Cargo Industry is Exempt From Flight/Duty Changes - Should They Be?

In the proceeding months and years after the 2009 Colgan Air Flight 3407 crash and various others, the FAA came to conclusion that something in the regulatory process must be changed. Previously, pilots were landing jobs with a little over the minimum of 250 hours and no ATP due to it not being required. This meant flight crews were severely under-experienced. The FAA instituted the 1500 requirement for the ATP, unless you came from a 141 school, where you are eligible to get the restricted ATP with 1000. With proper military experience, this can be possible with even less. Not only was flight time changed, but rest requirements were too. According to The Balance and FAA, Under the old rules, rest requirements were based on operations such as domestic and international flights. Now there is no difference as all rules apply. Flight hours were limited per day and per year with the old rules and now it are based of week, month, and year. Under old operating rules, the word “fit for duty” had a very vague language around it. Currently pilots must sign a document affirming that they are unable to fly and the company must remove the pilot if they are fatigued.

Technically speaking, cargo carriers are exempt from Part 117, but they could operate under those rules if they wish. Flight time and rest requirements are based on various different things. For 121 supplemental cargo operations, these rules relate to how many hours are operated in any calendar year, month, and day with a minimum 8 hour required rest period, pertaining to how long the operating day was and what kind of crew it was (standard, double, ect.). Every seven days, operating crews must get a 1/7 status (24 hours of duty rest, for a 7 day duty period).

Cargo carriers have been excluded from the Part 117 rules for various reasons. The main reason is these cargo carriers are working non-stop around the clock. If said company was to abide by part 117, they would lose out on huge amounts of revenue. Not only that, but with the pilot shortage that is among us today it would almost be impossible.  In the month of October, 2017, Part 121 cargo company Kalitta Air, LLC flew 6,332.1 hours, the busiest month they have ever had. If they were to partake in these rules, there is no way they would have been able to achieve that astonishing record. Not only would it affect smaller companies, but it would affect the industry as a whole. According to the FAA and USA Today, “the economic rationale behind exempting cargo pilots, saying it would cost the industry $550 million to comply, outweighing safety benefits. Originally, it said the rules would cost an additional $214 million.”

Personally, no I don’t think cargo carriers should be included in the new rules. As stated they can if they chose, but it could slow their success. Internally, these cargo carriers outside of Part 117 spend months contracting exceptional rest period requirments with union pilots that leave everyone pleased. For example, if you were operating a duty period up to 24 hours, you automatically get 18 a minimum rest period of 18 consecutive hours and so on.

If cargo carriers were included in the new rules, it wouldn’t matter what industry you went in. If you wanted more stable of a schedule, a lot of these cargo pilots would be joining the airline. On the other hand, cargo carriers like to have pilots on for half the month, then off half the month, so these schedules would likely change as well.

Sources:

Carroll, J. R. (2014, March 13). UPS pilots urge more rest for cargo crews. Retrieved February 02, 2018, from https://www.usatoday.com/story/news/nation/2014/03/13/ups-pilots-urge-more-rest-for-cargo-crews/6402615/

Advisory Circulars & Guides Associated with 14 CFR Part 117. (2017, October 16). Retrieved February 02, 2018, from https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/part117/Part117_General/

Houston, S. (n.d.). Learn About the FAA's Final Rule for Pilot Duty and Rest Requirements. Retrieved February 02, 2018, from https://www.thebalance.com/faa-final-rule-pilot-duty-and-rest-requirements-282927