Required Rest for Offshore Pilots

[reis0056]

Hello again,

 

I come with another question for an upcoming interview with an offshore company. Can someone please put the required rest times of FAR 135.265 and 135.267 into normal language. I have read, and re-read those parts, but I still don't get it. I guess I'm just dense lol. Also, is offshore work considered scheduled or unscheduled work?, does it depend on the company? Thanks so much to whoever can decipher the code that is the FARs.

[nbit]

OK.... Let's crack one egg at a time. First off, are your operations scheduled? Meaning - Do they operate like a commuter airline where all the flights are pre-arranged, or is it like an air-taxi service, meaning the flights are demanded by the customers on an as needed basis... That is how the terms scheduled and unscheduled are intended to be defined.

I am familiar with the unscheduled operations, and they do vary slightly from company to company interpretation, so I may be able to help a bit if that is the case...

Once the unsheduled 135.267 is understood, I would think you could decipher the 135.265 fairly easily...

When is your test again?

[reis0056]

nbit,

 

Thank you so much for posting on both my topics, people like you make these forums priceless. Anyways I don't know if Era does scheduled or unscheduled work. Would you mind explaining 135.267 briefly, at least that will provide a little guidance. Thanks again.

[nbit]

To make things easier, do what I have described below.

 

Make the 2 items described below, get a ruler and a pencil, and I will walk you through it (what I think is) a fairly easy way.

 

1) Make a graph formed by squares or rectangles on a sheet of paper or a spreadsheet seven rows high and 24 columns wide. Label each column '1'-'24' for the hours in a day. This is local time, not zulu. Add an twenty-fifth column, seperate of the others, off to the right hand side. Add a blank or cell below the twenty-fifth column in order to total the seven rows of that column. Put another cell or blank area below everything in the center. Label each of the rows off to the left hand side 'Monday' thru 'Sunday' with the numbered day of the month for each. Great, you have just made an unscheduled, part 135 weekly time sheet. If you made a speadsheet on your computer, you will need to print this, you can't do what is needed on the computer sad to say. Make one of these sheets for each week of the month.

 

2) Make another sheet. This will have 12 rows, three columns... Label the rows on the left column with each calendar month of the entire year. Above the center column, label that 'rest periods', and last column, label that 'hours flown'

 

Once you made those two types of items (one yearly sheet and enough weekly sheets to cover a month), here is how rest and crew duty works for unscheduled part 135...

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For unscheduled...

Basically, on a 2-person crew, part 135, you may work a 14 hour day e.g. - If you started flying at 2am, you may fly part 135 to 4pm, as long as that is not more than 10 hours of total part 135 flight time in that period. There is a very important distinction to make between part 135 and part 91 here.. When you have passengers or freight for hire, that is part 135. Otherwise, it is part 91.. Make sense?

But... Here's where it gets interesting... There are *no* time limits on part 91. If you started a part 135 or 91 flight at 2am for your certificate holder, your last part 135 flight must land by 4pm, 14 hours later, (unless there are "unforseen circumstances"). Now, after your last 135 flight of the cycle landed, you may fly part 91 for any length of time you needed to get home, as long as you have no passengers or freight on board for hire. Let's say that your part 91 leg you flew to get home ended at 6pm... The time which that part 91 flight ended, 6pm, will initiate the start of your crew rest. You cannot fly again with the intent of flight for hire under your operator's 135 certificate until 10 hours later, i.e., 4am the next day.

Make sense?

 

Here's the kicker... The part 91 time to get you home counts against your crew rest, but *not* against your duty time, which concluded at the end of your last part 135 leg. But also, part 91 flights can start your 14 hour duty cycle, in which all the part 135 time (a maximum of 10 hours per duty cycle) must be completed (barring "unforseen circumstances"). There are no time limits for amounts of part 91 time flown, and that is what makes this possible.

Because of this principle, you may have to also hang around on a rig if you haven't burned up much of your 14 hour duty cycle. Your dispatcher, if they care about company profits, may hold you there as he/she tries to find ways for you to burn up as much of the the 14 hour period and 10 hours of profiting 135 time as possible

 

Don't go on unless you understand above, or you may be more confused...

