Narrative:

Our crew went on duty at XA30 PDT and completed the last segment of the night at kalispell, mt, at XE00 mdt. The next morning we arrived at the airport at XL40 mdt, and departed fca on schedule at XM10 mdt, arriving at mso at XM52 mdt. We were scheduled to depart mso for geg at XN00 mdt, and the be released from duty, but the visibility at geg was about 1000', so our dispatcher requested that we hold on the ground at mso until further advised. The visibility at geg continued to deteriorate to less than 600', so the dispatcher requested that we repos the airplane (part 91) to walla walla, wa, and then fly 2 more segments (part 121) to pasco, wa, and sea. These segments were originally to be flown by another crew. Scheduled departure time from alw to psc was XP30 PDT. We arrived in alw at XP21 PDT and departed for psc at XP34 PDT. We departed psc at XQ22 PDT and arrived at sea at XR22 PDT. At that point, our crew was released from duty. While we were on the ground at mso the first officer, F/a and I discussed our options. We hoped that the fog at geg would lift so that if we could get into geg by XP30 PDT, we could give the airplane to the next crew and begin our rest period. When the dispatcher asked us to go to alw, then on to psc and sea, I looked at our flight and duty time rules in our flight operations manual and in far 121.471. Our flight operations manual no longer contains the statement that the company 'will not schedule a crew to be on duty for more than 16 hours,' so I reviewed 121.471(B). I know now that I misinterpreted this rule. When I looked at it, I thought that we had originally been scheduled legally and that the dispatcher's requested change of schedule was legal due to the WX at geg. Later that day I discussed this with some of our management pilots and I realized that, although the dispatcher had rescheduled us, it is still looked upon as scheduled flight time, as discussed in 121.471(B). Contributing factors: our crew spent 5 hours at the hotel in kalispell, which is typical for this trip. I had been awake for 19 hours, then slept for about 3 hours at kalispell. Fog in spokane disrupted the normal schedule. I later discovered that the dispatcher thought we had begun our duty time at XC30 PDT--we actually began at XA30 PDT. Despite the fatigue factor, the WX in spokane and being a little surprised by the dispatcher's request, I don't want to make any excuses for what happened. I have worked with part 121 rules for more than 4 yrs, and I felt (up until this incident) that I understood them. This incident was an error in judgement on my part and, in retrospect, I'm still surprised that I didn't catch my mistake.

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Original NASA ASRS Text

Title: DUTY TIME LIMITS EXCEEDED WITHOUT INTERVENING REST PERIOD.

Narrative: OUR CREW WENT ON DUTY AT XA30 PDT AND COMPLETED THE LAST SEGMENT OF THE NIGHT AT KALISPELL, MT, AT XE00 MDT. THE NEXT MORNING WE ARRIVED AT THE ARPT AT XL40 MDT, AND DEPARTED FCA ON SCHEDULE AT XM10 MDT, ARRIVING AT MSO AT XM52 MDT. WE WERE SCHEDULED TO DEPART MSO FOR GEG AT XN00 MDT, AND THE BE RELEASED FROM DUTY, BUT THE VIS AT GEG WAS ABOUT 1000', SO OUR DISPATCHER REQUESTED THAT WE HOLD ON THE GND AT MSO UNTIL FURTHER ADVISED. THE VIS AT GEG CONTINUED TO DETERIORATE TO LESS THAN 600', SO THE DISPATCHER REQUESTED THAT WE REPOS THE AIRPLANE (PART 91) TO WALLA WALLA, WA, AND THEN FLY 2 MORE SEGMENTS (PART 121) TO PASCO, WA, AND SEA. THESE SEGMENTS WERE ORIGINALLY TO BE FLOWN BY ANOTHER CREW. SCHEDULED DEP TIME FROM ALW TO PSC WAS XP30 PDT. WE ARRIVED IN ALW AT XP21 PDT AND DEPARTED FOR PSC AT XP34 PDT. WE DEPARTED PSC AT XQ22 PDT AND ARRIVED AT SEA AT XR22 PDT. AT THAT POINT, OUR CREW WAS RELEASED FROM DUTY. WHILE WE WERE ON THE GND AT MSO THE F/O, F/A AND I DISCUSSED OUR OPTIONS. WE HOPED THAT THE FOG AT GEG WOULD LIFT SO THAT IF WE COULD GET INTO GEG BY XP30 PDT, WE COULD GIVE THE AIRPLANE TO THE NEXT CREW AND BEGIN OUR REST PERIOD. WHEN THE DISPATCHER ASKED US TO GO TO ALW, THEN ON TO PSC AND SEA, I LOOKED AT OUR FLT AND DUTY TIME RULES IN OUR FLT OPS MANUAL AND IN FAR 121.471. OUR FLT OPS MANUAL NO LONGER CONTAINS THE STATEMENT THAT THE COMPANY 'WILL NOT SCHEDULE A CREW TO BE ON DUTY FOR MORE THAN 16 HRS,' SO I REVIEWED 121.471(B). I KNOW NOW THAT I MISINTERPRETED THIS RULE. WHEN I LOOKED AT IT, I THOUGHT THAT WE HAD ORIGINALLY BEEN SCHEDULED LEGALLY AND THAT THE DISPATCHER'S REQUESTED CHANGE OF SCHEDULE WAS LEGAL DUE TO THE WX AT GEG. LATER THAT DAY I DISCUSSED THIS WITH SOME OF OUR MGMNT PLTS AND I REALIZED THAT, ALTHOUGH THE DISPATCHER HAD RESCHEDULED US, IT IS STILL LOOKED UPON AS SCHEDULED FLT TIME, AS DISCUSSED IN 121.471(B). CONTRIBUTING FACTORS: OUR CREW SPENT 5 HRS AT THE HOTEL IN KALISPELL, WHICH IS TYPICAL FOR THIS TRIP. I HAD BEEN AWAKE FOR 19 HRS, THEN SLEPT FOR ABOUT 3 HRS AT KALISPELL. FOG IN SPOKANE DISRUPTED THE NORMAL SCHEDULE. I LATER DISCOVERED THAT THE DISPATCHER THOUGHT WE HAD BEGUN OUR DUTY TIME AT XC30 PDT--WE ACTUALLY BEGAN AT XA30 PDT. DESPITE THE FATIGUE FACTOR, THE WX IN SPOKANE AND BEING A LITTLE SURPRISED BY THE DISPATCHER'S REQUEST, I DON'T WANT TO MAKE ANY EXCUSES FOR WHAT HAPPENED. I HAVE WORKED WITH PART 121 RULES FOR MORE THAN 4 YRS, AND I FELT (UP UNTIL THIS INCIDENT) THAT I UNDERSTOOD THEM. THIS INCIDENT WAS AN ERROR IN JUDGEMENT ON MY PART AND, IN RETROSPECT, I'M STILL SURPRISED THAT I DIDN'T CATCH MY MISTAKE.

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.