Confidential Human Factors
Incident Reporting Programme
The Charity
Aviation
Maritime
CC6936
Initial Report
My FDP and report time have been manipulated for company benefit. A text message and a roster notification was sent at HH:MM (2hrs25 before scheduled report) and I had a call from crewing at HH:MM (1hr55mins before scheduled report) but it was unsafe for me to read the text or take the call. I reported as normal at my rostered report time to find my flight was delayed by 55 mins. I could not check in for the flight without acknowledging the delay, which then changed my report time to HH:MM (55 minutes later). The system is set up, to prohibit the crew member to report at their scheduled report time which falsely adjusts the report time.
Company Comment
Thank you for raising your concerns regarding the delayed reporting process and how your FDP and report time were handled.
In the Operations Manual, there are set procedures for delayed reporting at home base, outlining the responsibilities of both the crewmember and Crewing:
Notification Timing
The manual states that Crewing must send delay notifications no more than 3 hours and no less than 2 hours before a UK report time. In your case, the text and Crew Portal update were sent 2 hours and 25 minutes before the scheduled report time, which aligns with the policy. The call from Crewing at 1 hour and 55 minutes before report time also appears to have been a follow-up, as outlined in the manual, since no response had been received.
Crewmember Actions
If a crewmember has already left their place of rest, they are given options at [reference] to report as scheduled, then advise Crewing at check-in that they did not receive the delay notice prior to leaving their place of rest and have therefore reported on time.
System Functionality – Unnotified Duty
As you’ve pointed out, the system does not allow check-in for duties marked as ‘unnotified’ — and a delayed duty that has not been acknowledged is treated in this way. This is an intentional safeguard which acts as a prompt for the crewmember to call Crewing or discuss with the crew check-in team. This is important not just to allow check-in, but also because Crewing may need to reassess whether the crewmember can continue to operate the flight under the FTL and FRM rules. This is outlined in [reference] of the procedure.
Correct Procedure in This Scenario
When a delay notification hasn’t been received or acknowledged before leaving your place of rest, the crewmember should report as scheduled and contact Crewing at check-in. At that point, Crewing will manually revert the duty to the original report time, assess the FDP limit and discuss any IFR/augmentation needs, which when completed, will allow check-in. This ensures compliance with both the Operations Manual, FRM policy and system controls.
CAA Comment:
An operator may delay reporting for a flying duty in the event of unforeseen circumstances in accordance with the procedure for notification detailed in the operator’s flight time limitations scheme. Where a crew member does not receive notification this should be communicated to the Commander and SCCM for the flight in question and the operator notified.
CHIRP Comment
Under UK Flight Time Limitation (FTL) regulations, an operator may delay a crew member’s reporting time in unforeseen circumstances. The term ‘unforeseen’ refers to events that are unexpected or not predicted, although interpretations of this can vary between individuals.
This regulation enables operators to delay report times while preserving the maximum flight duty period (FDP). This flexibility is particularly useful when scheduled duties are close to the maximum FDP and unexpected delays occur.
A delayed reporting procedure can be initiated by the operator while the crew member is still at home or in suitable accommodation, provided the unforeseen event causing the delay happens before the start of the planned flight duty period.
- If the delay is less than 4 hours – the maximum FDP as originally planned, remains the same.
- If the delay is more than 4 hours – the maximum FDP will be shorter than the originally planned FDP, because the delayed reporting time has a limiting effect on it.
The regulations do not specify a length of time required to delay a report. However, procedures for delayed reporting must be detailed in the Operations Manual, including a notification time that allows the crew member to continue their rest when the delayed reporting procedure is activated.
In this case, the reporter was already enroute to the airport and therefore not in ‘suitable accommodation.’ At a safe and appropriate time, crewing must be informed of this so the report time can be adjusted accordingly. It is also important that the crew member communicates this information to the flight crew and SCCM, as their report time may differ from the rest of the team and this can impact FTLs. Delays are common in aviation and all crew members have a personal responsibility to ensure they are adequately rested for the maximum FDP assigned that day.
CS FTL.1.205 Flight duty period (FDP)
(d) Unforeseen circumstances in flight operations — delayed reporting
(1) The operator may delay the reporting time in the event of unforeseen circumstances, if procedures for delayed reporting are established in the operations manual. The operator keeps records of delayed reporting. Delayed reporting procedures establish a notification time allowing a crew member to remain in his/her suitable accommodation when the delayed reporting procedure is activated.