ECA has also received growing numbers of reports about irregularities. ECA Member Associations were therefore invited to provide pilot rosters and OPS Manuals that violate EU law or use ‘creative’ interpretations that are incompatible with the EU’s safety objective. While information is still coming in, data received so far shows a worrying picture. On the one side there are those operators who do not seem to understand the complexities of Subpart Q.  

Obviously, they are not helped by the imprecise wording of its provisions, which can leave even the most well-intentioned operator at a loss. For these cases, ECA has requested the EU Commission to urgently provide clarification through guidance material on how to correctly interpret Subpart Q. On the other hand, there are those operators who understand Subpart Q to a level of perfection where they exploit – very skillfully – each and every loophole. The resulting rosters are of serious concern as to their potential impact on flight safety. Again, ECA has informed the Commission and requested it takes appropriate action.

It comes as no surprise that most of the extreme excesses take place in companies with a punitive management culture, little consultation of flight crew on safety issues, and sometimes even outright hostility towards any kind of staff representation. It also is not surprising that such practices are only possible because the National Safety Authorities do not exercise proper safety oversight of their operators. This is either due to a lack of personnel and expertise, or because they prefer to look away to allow their national operators to “prosper” unhampered by European safety requirements.