Cargo Industry is Exempt from Flight/Duty Changes, should they be?

       1. As a result of the Colgan Air accident, the FAA instituted new flight and duty regulations. Summarize these new regulations and describe how they are different from the old flight and duty regulations.

I learned from my research at (Duty Limitations, n.d.) and (Department of Transportation). These new regulations are to eliminate the current distinctions between domestic, flag and supplemental passenger operations. The rule provides different requirements based on the time of the day, whether an individual is acclimated to a new time zone, and the likelihood of being able to sleep under different circumstances. This rule is to have consistency across different types of operations. This is a system approach where the carrier and pilot accept responsibility for mitigating fatigue. The new rules are to provide sufficient sleep and recovery periods. Flight crew members will be able to work longer hours during the day than during the night.

If the pilot’s first flight of the day begins between 5 a.m. and 7:59 p.m., the maximum flight time limitation is nine hours if there is only one pilot on the flight. If the first flight begins at any other time, the maximum flight time is eight hours. If there are three pilots on the flight, the limit can be extended to 13 hours, and four pilots increase the limit to 17 hours. With a single flight crew, duty limits range between nine and 14 hours. With multiple pilots, flight duty limitations are between 13 and 19 hours.

Under the old rules, rest breaks were to be at least nine hours, but unforeseen circumstances allowed airlines to reduce the breaks to eight hours. The new rules extend the minimum rest period to 10 hours with no allowable reduction. Pilots must have the opportunity to have eight hours of sleep during the rest break. The rest period does not begin until the pilot is released from duty, and it ends when he reports back for duty. The new rules also require airlines to ensure that pilots are free from duty for a minimum of 30 consecutive hours per week.The new rules limit pilots to a maximum of 60 hours of flight duty per week, defined as 168 consecutive hours. In any consecutive 28-day period, a pilot cannot exceed 290 hours, of which no more than 100 can be flight time. During 365 consecutive days, pilots cannot exceed 1,000 flight time hours. 

2.     Cargo carriers are exempt from the Part 117 rules. What are the current flight and duty limitations for cargo carriers? 

The FAA also has removed all-cargo operations from the applicability section of the new part 117 because their compliance costs significantly exceed the quantified societal benefits. All cargo carriers may choose to comply with the new part 117 but are not required to do so.


3.     Why do you feel that cargo carriers have been excluded from the new changes? Value of life? Public perception? Too much money for the carrier? Other reasons? All the above? You may find that reading the preamble of the final rule is helpful in answering this question. 

I think that the implementation of the regulations for cargo carriers would be extremely costly and restrictive to implement because of the boundaries that would prevent a smooth transition. From my research at (Wells, D.J.,2004) I found many items about cargo operations that would be huge reasons why cargo carriers have been excluded from the new changes. Cargo carriers operate 24 hours per day. The growth in global long-haul has increased dramatically to meet operational demands. Both domestic and international cargo carriers are required to cross multiple time zones, which leads heavily to fatigue. Cargo carriers have to operate with less support staff and have to spend more time and energy outside the cockpit operations, this weighs on time limitations. Another factor that is a negative for cargo carriers, is the age of the cargo fleets. The older aircraft require more maintenance and greater attention that requires more pilot focus and thus can create more pilot error when fatigued.  A significate amount of cargo flight, occurs at night, and operations that take place from midnight to 6am are more susceptible to making errors. During this time, it is more likely that errors will not be noticed, and the response to quickly and accurately rectify errors goes down. Overnight cargo crews reported headaches more than twice as often as short-haul crews. These pilots also have reported congested noses, burning eyes, and more negative effects of appetite. Not to mention, route structures and the changing destinations, decreases the safety margins afforded by route familiarization. The airports that cargo airlines serve have less supporting infrastructure, such as comfortable briefing rooms, available dining facilities, and the ease of access to crew hotels. All these factors can either increase crew workload directly, or decrease a crew’s ability to obtain adequate rest. With all these limitations, it is no wonder the cargo carriers have been excluded from the new changes. Having nonpublished operational schedules and night operations provide less opportunity for the FAA inspectors to maintain oversight of cargo operations. The manpower to oversee this type of regulation for the cargo industry may not be available, which is unfortunate.

4.     Do you believe cargo carriers should be included in the new rules? Why or why not? 

After the research on this topic, I absolutely believe that cargo carriers need these new rules more than passenger carrier pilots. There are too many odds against the cargo carriers and they are more accessible to errors do to all of the limitations the cargo carriers have to face.

In the past, I have thought about possibly flying cargo but after this project and the research on cargo pilots, I have lost all my ambition to fly cargo at all. This topic really opened my eyes to the quality of life these pilots are living, and I have no desire to pursue this line of work in the aviation industry.

5.     Finally, what would be the impact to your career if cargo carriers were to be included in these new rules- pilots, address this from a pilot perspective management address from a management perspective.

I personally feel that if cargo operations had stricter regulations and better schedules, cargo jobs would be more desirable and pilots may shift their careers into that direction, opening up more jobs in the passenger transport division of the industry. I am not sure if cargo pilots feel like their needs are getting met, but as it sits presently, based on this research, the errors based on fatigue and oversight of the complete cargo operation, seem greater than other pilots.  I do not see the drive to inspire more pilots to make cargo flight their career. In a way, I feel that cargo pilots are becoming the forgotten pilots. Cargo pilot’s lives are just as valuable as pilots of aircrafts transporting passengers. Even though the cost of implementing a better system for the cargo pilots may be difficult we should not jeopardize the safety and well-being of this category of pilots.

Department of Transportation. Retrieved February 02, 1018, from https://www.faa.gov/regulations_policies/rulemaking/recently_published/media/2120-AJ58-FinalRule.pdf
Duty Limitations of an FAA Pilot. (n.d.). Retrieved February 01, 2018, from http://work.chron.com/duty-limitations-faa-pilot-17646.html
Wells, D.J. (2004, September). Flight Time/Duty Time for Air Cargo. Retrieved February 01, 2018, from http://www2.alpa.org/alpa/DesktopModules/ViewAnnDocument.aspx