Narrative:

I am a pilot for a commuter airline. When I serve as a 'reserve' or 'standby' pilot, my duty period is from XA00 to XX00. If I do not have a flight assignment, my mgrs state that I am on a rest period. I can be called at any time during my reserve or standby status, and must respond for flight duty in a timely manner, usually within 2 hours. No rest period exists. Far's provide outlines for rest and flight time limitations. Although flight time limitations are adhered to, the same cannot be said for rest periods. The FAA's consistent interpretation of reserve or standby falls within the definition of duty, in the context of rest period regulations. The FAA has defined duty as: '..either actual work for an air carrier or present responsibility for work should the occasion arise.' under this interpretation, no time during which a pilot is on reserve or standby duty could be considered 'rest'. Additionally, an associate FAA administrator and legal council are aware of those violations existing, but have elected not to take action. Only to survey and evaluate the situation. Flight mgrs working for my carrier are aware of the rules and present interps regarding rest periods. They are also aware that the FAA is taking no action. Usually, a reserve or standby status is an assigned period of from 2 to 6 consecutive days. Normal fatigue and stress induced fatigue due to this type of assignment is unsafe. The threat of job security and loss of pay is management's motivator. My job is in jeopardy if I elect not to fly when fatigued as a reserve or standby pilot. The public's safety is being ignored by my carrier's mgrs and the FAA. The burden to preserve safety rests totally on me alone. 'Help.'

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Original NASA ASRS Text

Title: FLT TIME, DUTY TIME, REST TIME COMPLAINT.

Narrative: I AM A PLT FOR A COMMUTER AIRLINE. WHEN I SERVE AS A 'RESERVE' OR 'STANDBY' PLT, MY DUTY PERIOD IS FROM XA00 TO XX00. IF I DO NOT HAVE A FLT ASSIGNMENT, MY MGRS STATE THAT I AM ON A REST PERIOD. I CAN BE CALLED AT ANY TIME DURING MY RESERVE OR STANDBY STATUS, AND MUST RESPOND FOR FLT DUTY IN A TIMELY MANNER, USUALLY WITHIN 2 HRS. NO REST PERIOD EXISTS. FAR'S PROVIDE OUTLINES FOR REST AND FLT TIME LIMITATIONS. ALTHOUGH FLT TIME LIMITATIONS ARE ADHERED TO, THE SAME CANNOT BE SAID FOR REST PERIODS. THE FAA'S CONSISTENT INTERP OF RESERVE OR STANDBY FALLS WITHIN THE DEFINITION OF DUTY, IN THE CONTEXT OF REST PERIOD REGULATIONS. THE FAA HAS DEFINED DUTY AS: '..EITHER ACTUAL WORK FOR AN ACR OR PRESENT RESPONSIBILITY FOR WORK SHOULD THE OCCASION ARISE.' UNDER THIS INTERP, NO TIME DURING WHICH A PLT IS ON RESERVE OR STANDBY DUTY COULD BE CONSIDERED 'REST'. ADDITIONALLY, AN ASSOCIATE FAA ADMINISTRATOR AND LEGAL COUNCIL ARE AWARE OF THOSE VIOLATIONS EXISTING, BUT HAVE ELECTED NOT TO TAKE ACTION. ONLY TO SURVEY AND EVALUATE THE SIT. FLT MGRS WORKING FOR MY CARRIER ARE AWARE OF THE RULES AND PRESENT INTERPS REGARDING REST PERIODS. THEY ARE ALSO AWARE THAT THE FAA IS TAKING NO ACTION. USUALLY, A RESERVE OR STANDBY STATUS IS AN ASSIGNED PERIOD OF FROM 2 TO 6 CONSECUTIVE DAYS. NORMAL FATIGUE AND STRESS INDUCED FATIGUE DUE TO THIS TYPE OF ASSIGNMENT IS UNSAFE. THE THREAT OF JOB SECURITY AND LOSS OF PAY IS MGMNT'S MOTIVATOR. MY JOB IS IN JEOPARDY IF I ELECT NOT TO FLY WHEN FATIGUED AS A RESERVE OR STANDBY PLT. THE PUBLIC'S SAFETY IS BEING IGNORED BY MY CARRIER'S MGRS AND THE FAA. THE BURDEN TO PRESERVE SAFETY RESTS TOTALLY ON ME ALONE. 'HELP.'

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.