FAA Proposes Federal Standard for Crew Breaks

Recent litigation prompted the proposal, which would preempt state and local meal and rest break laws for Part 121 crews.

FAA Proposes Federal Standard for Crew Breaks
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Key Takeaways:

  • The FAA has proposed a new rule to establish federal aviation regulations as the sole standard for flightcrew and flight attendant duty, rest, and meal break requirements, explicitly preempting state and local laws.
  • This proposal directly responds to several years of litigation, notably the "Bernstein v. Virgin America" case, which found that California's state break laws were not preempted by federal acts.
  • The rule aims to clarify that crew members remain available for safety responsibilities while also being able to meet physiological needs during duty periods, distinct from existing post-duty rest requirements.
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The FAA proposed a rule Monday that would make federal aviation regulations the controlling standard for flightcrew member and flight attendant duty, rest and meal break requirements.

The notice, published July 6 in the Federal Register, would add language to Parts 117 and 121 stating that state and local requirements covering the same subject matter are preempted. Comments are due Sept. 4.

Litigation prompted review

The proposal follows several years of litigation over whether California meal and rest break law applies to airline cabin crews. In Bernstein v. Virgin America, the 9th U.S. Circuit Court of Appeals held in 2021 that California’s meal and rest break requirements were not preempted by the Federal Aviation Act or the Airline Deregulation Act, and the Supreme Court declined to review the case in 2022.

California later enacted SB 41, which exempts airline cabin crew employees from those state requirements when they are covered by qualifying Railway Labor Act collective bargaining agreements that address meal and rest breaks.

“Recent litigation prompted FAA to review regulations relating to duty and rest for flightcrew members and flight attendants,” the agency said in its proposal.

The FAA said the proposed rule is intended to clarify that crew members remain available for safety-related responsibilities during a duty period, while flight attendants also have the ability to meet physiological needs such as eating or using the restroom.

Existing rest rule remains

The proposal follows the FAA’s 2022 final rule requiring Part 121 operators to provide at least 10 consecutive hours of scheduled rest for flight attendants assigned to duty periods of 14 hours or less. That rule took effect Nov. 14, 2022 and removed a previous option that could allow a reduction to eight hours under certain circumstances. The new proposal addresses break requirements during duty periods rather than the minimum post-duty rest period.

The proposed rule would add § 117.31 for flightcrew members and § 121.468 for flight attendants. Under the proposed Part 121 language, certificate holders would have to ensure flight attendants remain available for safety duties and are able to meet physiological needs during a duty period.

Matt Ryan

Matt is AVweb's lead editor. His eyes have been turned to the sky for as long as he can remember. Now a fixed-wing pilot, instructor and aviation writer, Matt also leads and teaches a high school aviation program in the Dallas area. Beyond his lifelong obsession with aviation, Matt loves to travel and has lived in Greece, Czechia and Germany for studies and for work.
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