This is a legality alert affecting every Flight Attendant flying domestic IDs.  The Company continues to build IDs that do not operate as planned.  Much of our domestic flying is comprised of long work days and short periods of rest.  As the Company continues to ignore the practical realities of scheduling IDs in this manner, frequently we are confronted with the actual duty period being extended in the operation up to the maximums set forth in the Contract.  Working in excess of these maximums creates a situation that fosters fatigue and potentially compromises your personal well being as well as that of your flying partners and the passengers in your care.

Every day, Flight Attendants experience the impact of fatigue on their work life. As we fight on Capitol Hill for improvements in rest provisions, we must be vigilant about protecting Contractual legalities and current Federal Air Regulations (FARs).  In most cases, our Contract provides greater protection than the FARs.

Contractual Maximum Domestic Duty Time

Maximum domestic duty time provisions are defined in Section 7.I. of our Agreement.  The maximum time a Flight Attendant may remain on duty for a Domestic ID is determined by the hour of the day in which the duty period begins:

Both of these periods are based on your home domicile time.

Duty Time Starts at Check-In

Duty time starts at check-in, includes flight, deadhead, sit time and concludes after a period of debriefing.  We recommend you carry a copy of your DSL ID from the Key Pages to have for reference throughout your trip.  Your Key Pages contain your scheduled duty time and the start of your duty day which begins at check-in.  Your ID contains your updated duty time within the actual operation.

The actual maximum duty times apply only once you have checked in for the first flight in the duty period.  Any rescheduling must be done without exceeding the maximum actual duty time based on the original commencement of duty.

Take Action When Approaching Duty Time Maximums

Section 7.I.4.b. provides under no circumstances shall a Flight Attendant be required to remain on duty in excess of the maximum duty time hours, including deadhead, in any 24 hour period.  In the actual operation, when you find you are approaching your duty time maximum:

• advise the Crew Desk of the legality so they can make appropriate arrangements for replacements.
• Call early.  Call often.

Published DSL Flight Time Must Be Used for Duty Time Calculations

When calculating maximum duty times, the published DSL flight time must be used; not the estimated flight time based on that day's operating conditions.  The DSL time is the scheduled flight time appearing in the Key Pages.  The maximum actual should include this scheduled DSL time and any associated debriefing.

Additional Staffing Required by FAR 121.467

When any member of the crew is rescheduled into a duty period exceeding 14 hours, the requirements of FAR 121.467 must be met.  This important FAR requires augmented (or additional) staffing beyond the FAA minimum staffing required by aircraft type.  This augmented staffing becomes "part" of the FAA minimum staffing requirement and increases based on the length of the duty period involved.  The FAR applies differently if you are working your original schedule or if you become involved in a reassignment. 

FAR example:
Three Flight Attendants are working their flight as originally assigned in their ID when they started their duty day on a 737-300 aircraft.  The FAA minimum crew for this aircraft is three.  Their flight is delayed and the duty time of the ID is projected to 14:20.  Augmented staffing would not be required on this flight.

In contrast, if these same three Flight Attendants were reassigned to work a segment that was not part of their original ID and the reassignment projects any member of the crew beyond 14 hours, augmented staffing would be required.  In this case, the Company would be required to schedule one additional Flight Attendant as a member of the working crew.

FAR Review:

1. If the entire crew is on their originally scheduled ID and flight, a delay may not trigger the augmented staffing requirement. 
2. If the delay results in any single member of the crew being reassigned to a duty period in excess of 14 hours, the Company must comply with the FAR and add the additional crew member (s) to the remaining flights in the duty period.

Crew Scheduling Personnel and Flight Attendants are both responsible for compliance with the FARs.  Details of the FAR are explained on FAOM pages 4.10.3. and 4.20.1. 

Report FAR Violations to AFA Safety Committee and File an OSAP Report

If you have any questions or believe your flight has been improperly dispatched without the required augmented crew, write a report to your Local AFA Safety Committee and file an OSAP report immediately.