WITH TIGHTER RULES BEING PROPOSED FOR PART 135 COMMUTERS; RPTR COMPLAINS ABOUT THE INADEQUACY OF THE PRESENT PART 121 DISPATCHER DUTY AND REST LIMITATIONS.

Narrative

I AM AN ACFT DISPATCHER FOR A LARGE REGIONAL AIRLINE. LATELY; THERE HAS BEEN A LOT OF DISCUSSION ABOUT THE SAFETY OF PART 135 VERSUS PART 121 COMMUTERS; SPECIFICALLY WITH REGARD TO PLT FLT AND DUTY TIME LIMITS. I HAVEN'T HEARD ANYONE ADDRESS THE DUTY TIMES OF THE PEOPLE WHO MAKE THE DIFFERENCE BTWN PART 121 AND PART 135; ACFT DISPATCHERS. I FEEL THAT OUR DUTY AND REST TIMES ALSO NEED TO BE LOOKED AT; AS THEY ARE ANTIQUATED; AND ANOTHER PART OF THE SAFETY QUESTION. FAR 121.395 ADDRESSES HOW MANY DISPATCHERS ARE REQUIRED TO BE ON DUTY; BUT IT GIVES NO GUIDELINES; AND ALLOWS AN AIRLINE TO DO HOWEVER IT PLEASES. THIS CAN INCREASE DISPATCHER WORKLOAD IF STAFFING IS INADEQUATE AND LEAD TO FATIGUE AND MISTAKES. FAR 121.465 IS ABOUT OUR DUTY AND REST TIMES; AND PARAGRAPH (B) ALLOWS THE AIRLINE TO DO WHATEVER THEY WISH. ALSO; 8 HRS OF REST BTWN SHIFT IS NOT ENOUGH; AND LEADS TO DISPATCHERS COMING TO WORK EXHAUSTED. I RECENTLY WORKED 8 DAYS IN A ROW; WITH AN 8 HR REST PERIOD BTWN LEAVING ONE EVENING AND MY MORNING RPTING. THEN AFTER EATING AND GETTING READY; THIS ONLY LEAVES ABOUT 6 - 6 1/2 HRS OF SLEEP; IF YOU CAN GET TO SLEEP AFTER HAVING YOUR CIRCADIAN RHYTHMS MESSED UP LIKE THAT. ALSO; SINCE PARAGRAPH 3 SAYS 'OR THE EQUIVALENT THEREOF WITHIN ANY CALENDAR MONTH;' AN AIRLINE CAN LEGALLY WORK YOU FOR 27 DAYS STRAIGHT; AND THEN GIVE YOU 4 DAYS OFF AT THE END OF A MONTH. THAT PROBABLY DOESN'T HAPPEN VERY OFTEN; BUT THE MEANS FOR ABUSE ARE THERE. AT LARGER AIRLINES THAT HAVE UNION PROTECTION FOR THEIR DISPATCHERS; THEY HAVE BETTER WORK RULES BY CONTRACT. BUT; FOR US AT THE COMMUTERS; AIRLINES WILL SAVE MONEY BY WORKING A FEWER PEOPLE AS MUCH AS THEY CAN; RATHER THAN HIRE MORE DISPATCHERS WHO HAVE TO BE PAID BENEFITS. I'M SURE THE RULES WERE WRITTEN ONLY TO BE USED IN EXTREME CASES; BUT JUST LIKE THE PLTS; AIRLINES WILL USE THE REGS TO THEIR FULL ADVANTAGE; AND WORK PEOPLE TO THE LIMIT OF THE LAW. MY EMPLOYER HAS EVEN TOLD ME THAT HE COULD GIVE ME LESS THAN 8 HRS REST IF SOMETHING KEEPS ME LATE THAT IS BEYOND HIS CTL. I FEEL THAT IT MAY BE TRUE THAT HE HAS TO KEEP ME HERE; BUT WHAT WHEN I ARRIVE THE NEXT MORNING IS WITHIN HIS CTL. THE ONLY REASON WE ADJUST THE RPT TIMES FOR PLTS IS BECAUSE THEY HAVE A LEGAL CONTRACT THAT WAS NEGOTIATED BY THEIR UNION. I HAVE NO SUCH PROTECTION. I HAVE ARRIVED AT WORK WITHOUT ADEQUATE REST ON SEVERAL OCCASIONS BECAUSE MY EMPLOYER HAS USED THE LIMITS OF THE RULES. PLEASE LOOK AT THE DISPATCHER'S DUTY AND REST REQUIREMENTS; AS WELL AS THE NUMBER OF DISPATCHERS REQUIRED FOR OPERATIONAL CTL; NOW THAT THE PART 135 RULES ARE BEING LOOKED AT.