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On the weekly time sheets I described, mark lines horizontally, leaving room for another set of horizontal lines. These lines represent the flight time from when a flight starts to when a flight ends. Label each leg '135' or '91' appropiately above the line, and also put the length of the leg in flight time under the line. Remember that the last 135 flight must end (barring "unforseen circumstances") before 14 hours from the time your flight time initiated (this is true whether the first flight of the day was part 91 or part 135, because it initiated your daily duty time). These lines may be interspersed with any connecting 91 flights in that 14 hour time window. You may fly a part 91 flight for a theoretically limitless time to finish up get home, relocate, etc... Put another horizontal line, under those lines that represented individual legs of part 91 or 135 flight, that line represents the time from which your flying started for that duty cycle started to the time that all flying ceased for the duty cycle. These sheets allow you to graphically picture several 24 hour time periods (i.e.: up to 14 hours duty time + 10 hours rest) during a calendar week...

 

Make up some flights for the week using the principals that outline "legal flights" I described above. Tally up your daily time totals in the 25th column and total every row in that 25th column for the week.

(Some duty cycles could cut through midnight, that is OK)

 

Now, let us suppose you have flown all week... Maybe a day or two, you didn't fly at all. The bottom of the weekly time sheet, I described a blank cell at the bottom center... Label that 'rest periods'.

 

Tally up all the time periods in which you had 24 consecutive hours rest on that weekly time sheet. They should be easy to pick out. Put the number of those periods in the area labeled "rest periods".

Now, imagine you have a bunch of these time sheets for a month, a quarter, consecutive quarters, and a half a year, and ... Read 135.267(a)(1), 135.267(a)(2), 135.267(a)(3), and 135.267(f) and look at the yearly time sheet and a light bulb should come on quickly if you understood everything else...

 

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I used the term, "unforseen circumstances" several times above. This was to account for the conditions outlined in 135.267(e), which amend your crew rest if you "accidently" bust your 135 time limit (10 hours for a crew of two), and you should easily be able to conceive how to apply what is outlined there, if you understand everything else here...

[reis0056]

Thanks again for the post. I understand everything you told me in the last post. However if you look at 135.267 © it states you can fly more than 10 hrs? How is this possible? More rest? If you are sick of posting here I can ask them during the interview. Thanks again.

[nbit]

Thanks again for the post. I understand everything you told me in the last post. However if you look at 135.267 © it states you can fly more than 10 hrs? How is this possible? More rest? If you are sick of posting here I can ask them during the interview. Thanks again.

 

You may exceed 10 hours flight time if you were "assigned" no more than 10 hours during a 14 hour period... "assigned" is the key word... Things unexpected happen... I was maybe being too stringent using words like "must" where the 10 hours of 135 time is concerned...

 

Remember, they talk about different types of flying, "assigned flying", "commercial flying", and it also may be implied that non-commercial flying may take place. Some of this is open to interpretation.

 

In 135.267( b ) it says "the total flight time of the assigned flight when added to any other commercial flying may not exceed 10 hours"... The words "assigned flight" are the key... The word "assigned" in a sense may also mean that it was planned before you started flying. e.g.- The assigned flight was supposed to take 10 hours and actually took 11 hrs. The company I flew with allowed us to fly past our 14 hour duty period to return home. Their stand was that it was not commercial flying and it was not assigned, because our crew was given a choice as to fly home, and we had no duty responsibilities, and we were not paid for that flying. The company would not include that time in our rest period either, and would give us 10 hours of rest (real rest) before a new flight could be assigned. You could take the definition of a "rest period" in 135.273(a) and claim that our flight home was rest... It is another area open to interpretation.

 

If the 24 hour period from the beginning of the first assigned flight included a follow on 10 consecutive hour rest period, or the rest periods described in 135.267(e) were required and taken into account, if they apply, it is legal.

 

It sounds like you have a pretty good handle on things if you caught the fact that 10 hours of 135 may be exceeded.

 

Yes... One could type a lot here about the interpretations!

My fingers are a little tired, but hopefully it helped...

[gmsemel]

Starting to pull your hair out are we? Thats ok, till you start using the reg on a day by day basis its a little hard to understand. First off ERA and all the rest of the Gulf Operator operate Unscheduled. Most all of them will asign you to a duty day. this cuts down on confusion and errors.

