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ORO.GEN.110 (a): “The operator is responsible for the operation of the aircraft in accordance with Annex IV to Regulation (EC) No 216/2008”. Is this requirement met when an Operator follows the Implementing Rules (965/2012)?

What are the responsibilities of the AOC holder required to implement a management system in accordance with ORO.GEN.200 in regards to continuing airworthiness management and contracted maintenance?

Is there a difference between safety risk management (SRM) and SMS?

Why do the EASA Air Operations rules use the term ‘management system’ (ORO.GEN.200) and not ‘safety management system’ (SMS), like in ICAO Annex 19? Is there a difference between the two concepts?

If an operator is considered complex , may a person hold the position as a Safety Manager and at the same time be one (or more) of the nominated persons as described in ORO.GEN.210(b), taken into account the size and complexity of the operator?

I am looking for the acceptance of post holders, particularly the Safety manager. In the AMC we agreed on the functions of the Safety manager, but did we agree on his or her acceptance?

Regarding ORO.GEN.200, could a commercial operator of complex motor powered aircraft, such as the Cessna Citation Bravo that operates within Europe and with no SPAs, be considered non-complex?


How should an operator use external material in relation with its operations manual (OM)?


Status of the EASA FAQ: What is the legal status of the EASA FAQ? My own understanding of this document is that it has no legal standing at all, insofar as it is neither an Implementing Rule (IR), Acceptable Means of Compliance (AMC), Alternative Means of Compliance (AltMoc) nor even Guidance Material (GM).

Applicability of FTL requirements of Regulation (EU) No 965/2012: Why should we comply with the FTL requirements of Regulation (EU) No 965/2012, since we have a policy in our company that says otherwise?

Applicability of Regulation (EU) No 965/2012: What is the meaning of "applicable national flight time limitation legislation" in Article 8 (4) of Regulation 965/2012?

Collective Labour Agreements (CLA) - Regulation (EU) No 83/2014: Our company has a Collective Labour Agreement (CLA) and an approved IFTSS. Both contain rules about FPD’s, DP’s and rostering. Which one is leading?

Applicability of Subpart FTL (see also ORO.AOC.125): Does Subpart FTL apply in relation to non-revenue flights (ferry flights)?

Acclimatisation ORO.FTL.105(1): How should we determine the state of crew member acclimatisation in complex rotations?

Accommodation ORO.FTL.105 (3): Can the airport crew lounge be considered as “accommodation” for the purpose of standby or split duty? Can a hotel room for several crew members of the same gender be considered as “accommodation” for the purpose of standby and split duty?

Disruptive schedule ORO.FTL.105(8): Which criteria should be applied to determine a duty as disruptive if there is a time zone difference between the reporting point and the place where the duty finishes?

Definition of duty and duty period, ORO.FTL.105 (10), ORO FTL 105 (11): Must the time for self-preparation (e.g. preparing for the checks associated with initial or recurrent training) be entered in the schedule of the crew members and recorded?

Single day free of duty ORO FTL 105 (23): A ‘single day free of duty’ consists of one day and two local nights. Does the last day of several consecutive days free of duty need to contain at least one day and two nights?

Sector ORO.FTL.105 (24), (see also ORO.FTL.205 (f)(6)): In an abnormal or emergency situation a take-off might not be executed meaning that a sector was not completed. Such situation is likely to increase flight crew workload and fatigue. How could this be mitigated?

Changes to a published roster: Is it possible to make changes to a published roster?

Change of FDP after reporting: Can a rostered FDP be changed (re-planned) after crew members have reported?

Roster publication, (see also AMC1 ORO.FTL.110(a) and ORO.GEN.120): Are airline operators allowed to publish monthly rosters in less than 14 days in advance?

Reporting times ORO.FTL.110(c), (see also ORO.FTL.205(c)): Can the pre-flight reporting time for non-augmented flight crew members reporting for the same FDP be different?

Operational robustness ORO.FTL.110(j): How should operational robustness be assessed?

Flying activities outside an AOC (see also ORO.FC.100): How will activities as an instructor or an examiner performed by an operating crew member in their free time be considered for the purpose of duty time and rest periods?

Deviation from the applicable CS ORO.FTL.125 (c) (see also ARO.OPS.235): What does a deviation from the applicable CS mean or derogation from an implementing rule?

Flight time specification scheme for air taxi operations, (see also Articles 2 (6) and 8(2) of Regulation (EU) no 965/2012): An air taxi operator has both an aeroplane with less than 19 seats and one aeroplane with more than 20 seats. What FTL regulation shall the crew who is flying both types follow?

Approval of Individual Flight Time Specification Schemes (IFTSS), (see also ARO.OPS.235):

Unknown state of acclimatisation GM1 ORO.FTL.205(b)(1): If the crew member is in an unknown state of acclimatisation, what is the reference time?

Unknown state of acclimatisation ORO.FTL.205(b)(3): What are the daily FDP limits when crew members are in an unknown state of acclimatisation under fatigue risk management (FRM)?

