JOINT POSITION PAPER
on Flight Time Limitations
for Commercial Air Transport
(EASA Rulemaking task OPS.055)
This position paper is a joint position from all of the four main airline associations (AEA, ELFAA, ERA, IACA) on the subject of Flight Time Limitations for Commercial Transport (EASA Rulemkaing Task OPS.055)
- EU-OPS Sub Part Q in its current form, complete with all existing definitions, limits and delegated National variants is, and must remain, available to all European airlines as an acceptable FTL system.
- Fatigue risk management should be seen as an integral part of an operator's safety management system to review the effectiveness of FTL systems, propose changes and support variations to EU-OPS Sub Part Q guided by operational experience or scientific study. Further guidance on FRMS will be provided by ICAO, FRMS does not need additional prescriptive regulation by EASA.
- All EU airlines are agreed on the above points and cannot accept any changes to EU-OPS Sub Part Q which is already in operation, state-of-the-art, demonstrably safe, and more comprehensive than foreign FTL schemes.
EASA is a safety regulator and not a social mediator. FTL is an established safety system and not a social tool.
European airlines unanimously call on EASA to confirm that above agreed principles will be implemented in the interest of European air safety, and not driven by social agendas.
28 September 2009
Ulrich Schulte-Strathaus, Secretary General, AEA (Association of European Airlines)
John Hanlon, Secretary General, ELFAA (European Low Fares Airline Association)
Mike Ambrose, Director General, ERA (European Regions Airline Association)
Sylviane Lust, Director General, IACA (International Air Carrier Association)
Author:
Publication Date: 12 Oct 2009
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