Whilst we accept that the company comment provides appropriate guidance, its contents appear to be somewhat at odds with the directive nature of the initial email that was sent to crews in which the expectation was that “If you are on a remote stand please ensure you are briefing on the bus journey over… You should not be waiting until you are onboard to begin your brief.”   The company’s subsequent comment to CHIRP therefore provides welcome clarification that “Our crews should not be conducting the briefing in a location if it is not safe or appropriate to do so, or they do not yet have access to the information required.” thereby confirming the captain’s authority not to brief on the bus if they do not think it appropriate and to delay the briefing until on the aircraft if necessary.

The disparity between the original email and the Company comment clarifying their position on briefing requirements highlights the need for care in publishing email communications to company personnel. Crews are busy people and will likely take at face-value such communications when they might not necessarily be framed in the way intended. To remove all doubt in this case, CHIRP suggested to the Company that they issue a further clarification email based on their comment to us that captains should not be conducting the briefing in a location if it is not safe or appropriate to do so, or if they do not yet have access to the information required. In response, the Company have confirmed that communications have been sent out to the crews to provide clarity around suitability of briefing areas (bus or otherwise); that crew should only brief on the bus if appropriate; and that other locations may be utilised, including on the aircraft if nothing is suitable before this point.

Briefing on a small bus with seats during journeys where the crew are the only occupants may be one thing (such as travelling from a stop-over hotel to the airport where it may be a pragmatic use of ‘dead’ time), and is probably fine on occasion. But CHIRP does not think that it is appropriate as a routine procedure when travelling by airport buses to remote stands, potentially with other crews, and potentially in buses where there are no seats.  Such airport crew buses are generally large buses that are not conducive to conducting pre-flight briefings, especially because the airport environment is such that frequent sharp turns, stops and starts will be experienced that mean the bus is unlikely to be a stable environment for people to stand up and brief their crew. There are also potentially serious safety implications if crew members do not properly hear such bus briefings due to noise etc or are not able to give their full attention to the brief as they try to retain their own balance; associated misunderstandings could easily lead to accidents or incidents.

We would also suggest that any reference to OTP, KPIs and the impact on bonuses is inappropriate in email correspondence of this nature because it will be perceived as overtly encouraging people to cut corners (such as by briefing on buses) as an expected norm, which is counter-productive to safety.

The reporter’s comments reflect perennial conversations we’ve been having with airlines and the CAA for many years. On the one hand, it was ever thus that report times are tight on FTLs, and the advent of EFBs has to some extent been a double-edged sword. There are 2 clear issues behind this report: firstly, the amount of time allowed by companies to conduct pre-flight tasks between report time and departure from the stand; and secondly, the degree of assumption that companies have that crews will conduct significant amounts of their pre-flight planning and briefing whilst off duty before report time. Although the company concerned may have a standard allowance of 1hr from report time to off-stand, this is not a universal policy and some companies have different allowances that often reflect whether the report point is airside or groundside.  We recognise that tailoring report times to suit specific locations and journey-through-airport dynamics is not an easy rostering task because daily changes in aircraft availability, gates and terminals are a tactical factor that are not easily incorporated into pre-planned rostering. Nevertheless, it ought to be possible to incorporate better time-and-motion metrics into individual rosters for average report-to-departure durations (including airport arrival to report point) for individual airports to take into account the realities of what crews experience in practice (which may vary according to time of day) rather than assume a blanket 1hr standard for all.

With regard to EFBs and pre-flight activities themselves, whilst the expectation of some pre-preparation is not unreasonable, there are indications that companies are relying more and more on crews conducting pre-flight tasks using their EFBs whilst still at home and not on duty. Before EFBs were introduced, timings were very tight indeed, and their introduction has meant that at least some of the information is now more easily accessed and interpreted with the ability to do so well before report time. But there comes a point when company expectations need to be realistic in acknowledging what they assume to be done in off-duty time. Some sectors are of course more complex than others and so may attract a greater planning burden depending on conditions pertinent to that flight. Whilst pilots are generally a ‘can do’ bunch of people who accept a bit of duty-time flexibility, if companies start to rely heavily on such pre-planning before report point then this should be recognised within rosters as additional time added to the FDP.

