Founded in 1958, the Federal Aviation Administration (FAA), a designated national authority, regulates all activities of civil aviation in the USA. FAA was established by the Federal Aviation Act of 1958, to regulate US commercial space transportation and air navigation facilities, issue or suspend pilot certificates, to promote air safety and regulations governing airline operations and crew members, and to implement programs to control environmental related issues (Federal Aviation Administration). The General Civil Aviation Authority (GCAA) carries out these responsibilities in the United Arab Emirates (UAE).
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It was established by the Federal Cabinet Decree, Law 4 (General Civil Aviation Authority). While the two agencies regulate all issues related to airline operations and air safety, some differences are seen in rules and regulations for crew members’ rest and fatigue management. This paper examines and compares regulations covering cabin crews. Cabin crews are personnel such as stewards, air hostess, and other staff of an airline, who provide in-flight services. Flight crew members are the pilots and navigators who pilot the airplane. FAA and GCAA subscribe to rules and regulations of the International Civil Aviation Organization (ICAO). Standard operating procedures are prescribed for all operators and their crew. Differences are seen in some specific areas.
The paper is written for a new airline operator, who wants to start operations with modern jet aircraft on international routes. The paper identifies the regulatory requirements of the US and UAE for flight duty time and rests requirements for each regulator.
Findings and Analysis
Regulations of FAA and GCAA for Applicability and General Principals
Considering the volume of air traffic, airports, and operators in the US, the FAA has extensive rules and regulations. The FAA defines rules and regulations as per four lines of business. These include airports, air traffic organizations, aviation safety, and commercial space transportation. FAA and GCAA lay down rules covering subjects such as air navigation facilities, flight and aircraft inspection, cabin crew service, layover duration between flight for the long haul and short-haul flights, etc. (Federal Aviation Administration).
FAA Rules: The FAA prescribes all the rules through a set of Federal Aviation Regulations (FARs) that are structured into sections called parts. About 1552 parts are available, governing various sections and areas of air operations. The Aeronautical Information Manual (AIM) provides information on governing pilot’s health and safety, health and medical factors, flight safety, hazard operating, and on other subjects. Rules and procedures are very extensive and cover details such as navigation aids, performance-based navigation, airport visual aids, airspace, air traffic control, health and safety of flight crew, and several others. The overall assessment is that the majority of rules are directed towards flight and airport operations (Aeronautical Information Manual 56). The Department of Transportation, on behalf of FAA, has released a document 14 CFR with three Parts, 117, 119, in addition to part 121. This document specifically covers rules and regulations for a flight crew member duty, rest, and fatigue management. The document provides detailed rules governing fatigue, risk, flight duty period, split duty, consecutive nights, etc. (Department of Transportation 79).
GCAA Rules: The GCAA has rules for airspace policy, airworthiness licensing directive, safety and security directives, and a list of standards. It has prescribed a set of Civil Aviation Regulations (CARs), where rules and regulations for local and foreign operators are prescribed, under the Civil Aviation Law No. 20 of 1991. CARs are arranged in XI parts, with each part covering specific areas such as safety management system, aerodrome emergency services, air navigation regulations, air safety regulations, airworthiness regulations, etc. (Civil Aviation Regulations). CAR–OPS 1.1135 specifies rules and regulations related to aircrew safety, working hours, rest, etc. (CAR–OPS 1.1135 29).
Differences in Responsibilities of Operator and Crew Members
The operator is the airline owner, licensed to fly the plane on assigned routes. To a large extent, GCAA has followed the rules and regulations of the FAA on many subjects related to the roles and duties of the airline operator and crew members. The operator is responsible to implement a Fatigue Risk Management System (FRMS) and indicate methods to address negative effects on safety, provide for circadian rhythms, homeostatic processes, sleep and alertness strategies, diet and hydration, prescription and non-prescription medications, hygienic in-flight environment, provide a healthy work schedule and bear the consequences of delays and flight disruptions (FAA/GCAA Procedure 6). Fig 1 illustrates the similarities in rules for FAA and GCAA. Entries on the left indicate requirements of FAA and the right panel shows GCAA regulations. As seen in the figure, both are identical. The two agencies work closely and share information about changes in rules. This cooperation is essential since airlines operate common routes with destinations in these countries.
