FC5342 - Insufficient time allowed for duties
Initial Report
We fly an international programme from large airports. Report time is 1hr for all pre-flight planning, clearing security and preparing the aircraft. We routinely fly extremely long two crew sectors very close to flight time limits. If the true time taken was accounted for these flight’s they would be illegal. It is the norm for pilots to arrive in the crew room having pre-briefed the entire flight at home and proceed directly to the aircraft without further time being spent. Even then 1hr is not enough.
comments
CAA Comment
Operators are required to demonstrate that the report time is sufficient for the tasked required, if there is a systemic issue then we would raise this as a finding. 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 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.