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FAR Part 121 allows for a maximum 16-hour duty period. Pilot must be able to "look back" at any time and see at least 8 hours of rest within the past 24 hours.

FAR Part 121 allows for a maximum 16-hour duty period. Pilot must be able to "look back" at any time and see at least 8 hours of rest within the past 24 hours.

until departure minimums can be met. In air ambulance operations, the delays are typically patient-related. None of these delays typically result in any

increase in the flight hours required to complete the assigned flights, but such delays could easily result in crewmembers exceeding the rest require- ments that dictate the maximum length of a duty period. Yet, the language of both rules clearly provides for exceptions only to flight time limits, with no mention of any exception to the rest requirements that dictate the maximum length of the duty period. The fact that the FAA finds it necessary to officially re-state what the language in the rules already clearly says forces us to spec- ulate whether this action is motivated by abuses by a few operators who have used a liberal inter- pretation of the the rules as a loophole to extract more duty out of fewer pilots in order to bolster the bottom line. An additional important consideration in

comparing the impact on operational safety that these rules have for Part 121 certificate holders vs. Part 135 air medical transport providers, is the large disparity in actual flight hours flown in a typical duty period by the two types of opera- tions. The economies of scheduled air carrier operations naturally require that those services be provided using the minimum number of pilots commensurate with safety and the requirements of the FAR's. The same is true of Part 135 oper- ations, including air medical transport services. But, the demands of the flying public are such that the pilots of Part 121 operations frequently spend close to the maximum allowable flight hours in the air during each duty period, while air med-


ical pilots typically spend the majority of their duty period in the crew quarters doing a variety of sedentary duty-related tasks, or just reading, or watching TV. Or, they may actually be asleep in bed, since a sleeping area is typically provided for EMS pilots to obtain additional rest while wait- ing for a flight request; if one occurs at all dur- ing any given duty period. In both of the two hypothetical scenarios

presented above, it is very possible that the flight which occurred late in the pilot's shift was his first flight of the duty period, and that it came after 3 or 4, or even 5 or 6 hours asleep in bed . In the "off the record" inquiries mentioned above, the 22 respondents that had exceeded the duty period limits due to patient delays exceeded the 14 hour limit by an average of 42 minutes, with a high of 2.0 hours and a low of six minutes. I found it interesting that, in none of the cases reported to me did the pilot have a need to exceed the 16 your duty day that would be granted to the Part 121 airline pilot by FAR 121.471(c)(1). But, if there have been occasions of an

under-the-counter common-sense approach to handling the issue of patient delays in the past, it is about to be explicitly outlawed by the pro- posed new legal interpretation. The regulations that limit duty time for pilots are enacted to pro- tect life and limb, but in certain circumstances related to emergency air medical operations, the rules can, and I would assert that they will have just the opposite effect for a patient whose life depends on rapid transport to the medical facil- ity that has the special resources needed to save his or her life. The disparity between the duty period

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