Redneck_pilot86 wrote:As Roar said, you can't paint all pilots with the same brush any more than truck drivers, cabbies, train conductors and school bus drivers should be on the same set of regs.
Yes you can. Humans are humans, and we are all subject to the same circadian rhythm and fatigue influences as the next guy regardless of what we're doing for a living. F&DT regulations have to be written according to science which they are on the cusp of being. In cases where fatigue is present despite the regulations we have CAR 602.02. There cannot be rules exempting pilots allowing them to go beyond the regulations because 1. we are the worst judges of when we are fatigued, and 2. it is open for abuse.
By the way, train crews and truck drivers have much lower duty times than we do.
So you're trying to tell me I have the same fatigue levels working 4 days a month as someone working 20? That's comical.
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Roar wrote:So you're trying to tell me I have the same fatigue levels working 4 days a month as someone working 20? That's comical.
No, that isn't what I'm saying. I'm saying you get just as tired during the course of a single day as anybody else. Lucky you that you only work 4 days a month, but if you're cramming a month's work into those 4 days then yes, you are without a doubt more fatigued while you are at work.
Roar wrote:So you're trying to tell me I have the same fatigue levels working 4 days a month as someone working 20? That's comical.
No, that isn't what I'm saying. I'm saying you get just as tired during the course of a single day as anybody else. Lucky you that you only work 4 days a month, but if you're cramming a month's work into those 4 days then yes, you are without a doubt more fatigued while you are at work.
That's not how it works for me though, my four days are not consecutive. A normal month would be something like a 6 hour duty day flying to New York, sit there doing nothing for 4 days then have a 6 hour duty day flying home, two weeks of no work at home then a 14 hour day to Stockholm, spend 7 days there hanging out then 14 hour day home followed by two weeks off. I know that's not a typical job but that's why the new rules make no sense to the operation I'm in, I'm no way fatigued. I understand a tier 3 704 carrier flying 20 days a month doing 8 sectors a day need the new rules. Just don't force one set on us all. They need to reflect what an operation actually does.
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"If nothing else works, a total pig-headed unwillingness to look facts in the face will see us through."
You're still tired on that 14 hour day especially if you're flying overnight to Stockholm. It doesn't matter if you say you can do it, science says you're fatigued after that length of time on duty particularly at night. Whoever you work for will have to make some changes as will everybody else.
I see, but you're fine at 13 hours as per the new regs. I guess one hour makes all the difference.
The scientific studies looked at airline pilots, not all types of flight operations. One 14 hour day then a week or two off does not make you fatigued. Using airline pilots data to impose requirements on corporate operations is a disingenuous argument.
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"If nothing else works, a total pig-headed unwillingness to look facts in the face will see us through."
Roar wrote:I see, but you're fine at 13 hours as per the new regs. I guess one hour makes all the difference
According to the proposed rules published in the Canada Gazette, the only time 13 hours is approved is for flight duty times starting from 07:00-12:59, and with the least amount of flights. Increase the number of flights beyond a threshold and the permitted hours is reduced. Begin duty outside those hours and the permitted hours is reduced. For instance flight duty periods beginning 24:00-03:59 under any circumstance is 9:00 hours.
Science based, and much better than the old 14 hours regardless of time of day if you ask me.
So Roar, I'd like to know what you propose for the 704 operators who work their pilots 18 days a month?
It sounds like you have a pretty cushy job and don't work all that often, I'm curious though, those two weeks off, are they days attached to a cell phone to be on your way to wherever or scheduled days off? If you are on call and only get called in four times a month, you're more fatigued than you think.
If you know when you're flying well in advance with no chance of being called for anything, yah you're probably fairly rested but as Rockie said 14 hours on the back of the clock is still fatiguing and seriously how do they regulate that, "well Roar only works 4 days a month so we'll just give him an exemption"
Roar wrote:I see, but you're fine at 13 hours as per the new regs. I guess one hour makes all the difference
According to the proposed rules published in the Canada Gazette, the only time 13 hours is approved is for flight duty times starting from 07:00-12:59, and with the least amount of flights. Increase the number of flights beyond a threshold and the permitted hours is reduced. Begin duty outside those hours and the permitted hours is reduced. For instance flight duty periods beginning 24:00-03:59 under any circumstance is 9:00 hours.
Science based, and much better than the old 14 hours regardless of time of day if you ask me.
I'm all for lowering the max duty times. Make it 12. Make it 10. I don't care. But don't make it so that you need a lawyer on staff to determine whether a charter can be done or not.
I can absolutely without a doubt say I am significantly more fatigued after 8 hours of hauling groceries than I am after 12 hours of hauling bulk fuel. Its the physical labour associated with the flying that causes the bulk of the fatigue, not sitting there minding an autopilot. I guess most of you 705 types have forgotten that.
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The solution is easy for corporate operators. Conduct your flights under 604 regulations. Operating under 704 is likely nothing more than a tax dodge so it is about time fatigue is addressed and money take the back seat.
The solution is easy for corporate operators. Conduct your flights under 604 regulations. Operating under 704 is likely nothing more than a tax dodge so it is about time fatigue is addressed and money take the back seat.
Roar wrote:The new duty time regs. Are a ridiculous attempt at a one size fits all solution designed for the airlines. I understand that the 705 world needs new duty limits but to paint all 704 operations with the same brush is asinine. I personally fly on average 3-4 days a month so even if all of my days were 14 hours on duty TC is going to tell me I'm fatigued? It's a joke.
I don't think as humans evolved they did so to fit into to 704 or 705 categories. Fatigue is fatigue.
And not being fatigued is not being fatigued. So because a 705 pilot is fatigued after doing 20 days flying in a month with 14 hour duty days, that means that I can't work even one 14 hour day of the whole 4 days a month I fly. One is not equivalent to the other so the rules should reflect the actual operation one conducts, not just blanket cover everyone with the same rule.
Then your company creates an Fatigue Risk Management System and presents it to TC and requests an exemption..
Did you read any of the proposed changes before you freak out?
