With the high season ahead of us, fatigue mitigation will be crucial to ensure a safe operation of the aircraft. George Karambilas answers questions in regards to EASA FTL, fatigue mitigation in general and filing Fatigue Reports aiming at giving our members guidelines and support to fly safely through the peak season.
Please click here for some legal references, which may be of interest.
Guidance on how to Report Fatigue or Potential Fatigue can be downloaded here.
After we looked at the general rules covering Off- Days in the last issue of our series “Know your CWA”, in this issue we take a closer look at “Consecutive Off- Days” or in short CODs.
Below you find the article as published in the current CWA. Further below we provide some comments and explanations for this article.
These rules are applicable for all pilots except for the allocation and entitlement of RBO. The entitlement of RBO for pilots employed at or after 01 December 2015 is regulated differently and was explained in our last issue “Off Days – General”.
Like always it is the obligation of the company to follow these rules and a pilot is entitled to a roster reflecting these rules. However as a pilot you should know what these rules are. If a pilot notices a none compliance with the CWA it is his right that his roster will be changed to be fully compliant with the CWA.
37.1.2. CODays
a)Under exceptional circumstances (not more than 2 occurrences per calendar year), up to 2 days of the 6 or more CODays can be scheduled to overlap into the next Roster Period. If the COD’s are overlapping into the next Roster Period, it must be clearly identified on both Rosters.
b)Once a block of 6 or more CODays have been published, they can not be altered without the consent of the Pilot concerned.
c)A Pilot can request:
i) To have the CODays starting on a specific date via the PBS.
ii) Three times per year the CODays to be scheduled “back to back” in
2 consecutive Roster Periods.
iii) CODays to encompass specific dates via the PBS.
d)If the CODays and a block of vacation days are scheduled back to back, regardless if requested by the Pilot or not, one 24RBO is scheduled preceding this combined block of off and vacation days.
e)If a Pilot’s ground Duty is not completed by 22:00 local before the 1st CODay, or if the Pilot Duty ends – whether operating, positioning or dead-heading – 00:01 or later on the day before the first planned CODay, then the Pilot is entitled to select compensation from the following 3 alternatives:
i) Move the CODays as a block to accommodate the operational delay, including the 24RBO.
ii) The block of CODays may be shortened to accommodate the late arrival at Home Base by receiving compensation at the rate of 2 Off-Days for every CODay and 24RBOday within the next unpublished Roster Period, attached to the 6 CODays block for that Period.
iii) The block of CODays may be shortened to accommodate the late arrival at Home Base receiving compensation by the payment of Off-Days overtime according to the following formula:
(Basic salary divided by 173) plus 50% supplement with not less than 8 hours counted per missing Off – Day. In this case, duty hours worked in CODays are not added to the total Roster Period credit hours.
Below you will find some comments and explanations regarding Art. 37.1.2.
Important: According to B1-37.1.1., the RBO can be reduced from 24 hours to 18 hours without receiving any compensation in the event of a delay.
In other words:
1. In case of a delay, compensation according to Art. 37.1.2 e) is only applicable if the pilot´s duty ends at 06.01h local time or later.
2. In case of a reschedule, e.g. roster change with different return flight, the pilot is entitled to select compensation if the duty ends already at 00.01 h local time or later on the day before the first planned COD.
Please refer to CWA B1-36.2 Specification of Beginning and End of Duty times for the correct calculation of duty times.
It is only the pilot who decides how he wants to be compensated. The pilot may select between the following options:
1. Move COD, including the RBO, as a block.
2. Receive 2 Off-Days for every COD and the RBO to be scheduled within the next unpublished roster period, attached to the 6 COD block for that roster period. These “owed COD” keep the same value, meaning they remain COD and cannot be moved without the consent of the pilot.
3. Payment of Off-Days overtime as defined in Art. 37.1.2 e) iii)
Example A:
Below is the roster of a pilot, showing that he was planned to return for his COD on 17 March:
The flight back from IAH was then delayed and he now arrives back on 18 March, which is the RBO. As explained it is possible for the company to extend a Duty into the RBO. His duty ends at 06.01h local time.
The pilot can now choose the compensation:
If he decides that his COD including the RBO would be moved as per Art. 37.1.2. e) i), his roster would look like this in AIMS eCrew:
If he elects to receive compensation of the missing RBO on 18 March by receiving 2 Off- Days for the RBO as defined in Art. 37.1.2. e) ii); or payment as defined in Art. 37.1.2. e) iii), his roster would look like this in AIMS eCrew:
Example B:
Due to several roster changes the return flights to LUX for 2 pilots are now completely different from what they originally have been scheduled when they left LUX.
