Narrative:

I also submit this report on behalf of mr X (my first officer/co-captain on this trip) and mr Y (my flight engineer during this particular trip). On a recent trip with a part 121 supplemental carrier (my first as PIC for this carrier and under these regulations); I believe my crew and I inadvertently under-rested after exceeding 24 hours of flight time in a 72 hour period (reference far part 121.521). This is my first employment within the supplemental airline ranks and I have found the flight/duty/rest regulations to be a whole new and very large pill to swallow. By my calculations; as of nov/tue/05; we had accrued 27 hours 28 mins of flight time during the previous 72 hours with legal rests; but we had triggered the necessity for 18 hours of rest following our arrival on nov/tue/05. Unfortunately; due to the pace of this trip; the irregular operations of this trip; my own and apparently crew scheduling's lack of familiarity with supplemental regulations governing us; we departed on nov/wed/05 after only a little over 14 hours of rest. Our crew scheduling department intervened in no way; shape; or form. Point of view: the rules governing supplemental operators and their employees; like all flight and duty limits; require an attorney and accountant on staff to decipher and track. At all previous airlines in my experience; we have had crew schedulers/planners that were constantly looking forward and backward using their own knowledge of the regulations and backed up with the software to flag any problem areas to ensure that no violations existed or developed. The rules currently under discussion require a flight crew member to be constantly aware of multiple rolling clocks 24/48/72 hours; not to mention the 24/7 rolling; 120/30 day rolling; the 300 in 90 day rolling; and of course the 1000 in any rolling 12 months. If you happen to conduct a domestic portion then; of course; the rules and limits change. Surely there must be a better way to ensure crew members are adequately rested without adding additional duress during the course of an already tiring trip caused by mysteriously convoluted regulations. It's as if one needs additional rest to recuperate from tracking the flight time and rest requirements. The complexity of the regulations and tracking requirements seem to defeat their own purpose.

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Original NASA ASRS Text

Title: FATIGUED B747-200 FLT CREW FOR SUPPLEMENTAL CARRIER BELIEVE THEY FAILED TO OBTAIN THE REQUIRED REST FOLLOWING AN IRREGULAR INTL OP.

Narrative: I ALSO SUBMIT THIS RPT ON BEHALF OF MR X (MY FO/CO-CAPT ON THIS TRIP) AND MR Y (MY FE DURING THIS PARTICULAR TRIP). ON A RECENT TRIP WITH A PART 121 SUPPLEMENTAL CARRIER (MY FIRST AS PIC FOR THIS CARRIER AND UNDER THESE REGS); I BELIEVE MY CREW AND I INADVERTENTLY UNDER-RESTED AFTER EXCEEDING 24 HRS OF FLT TIME IN A 72 HR PERIOD (REF FAR PART 121.521). THIS IS MY FIRST EMPLOYMENT WITHIN THE SUPPLEMENTAL AIRLINE RANKS AND I HAVE FOUND THE FLT/DUTY/REST REGS TO BE A WHOLE NEW AND VERY LARGE PILL TO SWALLOW. BY MY CALCULATIONS; AS OF NOV/TUE/05; WE HAD ACCRUED 27 HRS 28 MINS OF FLT TIME DURING THE PREVIOUS 72 HRS WITH LEGAL RESTS; BUT WE HAD TRIGGERED THE NECESSITY FOR 18 HRS OF REST FOLLOWING OUR ARR ON NOV/TUE/05. UNFORTUNATELY; DUE TO THE PACE OF THIS TRIP; THE IRREGULAR OPS OF THIS TRIP; MY OWN AND APPARENTLY CREW SCHEDULING'S LACK OF FAMILIARITY WITH SUPPLEMENTAL REGS GOVERNING US; WE DEPARTED ON NOV/WED/05 AFTER ONLY A LITTLE OVER 14 HRS OF REST. OUR CREW SCHEDULING DEPT INTERVENED IN NO WAY; SHAPE; OR FORM. POINT OF VIEW: THE RULES GOVERNING SUPPLEMENTAL OPERATORS AND THEIR EMPLOYEES; LIKE ALL FLT AND DUTY LIMITS; REQUIRE AN ATTORNEY AND ACCOUNTANT ON STAFF TO DECIPHER AND TRACK. AT ALL PREVIOUS AIRLINES IN MY EXPERIENCE; WE HAVE HAD CREW SCHEDULERS/PLANNERS THAT WERE CONSTANTLY LOOKING FORWARD AND BACKWARD USING THEIR OWN KNOWLEDGE OF THE REGS AND BACKED UP WITH THE SOFTWARE TO FLAG ANY PROB AREAS TO ENSURE THAT NO VIOLATIONS EXISTED OR DEVELOPED. THE RULES CURRENTLY UNDER DISCUSSION REQUIRE A FLT CREW MEMBER TO BE CONSTANTLY AWARE OF MULTIPLE ROLLING CLOCKS 24/48/72 HRS; NOT TO MENTION THE 24/7 ROLLING; 120/30 DAY ROLLING; THE 300 IN 90 DAY ROLLING; AND OF COURSE THE 1000 IN ANY ROLLING 12 MONTHS. IF YOU HAPPEN TO CONDUCT A DOMESTIC PORTION THEN; OF COURSE; THE RULES AND LIMITS CHANGE. SURELY THERE MUST BE A BETTER WAY TO ENSURE CREW MEMBERS ARE ADEQUATELY RESTED WITHOUT ADDING ADDITIONAL DURESS DURING THE COURSE OF AN ALREADY TIRING TRIP CAUSED BY MYSTERIOUSLY CONVOLUTED REGS. IT'S AS IF ONE NEEDS ADDITIONAL REST TO RECUPERATE FROM TRACKING THE FLT TIME AND REST REQUIREMENTS. THE COMPLEXITY OF THE REGS AND TRACKING REQUIREMENTS SEEM TO DEFEAT THEIR OWN PURPOSE.

Data retrieved from NASA's ASRS site as of January 2009 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.