A WDB FREIGHTER CAPT COMPLAINS OF FATIGUE IN INTL OPS.

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THE FLT WERE CONDUCTED UNDER THE FLAG ACR PROVISIONS OF FAR 121. THE PAIRINGS WERE CONSTRUCTED TO BE WITHIN THE ALLOWABLE FLT AND DUTY TIME LIMITS OF THOSE REGS. ON MY FIRST RETURN TO ANC; MY 7 DAY TIME WAS 32 PLUS 25. ON MY SECOND RETURN TO ANC; MY 7 DAY TIME WAS 38 PLUS 26. 7 DAY TIME IS NOT REGULATED IN FAR 121 FLAG CARRIER TIME LIMITATIONS. MY COMPANY HAS BEEN GIVEN AN OPINION BY OUR FAA PRINCIPAL OPS INSPECTOR THAT 7 DAY TIME STARTS AT MIDNIGHT AT SDF; WHICH COMPLICATES THE CALCULATION OF 7 DAY TIME DOES NOT ACCURATELY REFLECT FATIGUE LEVELS OF PLTS. REST IN ANY HOTEL DURING THE DAY IS MARGINAL AT BEST. ON THE FIRST TRIP FROM HKG TO ANC; I WAS UNABLE TO SLEEP AFTER XA00Z (XIAM HKG TIME). THAT RESULTED IN A WAKING DAY OF 21 PLUS HRS PRIOR TO MY LNDG AT ANC. ON MY SECOND TRIP FROM HKG TO ANC I DID SLIGHTLY BETTER; AND AWAKENED AT XB00Z. ALTHOUGH THIS PAIRING IS LEGAL; I WAS EXTREMELY FATIGUED; AND BY THE LAST RETURN TO ANC; AK; I WAS MARGINALLY EFFECTIVE AS A CAPT. FORTUNATELY; THE ACFT FLOWN WAS SOUND MECHANICALLY AND THE WX WAS NOT TOO BAD. THERE WAS SOME CONFUSION RESULTING FROM A CHANGE OF OPERATIONAL RWYS. I REALLY FELT UNSAFE BUT LUCKY NOTHING SERIOUSLY UNUSUAL HAPPENED. I HATE RELYING ON LUCK. I THINK THE FAR STANDARDS FOR FLAG DUTY AND FLT TIME LIMITATIONS; WHEN CONSTANTLY PUSHED TO THE MAX; POSE A REAL SAFETY HAZARD. I FEEL THAT INADEQUATE CONSIDERATION OF CIRCADIAN RHYTHM POSES AN IMMEDIATE DANGER (SUCH AS AN INORDINATELY FATIGUED CREW IN A DEMANDING SIT) AND A LONG TERM CUMULATIVE DANGER (E.G.; EARLY MORTALITY). THE REGS GIVE NO CONSIDERATION TO THESE FACTORS; BUT IN COMBINATION; THEY POSE AVIATION'S DEADLIEST COCKTAIL.