Some differences are seen in the requirements of foreign-registered airlines and aircraft, FAA has formed the Flight Standard District Office (FSDO), which is responsible for the implementation of the Code of Federal Regulations. All foreign registered operators have to adhere to the Code of Federal Regulations (14 CFR). As per these requirements, airlines must submit aircraft and crew details as per ICAO standards. In addition, the FAA can impose special requirements for Special Interest Flight, which are flights operating from countries that the US State Department has designated as a special interest country (Flight Standard District Office). The GCAA has introduced the National Safety Assessment of Foreign Aircraft (SAFA) program to regulate and monitor foreign-registered operators. As per these regulations, the foreign operator is required to present data sheets of foreign operators and aircraft, insurance requirements, and flight crew details (National Safety Assessment of Foreign Aircraft).
Responsibilities of the crew: FAA and GCAA follow rules prescribe by the ICAO. The cabin crew made of flight stewards and air hostesses are responsible to ensure the safety of all passengers, ensure that passengers use the seat belt during landing and takeoff, that they dispense food and beverages as per the rules, and ensure that passengers are not unruly. In the event of emergencies, the crew needs to inform and guide passengers about the safety procedures to follow evacuation methods and order, indicate the position of exit doors, and ensure that passengers deplane in an orderly manner (FAA/GCAA Procedure 10).
Comparison of Absolute Limits on Flying Time and Duty Period
Flying time or the Flight Duty Period (FDP) is calculated when a person registers attendance at the beginning of the duty to the time when the aircraft stops at the destination without further takeoff by the same staff. FDP considers the tasks performed before, during, in between, and after the flight, and where resting is not taken. Flight time (FT) or flying time is the duration when the aircraft moves with its own power for flying and it ends after the aircraft lands and rests. Operating crew members are members who are not resting but are engaged in carrying out their duties. Long haul routes may have two or more teams alternating their roles between operating and non-operating crew members. This definition applies to cabin crew also (Foltz).
As per CAR–OPS 1.1135, GCAA has a number of requirements for flight crew members and cabin crew members. Generally, specifications for cabin crew are less stringent than those for flight crew (CAR–OPS 1.1135 21). The stringent requirements for flight crew come from the critical health and well-being requirement of pilots, who fly the aircraft, and who have to be alert at all times (CAR–OPS 1.1135 22). The cabin crew, on the other hand, carries out non-flying related tasks of caring for passengers (CAR–OPS 1.1135 20). The FDP for cabin crew can be one hour longer than that allowed for the flight crew. There is a further requirement for the minimum rest period.
The minimum rest period before taking an FDP should be at least 1 hour more than the preceding FDP or 11 hours, whichever is lesser (CAR–OPS 1.1135 22). There is a limit on the consecutive duty hours for cabin crew. The maximum duty hours allowed for cabin crew should not be more than 60 hours for seven consecutive days. It should not be more than 105 hours for 14 continuous days, or 210 hours for 28 days (CAR–OPS 1.1135 23). A cabin crew member is not allowed to act as an operating crew member of a flight if, at the beginning of the flight, the aggregates of all FDP is more than the specified times for 28 days. For long haul flights, the requirements are different (CAR–OPS 1.1135 23).
Rules of rest for the FAA are more elaborate and well-considered. As per the FAA regulations, rules of flight duty time address factors such as fatigue, circadian rhythms, fitness for duty, fatigue education and training, and the fatigue risk management system. Augmented operations and extensions of flight duty periods are allowed when operations requirements of even short flights are exceeded and it is not possible to obtain a replacement crew. Fitness for duty covers all these factors. Airlines consider that if a crew member works continuously for beyond the maximum allowed time, then fatigue sets in with the severe loss of operational ability, increasing risks of errors. Longer shifts tend to affect the health and performance of crew members (Department of Transportation 45).
