Ronald Gliganic 

87 Fitchburg Street 

Bayshore, N.Y. 11706 

June 13, 2011 

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Docket Operations, M-30 

Federal Aviation Administration 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Room W12-140 

West Building Ground Floor 

Washington, DC 20590-0001 

Re: Docket Number FAA-2011-0367 (proposed Re-Interpretation of 49CFR 121.377) 

To The Federal Aviation Administration: 

I am submitting these comments in response to the Federal Aviation 

Administration's request for comments regarding the interpretation and application of 49 

CFR 121.377 "Maintenance and preventative maintenance persormel duty time 

limitations". I am a certificated Aviation Maintenance Technician and work for a 121 Air 

Carrier. 

I believe that, the FAA needs to revisit the issue of maintenance personnel duty 

time limitations. The current interpretation of FAR 121.377 is inadequate, ambiguous and 

lax. The alternative equivalent is, I believe a threat to aircraft safety. The understood 

ideal of 121.377 is predicated on having a reasonably rested and alert technician working 

on an aircraft. Unfortunately it is extremely difficult to gauge how a technicians fatigue 

plays a role in his craftsmanship. When a technician is fatigued, the chances of mistake or 

oversight are increased dramatically. Allowing a technician to work an unlimited amount 

of hours for up to 6 days in a row is not serving the interest of safety. Under the 

alternative interpretation, allowing a technician to work an unlimited amount of hours for 

up to 27 consecutive days is just unsafe. 

Human factors' training has taught me that fatigue is an insipid enemy that I need 

to be aware of and its effect on me. Concerns of fatigue need to be addressed at the very 

basic level of technician scheduling. When a technician is required to work extended 

periods of time or when the schedule is changed there is no recourse for the technician, 

but to comply. He is then obligated to ftilfill the demands of his employer and make 

himself available even though the technician might be fatigued. The existing practice of 

deferring rest time is completely useless from a human factors stand-point. Human factors 

research clearly shows that fatigue has a cumulative negative effect on people and must 

1 
be combated with effective countermeasures. Prevention of fatigue is the best 

countermeasure. Not only the amount of rest time an Aviation Maintenance Technician 

receives, but also the amount of hours actually performing aviation maintenance needs to 

be regulated. 

The "equivalent" interpretation of FAR 121.377 does not properly address the 

needs and concerns of human factors in the aviation maintenance industry. The FAA has 

done much work with human factors research in the past several years and it is past time 

to reinterpret this requirement. The Aviation Maintenance Technician is the corner stone 

of safety and as such the 121 certificate holder should be mandated to provide a culture 

that breeds the highest level of safety. In order to avoid misinterpretations and ambiguity, 

clear and concise duty time limitations need to be established for the Aviation 

Maintenance Technician. Present studies and research can be used to establish these 

guidelines for a daily, weekly and monthly limit. 

I applaud the FAAs concern about the Aviation Maintenance Technician's duty 

time limitations and implore the agency to affect a clear and concise regulation that will 

fulfill the needs of the human factors portion of aircraft maintenance. 

Sincerely 

Ronald Gliganic 

Aviation Maintenance Technician 

2728096