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Draft effective 1Dec drafted by DGCA to be voided

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Respected Sir


As Airline Transport Pilots who take immense pride in the critical responsibilities entrusted upon us by the regulator towards safe conduct of public transport operations, we are writing this to you to express our grave concerns about the aforementioned draft CAR.

As this CAR addresses Pilot Sick Reports, we request that your kind office investigate if airlines have sufficient number of pilots to cater for seamless operations in case of minimal sick reports. Pilots, as per contract, have limited number of Sick Leave per year. Violation of this should be a simple matter of employer-employee resolution.

We would like to express our whole hearted agreement with point 3.1.

With respect to point 3.2 and "Dynamic Roster";

The provision demands that a pilot be available and ready for flight duty, inclusive of handling emergencies, on a 24 x7, 365 day basis, if within FDTL. This is not humanly possible.

For example, a pilot deep in sleep, while resting for a rostered 6 p.m departure the next day, could be disturbed at 2 a.m by a phone call from his employer to operate a flight at 6 a.m, under duress within the provisions of this CAR. This is a flight safety hazard.

Fatigue:

Mental or physical fatigue is not a quantifiable medical condition. Our profession entails erratic sleep patterns and irregular intake of nutritious food. FDTL does not take into account such biological factors. A pilot, without undue duress, is the only one who can decide if he is fit or unfit to carry out his duties to a completely safe standard.

Work/life balance:

This provision totally ignores the existence of life beyond flying duties. Please consider us as human beings with families and personal commitments as well.

With respect to point 3.3:

The provision of this CAR identifies weekends (104 days per annum) and festivals (depending upon region/religion, approx 50 per annum). This accounts for 1/3rd of the entire year, when a pilot is not supposed to fall sick. This is unrealistic.

If the concern is about medical fitness of pilots who report sick on a periodic basis, we request that your esteemed office define a numerical value for the same. Allow us to also point out that detailed medical appointments/investigations by company doctors/IAM/AFCME etc. will result in further loss of man-days, which will lead to further flight disruptions.

With respect to point 4:

A pilot, for reasons best known to himself, being unable to conduct his duties, being forced to fly, is a bigger threat to flight safety. Such danger supersedes any inconvenience caused by flight disruptions. A pilot reporting sick has no effect on flight safety.


Airline Managements have a majority say in Flight Duty Time Limitations and often interpret the same as per their requirements. There have also been multiple cases of flights being delayed by even just a minute to fit a pilot with minimum rest for the sake of flight operations. No other industry requires its employees to provide six months notice on one hand at the same time regulate basic employee privileges such as Sick Leave.


With the increasing number of regulations forced upon us, passenger safety will further be deeply impacted if sick pilots are forced to fly due to legal implications on their license. 


Indian aviation has already seen one terrible accident in the form of Mangalore before our regulations were updated. Let us all work together to prevent such an event from ever happening again.


Pilots only report sick when they believe that operating flight may not be safe due to their medical condition or fatigue. If their children or parents are very sick and there is no one to look after, they are denied casual leave by employers.

If a pilot thinks he is under some mental stress and it's not a good idea to operate flight and endanger lives of hundreds of passengers in that condition pilot report sick.

Pilots are human, we have emotions and we don't want to endanger even on passenger's life by flying when it's not safe to fly .

We sincerely hope that your esteemed office under your guidance will reconsider this CAR and keeping in mind public interest and flight safety void the same.


Thanks

Regards

Yours Sincerely

AIRLINE PILOTS



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