Narrative:

The following is my interpretation of far part 135.271 as applied to the hemes program here. Crew members performing 48 hour duty assignments are not in violation of this paragraph when 8 hour consecutive and uninterrupted rest periods are observed. When flight activity is such that the 8 hour requirement is threatened, an on-call back-up pilot is immediately summoned to assume hospital duty. The recent change to 12 hour shift rotations here and throughout company EMS operations has actually hampered efforts toward sufficient crew rest. Many EMS pilots reside a considerable distance from their hospital duty assignments. In changing from the former 48 hour shifts, to the current 12 hour rotations, these pilots find it impractical to commute between home and work on a daily or even near daily basis. The result is either poor quality rest at or near the hospital or countless hours and miles on the highway. Job satisfaction, family relations, and financial well being all suffer. Another problem associated with the 12 hour shifts is the inflexibility of duty schedules when attempting to accommodate personal needs for time off such as vacations, military reserve duty and illness or unanticipated family emergency. Even with 4 pilots per aircraft, as most programs are, any deviation from the normal rotation becomes a major disruption for all concerned. 48 hour shifts were far more conducive to minor schedule adjustments. It is my understanding that some industry support groups have historically been in favor of the 12 hour shift. In talking to fellow EMS pilots, there seems a conflict in opinion. Most of the pilots that I know, prefer the longer duty periods with more time off between shifts. The FAA would do well to re-evaluate their stand on the interpretation of the paragraph covering hemes operations and return the choice of hospital shift lengths to the discretion of the operators and crews. A more lenient stand is called for. Crew and patient safety would be enhanced. There is nothing to be gained by requiring 12 hour shifts, particularly in the less busy programs.

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Original NASA ASRS Text

Title: EMS SMA PLT COMPLAINT ABOUT SCHEDULING.

Narrative: THE FOLLOWING IS MY INTERPRETATION OF FAR PART 135.271 AS APPLIED TO THE HEMES PROGRAM HERE. CREW MEMBERS PERFORMING 48 HR DUTY ASSIGNMENTS ARE NOT IN VIOLATION OF THIS PARAGRAPH WHEN 8 HR CONSECUTIVE AND UNINTERRUPTED REST PERIODS ARE OBSERVED. WHEN FLT ACTIVITY IS SUCH THAT THE 8 HR REQUIREMENT IS THREATENED, AN ON-CALL BACK-UP PLT IS IMMEDIATELY SUMMONED TO ASSUME HOSPITAL DUTY. THE RECENT CHANGE TO 12 HR SHIFT ROTATIONS HERE AND THROUGHOUT COMPANY EMS OPS HAS ACTUALLY HAMPERED EFFORTS TOWARD SUFFICIENT CREW REST. MANY EMS PLTS RESIDE A CONSIDERABLE DISTANCE FROM THEIR HOSPITAL DUTY ASSIGNMENTS. IN CHANGING FROM THE FORMER 48 HR SHIFTS, TO THE CURRENT 12 HR ROTATIONS, THESE PLTS FIND IT IMPRACTICAL TO COMMUTE BTWN HOME AND WORK ON A DAILY OR EVEN NEAR DAILY BASIS. THE RESULT IS EITHER POOR QUALITY REST AT OR NEAR THE HOSPITAL OR COUNTLESS HRS AND MILES ON THE HWY. JOB SATISFACTION, FAMILY RELATIONS, AND FINANCIAL WELL BEING ALL SUFFER. ANOTHER PROB ASSOCIATED WITH THE 12 HR SHIFTS IS THE INFLEXIBILITY OF DUTY SCHEDULES WHEN ATTEMPTING TO ACCOMMODATE PERSONAL NEEDS FOR TIME OFF SUCH AS VACATIONS, MIL RESERVE DUTY AND ILLNESS OR UNANTICIPATED FAMILY EMER. EVEN WITH 4 PLTS PER ACFT, AS MOST PROGRAMS ARE, ANY DEVIATION FROM THE NORMAL ROTATION BECOMES A MAJOR DISRUPTION FOR ALL CONCERNED. 48 HR SHIFTS WERE FAR MORE CONDUCIVE TO MINOR SCHEDULE ADJUSTMENTS. IT IS MY UNDERSTANDING THAT SOME INDUSTRY SUPPORT GROUPS HAVE HISTORICALLY BEEN IN FAVOR OF THE 12 HR SHIFT. IN TALKING TO FELLOW EMS PLTS, THERE SEEMS A CONFLICT IN OPINION. MOST OF THE PLTS THAT I KNOW, PREFER THE LONGER DUTY PERIODS WITH MORE TIME OFF BTWN SHIFTS. THE FAA WOULD DO WELL TO RE-EVALUATE THEIR STAND ON THE INTERPRETATION OF THE PARAGRAPH COVERING HEMES OPS AND RETURN THE CHOICE OF HOSPITAL SHIFT LENGTHS TO THE DISCRETION OF THE OPERATORS AND CREWS. A MORE LENIENT STAND IS CALLED FOR. CREW AND PATIENT SAFETY WOULD BE ENHANCED. THERE IS NOTHING TO BE GAINED BY REQUIRING 12 HR SHIFTS, PARTICULARLY IN THE LESS BUSY PROGRAMS.

Data retrieved from NASA's ASRS site as of August 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.