Pilot A now only positions from GYD to LUX while Pilot B operates the same flight. Both pilots have their COD scheduled to start after this flight, with the RBO scheduled on the day after they arrive back in LUX.
The flight from GYD to LUX arrives at 23.45h local time. The duty of Pilot A ends at Block On, at 23.45 local time, as his duty consisted solely of positioning. His duty does not extend into his RBO and he is not entitled to compensation as per Art. 37.1.2. e).
The duty of Pilot B ends 30 minutes after Block On at 00.15h local time. His duty does extend into his RBO and he is entitled to compensation as per Art. 37.1.2. e).
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.
Please read the attached letter we sent to the CEO on 14 August. The ALPL remains alert and concerned about continued efforts to recruit and possibly train Direct Entry Captains here at Cargolux for Henan Cargo Airlines (JVA). Already one year ago we first saw such an attempt where a pilot with command experience only on B737 was offered command training at Cargolux‘ earmarked to operate at the JVA.
This resulted in a meeting late last year where management was informed this pilot would not qualify to operate as a Captain in China on the B747 as he had no experience on a weight class similar to the B747. In fact, for this pilot to meet the Chinese commander requirements would have taken close to four years operating in Cargolux.
As no fault of his own, we believe Cargolux management misinformed this pilot and created an unnecessary and embarrassing situation. A compromise was found to complete his B747 type-rating and Captain training, but thereafter only operate from the right seat as a First Officer until his one year contract would expire. This pilot is no longer part of the pilot group at Cargolux.
Since those discussions in November last year, management appears to ignore our voiced concerns by allowing the joint venture team to continue recruitment efforts for pilots, even promising some of them Direct Entry Captain training and initial operating experience (IOE) here at Cargolux before heading to China.
According to the Chinese Pilots Association (ChALPA), our IFALPA colleagues, the legal requirements of flight experience, training and hours on weight-class category aircraft to be eligible for commander training at Henan Cargo are actually fulfilled by most of our Cargolux Senior First Officers today. Disappointingly, management is not talking with us about how to facilitate a possible career path opportunity for our First Officers and Captains which could include secondment to Henan Cargo Airlines.
We recall hearing promises by management about continued growth of Cargolux in Luxembourg, yet what can be seen is Cargolux Italia still operating Cargolux SA flights and employing roughly 100 pilots not paying taxes in Luxembourg. This does impact the career paths of crews which have been loyal to Cargolux for more than 12 years!
Management needs to initiate constructive dialogue!
Cargolux Italia, Henan Cargo and not enough pilots. Whatever else is coming up on the radar will push-up against the already very (over)stressed patience of the Cargolux pilot community.
In this issue of our series “Know your CWA” we take a closer look at “Off-Days”, starting with Art. B1-37.1.1., which provides general rules for Off-Days. We will expand on the COD and FOD in the next issues.
Below you find the article as published in the current CWA. Further below we provide some comments and explanations for this article.
In general, these rules are applicable for all pilots except for the allocation and entitlement of RBO. The entitlement of RBO for pilots employed at or after 01 December 2015 is regulated differently and explained in the text below.
Like always it is the obligation of the company to follow these rules and a pilot is entitled to a roster reflecting these rules. If a pilot notices a none compliance with the CWA it is their right that his roster will be changed to be fully compliant with the CWA.
B1-37.1. Off-Day Scheme
B1-37.1.1. General
a) An Off-Day is defined as a period of 24 hours free of all Duties commencing at 00:01 local time.
b) All Off-Days will be fixed at Home Base, if not agreed otherwise by the individual Pilot and Company.
c)Each Pilot is entitled to 9 Off-Days at Home Base per 28 days Roster Period. Off- Days will be allotted to each Pilot in 2 blocks and will be clearly identified on the published Rosters as:
i) 6 Consecutive OFF-Days (CODays)
ii) 3 Consecutive Floating OFF Days (FODays)
d) Each block of Off-Days (CODays and FODays) will be preceded by a period of 24 hours Rest Before Off day (24RBO). The rest time guaranteed before a block of Off-Days is 24 hours.
* Note: There are some differences for pilots employed after 01 December 2015, which are mentioned in CWA B3-35.2.
************************
B3-35.2 OFF days
OFF days and RBO will be planned the same as pilots starting before December 01 2015, except for the first 5 years of a contract.
