The FAA has reversed its maintenance duty time legal interpretation and comments submitted by the Professional Aviation Maintenance Association played a role in that decision.
Back in May 2010, the FAA released a legal interpretation meant to clarify rest provisions for aviation maintenance technicians, concluding that the rule required one day off out of every seven days. In December 2010, the Aeronautical Repair Station Association (ARSA) filed a complaint, prompting a reevaluation of the interpretation and a request by the FAA for comments. PAMA, along with ARSA, and the Transport Workers of America, submitted comments. In late December, the FAA reversed its stance, acknowledging, “The requirement for equivalency lies in the amount of rest given, not in the way the schedule itself operates or is developed.”
At PAMA, we believe that only looking at days worked totally misses the mark when it comes to fatigue. There are numerous factors that must be considered as a whole to have a viable fatigue prevention system.
Some of the issues concern hours worked in a day. A technician might work three days in a row of 16 hours each and become fatigued way before a six-day work week ever becomes an issue. Also, a technician who normally works until midnight might become fatigued after only two hours of overtime due to working past the time he would normally go to sleep.
Additionally, what the person is doing while off duty can play a large role in the ability to perform their duties safely. A technician who works nights could easily spend their day cutting down trees or cultivating a garden. Many of these tasks are more labor intensive than actual aircraft maintenance.
These thoughts were put together by a group of individuals who serve on PAMA’s Technical Committee. All are A&Ps with more than 20 years each in the field. Several have DME, DAR, DER, and IA behind their names. They are from diverse backgrounds in corporate aviation, general aviation, and the airlines, plus manufacturing.
The comments didn’t come out of a vacuum, which is the best thing I see from this committee. They know and have experienced a lot, plus they research it within their own business environments. I hold them in high esteem and greatly appreciate all they do for PAMA members.
More information can be found at PAMA.org/node/15599.