I've been out of touch for a while with the blog on automatic, but I've returned just in time to read Syrad's question and it's important enough to merit an entry in reply, rather than an extended comment. There are lots of people who don't read the comments. (They probably think they are like normal blog comments, but Cockpit Conversation readers are brilliant, so those that skip the comments are missing out). To recap for them, after I described my extended duty day, airline pilot Syrad asked:
Rest regulations and their current shortcomings are a big issue for me. I fly under 121 in the States, where the regulations say that we have to have at minimum eight hours of rest. However, that clock starts ticking fifteen minutes after we set the brake regardless of where we are. After deplaning passengers, doing postflight walkarounds, and shutting down the airplane we're rarely out of the airport by then. Our clock goes until our show time, which the company can reduce to thirty minutes before departure.
Essentially, this means that all the time we spend waiting for the hotel van/car service, travelling to and from the hotel, and checking in are part of our eight hours of rest. At my company we rarely only have minimum rest, but when we do it's common to only get five hours of actual sleep. Obviously these all come after long and hard days, because something unusual and annoying is happening at work if we're so delayed we're down to minimum rest. I hate doing min rest overnights, and I am frustrated that they're legal for us to do even though there has been copious research showing the wide-reaching consequences of not getting enough sleep. Research has shown that 97% of the adult population needs somewhere between seven and nine hours of sleep to be fully rested. Current regulations ensure that a US airline crew on a minimum rest overnight is not getting anywhere near the amount of sleep needed to be fully rested.
With your operation, how does rest work? Obviously you have control over many things that airline crews don't have, so do you calculate the start of your rest time as when you walk in the hotel door and the end as when you leave the hotel? Or do you work it some other way? I'm curious because I believe that eight hours "behind the door" (at the hotel) is the absolute minimum that should be allowed. I'm also not a fan of sixteen hour duty days, which are legal for us. Fortunately they don't happen much, either, because I don't know many people who are still completely safe to operate an aircraft after sixteen straight hours of work.
The information in Syrad's question stunned me a little. I well know that the US border separates me from a country with its own laws, culture and tradition, but we use the same species of H. sapiens to operate the same kinds of airplanes on much the same kinds of routes. I know Canadian regulators look at research and changes in regulations in other similar countries, such as the US and Australia, and Transport Canada prides itself on being proactive in improving safety. For many regulations the wording is almost identical in the FARs (US Federal Aviation Regulations) and the CARs (Canadian Aviation Regulations). I'd expect the FAA to do the same thing. They must know about the big ugly loophole that leaves Syrad and her colleagues sleep deprived. Odd that they let it remain.
In Canada the CARs definitions, explain what is meant by "minimum rest period."
"minimum rest period" - means a period during which a flight crew member is free from all duties, is not interrupted by the air operator or private operator, and is provided with an opportunity to obtain not less than eight consecutive hours of sleep in suitable accommodation, time to travel to and from that accommodation and time for personal hygiene and meals.
That is, my duty day clock stops at shut down (it would end fifteen minutes later were I an airline pilot), so if I kill the engines at the last minute of my duty day, but then spend an hour unloading baggage and negotiating with the FBO for a tow into the hangar, I am still legal, but my rest clock doesn't start until I have been fed, transported to the hotel and had a shower, and I must be allowed opportunity to sleep for eight hours before I have to get up and get ready for the next day. My chief pilot says that to accomplish that, it should usually be ten hours between walking away from the parked airplane and being required to get back in.
The start of the next duty day is a little less defined. If you work for an airline it is at report, so the ride in the hotel van is on your own time, but the ride in the hotel van has to start after that opportunity for eight hours sleep. Your employer may define it for you, e.g. if you work for Transport Canada, your duty day starts when you leave your house in the morning. I start mine when I meet the client in the lobby to discuss the day's work.
On the flip side, the law also requires me to use the eight hours to sleep. I would be breaking a federal law if I party, go sightseeing, or otherwise fail to use eight hours of my rest period to sleep.
The law also defines where the company can dump me for my rest period.
"suitable accommodation" - means a single-occupancy bedroom that is subject to a minimal level of noise, is well ventilated and has facilities to control the levels of temperature and light or, where such a bedroom is not available, an accommodation that is suitable for the site and season, is subject to a minimal level of noise and provides adequate comfort and protection from the elements.
I'm thinking that part was written by someone who had lived in northern pilot accommodations. There are lots of ways to abuse a pilot.