Following rules apply for the first 5 years:
• Year 1: No RBO before FOD and COD
• Year 2: No RBO before FOD and COD
• Year 3: No RBO before COD, 24/18 hours RBO before FOD
• Year 4: 12 hours RBO before COD, 24/18 hours RBO before FOD
• Year 5: same system as pilots starting before December 01 2015
************************************
In the event of a delay, the 24 hours rest can be reduced to 18 hours and no compensation will be given for the reduced rest.
e) If a block of 6 or more CODays and a block of 3 FODays are scheduled back to back, only one 24RBO is scheduled preceding the total block of Off-Days. If during the daily operation phase of a Roster, the FODays are rescheduled away from the block of CODays, a 24RBO is scheduled preceding the block of CODays and 3 FODays.
f) No Duties consisting solely of ground training will be scheduled between:
i) two Off-Day blocks
ii) an Off-Day block and a vacation block
g) No period in excess of 24 consecutive calendar duty days will be scheduled between 2 blocks of OFF days, or a block of OFF days and a block of vacation days.
h) A block of CODays and/or a block of FODays can be planned to start on the day following a ground Duty planned at Home Base provided that this ground Duty is planned to finish no later than 22:00 local time. In this case, the 24RBO does not apply, but shall be compensated by adding an additional day to the FODays within the next unpublished Roster.
Below you will find some comments and explanations regarding Art. B1-37.1.1. However, most of this article should be self-explanatory.
Please take particularly note of the definition of the Rest Before Off- Day (RBO) below.
a) This paragraph defines the term Off- Day as free off all duties commencing at 00.01 local time.
b) Off- Days can only be scheduled at Home Base, which is defined in CWA Part III as “For all Employees at the Company and for the Company itself: Luxembourg Airport.” However a Pilot could agree with the Company that his Off-Days would be scheduled at a different location. This would require mutual consent.
c) Stipulates that per 28 day Roster Period 9 Off- Days have to be scheduled. The Off- Days will be allocated in 2 blocks, 6 as COD and 3 as FOD. Both COD and FOD blocks consist of consecutive blocks of Off- Days.
The text of this paragraph does not prevent that both Off- Day blocks, FOD and COD, are scheduled back-to-back, meaning as one block of consecutive Off- Days. However even if scheduled as a block FOD remain FOD and COD remain COD, meaning that FOD could still be rescheduled without the consent of the pilot. We will expand on FOD and COD in the next issue in more detail.
d) This paragraph defines that before each Off- Day block one RBO needs to be scheduled.
Please note, that per definition a RBO is not an Off- Day and that you may be scheduled to operate into the RBO. However, the RBO will be compensated, if a duty extends into the RBO. We will expand on this in the next issue of this series.
*Note: The following is applicable for pilots employed at or after 01 December 2015.
During the first 5 years, a spool up of RBO as mentioned below is foreseen:
• Year 1: No RBO before FOD and COD
• Year 2: No RBO before FOD and COD
• Year 3: No RBO before COD, 24/18 hours RBO before FOD
• Year 4: 12 hours RBO before COD, 24/18 hours RBO before FOD
• Year 5: same system as pilots starting before 01 December 2015
e) Whenever the blocks of COD and FOD are scheduled back to back, meaning as one consecutive block of Off- Days, the Pilot is only entitled to one RBO before this consecutive block of FOD and COD.
If COD and FOD have been scheduled back to back and if the FOD block is rescheduled away from the COD block, the Pilot is entitled to one RBO before each Off- Day block.
f) This paragraph prevents, that ground training events, e.g. simulator or ground school, are scheduled between two Off- Day blocks or between a block of vacation days and an Off- Day block.
g) This limits the number of consecutive calendar days between Off- Day blocks or between an Off- Day block and a block of vacation days to a maximum of 24 days. It is the obligation of the company that this is observed and a pilot is entitled that his roster is changed accordingly, if more than 24 calendar duty days are scheduled.
h) If before COD or FOD a ground Duty, e.g. simulator or ground school, at Home Base, which is per definition Luxembourg, finishes latest at 22.00 local time, the FOD and COD may start at 00.01 of the next following day. In this case a RBO does not have to be scheduled between the ground Duty and the first COD or FOD. However, the RBO will have to be added to the next unpublished roster period.
Example A:
Ground duty finishes latest at 22.00 local time – the RBO is not required before the Off- Day block:
Roster is indicated in UTC.
Example B:
Ground duty finishes after 22.00 local time – the RBO is required before the Off- Day block:
Roster is indicated in UTC.