 

Ok now then as to your question can you fly over 10 hours in a two pilot operation and not break the rules. Yes you can. But you pay a price for it if you will: You fly more than 10 hours but less than 10.5 hours ok, you add another hour to your rest period, you have to now show 11 hours of rest. If you go more that 10.5 hours but less than 11 hours you need to add another hour of rest, you are now up to 12 hours of rest, if by chance you go over that by an hour in other words if you exceed your 10 hours of flight time by more than one hour you now need to have 16 hours of rest before you can go on duty. In simple terms when you exceed your 10 hours of flight time, you pretty much are going to get the next day off. The Idea is not to go over, it cost you in time that you will have aviable the next day. In other words don't go over your time.

 

Just remember that a day is 24 hours that start at 0001 and ends at 2359. You must show enough rest in the preceeding 24 hours, from the time you compleat your duty day! This is one of the reasons you will be assigned a duty day time ie 0600 to 2000. Its just plain easier to keep track that way. Rest means rest, not doing all kinds of work related things, thou that will happen. Most of the time your work day will start and end and will leave an hour or two for the work related things like paper work and washing the aircraft etc.

 

All you have to remember is that in 24 hours you can be on duty 14 hours in that 14 hours you can fly 10 two pilots or 8 single pilot, and 10 hours rest. Then the other part of the rule kicks in the 1400 hours a year flight time 800 hours in a half a year and 500 hours in a quarter, and 13 days off a quarter. It so happens that there is 13 weeks in a quarter, so need per regulation one day off a week. Now you could fly the full quarter, some companies are so short that you could do this, and then take 13 days off and do it again. But you could run out of time before the year is over, so not only do you need to keep track of your flight and rest times per day, you also need to keep track of how much flight time you have left as the year goes by. Remember All commercial flying counts toward that 1400 800 and 500. Taking a second job, could put you over before the year is finished. You don't want to be sitting in November timed out, this dose not happen much on a 7/7 or 14 /14, but is sure could if you are doing a lot of fly overs. Once you get in a few weeks it will be easy enough to keep straight.

 

Don't over think this, they know that you don't have any previous 135 experience, but they might ask you about flight and duty time with regard to flight instruction, that is If you been a flight instructor. I would be more up on the systems and limits for the helicopter that you been flying Along with the part 61 and 91 rules you have been using.

[delorean]

The confusing part of that section is that it says you must have 10hrs rest BEFORE you report to a duty shift. It doesn't say anything about how much need afterward (because it doesn't assume you're working the next day.) So if you rest 10hrs, work 14hrs, that equals 24.

 

On that "unforeseen circumstances".....As long as your flight plan shows you landing at your destination by the 14th hour, you can take the flight. The Ops Manual may provide guidance with this--for instance, ours says add 20 minutes ground time for scene landings, 30 minutes hospital transfers. If it takes longer at either, and you bust the 14th hour, no big deal! Just file a report with the chief pilot and come back to work 10 hrs later.

 

That 10-hours rest starts after the end of the part 91 leg back to base. Keep in mind that you CAN have passengers or freight on board, as long as they are not for hire. This means, YOUR company's employees or company owned freight. For EMS, that would be your med crew.

[67november]

WOW this place can be better than a classroom.

 

thanks for the lesson

[reis0056]

Yes, I totally agree, the people that post on this forum are fantastic. Thanks for all your help, I now know the required rest period for on demand 135. Thanks guys and gals.

[Gomer Pylot]

You have to have 10 hours of rest in the past 24, regardless of flight time. You can't continue on duty for more than 14 hours unless there are unforeseen circumstances beyond your AND your employer's control, and if you do, then you have to have 10 consecutive hours of uninterrupted rest before you can sign back in for duty.

 

The flight time only comes into play when you fly more than 8 hours in one duty period if any time at all was as a single pilot, or 10 hours if it was all dual pilot. ALL commercial flying counts, no matter under which part it was done. Part 91, Part 135, Part 133, Part 121, it's all the same. If you fly more than the allowed time, then you have to prove that you didn't exceed the allowed time at any time during the past 24, also known as the 'rolling clock'. That means 24 hours IS NOT from 0000 to 2359; you must, at any given time, be able to look back for 24 consecutive hours and not exceed the maximum flight time. This is a PITA, and I've known people to lie about flight time (a little) just to not have to fill out the required forms. You also have to have more than the 10 hours of rest before coming back on duty. Read the FARs.

 

As a rule, you have to have 10 hours of rest, no matter what, and don't have to worry much about anything else. If you exceed your 14 hours of duty time, you just have to get 10 hours of rest before signing back in. Most GOM operators don't even take notice of Part 91, insisting that everything be done as if Part 135 applied, which makes everything easier.