msg ID: 2564991 you can turn down flights all day long because (NT) +0/-0     
Author:there is a tail-end pilot meeting. yahoo
4/9/2019 8:29:26 PM

Reply to: 2564988


Return-To-Index  
 
Msg ID: 2564993 Wow, this is great news. this means a pilot can't +0/-0     
Author:Already donít have at AMC
4/9/2019 8:37:17 PM

Reply to: 2564988

CBA says you can stay from 12-14 for the sole reason of accepting a flight. If you stay, you click off and click back in for “voluntary“ workover. Don’t let management fool ya.



Return-To-Index  
 
Msg ID: 2565001 You lost that arbitration dude! Your lawyer (NT) +0/-0     
Author:sucked
4/9/2019 8:54:21 PM

Reply to: 2564993


Return-To-Index  
 
Msg ID: 2565006 FAA Rules with Union on Duty Period Issues +3/-0     
Author:Elohssa Nami
4/9/2019 9:24:54 PM

Reply to: 2564921

I work for a company that doesn't play this game.  I turn into a pumpkin at 14 hours.  If I can't reasonably expect to complete a flight by the end of 14 hours, they don't want me to initiate it unless it is agreed upon beforehand that I get relieved by another pilot at some place other than the base.  We try to not do that, either, because it is painful  for everybody involved.



Return-To-Index  
 
Msg ID: 2565010 no different here... 'cept the union hates it (NT) +0/-0     
Author:Anonymous
4/9/2019 9:31:14 PM

Reply to: 2565006


Return-To-Index  
 
Msg ID: 2565007 FAA Rules with Union on Duty Period Issues +0/-0     
Author:Elohssa Nami
4/9/2019 9:25:42 PM

Reply to: 2564921

I work for a company that doesn't play this game.  I turn into a pumpkin at 14 hours.  If I can't reasonably expect to complete a flight by the end of 14 hours, they don't want me to initiate it unless it is agreed upon beforehand that I get relieved by another pilot at some place other than the base.  We try to not do that, either, because it is painful  for everybody involved.



Return-To-Index  
 
Msg ID: 2565033 FAA Rules with Union on Duty Period Issues (NT) +0/-0     
Author:stabbar
4/10/2019 1:08:08 AM

Reply to: 2565007


Return-To-Index  
 
Msg ID: 2565034 FAA Rules with Union on Duty Period Issues +0/-0     
Author:stabbar
4/10/2019 1:11:10 AM

Reply to: 2565033

So, how do you claim a non passenger leg as Part 91 when the company is compensated for that leg of flight?  Part 91.146 and 147 tell a different story.  Parts 135 and 121 were written for compensation.   



Return-To-Index  
 
Msg ID: 2565047 because they aren't compensated for it! (NT) +0/-0     
Author:Anonymous
4/10/2019 8:00:00 AM

Reply to: 2565034


Return-To-Index  
 
Msg ID: 2565048 the only leg they are compensated for it the (NT) +0/-0     
Author:patient leg
4/10/2019 8:00:56 AM

Reply to: 2565047


Return-To-Index  
 
Msg ID: 2565068 FAA Rules with Union on Duty Period Issues +1/-0     
Author:Yeup
4/10/2019 9:28:25 AM

Reply to: 2564921

it's all about duty in, duty out, and what is involved, no exceptions.

Hello, I'm now at work and starting to get my act together for the purpose of accepting a flight = now on duty.

Goodbye, I'm now done with all that stuff and going out the door = now off duty, see you in 10, or 11, or whatever.

I love it when the operator says the first 15 minutes of preparation to accept a flight at the start of a shift is not duty, but industry standard. 

Where's that in the regs?  And just how does one get everything done, in 15 minutes?

For the most part I just ignore the company trying to chip away at the regs.  I pay attention to the FAA because they own the regs and have the bigger stick, much bigger.



Return-To-Index  
 
Msg ID: 2565123 No operator is saying that, especially AMC! +0/-1     
Author:Anonymous
4/10/2019 11:39:22 AM

Reply to: 2565068

AMC says to duty-on when you get to work and duty-off when you finish work.  They've been saying that since 2009 at least!   Part 91 is still duty, but it is still Part 91, meaning there are no 14 hour restrictions!