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.
In this issue of our series “Know your CWA” we take a closer look at “Standby (SBY)” and “Reserve (RES)”. The CWA distinguishes between:
• Home Base Airport Standby
• Standby other than airport standby and
• Reserve
B1-36.7 Standby
B1-36.7.1 Home Base Airport standby
The following applies to Pilots on airport standby:
Limitation for airport standby in addition to any other standby will be 3 times per year and no more than 2 consecutive days.
B1-36.7.2 Standby other than airport standby
The following applies to Pilots on standby other than airport standby:
Pilots may be scheduled for standby duties as per B1-36.7.2 above for minimum 1 day and maximum 4 days consecutively for no more than 5 times per calendar year. A Pilot cannot be scheduled for more than 7 standby days in a roster period.
Let’s have a look at the definitions first:
Standby is defined in Part III of the CWA as “Means a pre-notified and defined period of time during which a Pilot is required by the Company to be available to receive an assignment for a flight, positioning or other duty without an intervening rest period, as follows:
(a) “Airport Standby” means a standby performed at the airport or any other location defined by the Company with the exception of Standby away from Home Base
(b) “Other Standby” means a standby either at home or in a suitable accommodation.”
Reserve is defined as “Means a period of time during which a Pilot is required by the operator to be available to receive an assignment for an FDP, positioning or other duty notified at least 18 hours in advance.”
Accommodation is defined as “Means, for the purpose of standby and split duty, a quiet and comfortable place not open to the public with the ability to control light and temperature, equipped with adequate furniture that provides a Pilot with the possibility to sleep, with enough capacity to accommodate all Pilots present at the same time and with access to food and drink.”
Suitable Accommodation is defined as “Means, for the purpose of standby, split duty, and rest, a separate Hotel room for each Pilot located in a quiet environment and equipped with a bed, which is sufficiently ventilated, has a device for regulating temperature and light intensity, and access to food and drink.“
It can be summarized, that in case of Home Base Airport standby:
Standby other than airport standby can be summarized as follows:
Please refer to the previously distributed issue of this series “When do I need to be contactable” for more details regarding when you have to be reachable. This issue, like all other issues, is also available at www.alpl.lu.
B1-36.8 Reserve
B1-36.8.1 The following provisions apply to Pilots assigned to reserve duties:
Pilots may be scheduled for reserve duty on days which are unschedulable or in lieu of a duty from which the pilot is de-assigned.
Reserve 1 is scheduled from 06:00 to 14:00 CET
Reserve 2 is scheduled from 12:00 to 20:00 CET
Reserve 3 is scheduled from 16:00 to 24:00 CET
Reserve in a roster implies that a reserve period, which does not result in a duty period, may not be retrospectively considered as part of a recurrent extended recovery rest period.
During Reserve, a minimum of 8 hours per day is counted towards the Pilot credit time limit. The minimum time between notification during a reserve duty and start of the duty notified is 18 hours.
In case of Reserve, the following is applicable:
Please refer to the previously distributed issue of this series “When do I need to be contactable” for details regarding when you have to be contactable during Reserve (RES), which is also available on www.alpl.lu.
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.
Please find below an update on Rostering, CWA, Back to Back (B2B) rotations and the Vacation bidding process.
Rostering
Most of you certainly do experience the effects of the disruptive rostering which has not abated since the high season began in September 2016. With the imminent high season in 2017 approaching and still not having enough crews to cover the flights, the impact on fatigue will potentially cause additional delays due to the requirement for you as crew to have additional recovery time.
We ask you to assess every FDP in regards to fatigue and once again would like to remind you that every pilot suffering or potentially suffering from fatigue must file a Fatigue Report whether it is reactive or proactive.
Proactive fatigue reports should be written if you advise crew control that you need additional rest due to delays or changes in rotations that are disruptive that may potentially impact your next duty or series of duties. If you need guidance, please send an email to cvboard@alpl.lu.
If you do send a delay request to crewcontrol@cargolux.com, please copy in the station, which you are departing from; e.g. IAH, iahops@cargolux.com and opscrtl@cargolux.com (Dispatch) so they are able to coordinate.
Please use the iQSMS or the LEAF applications to submit reports, both are provided on your iPad. When entering the data be as accurate and as complete as possible. You can click here for additional guidance.
Furthermore it is according to OM-A Chapter 11, Section 2 mandatory to submit an ASR if the fatigue you experienced impacted or could have potentially impacted your ability to perform your flight duties safely.
