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Returning back to compliance with FDTLs in COVID-19 conditions

Vetruvian man.jpgCOVID-related constraints and concerns have resulted in many operators being unable and/or unwilling to schedule normal rest periods for crew down route. Operators have sought to avoid onerous State restrictions to their operations and/or exposing their crew to increased risk of infection or having them subjected to invasive testing or quarantining.  This has led to extensions well beyond established national flight and duty time limitations (FDTLs). 


The world has now had time to adapt to the challenges that Covid-19 has presented. States are protecting their citizens with screening, quarantine and air traffic passenger reduction policies. Often these policies change at short notice, but this very changeability is now an expected situation. Airports and airport hotels are developing Covid-19 secure procedures and aviation activities are continuing, albeit at greatly reduced levels in many cases.


While the continuation of international operations remains essential, "normal" international operations are not urgent to a level that justifies the increased risk associated with significant extensions to FDTLs.  Even the continued use of relatively minor extensions in the more-demanding context of COVID- operations (e.g. potential job loss, fear of infection, changed operational environment) can result in crew experiencing cumulative fatigue - with likely implications for their performance.


Operators now need to return to managing fatigue within existing FTDLs (or using an approved FRMS) and take the time to prepare for an increase in operational activity in the medium term.  Regulators need to ensure that the management of overall fatigue risk and the safety of operations is maintained, taking into account the basic fatigue-related scientific principles and recognizing the extra burdens associated with operating in COVID-19 conditions. 


This webpage provides guidance for regulators to support operators in returning to "normal" scheduling limits and practices while managing the fatigue risks during the transition back to more "normal ops" under the following headings:


1. Applying the basic scientific principles to manage fatigue risks within the prescribed limits

This section explains what a prescriptive approach to fatigue management entails and identifies the 4 basic fatigue management principles that need to be considered.

2. Operating within the prescribed FDTLs

While some airlines may use advanced approaches and have an approved fatigue risk management system, most will be scheduled within the prescribed flight and duty limits and managing their fatigue risks through their SMS processes.  This section focuses on the basic expectations of Operators complying with FDTLs. 

3. Fatigue-related challenges in COVID-19 conditions

This section identifies additional fatigue-related challenges that may be presented by COVID-19 conditions.  

4. Managing the additional fatigue challenges in COVID-19 conditions

This section outlines things that Operators can do to address the additional fatigue-related challenges.

5. Approving variations to existing State FDTL regulations

It is recognized that rare situations may still present themselves that necessitate international flights flown by crew members under approved extensions to FDTLs.  This is provided for in Annex 6, Part I SARPs.  This section provides guidance to regulators on approving variations to FDTLs.

​6. Extreme extensions to flight duty periods

Ultra-long range (ULR) flights have been operated safely for many years but under carefully designed conditions and with scientific input and regulatory oversight.  This section aims to assist regulators and operators understand the safety implications of flight duties where the normal layover between long-haul flight sectors is removed, resulting in duty periods beyond those previously operated (e.g. longer than approx. 19 hours).


7. Further guidance

Go here to access manuals and webinars for more information. 



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