4/10/2026
MEC Brief 26-05_FTDT_Four_Pilot_FRMS_Trips
DALMECBrief
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A Publication of the Delta Master Executive Council
Flight Time Duty Time (FTDT) Update
April 10, 2026
26-05
Four-Pilot FRMS Operations -- Scheduling, Delays, Cancellations

The FAA has approved Delta Air Lines to operate certain A350 four-pilot operations under Fatigue Risk Management System (FRMS) DALA-001 [FOPP 20-00-65 Sup. 2] using an operable Class 1 rest facility and four pilots. This FTDT Update is intended to provide a brief overview of the FAR/PWA rules and restrictions of such operations.

Background
When FAR 117 was crafted, the FAA recognized that certain aspects of the rule would prevent some operations that were either planned or already ongoing at the time. For example, §117.11(a)(3) limits the total flight time in an FDP for a four-pilot crew to 17 hours, while some carriers were already operating flights above that limit.

The FRMS process allows a certificate holder to develop an alternative means of compliance [AMOC] for operating such flights, provided that at least an equivalent level of protection against fatigue-related accidents or incidents is established and maintained. This extended process includes an initial application followed by a period of data collection prior to final approval.

Delta may operate any of its A350 four-pilot flights under FRMS DALA-001, provided it complies with the restrictions below (see DALA-001; FOPP 20-00-65 Sup 2 in Comply365 for full details). The benefit to Delta is that it increases the crews’ FDP and flight time limits beyond what they would have been under FAR 117. However, greater than standard rest is required before, on the layover, and after these flights.

Flights currently operating as FRMS are: DTW-ICN, ICN-DTW, ATL-ICN, ICN-ATL, DTW-PVG, PVG-DTW, LAX-BNE, BNE-LAX, LAX-SYD, SYD-LAX, LAX-MEL, MEL-LAX, ATL-CPT, CPT-ATL, ATL-JNB and JNB-ATL. Two other city pairs are approved but currently unused: DTW-PEK-DTW and ATL-PVG-ATL.

FDP and Flight Time Limits
A Flight Duty Period under FRMS DALA-001 will not be scheduled to exceed 20:30, and may be extended up to a maximum of 22:30 with the concurrence of the Supervisor of Flying (SOF) via the OCC Duty Pilot, the dispatcher, and each member of the four-pilot crew. There is no flight time limitation for an FDP under this op spec; however, cumulative FDP and flight time restrictions DO still apply.

FDP and/or flight time limits on the rotation display identify which flights are operated under DALA-001. The FDP limit will be shown as 20:30 and the flight time limit as 99:59 (i.e., no practical limit).  In their monthly bid packages, pilots should also see an asterisk after the number 4 (i.e., 4*) for required crewmembers of a four-pilot FRMS flight.

FTDT_FRMT_sm_3266389.png

Duty and Rest Provisions
Before reporting for duty at the departure city of a four-pilot FRMS operation, a pilot must have been scheduled for the pre-duty or layover rest period, as applicable, as shown in the Rest Table Appendix A below. The reduced actual rest period is only permitted if the deadhead flight on the previous day was delayed due to an unforeseen operational circumstance such as a mechanical problem with the aircraft, significant weather, or air traffic delays.

Greater than standard rest is required on the layover as well. See the Rest Table Appendix A for these planned and minimum values.

After returning to base from a DALA-001 rotation that traversed over 60 degrees of longitude, pilots must have at least 56 hours of rest that encompasses three physiological nights. Please remember that FAR 117.25(a) prohibits assignment to any reserve or duty during any required rest period.  

Scheduled and Minimum Rest Requirements Pre-Duty FRMS
FTDT_FRMS_2_3266394.png

Note that the top rows are specifically for ATL – JNB – ATL and ATL – CPT – ATL operations while the remainder of the table is for all other A350 FRMS operations.

Short Call Reserve Coverage for Four-Pilot FRMS Flights
To provide reserve coverage for last-minute needs for four-pilot FRMS flights, Crew Scheduling will notify reserve pilots of their conversion to short call at least 24 hours in advance and place them into rest at the time of notification.

Note: FRMS Authorization DALA-001 requires that the FRMS short call period be assigned to begin at the scheduled departure time of the FRMS flight. The PWA has a provision whereas an A350 pilot whose bid package contains an FRMS rotation(s) may be converted to short call on their first on-call day following a non-fly day or block of non-fly days, so long as the pilot is notified of the conversion to short call no later than 1200 (pilot base time) on the last on-call day prior to the non-fly day or block of non-fly days. Such pilot will be free from duty from the time they are notified of the conversion to short call until the start of the short call period. Although Delta’s FRMS Authorization DALA-001 requires that the FRMS short call period be assigned to begin at the scheduled departure time of the designated FRMS flight, Delta has been scheduling the FRMS short call periods to start as early as 4 hours prior to departure time for that designated flight. ALPA has been participating in ongoing talks with the company to resolve this disparity and we will notify the pilots when a solution has been agreed upon and implemented. 

The total number of hours a short call pilot may spend in a flight duty period and reserve availability period is 20:30 plus four hours (24:30) as measured from the beginning of the reserve availability period.

Four-Pilot FRMS Flight Delays
If the notification of a flight delay is made to the pilots at least 10 hours before their initial scheduled report time, a new report time may be set. If notification of a delay to the pilots has not been made prior to 10 hours to report, the initial report time cannot be adjusted, and the flight duty period (FDP) will need to be monitored to ensure completion of the flight remains within the maximum 20:30, extendable to 22:30 FDP. 

The PWA and Four-Pilot FRMS Flight Delays
PWA section 12.D.1 Exception Two states: 

The scheduling limit for a trans-oceanic FDP will be the time from scheduled report to scheduled block-in, and a pilot will not be rerouted or required to remain on such an FDP more than two hours beyond such scheduling limit, if: 

a) the flight crew is augmented with a relief crew, 

b) the FDP contains only one scheduled landing, and 

c) the flight segment operates under an approved FRMS

 

If flight crewmembers report as scheduled and are delayed such that their FDP to be more than two hours longer than originally scheduled, they are not required to remain on that FDP. No fitness for duty report would be required in this circumstance, and the pilots’ pay would not be subject to review by the FRB.

Reserve Pilots: When the FDP is assigned to a reserve pilot, it has a scheduled length. The pilot can be required to remain on duty for up to two hours beyond that limit. The reserve pilot can walk if, prior to pushback, the flight plan shows the FDP to be more than two hours longer than as originally assigned. No fitness for duty report would be required in this circumstance, and the pilot’s pay would not be subject to review by the FRB.

If a short call reserve pilot elects to remain on an FDP that exceeds the originally scheduled FDP by two hours or more, they can then legally remain on duty up to 24:30 after the start of his reserve availability period.

Four-Pilot FRMS Flight Cancellations

If the FRMS crew reports for duty and the flight is canceled for any reason, including the reason that the duty period limitations would be expected to be exceeded, then that crew must be given no less than 10 hours of rest. If the crew reports back for duty and the flight is canceled again, then each crewmember must be given 24 hours of rest before being required to report for duty again.

 

Further information on this and all of Delta's FRMS operations can be found in the Flight Operations A350 4-Pilot FRMS Operations Guide and FRMS A350 4-Pilot Ops Manual FOPP 20-00-65 Sup2 in the FAR117 & FRMS section of Comply365.

 

For questions on FRMS, please contact the Fatigue Risk Management Team at: DALFRMT@alpa.org.


This is a product of the Fitness Review Board.  
 
 
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