CWA
You might also have recognized the launch of the second edition of our series “Know your CWA” in June. The intention of this series is to make you familiar with your CWA and to give you a better understanding of the most important articles in this document.
Knowing the content and limitations herein certainly will help you to be aware of your rights and obligations and also when checking your roster for compliance. After all, the CWA is one tool to protect your health and a guideline for you when duties or rest periods are scheduled in a questionable way. Use it!
Back to Back (B2B) Rotations
The recent email from the Chief Pilot’s Office on “Clarification on back to back rotations” has not clarified the situation. If the authority has confirmed that Cargolux Flight operations is compliant with the regulations, the minimum that we could expect is this information is made transparent.
Knowing that the DAC-L is the authority in Luxembourg that oversees the regulations, we can only assume that a letter or call to EASA has or has not been made, which ultimately delays the correct application of the B2B.
As the ALPL, our request for clarification has still not been answered. You can draw your own conclusions why this has not happened.
Please see attached our guidelines. If you have been confronted with B2B, which has not been planned in advance email us on cvboard@alpl.lu so we can provide you with further assistance.
Vacation Bidding
The vacation bidding was launched a little later than normal as all stakeholders were finalizing the documents. In general only minor changes in the two step bidding process were made such as increasing the first round to 25 days, you can bid as low as 3 vacation block days, and that each pilot can maintain 5 vacation days in a ‘pool’ if they wish for an indefinite period of time.
After the unilateral allocation of outstanding vacation days, which occurred in January this year, it became obvious that a procedure to reduce outstanding vacation days is necessary to handle it correctly.
There a some pilots who are owed vacation days and this will be reduced to a maximum of 5 days over the next 5 years. Again, only by mutual consent.
The deadline for the first round of the vacation bidding is on 01 September 2017.
In part 11 of our series “Know your CWA” we would like to expand on when a pilot has to be contactable as per CWA.
According to the CWA a pilot must only be reachable during Standby (SBY) and Reserve (RES) as defined in CWA Art. B1-36.7 and B1-36.8 respectively.
In addition the CWA contains an article, CWA B1-37.4, which requires the pilot to check his or her roster for changes during certain times.
During all other times a pilot is not required to be contactable. It is solely up to the pilot to decide if he answers a phone call, checks his company provided email account or to access AIMS eCrew, any voice mailbox for messages or if SMS text messages have been received.
B1-36.7 Standby
B1-36.7.1 Home Base Airport standby
The following applies to Pilots on airport standby:
• Airport standby shall be in the roster and the start and end time of airport standby shall be defined and notified in advance to the Pilots concerned to provide them with the opportunity to plan adequate rest.
• The maximum duration of airport standby is 8 hours.
[…]
[…]
[…]
• The Pilot has to be reachable by phone during Standby.
Limitation for airport standby in addition to any other standby will be 3 times per year and no more than 2 consecutive days.
B1-36.7.2 Standby other than airport standby
The following applies to Pilots on standby other than airport standby:
• The maximum duration of standby other than airport standby is 8 hours.
[…]
[…]
• The Pilot has to be reachable by phone during Standby.
[…]
• The exact hours that the Pilot is required to be on Standby duty will appear on his Roster.
[…]
Pilots may be scheduled for standby duties as per B1-36.7.2 above for minimum 1 day and maximum 4 days consecutively for no more than 5 times per calendar year. A Pilot cannot be scheduled for more than 7 standby days in a roster period.
According to B1-36.7 a pilot on Standby, whether during “Home Base airport standby” or “Standby other than airport standby”, must be reachable by phone during the exact hours indicated on his roster.
Outside the times indicated as SBY on this roster, the pilot has:
Example:
The following depicts a roster with a “Standby other than airport standby” as per CWA B1-36.7.2:
The pilot has to be contactable by phone on each of the indicated days between 11.00 UTC and 19.00 UTC. Outside of these hours the pilot has no obligation to be contactable.
B1-36.8 Reserve
B1-36.8.1 The following provisions apply to Pilots assigned to reserve duties:
• Reserve is the period of time during which the Pilot is required to be available and contactable to receive an assignment for an FDP, positioning or other duty. Reserve periods are indicated on the roster.
[…]
• The maximum duration of any single reserve period is 8 hours per reserve day.
[…]
[…]
Pilots may be scheduled for reserve duty on days which are unschedulable or in lieu of a duty from which the pilot is de-assigned.
