Japan Airlines Flight/Duty time limitations -

Comparison of the Imposed company Work Rules

and the Abrogated Work (Labor) Agreements

Company Imposed Flight Time and Duty Time limitations

AFTER November 1, 1993 Based on the Work Rules unilaterally implemented by JAL

"Single Complement" i.e. Minimum Crew

Number of landings

1 landing

2 landings

3 landings

4 landings

Local time of day

of show up

(reporting)

Maximum

Flight

Time

Maximum

Duty

Time

Maximum

Flight

Time

Maximum

Duty

Time

Maximum

Flight

Time

Maximum

Duty

Time

Maximum

Flight

Time

Maximum

Duty

Time

06:00 to 07:59

10:30

14:30

09:00

13:30

07:30

12:00

06:00

11:00

08:00 to 14:59

11:00

15:00

09:30

14:00

07:30

12:00

06:00

11:00

15:00 to 21:59

10:30

14:30

09:00

13:30

07:30

12:00

06:00

11:00

22:00 to 05:59

09:00

13:00

08:30

13:00

07:30

12:00

06:00

11:00

"Multiple Complement" i.e. Augmented Crew

(2 captains + 1 copilot. 2 fight engineers on 3 crew aircraft)

Maximum

Flight

Time

Maximum

Duty

Time

15:00

20:00

"Double Complement" i.e. Augmented Crew

(2 captains + 2 copilots. 2 flight engineers on 3 crew aircraft)

"Double complement" is abolished on company-imposed work rule.

Maximum

Flight

Time

Maximum

Duty

Time

Not applicable

These limitations apply for monthly schedule planning purposes only, and newly implemented "Principle of completion of flight duty" clause governs once a flight departs from the boarding gate.

According to the newly implemented "Principle of completion of flight duty", as a principle, flight crew must complete a flight duty to the final destination once the airplane leaves the departure point. However, the pilot in command must discontinue the flight if he considers that safety may be jeopardized by extended period of flight duty upon consideration of operational situations, crew fatigue etc. and with consultation with other crewmembers.

 

Flight time and Duty Time limitations BEFORE November 1, 1993

BASED ON THE WORK AGREEMENTS UNILATERALLY REVOKED BY JAL IN 1993

"Single complement" i.e. Minimum Crew

Number of landings

1 landing

2 landings

3 landings

4 landings

Maximum Flight and

Duty time period

(regardless of

reporting time)

Maximum

Flight

Time

Maximum

Duty

Time

Maximum

Flight

Time

Maximum

Duty

Time

Maximum

Flight

Time

Maximum

Duty

Time

Maximum

Flight

Time

Maximum

Duty

Time

 

09:00

13:00

08:30

13:00

07:30

12:00

06:00

10:00

"Multiple Complement" i.e. Augmented Crew

(2 captains + 1 copilot. 2 fight engineers on 3 crew aircraft)

Maximum

Flight

Time

Maximum

Duty

Time

14:00

20:00

"Double Complement" i.e. Augmented Crew

(2 captains + 2 copilots. 2 flight engineers on 3 crew aircraft)

Maximum

Flight

Time

Maximum

Duty

Time

15:00

20:00

 

CHRONOLOGY

February 1990

With the advent of the introduction of B747-400 into the Pacific Route in August 1990, Japan Civil Aviation Bureau (JCAB) decided to enact standards for the flight time limitations and crew complement for long range operations of air transport services. (quoted from JAPA report)

Prior to that, there had been no specific national standard, and the Japanese air carriers had stipulated their own flight and duty time limitations in their operations manuals approved by JCAB.

May 1990

JCAB requested Japan Aircraft Pilot Association (JAPA) to review this matter. (quoted from JAPA report)

May 1990

JAPA established Committee on the crew complement of long range flight operations , and it started the study of flight time limitations within consecutive 24-hour period.

June 25, 1990

The JAPA Committee submitted an interim report to JCAB in which it proposed 12 hours for three-crew aircraft and "tentatively" 8 hours for two-crew aircraft as flight time limitations based on US current standard.