The relationship between report point, having sufficient time to conduct required tasks (including getting to the gate if appropriate), and FTL definition has been an ongoing topic that CHIRP has highlighted many times in recent months (most recently in AT FEEDBACK Ed149 Report No6 – FC5300).

As the reporter comments, although not applicable to UK AOCs, EASA has previously published a commentary about when FDP starts in relation to security checkpoints and report points in their document EASA FAQ n.135897 which is reproduced in full at the end of this report. The response is clear that, in their opinion, duty (and hence FDP) starts at the Report Point unless crew members are required to commence an activity such as passing through a security checkpoint. We have asked CAA whether they have a similar interpretation of when duty commences and they responded by saying that the journey time before report will be looked at as part of their ongoing overall FTL review this year which will consider the associated baseline assumptions and fatigue metrics. CHIRP thinks that more AMC/GM is required in this respect so that the burden of absorbing the time taken to pass through security etc does not fall solely on the crews as yet another stressor in their day but is included as part of FDP calculations for each airport situation.

EASA FAQ n.135897 (CHIRP underlining)

Reporting point ORO.FTL.105 (2): The global COVID-19 pandemic necessitated, on a number of occasions, a change to the typical aircrew reporting point. How should the operators address this change?

Answer

Aircrew typically used to report for duty at a crew room, at their home base or at outstation. The global COVID-19 pandemic caused disruptions in flight operations and necessitated, on a number of occasions, a change to the typical aircrew reporting point. Here below are some considerations that operators and aircrew should account for when addressing such change.

Notification to crew members. The operator must inform the crew about any change of the reporting point prior to operating as this is part of operator’s responsibilities under ORO.FTL.110.

Travelling time to the reporting point. Due to the change of reporting point, the otherwise duty time may turn into travelling time, thus extending the usual travelling time that a crew member is accustomed or prepared for. Therefore, the operator should make sure that the impact of the change of reporting point on traveling time and consequently on crew fatigue is not significant. The operator’ SMS has to manage the change of reporting point by assessing the potential negative impact on aircrew fatigue levels, based on evidence of adequate time frames and/or a comparison between the time necessary to report to the new point and the typical reporting point. In assessing the impact, the operator should account for additional operational factors e.g. standby call out times. The operator should address reporting at a place other than a crew room in the OM.

Commencement of duty. Duty starts from reporting for duty at the reporting point designated by the operator e.g. when the crew member checks-in in a crew room. In cases where the crew member is required by the operator to commence an activity prior to entering a crew room or a non-public area of an airport, so as to obtain flight documents at a check-in counter or ticket office, pass a security checkpoint or update the EFB, the duty starts at the point of commencing this activity. At airports where the crew members can access the non-public area or reach the departing gate through more than one security checkpoints, the operator should make sure that commencement time is the same for the same duty.

Aircrew briefing. The time for aircrew briefing is a duty time no matter where it takes place. If the briefing takes place at the gate where other people are also present, the operator should arrange for a secluded place considering security matters among other things. The size of the crew should not prevent crew members from talking to each other without disturbing and being disturbed. If the briefing takes place on board the aircraft, the operator should ensure that certain conditions are present, such as running APU/GPU, no disturbance from ground personnel or cleaning staff. Where the operator provides EFB, the briefing material should already be uploaded to it or if, new material is to be downloaded, the crew must be provided with means to do so.

Reporting times.  The operator should specify in the OM reporting times that account for the type of operation, ground duties, size and type of the aircraft and the airport conditions (GM1 ORO.FTL.205(a)(1)). Ground duties include pre-flight duties (briefings; provision of documentation; transport to the aircraft parking stand, etc.).