Reserve 1 is scheduled from 06:00 to 14:00 CET
Reserve 2 is scheduled from 12:00 to 20:00 CET
Reserve 3 is scheduled from 16:00 to 24:00 CET
Reserve in a roster implies that a reserve period, which does not result in a duty period, may not be retrospectively considered as part of a recurrent extended recovery rest period.
During Reserve, a minimum of 8 hours per day is counted towards the Pilot credit time limit. The minimum time between notification during a reserve duty and start of the duty notified is 18 hours.
According to article B1-36.8.1 a pilot can be scheduled for 3 different Reserve Duties – RES1, RES2 or RES 3. During Reserve (RES) a pilot must be reachable only during the following times:
The pilot has no obligation to be reachable outside of these times.
Example:
The following depicts a roster with Reserve (RES) as per CWA Art. B1-36.8.1:
The pilot has to be contactable by phone on each of the indicated days between 04:00 UTC and 12:00 UTC. Outside of these hours the pilot has no obligation to be contactable.
B1-37.4 Changes to Rosters
Pilots shall inform themselves of their duty assignments between 18 and 12 hours prior to the ending of unassigned time, COD, FOD, Sickness or Vacation time period and acknowledge the assignment to crew control.
According to this article each pilot is obliged to check the roster once between 06:00 and 12:00 local time in Luxembourg for any changes to his roster during following times:
During all other times, e.g. Rest (which is assigned as indicated on the roster), the pilot has no obligation to check the roster for any changes.
We will expand in more detail on Standby and Reserve in the next issue of this series.
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.
Part of the new CWA 2015-2018 is the Pilot Off-Day Pool (CWA 5.3.1). Although already established in 2014 through a Memorandum of Understanding (MOU), it is now for the first time written in the CWA with the purpose to ensure adequate resources for Pilot Representatives and individual nominated pilots for representative work.
For 2017 our members donated 53 days. Please find below a brief update on how many days have been requested or used until now and for which purpose. It is our intention to stay transparent in what we do and to show you, that your donation is a valuable contribution, which indeed assists us in our work. Thank you for that!
In order to be able to continue to participate in working groups or committees and to have enough POD at hand in the future we would like to invite you to donate one or more of your VAC days for 2018 to the Pilot Off- Day Pool to top it up again.
Like in the past the donation of VAC days is on a voluntary basis and the details how the Pilot Off- Day Pool is managed are outlined in the “Agreed Off-Day-Pool Procedure”.
We sincerely hope that this solution is acceptable for those wishing to help, support and participate. Please do not hesitate to contact your ALPL Board at cvboard@alpl.lu in case you have any questions.
Please click on the button below in case you would like to donate.
Thank you for your participation!
In this issue of our series “Know your CWA” we expand on “Rest at Home Base” as defined in CWA B1-36.9.
From various communications you know about the different interpretations of how “Rest at Home Base with time zone difference compensation” should be applied. Currently we are preparing a law suit, which is a formal procedure to have this rule changed the way we believe it originally was intended for.
As the OM-A is accepted by the DAC-L we will use this as a reference pending the clarification.
We will focus on
B1-36.9.1 Minimum rest period and reduced rest
The required rest period before undertaking an FDP shall be in accordance with the Table B1-36.9.1-1 below.
Time zone differences are compensated by additional rest in the following cases:
Conditions for the use of reduced rest:
Note: At publication of this document Cargolux is not approved for FRM Reduced Rest!
Rest Period is defined in Part III of the CWA as “Means a continuous, uninterrupted and defined period of time, following duty or prior to duty, during which a Pilot is free of all duties, standby and reserve.”
Duty is defined as “Means any task that a Pilot performs for the Company, including flight duty, administrative work (as indicated on the Pilot’s roster), giving or receiving training and checking, Positioning, Reserve and Standby.”
Rest at Home Base without time zone difference compensation
The Minimum Rest Period at Home Base after and before any Duty Period is
Rest at Home Base with accommodation provided by Cargolux
The following graph nicely illustrates the correlation between Duty Period and Minimum Rest Period at Home Base without time zone difference compensation or in case of accommodation provided at Home Base by Cargolux.
Rest at Home Base with time zone compensation
B1-36.9.2 Rest at home base with time zone difference compensation
At home base, if a rotation involves a 4 hour time difference or more, the minimum rest is as specified in the table below.
Table B1-36.9.2-1 Minimum local nights of rest at home base to compensate for time zone differences when suitable accommodation is not provided by Cargolux.
As soon as a rotation involves a 4 hour time difference or more and no suitable accommodation is provided by Cargolux when returning to Home Base, the Minimum Rest Period with time zone compensation according to B1-36.9.2 must be applied.
