Tunnel Vision  

Scary.

Actually, it would change very little.  182 X 12 = 2184 hours.  40 X 52 = 2080 hours.

What it would do though is, require an extra pilot over the course of a day, or two extra pilots per base across the system to train, provide benefits to,  buy flight suits for and etc.  You're not climbing the corporate ladder with that suggestion, junior manager.

What would be a better suggestion is to acknowledge the existence of chronic fatigue and its role in mishaps.  Focus on other positive solutions rather than, "The pilot is lazy if they refuse a late flight"

 Some alternatives include:

• Standing up a second base with a staggered change time, or staggering changeout times on already existing local bases.
• Study the local call patterns and adjust base start times accordingly
• Work with local requesters regarding the base's no-go dutytime hours or no-later-than times.  Most hospital transfer patients have been on site 8 hours or more already.

I could go on all day.

Well, that's a 6/2, but if it's what it would take to keep amoral managers from continuing to push the 15-16 hour foolishness, it may be what is necessary.

Market forces would ultimately determine if it was a wise decision -

• Sick calls would never be covered, nor would vacations.  No one would willingly give up one of their two days off. (unless you had a large pool of float pilots for every airframe)
• Four ( or eight for IFR bases) days of training/travel per pilot per year would rarely be covered.
• A 6/2 changes the starting day of the hitch every time, which many would not be interested in, although I didn't mind when we did the 3d/3n/6off.
• Better pilots would look elsewhere for their old schedule
• Poor in service rate and pilot retention at your company would favor the competition

Instead of that, maybe just admit that a pilot is more likely to be unsafely fatigued at 15 hours, heading into darkness and probably deteriorating weather.  Knowing that, why would you even push it?

The 12 hour shift was meant to be a compromise between the 24 shift back in the day (with the voluntary rest period if needed) and the 8 hour shift no one wanted to do.  It was always meant to be used cautiously, with the 14 hour extension a rare occurence.  As it turns out, we can't really govern ourselves, though.

If this hammer is your only tool, you've already lost as a manager.  Business is down, blame the pilot.  There are so many alternatives to pushing the unsafe angle.  It's ironic, but the actual biggest factor in promoting safety is not a device like nvgs, instrument capability, twin engines, better training or anything like that which people would expect.  We can compulsively override all of those things.  The biggest positive influence on safety is having strong business development and plenty of business.  No one complains about missing a late flight when times are booming.

You're not my manager, and I'm grateful for that. I don't enjoy these arguments and their attendent pressure at the ends of shifts, but at this stage of my career, it wouldn't really matter.  My moral contract is with my medical crew and in getting them home safe. I've also noticed that managers never personally ride on these late flights.  Other pilots may be more impressionable.

I don't expect to change your attitude or fixation on this. It will probably only change when you are named in a wrongful death lawsuit.  I sincerely hope that is not the case. 

This 12 hr shift day is what you wanted.   So you can "maximize" your days off.   The schedule is actually the same scheduled hours either way. 

The Part 91 options are also for your benefit.   Flight schedules can terminate anywhere... ask an airline pilot or a GOM helicopter pilot about that.   The Part 91 actually gives YOU more flexibility.   The medcrews wanted to be considered paying passengers and lobbied Congress for that, so Congress gave them that.  Beyond medical crews now being considered 'paying passengers' requiring Part 135, nothing else changes.   They can be left behind so the pilot and company can continue to operate like any other Certificate Holder.   Even fixed-wing rules didn't change.  You think because you fly a helicopter, you are special in that category of duty/rest?   If it were really a big deal, the FAA would have required all Part 135 operators to consider their company crewmembes and employees "paying passengers" too, and demanded Part 135 rest requirements for them too.   

"The 12 hour shift was meant to be a compromise between the 24 shift back in the day (with the voluntary rest period if needed) and the 8 hour shift no one wanted to do.  It was always meant to be used cautiously, with the 14 hour extension a rare occurence.  As it turns out, we can't really govern ourselves, though."

14 hour shifts were always the norm for pilots in Part 135.   Had nothing to do with 24 hr shifts.   The 24 hr shifts under HEMES was the exceptiong created to compromise for companies (hospitals) who wanted one pilot to cover the whole day for 3 days in a row (making it easier to hire fewer pilots).   They learned that was not economical when they were required to give the pilot mandatory rest periods anyway (bringing the operation to a halt during that rest period).

14 hour extensions are a NORM in Part 135 operations.  It's just that HAA guy's think they are somehow a special bunch, which is surprising since most if not all but one fixed-wing accident was attributed to flying past 14 hours.  And that is ironic, wouldn't you say, since the fixed-wing air ambulance side of the house is not affected by Subpart L.

...the crux of my statement is the question, "Should we be extending this long anyway, crew or not?"

The FAA is sometimes subtle.  They actually give quite a bit of leeway to those (such as yourself), who want to push every boundary, but they indicate subtly that you shouldn't be doing it.  The distinction between Part 91 and Part 135 is one such way.  Under part 135 they indicate that paying passengers should not be carried beyond 14 hours pilot duty day.  They are indicating it is unsafe for the passengers to do so. The fact that they do not regulate your judgement under part 91 can only be explained as a throwback to the bold spirit of barnstorming, or something.  We children obviously need more observation.

In another area the FAA does this is in IFR departures.  Under part 135, the IFR departure minimum is 1/2 mile visibility.  Under part 91, there is no such minimum.  You can depart IFR 0/0.  What?!?  Are part 91 pilots more skilled than part 135 pilots?  No, the FAA just leaves room for you to kill yourself, if you're so desperately inclined.

You must be a manager or med type. There is no majority of opinion. I have talked to FAA reps who are very reticent to say if it is legal. But that shouldn't even be a question. It should be whether or not it's a good idea to continue to fly after 14 hours of duty.  If you asked that question you would definitely get a majority of opinion.

Hour limit. You can't look back even 1 leg to use a previous unplanned delay as an excuse.

Not according to Tripony. And come on, get real would you consider a delay from previous legs? The delay in question has to be enroute. That means the most current leg. You cannot apply the most current leg delay to future legs that would put them outside of a 14 hour window. Furthermore, the idiot started talking about legality, when he was responding to a post that was asking about common sense. 

How can a 135 operator HAA or otherwise exempt themselves from any part of 135.267? Also duty times of 14 hours, and rest times of 10 hours are specified in 135.267 (c)

Why are you fighting so hard for a pilot to exceed 14 hours of duty?

HAA ops under 135.267 must operate under 135.267(b) or (c). Regularly scheduled crews = (c). AMC needs to update their GOM 

True. See Triponey (2018) FAA Legal Interpretation. Each leg is evaluated separately.

And they don't tell you it's legal. Because if an accident or incident occurs outside of that 14 hour window, it's going to be pilot error, fatigue, and careless and reckless.