Narrative:

Day 1: on duty at XA05, off duty at XN05. Total duty time = 14 hours. Due to bad WX and flight cancellations we only flew 3 legs, 2.7 block hours. Day 2: company allowed reduced rest of 8 hours. On duty at XB05, off duty at XO00. Total duty time = 15.9 hours. If we had performed our normal post-flight duties we would have exceeded 16 hours duty. Due to bad WX at the beginning of the day, we had 7.8 block hours, 3.3 night and .7 IFR, 10 legs. The current rest requirements/duty limitations are terribly inadequate. During the last leg of the second day I found myself continuously asking the first officer if I had performed certain duties or functions because I just couldn't remember. Luckily I was on my second crew, the first officer had just come on duty and at least one of us was functioning normally. If there had been some sort of in-flight emergency we could have had serious trouble. Many airlines, especially the regional/commuters are having a difficult time retaining pilots and are always short staffed. Therefore, it seems we're in a constant state of crisis management, and using the rest requirement/duty limitation as a target value, rather than an absolute minimum/maximum. Due to delays such as waiting for hotel vans, time spent going to and from the hotel, checking in and out, getting dressed, etc. 8 hours of rest usually translates into approximately 6 hours rest. Let this be followed by a 16 hour duty day and you have an accident waiting to happen.

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Original NASA ASRS Text

Title: COMPLAINT ABOUT UNREALISTIC FEDERAL AVIATION REG LIMITATIONS ON CREW DUTY TIME AND CREW REST REQUIREMENTS.

Narrative: DAY 1: ON DUTY AT XA05, OFF DUTY AT XN05. TOTAL DUTY TIME = 14 HRS. DUE TO BAD WX AND FLT CANCELLATIONS WE ONLY FLEW 3 LEGS, 2.7 BLOCK HRS. DAY 2: COMPANY ALLOWED REDUCED REST OF 8 HRS. ON DUTY AT XB05, OFF DUTY AT XO00. TOTAL DUTY TIME = 15.9 HRS. IF WE HAD PERFORMED OUR NORMAL POST-FLT DUTIES WE WOULD HAVE EXCEEDED 16 HRS DUTY. DUE TO BAD WX AT THE BEGINNING OF THE DAY, WE HAD 7.8 BLOCK HRS, 3.3 NIGHT AND .7 IFR, 10 LEGS. THE CURRENT REST REQUIREMENTS/DUTY LIMITATIONS ARE TERRIBLY INADEQUATE. DURING THE LAST LEG OF THE SECOND DAY I FOUND MYSELF CONTINUOUSLY ASKING THE F/O IF I HAD PERFORMED CERTAIN DUTIES OR FUNCTIONS BECAUSE I JUST COULDN'T REMEMBER. LUCKILY I WAS ON MY SECOND CREW, THE F/O HAD JUST COME ON DUTY AND AT LEAST ONE OF US WAS FUNCTIONING NORMALLY. IF THERE HAD BEEN SOME SORT OF INFLT EMER WE COULD HAVE HAD SERIOUS TROUBLE. MANY AIRLINES, ESPECIALLY THE REGIONAL/COMMUTERS ARE HAVING A DIFFICULT TIME RETAINING PLTS AND ARE ALWAYS SHORT STAFFED. THEREFORE, IT SEEMS WE'RE IN A CONSTANT STATE OF CRISIS MGMNT, AND USING THE REST REQUIREMENT/DUTY LIMITATION AS A TARGET VALUE, RATHER THAN AN ABSOLUTE MINIMUM/MAX. DUE TO DELAYS SUCH AS WAITING FOR HOTEL VANS, TIME SPENT GOING TO AND FROM THE HOTEL, CHKING IN AND OUT, GETTING DRESSED, ETC. 8 HRS OF REST USUALLY TRANSLATES INTO APPROX 6 HRS REST. LET THIS BE FOLLOWED BY A 16 HR DUTY DAY AND YOU HAVE AN ACCIDENT WAITING TO HAPPEN.

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.