In the interim report, JAPA mentioned that 8-hour limitation is tentative and much too conservative a figure because the FAA rule had been made some forty years before when recent new-generation reduced workload two-crew aircraft capable of long range international flight had been non-existent.

It also stated that JAPA would propose extension of two-crew flight time limitation after comparison and analysis of workload and fatigue between two-crew and three-crew aircraft.

JAPA further mentioned that, in terms of flight time limitation for recently developed two-crew aircraft, it might not be appropriate to differentiate two-crew and three-crew aircraft, and that if the workload and crew fatigue of two-crew aircraft were found comparable, the flight time limitation could be extended to match that of three-crew aircraft.

June 26, 1990

A day after the JAPA interim report was submitted to Japan Civil Aviation BureauJCAB issued a official notice stipulating flight time limitation of 12 hours for three-crew aircraft and 8 hours for two-crew aircraft as a national standard.

August 1,1990

Japan Airlines revised its Operations Manual and extended the flight time limitation for three-crew aircraft from former 10 hours to 12 hours "to match the national standard (quote)".

This revision was accompanied by the note from the Director of Flight Operations mentioning that the new standard would not be applied for the time being.

   

Feb. - June 1992

JAPA conducted crew-fatigue study on Pacific routes with participation of Japan Airlines and All Nippon Airways with augmented crew complement (with one exception of non-augmented crew flight).

Sept. 17, 1992

Teiki Koukuu Kyokai (association of Japanese airline management) including Japan Airlines, All Nippon Airways and Japan Air System submitted to JCAB a petition calling for deregulation of safety regulations.

The first item on the 32-item petition was "the extension of flight time limitation for two-crew aircraft to match that of three-crew aircraft".

December 17, 1992

JAPA submitted to JCAB the final report of the study concluding that,

-Workload and crew fatigue levels of two-crew and three crew aircraft are comparable judging from the results of workload analysis conducted in the certification processes of new-generation two-crew aircraft, the results of the field measurement/comparison of crew fatigue as well as current limitations in effect in other countries.

-Therefore, it is not necessary to make two-crew flight time limitation more stringent than that of three-crew aircraft.

-Therefore, it is appropriate that the flight time limitation and crew complement for new-generation two-crew aircraft engaged in international long-range operations should be the same as those being applied to three-crew aircraft.

December 21, 1992

Four days after the JAPA final report was submitted to JCAB,

The JCAB issued an amendment of official notice stipulating 12 hours as flight time limitation for two-crew aircraft.

Feb. 20, 1993

Japan Airlines revised its Operations Manual to establish 12 hours as flight time limitation for two-crew aircraft which was 4 hours longer than the previous standard.

Feb. 26, 1993

Japan Airlines presented to Japan Airlines Flight Crew Union a new work agreement proposal, extremely inferior to the former one, which would enable non-augmented flight up to 11 hour block time (two-hour extension for three-crew aircraft and four hour extension for two-crew aircraft over the agreement that existed then.)

July 22, 1993

Japan Airlines notified Flight Crew Union that it would revoke the work agreement with the union (including flight/duty time limitations) that had been in effect for the preceding twenty years as of the end of October 1993.

(Japanese regulation requires 90-day prior notice.)

November 1, 1993

Following the revocation of the work agreement with Flight Crew Union, Japan Airlines unilaterally established new work rules identical with the proposed new agreement to which Flight Crew Union did not agree, and immediately implemented them in flight operations. Japan Airlines asserted that with no agreement in effect, the only applicable rule was the company work rules.

April 22, 1994

Japan Airlines Flight Crew Union filed a civil lawsuit at Tokyo District Court calling for the Court's judgment that there were no obligations on the part of union members to comply with the work rules conditions unilaterally implemented by Japan Airlines.

November 25, 1999

Tokyo District Court delivered court ruling.

December 7, 1999

Japan Airlines appealed.