Subpart Q - One year on

On 16th of July 2009, the EU celebrates the 1st birthday of the implementation of "Subpart Q". Being part of the "EU-OPS Regulation", it sets a minimum level of safety rules (Flight Time Limitations) aimed at preventing pilot fatigue from posing a danger to flight safety.

It is noteworthy that – one year on – there are still airlines that have not aligned to Subpart Q, or have been granted hastily fabricated temporary exemptions from Subpart Q, of which the EU Commission often only learned afterwards, when alerted by ECA's "whistle-blowing". For example, a National Aviation Authority granted an immediate exemption to a well-known Brussels-based company in Nov. 2008, but somehow "forgot" – for almost 7 months(!) – to inform the EU Commission, who needs to validate this exemption. Is this the way aviation safety should be dealt with by national Authorities?

It is also noteworthy that it is already 9 months since a group of EASA-mandated scientists presented their scientific and medical evaluation of Subpart Q. Their report concludes that Subpart Q is not sufficient to protect against pilot fatigue-related safety risks, and recommends to change it. Since then, 9 months without any steps to start the process of changing the legislation. Is this the way passengers expect the European Institutions to deal with their safety?