Narrative:

After extended duty day and minimum duty rest, our company told us they were assigning us additional legs to fly during our scheduled long remain overnight. We both felt tired and questioned if it was legal. Upon searching far part 121 for domestic rest requirements (121.147), we were extremely confused by the complexity of the wording. We discovered that, according to our company's definition of duty time (1 hour before flight to 15 mins after block in), we had violated the minimum allowable rest the previous night by 22 mins. Since we had actually arrived at the airport for duty 30 mins before the scheduled departure, we felt we were legally within the FARS (though outside our company's interpretation). Lessons learned: 1) the duty rules (far 121.147) are extremely confusing, difficult to apply, and have little to do with real world flying, 2) our company should track these rest periods and 'back up' tired pilots in catching such errors.

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Original NASA ASRS Text

Title: REST PERIOD VIOLATION.

Narrative: AFTER EXTENDED DUTY DAY AND MINIMUM DUTY REST, OUR COMPANY TOLD US THEY WERE ASSIGNING US ADDITIONAL LEGS TO FLY DURING OUR SCHEDULED LONG REMAIN OVERNIGHT. WE BOTH FELT TIRED AND QUESTIONED IF IT WAS LEGAL. UPON SEARCHING FAR PART 121 FOR DOMESTIC REST REQUIREMENTS (121.147), WE WERE EXTREMELY CONFUSED BY THE COMPLEXITY OF THE WORDING. WE DISCOVERED THAT, ACCORDING TO OUR COMPANY'S DEFINITION OF DUTY TIME (1 HR BEFORE FLT TO 15 MINS AFTER BLOCK IN), WE HAD VIOLATED THE MINIMUM ALLOWABLE REST THE PREVIOUS NIGHT BY 22 MINS. SINCE WE HAD ACTUALLY ARRIVED AT THE ARPT FOR DUTY 30 MINS BEFORE THE SCHEDULED DEP, WE FELT WE WERE LEGALLY WITHIN THE FARS (THOUGH OUTSIDE OUR COMPANY'S INTERP). LESSONS LEARNED: 1) THE DUTY RULES (FAR 121.147) ARE EXTREMELY CONFUSING, DIFFICULT TO APPLY, AND HAVE LITTLE TO DO WITH REAL WORLD FLYING, 2) OUR COMPANY SHOULD TRACK THESE REST PERIODS AND 'BACK UP' TIRED PLTS IN CATCHING SUCH ERRORS.

Data retrieved from NASA's ASRS site as of July 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.