Part 117 Violations — Who Pays, and What Gets Reported
Almost every Part 117 limit is written twice: "no certificate holder may schedule and no flightcrew member may accept". A busted limit is therefore two violations — one corporate, one personal — with a paper trail the FAA reads.
The built-in reporting machine
Part 117 does not wait for an inspector to find overruns. Three sections create standing reporting duties:
- §117.19(a)(4): report to the Administrator within 10 days any FDP that exceeded the Table B/C maximum by more than 30 minutes — including a description of the circumstances, and if they were within the company's control, the corrective action the company intends to take.
- §117.11(c): same 10-day duty for flight time that exceeded the Table A / 13 / 17-hour limits or the §117.23(b) cumulative flight-time caps.
- §117.29(e): for government-sponsored and §119.57-deviation operations, report within 10 days any FDP over Table B/C by more than 30 minutes, any Table A flight-time exceedance, and any §117.23 cumulative exceedance.
The corrective action has its own clock: §117.19(a)(5) and §117.29(g) require the company to implement the reported corrective action within 30 days of the extended FDP. If the same scheduling failure repeats monthly, the company's own filings become the evidence.
What reaches the crew member
Because the prohibition language is addressed to both parties, a pilot who accepts an assignment over a Part 117 limit is part of the violation — "I was told to" is not a defense the rule text recognizes. FAA enforcement against a certificate holder's airmen runs through the standard machinery:
- Investigation: 14 CFR Part 13 procedures (14 CFR §13.11 for carriers' airmen; §13.16 for others).
- Certificate action: suspension or revocation under 49 U.S.C. §44709.
- Civil penalty: 49 U.S.C. §46301 for violations by individuals.
In practice the FAA's first look is at the company — its 10-day reports, scheduling system and training records — but a pattern of individually accepted illegal assignments is exactly what Part 13 cases are built from.
The fatigue-call edge cases
- Flying while too fatigued is a §117.5(b) violation by the crew member — fatigue is a defined physiological state (§117.3), and "I felt fine" is judged against the fitness-for-duty standard.
- Continuing after a fatigue call is a §117.5(c) violation by the company: once you report yourself too fatigued to continue, it may not permit you to continue.
- Declining under §117.25(f) (no compliant 8-hour sleep opportunity) is not a violation by you — the rule text itself forbids you to report until a compliant rest is given. See rest interrupted & fatigue-call protection.
ASAP reports and the NASA/IRS anonymous program are voluntary safety layers with their own protections. They do not replace the mandatory §117.19/§117.11/§117.29 reporting — and an ASAP filing is not a defense to an accepted illegal assignment either.
The paperwork that protects you
When a day runs hot — an extension over 30 minutes, a post-takeoff flex past the cumulative caps (§117.19(b)(3)) — the company must report it and it is not held against the crew as discipline by design; §117.29(f)'s report is about circumstances, not blame. Your protection is a contemporaneous record: release time, rest actually obtained, who authorized what, and when. Regulatorily required rest and legally required reports are your paper trail; the calculator's exported report is a convenient artifact to attach.
Export a compliance report from the calculator (Pro)