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FAR 117 – and Commuting.

The following comment came to this blog recently:

FAR 117 wasn’t written to accommodate commuters. Living outside your base is totally optional, it was written to work with FCM that work where they live.

Response:

While I agree that FAR 117 does not provide any firm statutory requirements as how Airlines and Flightcrew Members need to deal specifically with “Commuting”, some Airlines do have policies for “commuters”.

In the end the FCM is responsible to adhere to 117.5 Fitness for duty, where the Joint responsibility is placed upon both the Airline and FCM.

The FAA has provided “best practices” guidance in the form of an AC.

AC 117-3 (link provided)

I suggest that All crew members read the entire AC, especially sections:

10. COMMUTING STRESSES.

11. COMMUTING AND DEADHEAD TRANSPORTATION.

12. COMMUTER INDUCED FATIGUE.

13. PRE-DUTY ACTIVITIES.

14. FIT FOR DUTY–FLIGHTCREW MEMBER’S RESPONSIBILITY.

Additional guidance may come from your Airline, with respect to it’s Fatigue Risk Management Policies and/or any Guidance that may be included in any Collective Bargaining Agreement or Union Material, (ask around, someone will know).

Again, if you feel fatigued, or suspect that you may become fatigued, don’t fly, better to stand down than have an incident.

Fly Safe, Fly Smart, Fly Well Rested.

Authors Note:

I am not a pilot, I do not commute like a crew member, so I will not pretend to understand how commuting impacts each and every individual. I have great respect for the professionalism of all crew members, so the input by individuals is seriously considered. I will always attempt to side on the side of safety.

 

 

 

Welcome

Source: Welcome

Acclimatisation Under EASA FTL

Source: Acclimatisation Under EASA FTL

FAR 117.1 “Part 91 tail end ferry”

Slater – (2015) Legal Interpretation

The FAA has clarified the necessary requirements as to when a part 91 ferry flight must be considered as a FAR 117 flight, and when those conditions do not pertain to the part 91 ferry flight.

FAR 117.25 (g) “Compensatory Rest Following Time in DHD Transportation”

On September 18th, the FAA released an interpretation concerning the application of rest following Time in DHD Transportation.

Duncan, Oliver – (2015) Legal Interpretation

This interpretation differs significantly from the FAA’s previous letter of clarification:

FAA Letters of Response 05-Mar-2013

search for viii. Deadheading to find the original clarification.

FAR 117.17 – Inflight rest rest requirements for Flight crewmembers on Augmented Crews.

Nelson – (2015) Legal Interpretation

Provides guidance for requirements of inflight rest.

Recommended reading material.

The links to the follow articles should prove to be insightful, Capt. Pierson has done an excellent job in the presentation of best practices.

ProPilotWeb Articles:

How to Ensure FAR 117 Compliance

How to make your commute work for you

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