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FAA reverses maintenance duty time legal interpretation — PAMA submission helps!

from PAMA

PAMA believes that looking at days worked alone totally misses the mark when it comes to fatigue. There are numerous factors that must be considered as a whole to have a viable fatigue prevention system.

Some of the issues concern hours worked in a day. A technician might work three days in a row of 16 hours each and become fatigued way before a six-day work week ever became an issue. Also, a technician who normally works until midnight might become fatigued after only two hours of overtime due to working past the time he would normally go to sleep.

Additionally, what the person is doing while off duty can play a large role in the person's ability to perform their duties safely. A technician, who works nights, could easily spend their day cutting down trees, or cultivating a garden. Many of these tasks are more labor intensive than the actual aircraft maintenance.

This was put together by a group of individuals who serve on our Technical Committee. They are all A&P's with over 20 years each in the field. Several have DME, DAR, DER or IA behind their names, and also diverse backgrounds in Corporate, General and Airline plus manufacturing. It didn't come out of a vacuum which is the best thing I see from this committee. They know and have experienced a lot plus they research it within their own business environments. I hold them in high esteem and greatly appreciate all they do for PAMA members.

We are pleased that ARSA, Transport Workers Union of America and PAMA made direct comments on this ruling. Many other organizations also supported the effort. more

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