From 18 February 2016 Commercial Air Transport operators of aeroplanes will need to have transitioned to EASA Subpart FTL. Operators can transition before this date and most major airlines plan to transition by October 2015 for the start of the winter season.
Who is affected?
The regulations apply to:
- Commercial Air Transport aeroplane operators
However, the following groups are currently exempt from the regulations:
- Air taxi operators of aeroplanes of 19 seats or less
- Emergency Medical Services (EMS)
- Single pilot operations
- Helicopter operations
EASA has a number of rulemaking tasks for FTL over the next few years including air taxi operators, EMS, single pilot operations and helicopters. In the future new rules will also cover ultra long range operations and non-commercial complex operations.
What does this mean for affected operators?
They will have to introduce both new prescriptive limitations and new demonstrable processes and procedures required by the regulations. This is a significant change in requirements and regulatory approach as operators will be required to actively demonstrate how they manage fatigue.
Affected operators will need to:
- Write a new scheme that demonstrates all the requirements under the regulations.
- Develop processes and procedures, including demonstrating how they are managing their crews' fatigue levels and associated operational risks. They will have to show how they can meet these new responsibilities before they transition.
- Submit a change management plan/safety case to show that they have assessed the risks of the change and how they will manage it.
- Conduct fatigue management training with all crew members, crewing and rostering staff and management. The initial training requirement must be completed during the transition process before the operator can secure a new FTL approval.
Further guidance materials and supporting documents on FTL are available, these include:
- FTL Q&A document
- Guidance on acclimatisation
- Audit checklist
- More information on operator responsibilities
What does this mean for crew?
All crew members flying for affected operators will have to learn the new regulations, take part in fatigue management training, and be aware of their increased rights and responsibilities.
Disruptive schedules - Early/late type decision
In implementing the requirements of ARO.OPS.230 (Determination of disruptive schedules) all CAT operators under a UK issued AOC will be required to comply with the ‘late type’ definition.
Within the new regulations there are two standard variations that an operator may apply for:
- Two pilot flight duty period limits when un-acclimatised
- Reduced rest provisions
These both require an increased level of risk assessment and full Fatigue Risk Management (FRM) approval. Unless an operator already holds an FRM approval, they will not be granted one with their initial EASA Subpart FTL scheme and therefore will not initially be able to use these variations.