Confidential Human Factors
Incident Reporting Programme
The Charity
Aviation
Maritime
FC5350
Initial Report
Definition of Duty is âany task a crew member performs for the operator, including flight duty, administrative work, giving or receiving checking, training and checking, positioning, and some elements of standbyâ. Currently our manuals have us as report to aircraft 45mins before departure. Competitors such as [Competitor] have their report point to the back of the security queue 1 hour before departure, since clearing security is a task that the crew member is doing as part of their duty. This gives [Airline] a distinct advantage as they can work us longer without going into discretion because youâve checked in 15mins later â typically, on restrictive early shifts reporting 15mins earlier reduces the length of the FDP by a further 15mins (30 mins longer each day).
Also within the EASA Q&Aâs it states:
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?
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.
I struggle to see how if EASA as the regulatory body state that passing a security checkpoint that it should be counted towards the duty period, how and why are [Airline] able to flagrantly circumvent this by requiring crews to make their way through security on their own time and be subject to less restrictive duty periods?
CAA Comment
The EASA FAQ material is not guidance nor AMC and so has no formal recognition. The CAAâs role is to ensure that operators define their report point and that sufficient time is available to perform the required duties. We do not comment or compare individual airlinesâ policies in this respect but we have commenced a post-BREXIT implementation review of the assumptions within the whole UK rostering and FTL/FDP regulatory set so that they can determine whether there are any areas that could be better defined, harmonised or re-evaluated now that we are no longer part of the EASA regulatory regime.
CHIRP Comment
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 â 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 operatorâs 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 operatorâ 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. Â 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.).