Narrative:

Upon pulling the flight plan we noticed a planned out to in time of 12 hours 20 mins. Referring to far 121.483; flight time limitations: 2 pilots and 1 additional crew member -- a) no certificate holder conducting flag operations may schedule a pilot to fly; in an airplane that has a crew of 2 pilots and at least 1 additional flight crew member; for a total of more than 12 hours during any consecutive 24 hours. Regulations require a fourth crew member when block times will exceed 12 hours. This flight routinely goes over 12 hours during the winter months; 60% in december and greater than 50% in january. The captain brought this issue to dispatch's attention and requested a fourth crew member. He was xferred to crew tracking and eventually to the chief pilot. His request was denied; so we went with 3 pilots. Our flight experienced a departure delay due to baggage issues; and an arrival delay due to an occupied gate. As a result we found ourselves performing crew duties for approximately 13 hours 20 mins. We found ourselves; by landing time; operating close to the limits of what would be considered safe and aware. All 3 of us were in agreement on that. Operating like this is obviously at the extreme limit of safety if not flat out compromising it; and allows no room for an abnormal situation that would require further attention. As has been well documented by past accidents and incidents; fatigue plays a very large role in the success or failure of an operation. Our air carrier needs to staff this schedule realistically instead of pushing the extreme limit of safety on a regular basis. They are forcing crews into a situation where they must choose between conducting a flight at the extreme limits of safety or inconveniencing our passenger by refusing the flight due to fatigue issues and no fourth crew member. By conducting this operation repeatedly in this manner; air carrier is leaving the door wide open for a fatigue related issue.

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Original NASA ASRS Text

Title: A B777 CAPT REPORTS THAT AN INTL FLT EXCEEDS 12 HOURS MORE THAN 50% OF THE TIME BUT HIS ACR WILL ONLY SCHEDULE 3 PLTS; VIOLATING FAR 121.483.

Narrative: UPON PULLING THE FLT PLAN WE NOTICED A PLANNED OUT TO IN TIME OF 12 HRS 20 MINS. REFERRING TO FAR 121.483; FLT TIME LIMITATIONS: 2 PLTS AND 1 ADDITIONAL CREW MEMBER -- A) NO CERTIFICATE HOLDER CONDUCTING FLAG OPS MAY SCHEDULE A PLT TO FLY; IN AN AIRPLANE THAT HAS A CREW OF 2 PLTS AND AT LEAST 1 ADDITIONAL FLT CREW MEMBER; FOR A TOTAL OF MORE THAN 12 HRS DURING ANY CONSECUTIVE 24 HRS. REGS REQUIRE A FOURTH CREW MEMBER WHEN BLOCK TIMES WILL EXCEED 12 HRS. THIS FLT ROUTINELY GOES OVER 12 HRS DURING THE WINTER MONTHS; 60% IN DECEMBER AND GREATER THAN 50% IN JANUARY. THE CAPT BROUGHT THIS ISSUE TO DISPATCH'S ATTN AND REQUESTED A FOURTH CREW MEMBER. HE WAS XFERRED TO CREW TRACKING AND EVENTUALLY TO THE CHIEF PLT. HIS REQUEST WAS DENIED; SO WE WENT WITH 3 PLTS. OUR FLT EXPERIENCED A DEP DELAY DUE TO BAGGAGE ISSUES; AND AN ARR DELAY DUE TO AN OCCUPIED GATE. AS A RESULT WE FOUND OURSELVES PERFORMING CREW DUTIES FOR APPROX 13 HRS 20 MINS. WE FOUND OURSELVES; BY LNDG TIME; OPERATING CLOSE TO THE LIMITS OF WHAT WOULD BE CONSIDERED SAFE AND AWARE. ALL 3 OF US WERE IN AGREEMENT ON THAT. OPERATING LIKE THIS IS OBVIOUSLY AT THE EXTREME LIMIT OF SAFETY IF NOT FLAT OUT COMPROMISING IT; AND ALLOWS NO ROOM FOR AN ABNORMAL SITUATION THAT WOULD REQUIRE FURTHER ATTN. AS HAS BEEN WELL DOCUMENTED BY PAST ACCIDENTS AND INCIDENTS; FATIGUE PLAYS A VERY LARGE ROLE IN THE SUCCESS OR FAILURE OF AN OP. OUR ACR NEEDS TO STAFF THIS SCHEDULE REALISTICALLY INSTEAD OF PUSHING THE EXTREME LIMIT OF SAFETY ON A REGULAR BASIS. THEY ARE FORCING CREWS INTO A SITUATION WHERE THEY MUST CHOOSE BTWN CONDUCTING A FLT AT THE EXTREME LIMITS OF SAFETY OR INCONVENIENCING OUR PAX BY REFUSING THE FLT DUE TO FATIGUE ISSUES AND NO FOURTH CREW MEMBER. BY CONDUCTING THIS OP REPEATEDLY IN THIS MANNER; ACR IS LEAVING THE DOOR WIDE OPEN FOR A FATIGUE RELATED ISSUE.

Data retrieved from NASA's ASRS site as of May 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.