Narrative:

I was assigned a trip that involved 3 flight segments. The first two segments were were operated under far part 135 with 8-passengers and a crew of two. The final leg; a repositioning leg; was operated under far part 91 with only the flight crew on the aircraft. The scheduled crew duty on time was XA48 CDT local. The crew duty off time for the first two flight segments was XO48 CDT; or exactly 14.0 hours scheduled crew duty hours. The far part 91 repositioning leg had a scheduled duty off time of XP45 CDT; for a cumulative total scheduled duty day of 14 hours and 57 minutes. However; the weather at our departure airport on the second flight segment was not cooperative; and delayed our departure until XO57 CDT; or 2 hours and 27 minutes later than scheduled. We arrived on the second segment at our destination at XQ51 CDT; at this point a duty day of 16 hours and 3 minutes (duty time ends 30 minutes after aircraft block in). We departed on our far part 91 repositioning leg at XR03 CDT and arrived at XR22 CDT. Duty off time was XR52 CDT; for a total cumulative duty day of 17 hours and 4 minutes. Flight crew fatigue was extremely high; perhaps more so that at any point in my 9-year professional piloting career; and normal flight crew duties were difficult to accomplish. I fear that should any of the last two flight segments have experienced an abnormal or emergency situation requiring flight crew aeronautical decision making and timely CRM the flight crew would not have been in a position to ensure the best possible outcome. The problem is that current FAA regulations (and thus my own company's operations specifications) allow for extended crew duty times for events considered outside the control of the operator. Weather delays are one of those exemptions. The FAA needs to consider the removal of all of these exemptions if it truly wishes to address the issues of flight crew fatigue. Taking this concept a step further; my company's training department has advised all flight crew members that even a late arriving passenger(s) is considered out of the operators control; and thus a flight crew is to extend their duty day for this event. Now let me ask you; what's to keep an operator from scheduling a flight crew within the maximum duty time and then advising the passengers to show up as late as they want beyond the scheduled departure time because at that point it would be out of the operator's control and thus an allowable exception for extending a crew's maximum duty day beyond 14 hours? How can my company's poi allow this interpretation of far part 135 crew rest and duty regulations to stand? Flight crew duty rest regulations are considered a joke by far part 135 flight crews. There are simply too many exceptions made for them to be effective. Also; any far part 91 repositioning flight(s) associated with an far part 135 operated flight segment(s) should be included in the total flight crew duty period. Please know that in my 4;500+ hours as a professional pilot this is the first NASA safety form I have ever completed. Also; please note that I did not fill this form out for immunity from any operational error. The issue of flight crew fatigue needs to finally be resolved. Sadly; you cannot count on operators to do the right thing; in terms of flight crew scheduling; on their own. One thing is certain; the current regulations as they are written are not effective whatsoever in reducing fatigue for far part 135 flight crew.

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Original NASA ASRS Text

Title: A Part 135 Captain reported abuses of flight crew scheduling.

Narrative: I was assigned a trip that involved 3 flight segments. The first two segments were were operated under FAR part 135 with 8-passengers and a crew of two. The final leg; a repositioning leg; was operated under FAR part 91 with only the flight crew on the aircraft. The scheduled crew duty on time was XA48 CDT local. The crew duty off time for the first two flight segments was XO48 CDT; or exactly 14.0 hours scheduled crew duty hours. The FAR part 91 repositioning leg had a scheduled duty off time of XP45 CDT; for a cumulative total scheduled duty day of 14 hours and 57 minutes. However; the weather at our departure airport on the second flight segment was not cooperative; and delayed our departure until XO57 CDT; or 2 hours and 27 minutes later than scheduled. We arrived on the second segment at our destination at XQ51 CDT; at this point a duty day of 16 hours and 3 minutes (duty time ends 30 minutes after aircraft block in). We departed on our FAR part 91 repositioning leg at XR03 CDT and arrived at XR22 CDT. Duty off time was XR52 CDT; for a total cumulative duty day of 17 hours and 4 minutes. Flight crew fatigue was extremely high; perhaps more so that at any point in my 9-year professional piloting career; and normal flight crew duties were difficult to accomplish. I fear that should any of the last two flight segments have experienced an abnormal or emergency situation requiring flight crew aeronautical decision making and timely CRM the flight crew would not have been in a position to ensure the best possible outcome. The problem is that current FAA regulations (and thus my own company's Operations Specifications) allow for extended crew duty times for events considered outside the control of the operator. Weather delays are one of those exemptions. The FAA needs to consider the removal of ALL of these exemptions if it truly wishes to address the issues of flight crew fatigue. Taking this concept a step further; my company's training department has advised all flight crew members that even a late arriving passenger(s) is considered out of the operators control; and thus a flight crew is to extend their duty day for this event. Now let me ask you; what's to keep an operator from scheduling a flight crew within the maximum duty time and then advising the passengers to show up as late as they want beyond the scheduled departure time because at that point it would be out of the operator's control and thus an allowable exception for extending a crew's maximum duty day beyond 14 hours? How can my company's POI allow this interpretation of FAR part 135 crew rest and duty regulations to stand? Flight crew duty rest regulations are considered a joke by FAR part 135 flight crews. There are simply too many exceptions made for them to be effective. Also; any FAR part 91 repositioning flight(s) associated with an FAR part 135 operated flight segment(s) should be included in the total flight crew duty period. Please know that in my 4;500+ hours as a professional pilot this is the first NASA safety form I have ever completed. Also; please note that I did not fill this form out for immunity from any operational error. The issue of flight crew fatigue needs to finally be resolved. Sadly; you cannot count on operators to do the right thing; in terms of flight crew scheduling; on their own. One thing is certain; the current regulations as they are written are not effective whatsoever in reducing fatigue for FAR part 135 flight crew.

Data retrieved from NASA's ASRS site as of April 2012 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.