INDIAN COMMERCIAL PILOTS ASSOCIATION

CENTRAL OFFICE
UNITY

INTEGRITY

DIGNITY

SAFETY

Ref: ICPA/SR/MAA/2015 (GS)/179

26th March 2015.
To:
The Director General
Directorate General of Civil Aviation
Aurbindo Marg, Safdarjung Airport,
New Delhi - 110 003.
Sub: Request clarification - Show cause notices issued to pilots.
Dear Madam,
This communication of ours is in respect to the show cause notices issued to pilots in the recent past for
reporting late at PFM by even as less as 1 minute and beyond. It is heartening to see that DGCA is
getting serious about its role as the regulator of the civil aviation industry.
Our concern is that the above mentioned notice threatens about action to be taken in case of
unsatisfactory or no reason given in reply to the show cause notices. We would like to know what are
the provisions of penalty as per the rules for jeopardising flight safety by unintentionally arriving late or
due to reasons beyond control of the individual pilot?
We request you to kindly let us know where and what is documented in the rules as to getting late for a
flight (inadvertently) is an offence or violation and what is the penalty or action reserved or
promulgated for it. We request you to kindly provide us with the copy of same so that we can educate
our member pilots regarding the consequences of such serious and life threatening lapses on their part.
We further request you to treat this as urgent because all these pilots who have been issued show cause
notices are flying under tremendous stress as they know not what is in store for them at the end of the
notice period and what can be the minimum or maximum action taken against them. We are sure as a
regulator you must be aware of the evils of pilots flying under stress.
Different airlines in India have different reporting times for different flights (domestic/international).
For the same kind of job i.e. preflight cockpit safety checks some have 30 minutes prior to departure
others have 35 minutes or even less or more as per their assessment. Accordingly they have fixed
reporting times at PFM/flight despatch, which are not uniform across the board. Clearly this time has
been fixed by individual airlines, and you as DGCA have approved it. We would like to know the rationale
behind this, how is pilot of one airline more efficient than that of other and is able to do the same work
for same type of aircraft and operation in lesser time? What is the criteria to judge such efficiency or
deficiency? What scientific study has been conducted anywhere in the world to arrive at a time which is
minimalistic to perform such duties? Moreover it would be surprising if the airlines would have failed to
keep some buffer or possibility of eventuality in deciding this time so much so that even 1 minute delay
in reporting will lead to flight safety hazard.
..2

C/O - AIR INDIA LIMITED, AIRLINES HOUSE, MEENAMBAKKAM, CHENNAI 600 027. INDIA.
Phone: (Direct) 044 2256 1552, 2256 1971 Ext: 4050. Mobile: 09551 9551 96.
Email: icpachennai27@hotmail.com

INDIAN COMMERCIAL PILOTS ASSOCIATION

CENTRAL OFFICE
UNITY

INTEGRITY

DIGNITY

SAFETY

.2.
We wonder, how have you ignored the stressful working conditions and plight of our pilots, cabin crew,
engineers and all other employees due to nonpayment of full salary and allowances for last almost 32
months, when you were very prompt in this aspect in regard of Kingfisher and Spice-jet employees. How
is it that not receiving salary is a matter of flight safety for Kingfisher and Spice-jet employees but not for
Air Indians?
We request you to kindly also look into the working conditions of pilots and cabin crew in respect of Air
India. Other than monetary, there are other issues also which we think should be looked into by your
good self, for example;
1. Flight patterns being printed. Crew are being printed back to back early morning flights leading
to cumulative fatigue. There is an endeavour by the airlines to utilise crew to the limits of FDTL
as often as possible. These limits of FDTL as per our understanding should be treated as
extremities and should be approached only in unavoidable circumstances, not as routine crew
schedule planning.
2. CAR speaks in length about consecutive night operations for cargo operations and has laid down
appropriate rest requirements. However there is no mention of such operations for passenger
flights. Air India is still operating international flights to destinations like Dammam which is 2:1/2
hrs time zone in consecutive night sequence stating DGCA approval.
3. Crew roster was being printed without weekly off's in total disregard to CAR and normal labour
practices. It took a directive from us to get it printed, however medium and long haul aircraft
operating crew is still getting a roster which doesn't have a printed day off. There are numerous
cases of FDTL violations and extensions forced by the management of Air India by misleading
and or coercing the crew.
4. We request you to go through the leave records of the crew flying for Air India, you would find
that most of them are not even given10 to 15 days of approved leaves in a year to enable them
to fulfill their social and family obligations. They are expected to work continuously without any
break. We request you to ensure that availability of flight crew is calculated after taking into
account entitled leaves, weekly off's, mandatory training days etc and not just by considering
them to be available 365 days a year.
5. We request you to clarify the status of your letter no 5-333/2007AI(2) DTD 5/10/2012 directing
AI not to route aircrafts with unserviceable APU to stations without serviceable external air
conditioning unit to avoid discomfort to passengers. However AI is still operating aircrafts with
unserviceable APU to such stations even in peak summers.
6. Snags reported in PDR by pilots are repeatedly being put in deferred maintenance citing lack of
spares as the reason.
..3
C/O - AIR INDIA LIMITED, AIRLINES HOUSE, MEENAMBAKKAM, CHENNAI 600 027. INDIA.
Phone: (Direct) 044 2256 1552, 2256 1971 Ext: 4050. Mobile: 09551 9551 96.
Email: icpachennai27@hotmail.com

INDIAN COMMERCIAL PILOTS ASSOCIATION

CENTRAL OFFICE
UNITY

INTEGRITY

DIGNITY

SAFETY

.3.

7. The classic A-320 aircrafts which are 26 years old (one of the oldest in the world) are being
operated with repetitive snags endangering flight safety. You may also note that the EDTO
operations for these classic aircrafts are suspended owing to exceeding the in-flight shutdown
rate per 1000 engine hours. DGCA should not permit AI to operate these lethal snag prone
classic aircrafts in lieu of passenger safety.
There are scores of other issues as well which we would like to bring to your notice but there is an
impression that DGCA is operator friendly and is willing to look the other way when short coming of the
operator is pointed out but unforgiving when employees are found even slightly wanting.
It has been well documented in enough case studies that human element is one of the most susceptible
part of the safety chain in air operations. It is undeniably one of the most important part as well. Other
businesses have realised that a disgruntled work force is a sign of impending disaster to their
productivity and profitability hence they try their level best to give issues related to HR outmost priority.
In aviation industry there is also an added angle of safety along with productivity and profitability, in
spite of that the management of Air India is evolving into a draconian avatar for whom employee
interest and wellbeing is no concern at all.
You madam, as the regulator and ensurer of safety in air operations in the country cannot afford to
ignore this ticking time bomb of HR issues and casual attitude of Air India and we therefore appeal to
you to take note of the real factors effecting flight safety and take necessary preventive measures
immediately.
Regards,

(CAPT. T. PRAVEEN KEERTHI)

GENERAL SECRETARY
Cc:

Executive Director (Ops), Air India Limited, New Delhi.

Executive Director (Flight Safety), Air India Limited, New Delhi.

C/O - AIR INDIA LIMITED, AIRLINES HOUSE, MEENAMBAKKAM, CHENNAI 600 027. INDIA.
Phone: (Direct) 044 2256 1552, 2256 1971 Ext: 4050. Mobile: 09551 9551 96.
Email: icpachennai27@hotmail.com