Page:Aviation Accident Investigation - TWA crash on 6 May 1935 - Memorandum to the Secretary of Commerce.pdf/2

 "(B) Such 45 minutes of additional fuel and oil shall be above and beyond that required by abnormal wind and weather conditions. This margin is intended to guard against possible extraordinary consumption, mechanical losses, or other unforseen contingencies."

"(C) On flights of unusual duration and/or circumstances, such as instrument or over top flying, the minimum amounts required for such flights shall be specified in the approved section of the company's operations manual."

Because it is deemed to be pertinent, Chapter 8, Section 7 (G) is also quoted. This regulation is equally applicable to the subject matter of dispatching.

Chapter 8, Sec. 7 (G) (International instrument flying authorized provided) — "There is an airport or intermediate field, equipped with radio range beacon within the fuel range of the airplane exclusive of the reserve fuel supply, other than the point of intended landing, which has a steady or improving ceiling of not less than 1,500 feet and a visibility of not less than 2 miles."

5. As to possible pilot fatigue, there was no direct evidence to prove that such was a contributory cause of the accident. Again, it should be mentioned that last Fall the Bureau reduced the maximum allowable time for first pilots from 1,320 hours yearly to 1,000 hours yearly, and the hours of co-pilots from no limitation to not more than 100 hours per month. From January 1st of this year, the Department policy has been to accept the recommendations of the specialized air line medical examiners for these maximum flight limitations. The pilot of the crashed plane had averaged 83 hours for the three previous months and has no flight duty for some five days prior to this flight.

However, there have been for a period of years, regulations prescribing a maximum total of 8 hours daily under certain conditions. TWA had been granted a waiver by the Bureau of this allowable maximum because the schedule between Kansas City and Los Angeles exceeded the limitation. The policy of that company was to fly the pilots more than the customary period in a single day, without however, exceeding the maximum total for the month. There are both advantages and disadvantages to this system, but it is now felt by the Bureau that delays enroute which add to both the scheduled flight time and time on duty, are of sufficient concern to rescind all waivers of this daily 8-hour total. Also, even though the pilot's condition could not be included as a contributory cause, further study is being made by the Bureau regarding the daily flight limitation and length of a division over which a pilot may operate.

Regulation applicable—Chap. 5, Sec. 3 (C)

"Waivers.—Upon application to and subject to the approval of the Bureau of Air Commerce, strict application of the 8-hour flying time limitation may be waived, but only under exceptional circumstances in which safety is not jeopardized."

6. According to the formal report of the Accident Board, Pilot Bolton was assigned to the Eastern Region on the Kansas City-Columbus-Newark run. The reason for his being assigned to the flight in question, No. 6, one SKY CHIEF, was that about five days previous, April 29–30, he had taken a charter party out to Los Angeles from the East, and when Flight No. 6 was originated, he was available and was assigned to the same. During the five days