Cargo Flight/Duty

Cargo Flight and Duty Regulation

As a result of Colgan Air 3407, the FAA established new flight and duty regulations for the airlines, effectively raising the industry standards. More stringent rest regulations along with increased pre-ATP flight time laws were implemented in what some feel was a knee-jerk reaction to the Colgan tragedy and all of its preceding factors (PNGLC). Effective January 2014, pilots are now required to sign a document affirming they are “fit for duty” (Houston). Additionally, the definitions of acceptable Flight Duty periods were adjusted based on number of legs per day and start-time of assigned flights (Houston). Flight hours are now limited per week, month, and per year, when previously they were only limited by day and year (Houston).  Additionally, pilots must be granted a 10 hour rest period with reasonable space for 8 hours of uninterrupted sleep per rest period (Houston). Previously, the legislation only required 9 hours of rest, with potential for a decrease to 8 hours per rest period (Houston).  Lastly, the overall allowable flight time per airline pilot per day is 9 hours, 8 hours at night (Houston).

Cargo carrier operators are exempt from the Part 117 rules. The current flight and duty limitations for cargo carriers remain the same as pre-Colgan standards for both airlines and cargo carriers. As it stands today, cargo carriers are allowed and “encouraged” to “opt-in” voluntarily to compliance with new Part 117 regulations Flight/Duty standards (FAA).

It is likely that cargo carriers were specifically exempt from this ruling because of the unreasonable reality of requiring freight dogs infamous for flying long late hours, especially at night, to take a structurally-critical hit and cut back their flight hours.

It is vastly more cost efficient to a cargo carrier to operate without Part 117 rest rules because it requires fewer pilots overall and maximizes the available workforce.

However, there is backlash from both sides. Airline (and cargo) pilots may find it hypocritical of the Administrator to remain lax on one type of operations safety standards in regards to flight/duty requirements.

An article published by an airline pilot organization (CAPA) asks:

Would you have separate fatigue rules or drinking and driving rules for school bus drivers and tractor trailer operators sharing the same roadways?  Would it make sense to allow a truck driver to drive while impaired by fatigue on the same highway as a school bus driving children home from school and jeopardizing their safety?  

The question of public perception has likely influenced the decision making. Flying an aircraft full of product is not the same as an aircraft full of people. Nevertheless, cargo carriers are operating in the same sky with passenger planes. CAPA continues, “[why] allow cargo pilots potentially impaired by fatigue to operate in the same skies as a passenger aircraft putting the flying public at risk”. The financial cost to cargo operators would go up if they decided to implement Part 117: ”the estimated cost of the FAA rule in the passenger pilot realm of the industry is $297 million”(PNGLC).

I believe cargo carriers should remain exempt for the new rules because of the effect it could have on the economic effect compliance could have on the industry. If cargo carriers were to adopt these new rules my career could potentially be affected in the long-term. I have held an interest in cargo operations for a while and am open to that potential avenue in my career. Overall, if flight and duty time standards are raised in the cargo world it would likely result in shorter flights for me, fewer flight hour options per day/week/month, and more sleep at night. If these changes occur they will likely already be in place by the time a cargo flying job is an option for me and I will not be massively affected.

References

CAPA: Coalition of Airline Pilots Associations. (n.d.). Cargo Carve-Out. [online] Available at: https://www.capapilots.org/legislative-issues/cargo-carve-out/ [Accessed 2 Feb. 2018].

Federal Aviation Administration (2015). Clarification of Flight, Duty, and Rest Requirements. [online] Federal Register. Available at: https://www.federalregister.gov/documents/2013/03/05/2013-05083/clarification-of-flight-duty-and-rest-requirements [Accessed 1 Feb. 2018].

Houston, S. (2018). Learn About the FAA's Final Rule for Pilot Duty and Rest Requirements. [online] The Balance. Available at: https://www.thebalance.com/faa-final-rule-pilot-duty-and-rest-requirements-282927 [Accessed 2 Feb. 2018].

Pnglc.com. (2013). Rest Requirements for Air Cargo Pilots | PNG Logistics. [online] Available at: http://pnglc.com/rest-requirements-for-air-cargo-pilots/ [Accessed 1 Feb. 2018].