The table considers the following:
Reference Time is defined in Part II of the CWA as “Means the local time at the reporting point situated in a 2-hour wide time zone band (+/- 02:00 hours) around the local time where a Pilot is acclimatised.”
The Reference Time can be determined using the table in CWA B1-36.3.
Rest at Home Base on EWWET
B1-36.9.3 Rest at home base on eastward-westward or westward-eastward transitions (EWWET)
In case of an Eastward-Westward or Westward-Eastward transition at home base, at least 3 local nights of rest at home base are provided between alternating rotations.
This article states that when a pilot is transiting through Home Base from East to West or West to East, a minimum of 3 local nights of rest must be provided.
According to EASA and DAC-L, EWWET is defined as “Eastward-Westward and Westward-Eastward transition means the transition at home base between a rotation crossing 6 or more time zones in one direction and a rotation crossing 4 or more time zones in the opposite direction”
Example A:
A pilot is scheduled to operate the flight LUX-ZAZ-LUX. Total Duty Time is 6 hours. Since there is no time zone difference between LUX and ZAZ, no time zone difference compensation is required and the Minimum Rest Period according to B1-36.9.1 is 12 hours.
Example B (B2B):
A pilot is scheduled for a B2B rotation. He returns to LUX from JFK and is supposed to stay in the hotel at Home Base. The total Duty Time is 10:30 hours and the crew crosses more than 4 time zones. Thus, the Minimum Rest Period with suitable accommodation provided by Cargolux is 14 hours.
Example C:
A pilot operates LUX (UTC+2) – GYD (UTC+4) on day 1. On the next day he operates GYD (UTC+4) – PVG (UTC+8), crossing for the first time 4 time zones. Reporting Time is 04:00 UTC. On day 3 he operates PVG – OVB (UTC+7), takes a Rest Period and continues back to LUX, where he arrives at 06:00 UTC on day 5. During the trip his Reference time changes from LUX to GYD and thereafter to OVB. According to B1-36.9.2 the biggest time difference between Reference Time and the local time where the pilot rests during the rotation is 5 hours – the difference between OVB (UTC+7) and LUX (UTC+2). Time elapsed since reporting for the first FDP involving 4 hours time difference is 74:30 hours (GYD 04:00 UTC on day 2 until LUX 06:30 UTC on day 5). Thus, according to B1-36.9.2 the Minimum Rest Period for time zone difference compensation is 3 local nights.
Example D (EWWET):
A pilot operates a rotation all the way to HKG and back to LUX. In this rotation, he crosses 6 time zones to the East [LUX (UTC+2)/HKG (UTC+8)]. Due to the nature of his trip he would only need a Minimum Rest Period for time zone compensation according to B1-36.9.2 of 2 local nights. However, his next Duty is a flight from LUX (UTC+2) to JFK (UTC-4). Because he did already cross 6 time zones on his last rotation and is scheduled to cross again 6 time zones to the West, the Minimum Rest Period is 3 local nights according to B1-36.9.3.
But what if the Rest Time at Home Base is scheduled to be shorter than stated in the CWA?
In this case it is the obligation of the company to change the roster accordingly to comply with the CWA.
Please note, the intention of the rest at Home Base is to have a pilot acclimatised at Home Base in order that he/she is rested for the next duty or series of duties.
If pilots feel that they are not acclimatised at the Home Base before the next duties then they should extend their 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.
In this part of our series “Know your CWA” we would like to expand on “Minimum Rest Periods” as defined in B1- 36.9. The focus lays on:
B1-36.9.1 Minimum rest period and reduced rest
The required rest period before undertaking an FDP shall be in accordance with the Table B1-36.9.1-1 below.
Time zone differences are compensated by additional rest in the following cases:
Conditions for the use of reduced rest:
Rest Period is defined in Part III of the CWA as “Means a continuous, uninterrupted and defined period of time, following duty or prior to duty, during which a Pilot is free of all duties, standby and reserve.”
Duty is defined as “Means any task that a Pilot performs for the Company, including flight duty, administrative work (as indicated on the Pilot’s roster), giving or receiving training and checking, Positioning, Reserve and Standby.”
Suitable Accommodation is defined as “Means, for the purpose of standby, split duty, and rest, a separate Hotel room for each Pilot located in a quiet environment and equipped with a bed, which is sufficiently ventilated, has a device for regulating temperature and light intensity, and access to food and drink.“
It can be summarized that away from Home Base (LUX) the
The following graph nicely illustrates the correlation between Duty Period and Minimum Rest Period away from Home Base.