Return-To-Index  
 
Msg ID: 2565136 That is incorrect. (NT) +0/-0     
Author:Anonymous
4/10/2019 12:20:15 PM

Reply to: 2565123


Return-To-Index  
 
Msg ID: 2565140 BS! The GOM, the CP, the DOO, the Chk Airmen +0/-0     
Author:never ever said you are on rest working!
4/10/2019 12:34:00 PM

Reply to: 2565136

What they might have said is you can't fly Part 135!   Nothng in that letter will change the fact once you drop the medical crew and patient, you are free to operate Part 91.   Because if it is anything like you describe, the FAA has rewritten the FARs completely with that letter.

 

That letter doesn't say what you think it says!



Return-To-Index  
 
Msg ID: 2565144 Still incorrect. No medical crew on board does not necessarily  +0/-0     
Author:mean it's a Part 91 leg.
4/10/2019 12:44:34 PM

Reply to: 2565140

.



Return-To-Index  
 
Msg ID: 2565165 yes, but under the same token, it doesn't mean +0/-0     
Author:it definitely is Part 135 either!
4/10/2019 1:39:46 PM

Reply to: 2565144

IOWs, we are back to the Union's assersion that once you start 135, you must forever fly 135 until back at the base is completly false.



Return-To-Index  
 
Msg ID: 2565242 Except that's not what the union said. (NT) +0/-0     
Author:...
4/10/2019 6:07:33 PM

Reply to: 2565165


Return-To-Index  
 
Msg ID: 2565243 That is what it's saying. It is telling pilots that +0/-0     
Author:Anonymous
4/10/2019 6:15:46 PM

Reply to: 2565242

The union is telling pilots they have to plan to be BACK AT THE BASE within 14 hours, when that is not the FAA's mandate.   The FAA wants you to plan to be finished with Part 135 within the 14 hours, whereever that is, and that they don't dictate to any company Part 91 operations after that (with regard to 135.267)

 

That's what the union is trying to say the FAA is telling them so they can turn down flight if they don't end back at the base with the crewmembrers aboard within 14 hours.   



Return-To-Index  
 
Msg ID: 2565244 No, they are not. +0/-0     
Author:.. .
4/10/2019 6:21:07 PM

Reply to: 2565243

I have no communication, email or otherwise, from the union that tells me I'm required to be back at the base by 14 hours.

 

 



Return-To-Index  
 
Msg ID: 2565273 from the Union: +0/-0     
Author:Anonymous
4/10/2019 8:16:10 PM

Reply to: 2565244

Communication from union:

 

The most consistent accepted and past practice has been to utilize the planning process to determine whether or not you can “plan” to complete the entire HAAO which includes patient drop-off and a subsequent reposition flight back-to-base and then complete all associated tasks related to your Part 135 assignment, and until which time you are free from all restraint, work, or duty. This is just one of the items that we will be seeking an FAA legal interpretation on related to this new policy/directive.

....It is the unions opinion that for planning purposes the flight assignment should consist of flight legs to complete pick-up, drop-off, and the subsequent reposition (return-to-base) legs; closing the loop and meeting requirements under the FAR’s and within the definition of an HAAO and also meets the scope and intent of realistic planning.

 

The union's position is that there can be no Part 91 segment AFTER dropping off all medical crewmembers and patient; that the FAR 135 flight must plan to end by flying back to base prior to the 14th duty hour, or checking into hotel somewhere away from base.   And, this is simply not the case, and certainly not IAW FAA long standing policy on the matter



Return-To-Index  
 
Msg ID: 2565413 Still incorrect. No medical crew on board does not necessarily  +0/-0     
Author:Yeup
4/11/2019 5:55:23 PM

Reply to: 2565144

Although I left them 2 years ago they always said 15 minutes prior to duty in is gratis per industry standard and all sectors were to be operated 135 and if challenged with getting back to base within 14 to call the right person and they may or may not authorize the RTB over 14, even with med crew on board whether company employees or otherwise.  Not sure where that is written, or if it is written, but seemed to be what was in play for many years I was there.  And yes, I disagree with it.  14 is 14, don't fiddle with it unless the circumstance is truly beyond your control and a minor amount over 14.



Return-To-Index  
 
Msg ID: 2565411 No operator is saying that, especially AMC! +0/-0     
Author:Whatever.
4/11/2019 5:50:49 PM

Reply to: 2565123

You need to go back to initial, better yet, get a pair of hearing aids.



Return-To-Index