Hazards associated with transitioning between appendices
The most probable hazard to arise when changing from one appendix to another is not being sufficiently alert to meet the safety standards of the activity the pilot is transitioning into. This can come about because the pilot's recent activities in another appendix have resulted in not having enough off-duty periods to adequately manage alertness. While the lower level of alertness may be acceptable in some operating contexts, it is not acceptable in public transport services and training activities.
Transitions from Appendix 5
Transitions from Appendix 5 (aerial work other than flying training) to other appendices are likely to cause the greatest challenge, in terms of meeting the different requirements across appendices. This is because Appendix 5 allows operations such as extended periods of 24 hour standby, and it has no requirement for a specific number of off-duty days to be completed across an 84-day period. This could result in a pilot with considerably less off-duty days than the minimum required to commence a flight duty period under Appendix 4 or 6, for example.
To address the difference in off-duty period requirements, the operator can develop a risk-based procedure to manage the transition. During this process, the operator should take into account that a sustained period of sleep restriction can result in the pilot stabilising their alertness level at a lower-than-normal level.
These procedures must be documented in the operations manual.
A procedure for managing the hazards associated with transitioning between Appendix 5 and 4 (or Appendix 6)
When transitioning a pilot from Appendix 5 operations, to conducting flying training under Appendix 6, or charter work under Appendix 4, an acceptable procedure might be for the pilot to first meet all the requirements of that other appendix except the requirement for 24 off-duty days in 84 consecutive days. This requirement could then be met by the pilot:
- having at least 7 days off duty in 28 consecutive days before commencing the flight duty period or standby, and
- having at least 24 days off duty in 84 consecutive days before commencing the flight duty period or standby, or
- completing a continuous period of consecutive off-duty days, equal to half the number of days they are short of the '24 off-duty days in 84 days' requirement (rounded up to the nearest whole number). For example, if the pilot only had 16 off-duty days in the preceding 84 days then they would be 8 days short of the requirement and need to complete a continuous period of 4 off-duty days (i.e., 24 - 16 = 8, and half of 8 days is 4 days) before they could transition to Appendix 4 or 6. If the pilot had completed 13 off-duty days in the preceding 84 days, they would need to complete 6 consecutive off-duty days (i.e., 24 - 13 = 11, and half of 11 days is 5.5 days which is rounded up to 6 days).
If the pilot starts operating in the new appendix with less than 24 off-duty days within 84 days, they have 28 days from the commencement of operating under the new appendix in which to meet this requirement. However, they must meet the requirement for 7 off-duty days in 28 days at all times.
If the pilot subsequently transitions back to Appendix 5 (aerial work operations, other than flying training), then the whole procedure may be reset and commence again when they again transition out of Appendix 5 to another appendix.
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