Mixing FDPs extended without in-flight rest and FDP’s extended due to in-flight rest ORO.FTL.205 (d) ORO.FTL.205 (e): Is it possible to roster two extended FDPs without in-flight rest and one extended FDP with in-flight rest in 7 consecutive days?

Planned FDP extensions ORO.FTL.205(d): Must planned extensions be included in the operator’s roster?

Planned FDP extensions ORO.FTL.205(d) (see also ORO.FTL.105(1)): Can a crew member acclimatised to the local time of the departure time zone (‘B’ state), but not acclimatised to the local time where he/she starts the next duty (‘D’ state), be assigned a planned extended flight?

Commander’s discretion ORO.FTL.205(f): Do we need to use Commander’s discretion if actual FDP is going to last more than planned but less than the maximum daily FDP allowed?

Commander’s discretion ORO.FTL.205(f): When should commander’s discretion be used?

Commander’s discretion ORO.FTL.205(f), (see also ORO.FTL.205 (d)): 1. What is the maximum FDP extension allowed under commander’s discretion? 2. How would commander’s discretion apply when the FDP of a non-augmented crew has already been extended in accordance with ORO.FTL.205 (d))?

Commander’s discretion ORO.FTL.205(f): Referring to commander’s discretion, do I need to consider the reporting time and number of sectors?

Conversion/line checks Post flight duty ORO.FTL.210: How should briefings and debriefings during conversion/line checks be accounted for?

Post-flight duty AMC1 ORO.FTL.210(c): What should the operator do if the actual post flight duty time is longer than the established time in the OM?

Positioning for purposes other than operating ORO.FTL.215 (b): How should time spent to travel from the place of rest or home base to a simulator (when outside the base) be taken into account?

Positioning ORO.FTL.215: Does positioning begin when the crew member arrives at the airport/train station or when the aeroplane/train leaves?

Positioning ORO.FTL.215: Shall a positioning between active sectors count as a sector for a pilot or cabin crew?

Split duty ORO.FTL. 220: Is it possible to have more than one split duty within one FDP?

Standby ORO.FTL.225(a) (see also CS FTL.1.225 and GM1 CS FTL.1.225(a)): Can a standby be finished before the planned “end time notified in advance”, after a notification during the standby (saying that there will be no assignment) and the rest period be initiated at the time of the notification of the new standby end?

Reserve ORO.FTL.230: Can a reserve, during which no flight was assigned, be considered as a day off afterwards?

Rest prior to an FDP ORO.FTL.235 (a): If a crew member with office duties spends one day in the office, what should be the duration of the rest before his/her reporting for an FDP?

Rest prior to a duty other than FDP ORO.FTL.235 (a): What is the duration of the rest period prior to a duty without FDP?

Reduction of recurrent extended recovery rest by commander’s discretion ORO.FTL.235(d) (see also ORO.FTL.205(f)): Can the extended recovery rest period be reduced with commander’s discretion?

Increase of interval between two recurrent extended recovery rest periods by commander’s discretion ORO.FTL.235(d) (see also ORO.FTL.205(f)): May the crew member exercise his/her discretion to finish back at home base exceeding the 168 hours’ time between two extended recovery rest periods? For example, a crew member is planned to finish his last FDP flying back to home base, two hours prior to reaching 168 hours. There is a departure delay which occurred after reporting. As a result, the crew member would exceed the 168 hours by 1 hour.

Increase of interval between two recurrent extended recovery rest periods ORO.FTL.235(d): Can the 168h limit between two extended recovery rest periods be extended? For example, a crew member reports at Paris on Monday at 7am and ends a series of flights in Singapore, on Sunday, at 8 pm; he/she should be given his/her extended recovery rest period in Singapore, but might be willing to come back to his/her base, hence infringing the 168h limit through positioning.

Re-planning of recurrent extended recovery rest period ORO.FTL.235 (d): Is re-planning of a recurrent extended recovery rest period allowed and when?

Record keeping ORO.FTL.245: Do records required in ORO.FTL.245 have to reflect planned or actual FDP, DP and rest?

Home base change CS FTL.1.200(b): Is it correct to understand that if a crew member is asked to report for an FDP at a reporting point other than his/her home base without extension of his/her recurrent extended recovery to 72h incl. 3 local nights, immediately prior to that FDP, the home base has not been changed for the purpose of Subpart FTL?

Consecutive night duties CS FTL.1.205(a)(1): What does ‘consecutive’ mean in the context of the requirements and limits of CS FTL.1.205?

Night duties CS FTL.1.205(a)(2), (see also GM1 CS FTL1.205 (a)(2)): Is it necessary to have an ‘approved’ FRM to operate long night duties (FDP over 10hrs)?

In-flight rest CS FTL.1.205(c) : Is it possible to extend the FDP, if not all pilots get an in-flight rest?

Maximum daily FDP with the use of extensions due to in flight rest CS FTL.1.205(c)(2): Why does the ‘maximum daily FDP with the use of extensions due to in flight rest’ not take into account the start of FDP at reference time?

Delayed reporting CS FTL.1.205(d)(1): Is it possible to inform crew members of a delay without giving the new reporting time?

