Serious Fatigue Memo 5/3/2024

If I remember the rules, doing it with only 8hr shifts is challenging so you'd have to manipulate the number of hours each day, something like:
Day 1 - 1415-0015 (10hr) NF to cover mid overlap
Day 2 - 1400-2200 (8hr) or 1300-2100
Day 3 - 0800-1600 (8hr) or 0700-1500
Day 4 - 0600-1200 (6hr)
Day 5 - 0000-0800 (8hr)
Doesn't work. Can't do a 6hr shift.
 
Doesn't work. Can't do a 6hr shift.
Just goes to show what we'll be up against: it was a management level person who told me that schedule worked.

Day 1 - 1545-0045 (9hr) NF to cover mid overlap
Day 2 - 1400-2200 (8hr) or 1300-2100
Day 3 - 0800-1600 (8hr) or 0700-1500
Day 4 - 0530-1230 (7hr) NF
Day 5 - 0030-0830 (8hr)

With that edit it starts to get ugly keeping the eves so late into the night, and the mids til 830...if that happened I definitely see some supervisors calling the midders back to work a rotation in the morning before they go home

If they can change the requirement for rest they could change min. 7 hours to min. 6 hours. Can be done with only that one simple change
If they went that route and were worried about a 6hr being assigned to anyone at any time they could stipulate a 6hr shift is only for the shift preceeding a mid
 
If I remember the rules, doing it with only 8hr shifts is challenging so you'd have to manipulate the number of hours each day, something like:
Day 1 - 1415-0015 (10hr) NF to cover mid overlap
Day 2 - 1400-2200 (8hr) or 1300-2100
Day 3 - 0800-1600 (8hr) or 0700-1500
Day 4 - 0600-1200 (6hr)
Day 5 - 0000-0800 (8hr)
I was thinking something similar to this but wasn't sure if it was legal
Day 1 - 1400-0000 (9 hrs)
Day 2 - 1200-2100 (9 hrs)
Day 3 - 0700-1500 (8hrs)
Day 4 - 0530-1130 (6 hrs)
Day 5 - 2330-0730 (8 hrs)

But a schedule like this essentially make shift swaps impossible. 🤷‍♀️
 
It's important to define what "legal" means.

14 CFR 65.47 is FAA regulation that has to go through a whole comment period and stuff if they want to change it. The wording only applies to control tower operators but I guess it's interpreted to mean 2152s in general? I'm not clear on that point. Anyway, this says that you can't work more than 10-hour shifts nor can you work more than 10 hours in any 24-hour period, unless you have an 8-hour break. No rule on minimum shift length.

Then the 7210.3 2-6-7 is an internal FAA document and they can change it with the stroke of a pen... unless NATCA pushes back and says it's a change in working conditions, which is what happened. This is the 9-and-8-hour rule for time off between shifts which they're changing to a 10-and-12-hour rule. Again, nothing about minimum shift length.

Finally the Slate Book Article 34 defines the basic workweek as 5x8 unless the employee voluntarily agrees to an Alternative Work Schedule. I guess this is what ManBearPig means about "can't do a 6hr shift" because a Flexible Work Schedule is just normal 8-hour shifts but with flex time, and the two types of Compressed Work Schedules are (1) 4-10 and (2) 5/4-9.

So if you wanted to write a schedule with 9-9-8-6-8 or whatever you would have to have NATCA and the FAA negotiate an MOU overriding Article 34. That's certainly doable, and NATCA should explore that if the workforce wants that kind of schedule. You just have to be aware of what it would take to make that legal.
 
Has anyone actually come up with a schedule for a 24 hour facility that doesn't involve a reverse rattler or a week of mids?
Mine doesn't yet but I have a friend at MIA that says their bidding guys have schedules made up already assuming everything goes through. It's some version of straight shifts is all I know. I told my rep to hit up their rep to see what they came up with.

The 6hr rule could be changed tho. They’ll have to rewrite all the rules for schedules anyways so there’s no reason NATCA couldn’t negotiate that.

Finally the Slate Book Article 34 defines the basic workweek as 5x8 unless the employee voluntarily agrees to an Alternative Work Schedule. I guess this is what ManBearPig means about "can't do a 6hr shift" because a Flexible Work Schedule is just normal 8-hour shifts but with flex time, and the two types of Compressed Work Schedules are (1) 4-10 and (2) 5/4-9.

So if you wanted to write a schedule with 9-9-8-6-8 or whatever you would have to have NATCA and the FAA negotiate an MOU overriding Article 34. That's certainly doable, and NATCA should explore that if the workforce wants that kind of schedule. You just have to be aware of what it would take to make that legal.
Exactly. Article 34 is the main culprit and would need a MOU to override the rule that the minimum length for a core shift is only 7hrs. It's doable but not sure the FAA "wants" it as they've been trying to get rid of the rattler schedule for a while and this is a roundabout way of keeping it with just a slight modification.
 
BWS negotiations are supposed to happen like normal with no change. Only if national levels come out with guidance will facilities renegotiate.

Another complicating factor is controllers have a requirement for a 40 hour week in the CBA, where the rest of the government is an 80 hour pay period.
 
In all fairness, a decent amount of people thought that whining about the schedule was a good idea at his townhall. Working in transportation and being mad about the schedule is like being a cop and complaining about having to arrest people.
 
In all fairness, a decent amount of people thought that whining about the schedule was a good idea at his townhall. Working in transportation and being mad about the schedule is like being a cop and complaining about having to arrest people.
The schedule absolutely should be changed and advocating for that isn’t unreasonable. It’s been proven time and again that the rattler is the absolute worst work schedule for fatigue and overall health. The issue is you can’t make drastic changes overnight. The administrator wanting to go from 8 hours before a mid to 12 and have it implemented within 90 days is absurd. If they took the time to formulate a plan that could be executed over time, it’d be great. Of course that’s not how the agency operates though.

Uhh it's supposed to change next bidding period as the union reviews how to have facilities implement it locally.

It is going to change.
Did you miss Stinger post above? Bidding is happening with no changes. Nothing is going to happen for at least another year, if ever.
 
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