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EASA Flight Time Limitations: soft rules, hard landings

by Simon Roberts BALPA Scheduling Specialist

We hear from UK pilots across the industry about their experiences of flying under new EASA rules since they became mandatory in February last year.

Amy* is a first officer at a regional airline

“With the current scheduling agreement being more restrictive than the EASA maximum hours, our crew do have a degree of protection afforded to them. Six successive earlies now being legal has, in my opinion, led to an increase in fatigue reporting. A number of flight crew who have been in the company for a significant number of years suggested that the summer schedule was the most fatiguing that they’d experienced.

“Rostering, on occasion, takes little account of training or otherwise, meaning that the extended time periods given to training sorties can require an earlier start or later finish. While this is transitory for trainees and line trainers, these rosters have potential to become substantially fatiguing. It should be considered that an increase in fatigue reporting is a good thing, but if the root cause is an increase in fatigue itself rather than a greater willingness to report, this is unlikely to be the case.

“As a low cost, regional airline often considered to be a stepping stone for individuals into the industry, the issue of the change in FTLs is perhaps overshadowed by the flight crew complement changing regularly due to individuals moving on, meaning that demands on those left can be great and many bases often report regular roster changes as a result. Many of the issues that the company thus faces in terms of roster patterns are not directly linked to EASA FTLs.”

Charles* is a long-haul first officer

“My company has both long and short-haul flying, and the EASA regulations have been in force for approximately 18 months. Up until now, I would say we have had a fairly strong scheduling agreement that pilots can to fall back on.

“However, in my opinion, the move to EASA regulations has placed significantly more responsibility on the pilot assessing themselves, and it seems that the protections that have been in place for so many years just aren’t there anymore. It is a steep learning curve that will probably take a while to get used to.

“Coupled with the fact that the fatigue reporting process does not yet seem fully understood by a number of pilots, is onerous and, in my opinion, feared by the wider community, we could see ourselves in the perfect situation where a pilot could get themselves into hot water for several reasons. Firstly, speaking from personal experience, it is very difficult to diagnose fatigue in yourself. Secondly, I believe that a significant number of pilots haven’t fully adapted to the subtle change in responsibility to themselves.

“I think it’s a bit of a grey area I feel my operator is perhaps a little comfortable sitting in. It is up to us at BALPA to educate all our colleagues that responsibility for reporting fatigue lies squarely at our feet and we really shouldn’t be fearful of doing so. We’ve got to be brave enough to stand up saying: “No, sorry I cannot do this duty. I am fatigued” and knowing you will have the full support of your colleagues, BALPA, your operator and the authority when you do so.”

Tom* is a captain at a low cost airline

“Working for a low cost airline, often operating four sector flights on a daily basis has been considered hard work by many and fatiguing for some, even under CAP 371, the ‘old’ CAA scheme. In my view, fatigue has mainly affected older pilots, predominantly because they have spent many years working at quite a relentless pace, often without a respite even during winter, as was perhaps enjoyed a decade or so ago. Now that EASA has introduced longer early multi-sector days, as well as getting rid of the variations pertaining to very long two sector days, I have now also seen younger pilots complaining of fatiguing rosters.

“Indeed, the talk on the flight deck is invariably about fatigue, rather than say sport, fast cars, or other interesting human activities. The company I work for has what is generally regarded as a fairly good fatigue reporting system, which I can vouch for through my own experience. However, all of us know of pilots who have been taken off flying for one or two months, sometimes several months, and occasionally a year, due to fatigue. Indeed all the new pilots remark how it is only the part-time pilots who seem happy, and how tired and sometimes miserable the full-time pilots are. And it is also remarked that you shouldn’t really have to go part-time in order to get a life, let alone avoid an early grave.

“The problem with ‘soft’ regulation is that it is down to the pilot who determines his fatigue level. You only really know what it is like to be fatigued when you have gone there before, as is perhaps common with older, experienced pilots. What we really do not want is a generation of pilots all testing their fatigue levels, and finding out what it is like on the job, whilst flying.”

James* is a long-haul senior first officer with a charter airline

“In common with other colleagues, when at work, I am involved in more and more discussions concerning fatigue which results directly from the job. My company operates a mix of long and short-haul flights. Coming from the former category, a recent example may be worth making. The shift to the new rules has coincided with installation of Category 3 crew rest facilities into our A330s. Along with that, some, in my opinion, excruciating flight pairings are now starting.

“Firstly the rest area. This comprises a row of three semi-upright seats which are curtained off from passengers at the back row of the front seating area of the aircraft. Whilst the EASA rules allow for this, noise levels are high, both from passengers and from the PA. Lighting is dim, not dark, and the constant movement of passengers and crew means that adequate rest is impossible, due to being jostled, woken, and trying to sleep semi-upright.

“When flying return trips to Goa, for example, both sectors are flown primarily through the night, and involve constant vigilance. Three-crew can seem insufficient on such operations, and the bare minimum rest facilities are of little help. ‘Bullet’ trips to destinations such as Las Vegas also seem to be creating problems, particularly when they can be immediately preceded by one or maybe two short-haul trips, and followed by two days off.

“Although the active encouragement from our Crew Council for submission of fatigue reports has been ongoing for a few months, only now has the level of reports started to increase. It is expected that this trend will increase. In many cases, these are from senior pilots who feel unable to cope with the rigours of full-time long-haul flying.”

[*] names have been changed to protect identity