In part 8 of our series “Know Your CWA 2017” we took a closer look at “Delayed Reporting”. In January 2018 Cargolux finally had to change the OM-A procedure for delayed reporting away from home base on request from DAC-L to be in line with the EASA FTLs. Please find below the text and explanation of the revised delayed reporting procedure as outlined in OM-A Chapter 7, Section 6.
FDP Rescheduling
- If in the period of 10 hours or more before the scheduled departure time, Cargolux informs the crew member of a delay, the delay counts as a rest period.
- A delay of 10 hours or more counts as a rest period.
Delayed reporting
If due to unforeseen circumstances, the report time has to be delayed, the following provisions apply based on the number of notifications issued by Cargolux to the crew member in the period between 10 and the latest possible notification time prior the scheduled departure.
The latest possible notification time is:
- At home base: 2,5 hours prior to the scheduled departure
- Away from home base: 3 hours respectively at the company provided wake-up call, whichever is earlier
To avoid interference with sleeping patterns a silent notification method should be used when possible.
Notification methods:
- Default: email
- Alternative method on Pilot’s request: SMS, phone call
Communications will be identified by the wording ‘delayed reporting’ and specify the updated reporting time.
Phone enquiries or information obtained otherwise by crew members are to be considered informal and do not qualify as delay notification.
The maximum FDP is calculated as follows:
With the implementation of EASA FTL every operator is obliged to establish a procedure to notify flight crews in case of a delay. The purpose of this procedure is to limit the total wakefulness prior commencing duties and to manage the starting time and/or length of a FDP due to such a delay. The delayed reporting procedure can only be applied in reference to delayed flights and not to bring the departure time forward. Furthermore it is only applicable for notifications between 10 hours and 2 ½ hours (at home base) respectively 3 hours (away from home base) before the scheduled departure time.
- If a delay notification is received 10 hours or more before the scheduled departure time or the reporting time is delayed by 10 hours or more, this notification does not qualify as “Delayed Reporting” as long as no further disturbances by Cargolux occur. In this case, the delay counts as rest period.
- If a delay notification is received less than 2 ½ hours (home base) or 3 hours (away from home base) before the scheduled departure time, the notification does not qualify as “Delayed Reporting” and the FDP starts at the original scheduled reporting time.
- If no delay notification is received, the FDP starts counting at the original scheduled reporting time.
Cargolux uses 2 notification methods. The default method is a notification by email. Alternatively, the pilot can also be notified by SMS or phone call if requested by the individual pilot. These two methods are the only official ones and any inquiries, e.g. by phone do not qualify as delay notification.
The delayed reporting table considers the number of notifications and the extent of the delay of the reporting time and can be summarized as follows.
- 1st notification
- Delay of reporting time less than 4 hours
- The maximum FDP is based on the original reporting time.
- The FDP starts counting at the new reporting time.
- Delay of reporting time 4 hours or more
- The maximum FDP is based on the more limiting reporting time, either the original reporting time or the new, delayed reporting time.
- The FDP starts counting at the new, delayed reporting time.
- Delay of reporting time less than 4 hours
- 2nd notification
- The maximum FDP is based on the calculation done for the 1st notification as explained above.
- The FDP now starts counting 1 hour after the second notification or at the first delayed reporting time, whichever is earlier.
Example A:
A Standard Flight Crew is scheduled to operate a flight departing LUX at 14:00 UTC. At 02:00 UTC on the same day the crew receives an email stating, that the flight is delayed by 4 hours and the new STD is 18:00 UTC. Since this email was sent more than 10 hours before the original STD, the notification does not qualify as Delayed Reporting. (Please be aware that the roster publication limit for a Standard Flight Crew of 11 hours in the CWA is now limited to 10:30 hours because of new departure time).
Example B:
3 hours before the STD of 18.00 UTC in example A, the crew receives an email mentioning “(Delayed) reporting times notification for flight : …“ with an amended STD of 19:30 UTC, a delay of 1:30 hours. According to the Delayed Reporting procedure, the maximum FDP is calculated based on the original scheduled reporting time of 16:50 UTC, but only starts counting at the new reporting time of 18:20 UTC.
Example C:
The story continues; The crew receives another email and SMS at 17:00 UTC. Crew control states that maintenance requires additional time for an unforeseen repair, causing another 1:30 hours delay and asks, if the pilots could consider it as unforeseen circumstances, waiving the need for a 2nd delayed reporting notification. To follow such a request would be a violation of the OM-A and shall not be done!
Instead, a 2nd delayed reporting notification must be sent, indicating the new departure time. The new departure time is 21:00 UTC. According to the Delayed Reporting procedure, the maximum FDP is based on the reporting time at 16:50 UTC but starts counting at 18:00 UTC, 1 hour after the 2nd delayed reporting message, which is earlier than the original delayed reporting time of 18:20 UTC in example B. Because of this, the flight cannot be completed within the 11 hours FDP for a Standard Flight Crew.
Example D:
A pilot is scheduled for a flight departing LUX at 13:00 UTC. Reporting time is 11:50 UTC. He only receives a wake up call at 12:00 UTC because the flight is delayed to 14:10 UTC. Since he did not receive any “delayed reporting notification”, the FDP is calculated based on the scheduled reporting time of 11:50 UTC and also starts counting at 11:50 UTC.
If due to the Delayed Reporting procedure a flight duty cannot be completed within the maximum FDP, it is the obligation of the company to either delay the flight for crew rest or add an additional crew member to augment the crew.
Ultimately the intention of the regulation is to limit the total time of wakefulness prior to commencing duties. If you deem that you will be awake for a period of time prior to commencing a FDP which may impact or potentially impact your ability to perform safely your flight duties, inform crew control and dispatch if you will require additional rest and complete a proactive fatigue report.
Please follow this link to download your copy of the CWA for your perusal on the company provided iPad or any other computer for future reference.
If you have any questions do not hesitate to contact us at cvboard@alpl.lu for clarification.
All parts of this series can be found here in the Publications section under Cargolux Board.
