A321
Flight Crew Air Transport Pilot (ATP)
Communication Breakdown; Situational Awareness; Time Pressure
Deviation / Discrepancy - Procedural FAR; Deviation / Discrepancy - Procedural Published Material / Policy
Human Factors
I was notified by a company representative of a potential FAR 117 violation that occurred approximately 10 days earlier. The potential FAR 117 violation was the result of Flight Duty 'mandatory' extensions that occurred on that pairing. At the time; I was unaware that any FAR 117 rules were (potentially) being breached and I acted in good faith to complete the pairing to the best of my ability and knowledge. At this point; it is my understanding that a flight operations team (along with the Federal Aviation Administration) will be looking into the behavior of Crew Scheduling to determine if there were misinterpretations and/or inappropriate applications of the new FAR 117 Time Limitations and Rest Rules that took effect earlier this year. Again; I was unaware (at the time) of any breach and acted in good faith to complete this pairing; as would be expected of me when acting in my capacity as First Officer. The primary cause of the event (if there was; in fact; an FAR 117 breach) was the likely misunderstanding of the proper application of FAR 117 during contingency operations. I believe clear guidance should be given to Airline Crew Schedulers by the FAA regarding the proper application of FAR 117; particularly during contingency [/irregular] operations. There are elements within FAR 117 that are somewhat ambiguous and highly open to 'interpretation' which may result in potential scheduling abuses and unsafe operations. Furthermore; both pilots and Flight Operations Safety Managers (including the Chief Pilots' Office) need to be provided clear; unambiguous FAA interpretation; so that any potential unsafe or aggressive 'interpretation' is held in check; thus promoting safety above 'mission completion.'
An A321 First officer reported he had been advised of a potential FAR 117 rules violation during irregular operation of a trip some 10-11 days previously by a company representative.