B1-36.9.4 Recurrent extended recovery rest periods
The minimum recurrent extended recovery rest period shall be 36 hours, including 2 local nights, and in any case the time between the end of one recurrent extended recovery rest period and the start of the next extended recovery rest period shall not be more than 168 hours.
The recurrent extended recovery rest period shall be increased to 2 local days twice every month.
Extended recovery rest periods may be scheduled concurrently with rest requirements for time zone difference compensation.
Recurrent extended recovery rest periods shall be planned and crew members notified sufficiently in advance.
This article states that the minimum recurrent recovery rest period must be a minimum of 36 hours, including 2 local nights. Furthermore, not more than 168 hours shall be between the end of one recurrent extended recovery rest period and the start of the next one.
Additionally, the recurrent extended recovery rest period must be increased to 2 local days twice every month and may be scheduled concurrently with rest requirements for time zone compensation.
B1-36.9.5 Increased rest requirements due to disruptive schedules
For a crew member performing 4 or more night duties, early starts or late finishes between 2 extended recovery rest periods, the second extended recovery rest period is extended to 60 hours. Such an extended recovery rest period may be scheduled concurrently to other rest requirements including but not limited to rest required for time zone difference compensation.
When a transition at home base is planned from a late finish/night duty to an early start, the rest period between the 2 FDPs includes 1 local night.
Additional increased rest is required if a pilot performs 4 or more Night Duties, Early Starts or Late Finishes between 2 extended recovery rest periods. In such a case the second extended recovery rest period must be a minimum of 60 hours.
Disruptive Schedule is defined in OM-A Chapter 7, Section 2 as “Means a crew member´s roster which disrupts the sleep opportunity during the optimal sleep time window by comprising an FDP or a combination of FDPs which encroach, start or finish during any portion of the day or night where a crew member is acclimatised. A schedule may be disruptive due to early starts, late finishes or night duties.”
In this context the OM-A defines
Important to know: The reference for determining an Early Start, Late Finish or Night Duty is the reference time a pilot is acclimatized to according to CWA B1-36.3.
Example A:
A pilot operates a flight as part of a Standard Flight Crew. The total Duty Time is 9:40 hours and ends at 07.45 UTC. The crew only crosses 3 time zones. As per CWA B1-36.9.1 the pilot is entitled to a Rest Period of 12 hours, meaning that the earliest Reporting Time for the next Duty Period, whether operating as active crewmember or positioning, would be at 19.45 UTC.
Please note that according to OM-A Chapter 7, Section 9, a Minimum of 10 hours rest at the hotel must be achieved in order to have an 8 hour sleep opportunity.
Example B:
A pilot operates a night flight as part of an Augmented Flight Crew. The total Duty Time is 12:45 hours and ends at 07:00 UTC. The crew crosses 4 time zones. As per CWA B1-36.9.1. the pilot is entitled to a Rest Period of 14 hours or as long as the previous Duty Period, if longer. The earliest possible Reporting Time for the next Duty would be at 21:00 UTC.
Example C:
A pilot positions from LUX to HKG resulting in a Duty Period of 18:45 hours ending at 04:45 UTC. The pilot is entitled to a Rest Period of 18:45 hours. The earliest Reporting Time for the next Duty would be at 23:30 UTC.
Example D:
A pilot is scheduled for a trip, which departs LUX on day 1 at 11:00 UTC and is supposed to come back on day 7 at 04:00 UTC. Time between reporting for duty at 10:00 UTC on day 1 and going off duty on day 7 at 04:30 UTC is 162:30 hours. During this rotation, the longest scheduled rest period is 32 hours. Due to delays and changes, the pilot departs late from CGO to OVB and is planned to continue to LUX on the same flight. ETA in LUX would be 12:00 UTC on day 7, resulting in more than 168 hours since the end of his last extended recovery rest period. As per CWA and the OM-A, the pilot must take a rest period in OVB and is not allowed to continue to LUX. Because he had a disruptive schedule with 4 night duties, early starts and late finishes, the rest period in OVB must be increased from the minimum of 36 hours and 2 local nights to 60 hours minimum.
But what if your Rest Time is less than what you are entitled to?
Then it is the obligation of the company to change your roster accordingly.
Even though these are the minimums the regulations state, a pilot may increase the Minimum Rest Periods in order to mitigate potential fatigue in the next duty or series of duties.
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.