The practice of split duty is allowed for airlines that take-off late in the night or very early in the morning. In split duty, the staff is permitted to take a non-legal rest of three hours or more. In addition, repeated flying at night is considered as more tiring and degrades performance, when a member flies for three nights continuously. Consequently, crew and flight crew members are given a sleep opportunity of two hours of nighttime sleep and this allows 5-nights of consecutive nighttime operations (Department of Transportation 68). These rules are the same for all types of flights such as domestic, international, and unscheduled. As per FAA, the maximum FDP varies is 9-10.5 hours, and these depend on the time when the flight takes off and the number of stops or segments. For flights starting at 13.00 to 16.59, the FDP is 12 hours for 1 segment of a flight, while it is 10.5 for flights starting at 20.00-23.59. This difference is considered since the FAA believes that crew starting at 23.00 would be more fatigued than crew starting at 13.00. One more difference between FAA and GCAA is that the US has four times zones, while GCAA has only one. Therefore, FA has defined a rule that crew should not cross three time zones on one flight without taking a rest. The rest period should be 10 hours with at least 8 hours of uninterrupted sleep in a day (Department of Transportation 124).
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Cabin Crew Requirements
For cabin crews, the rules specify that the 60 hours per week limitation can be increased to 65 hours when a flight commences and extends due to unexpected delays. There is a limitation of 105 hours for 2 successive weeks, 200 hours for 4 successive weeks, and 600 hours for 12 successive weeks. For cabin crews who log in more than 28 successive days, which expire at the end of a flight, starting 120 hours, the block hours for 12 months, such crew should not serve as operating crew members. There is a limit on the maximum duty hours for cabin crews and the maximum flight hours should not be more than 60 hours for 7 continuous days to 600 hours for 84 continuous days (CAR–OPS 1.1135 45).
Similarities and Differences in GCAA Regulations between Crews for Different Routes
This section discusses similarities and differences in rules for GCAA crews for different routes. The rules for short-haul and long-haul flights are the same in GCAA since the maximum distance between cities in the UAE is less. Differences in rules for crews are seen in ultra-long-haul flights of international flights. These rules of international flights are applicable for operators registered with GCAA and not with other countries. However, restrictions are placed on ultra long haul flights to the US, Australia, and other destinations where flight time can be more than 16 hours (Civil Aviation Advisory Publication 6). Specifications indicate that such flights must have at least four pilots, with 2 qualified as pilot-in-command. A number of cabin crew depend on the aircraft type, and an A380 will need 24 members while a B777 will need 16 members (Civil Aviation Advisory Publication 8).
Common rules for short and long-haul flights are that it is mandatory to have a Fatigue Risk Management System, with details of resting places, rest hours, nature of resting spaces, which should be protected against noise. The departure time window should be clearly specified and designed as per scientific principles (Civil Aviation Advisory Publication 10). Rest should cover pre-flight rest, in-flight rest, and post-flight rest. The program must be documented and presented for validation to GCAA who shall conduct an initial validation with on-going monitoring, subject to validation re-assessment. The FRM should provide for sleep diaries, acti-watches with diaries, and polysomnography, while alertness validation and performance validations should be as per rating scales, reaction time tests, and a set of cognitive tasks (Civil Aviation Advisory Publication 11).
The document examined rules and regulations governing flight and cabin crew for FAA and GCAA. The assessment is that both regulatory bodies follow the regulations specified by ICAO. Differences are evident in the rest and fatigue management of the crew. FAA covers domestic and international flights in the US and it has specified the same set of rules for domestic and international flights. GCAA, on the other hand, has different rules for short-haul domestic and international flights and ultra long haul flights. For the latter, the operator must provide a Fatigue Risk Management System, to provide rest for cabin and flight crew. The assessment is that the FAA and GCAA have elaborate systems for air safety.
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