Delayed reporting CS FTL.1.205(d)(1)(iii): Why does delayed reporting with a delay of less than 4 hours not account for the WOCL? Is there any scientific evidence for this?

Split duty (see also ORO.FTL.205 (b)(2) and ORO.FTL.220): Can split duty be scheduled when crew members are in an unknown state of acclimatisation?

Split duty CS FTL.1.220 (b): Are the 30 minutes for post and pre-flight duties as well as travelling counted in total or 30 min for post flight duties, 30 min for travelling after post flight duties, 30 min for travelling before pre-flight duties and 30 min for pre-flight duties?

Split duty CS FTL.1.220(d): Should suitable accommodation be provided for a split duty?

Rest after airport standby or other-standby CS FTL.1.225 (a)(1)& CS FTL.1.225 (b)(4): What is the basis for rest calculation after a standby followed by an FDP? Is it the reporting time for standby or the “actual reporting time” for the assigned FDP?

Airport standby CS FTL.1.225 (a)(2)(ii): Why does CS FTL.1.225 (a)(2)(ii) not stipulate the maximum duration of airport standby?

Airport standby CS FTL 1.225(a)(2)(ii), (see also ORO.FTL.205 (b)&(d); CS FTL 1.205 (a) (2)): We understand that the limit of 16 hours is not applicable when airport standby is followed by a FDP with in-flight rest. Does that mean that there is no limit for that kind of situation?

Other-standby followed by an FDP CS FTL.1.225(b)(2): How shall an operator expect a crew member to use whole or part of a standby for sleep when there are disturbance factors like difficulty to fall asleep, disturbed sleep due to sick children, waking-up by external noise, etc.?

Awake time CS FTL 1 225 (b)(2): Who is responsible for making sure that the 18h are not exceeded? The crew member or the operator? Can the operator fully transfer the responsibility to the crew member?

Other-standby CS FTL.1.225(b)(2), (see also CAT.OP.MPA.210(a)(3)): Would using a controlled rest procedure while the flight crew member is at his/her assigned station break the 18-hour awake time?

Other-standby CS FTL.1.225(b)(3): How is the time spent on other-standby before an assignment accounted for?

Other-standby CS FTL.1.225 (b), (see also ORO.FTL.105 (25)): Is it possible during other-standby to assign an FDP with a reporting time after the rostered end of that standby period has elapsed?

Other-standby modified to airport standby CS FTL.1.225, (see also ORO.FTL.105 (25)): Can other-standby be modified to airport standby during the standby? For example, can a pilot on home standby be required to go to the airport to continue on airport standby? What limits must be used?

Reserve and other-standby CS FTL.1.230: While a crew member is on reserve, can his/her assignment be changed and continue as a home standby?

Reserve CS FTL 1.230(b): Is there any rest requirement after a reserve period, if there is no assignment of duty period during the reserve?

Reserve CS FTL.1.230 (d): Is it necessary to have an FRM to protect an 8-hour sleep opportunity during reserve?

Reserve CS FTL 1.230(d): Should the period of 8 hours run consecutively or is it possible to break it in two different periods?

Rest between disruptive schedules CS FTL.1.235(a)(1), (see also ORO.FTL.105(8)): The rule for transition between late finish/night duty and early start says that the rest between the FDPs needs to include a local night. Does this mean that the rule only applies if the late finish/night duty and the early duty are FDP’s?

Rest compensation for time zone differences CS FTL.1.235(b)(3)(i): How should we count the time elapsed (h) since reporting for the first FDP in a rotation involving at least 4 hour time difference to the reference time?

Reduced rest CS FTL.1.235(b)(3)(ii), (see also ORO.FTL.235 (c) and (e)): Is it possible to reduce the 14h rest away from home base following an FDP involving a 4-hour time difference or more?

Rest to compensate for time zone differences CS FTL.1.235(b)(4): What does Eastward-Westward or Westward-Eastward transition mean?

Monitoring Time Zone Differences CS FTL.1.235(b)(5): Does the requirement to monitor combinations of rotations require FRM in accordance with ORO.FTL.120?

Reduced rest CS FTL.1.235(c)(5): Is it possible to apply reduced rest to two consecutive rest periods?

Nutrition ORO.FTL.240: Are nutrition provisions subject to a specific NAA's approval and can they be documented elsewhere in the OM-A, not necessarily Chapter 7.

Fatigue management training ORO.FTL.250 AMC1 ORO.FTL.250: What should be the minimum requirements for a fatigue management instructor? Is a CRMi course enough? Is a safety manager ready and without other training to deliver a course? Can someone that has received a few hours course in accordance with AMC1 ORO.FTL.250 repeat the course to others?

Reporting point ORO.FTL.105 (2): The global COVID-19 pandemic necessitated, on a number of occasions, a change to the typical aircrew reporting point. How should the operators address this change?

Individual crew members’ records of flight time and duty periods ORO.FTL.245, (see also ORO.FTL.105):

Must the time for all training at the behest of the operator be entered in the schedule of the crew members and recorded?