New duty regs are out

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schnitzel2k3
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Re: New duty regs are out

Post by schnitzel2k3 » Wed Dec 12, 2018 8:27 pm

lownslow wrote:
Wed Dec 12, 2018 5:10 pm
schnitzel2k3 wrote:
Wed Dec 12, 2018 5:06 pm
Someone who has way too much time on their hands should develop a flow chart for those regs.
Skip to the end for a summary of changes.
Danke!

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Re: New duty regs are out

Post by digits_ » Wed Dec 12, 2018 9:26 pm

nwopilot wrote:
Wed Dec 12, 2018 9:48 am
I really hope I am incorrectly interpreting these new regs!! Apparently Medevac operators are basically exempt from all the new regs and can continue to go for 14hrs!?!?!?!?! HAHAHAH that is just silly. Out of all of the jobs I have had, I was the most fatigued while operating on a 24hr on-call medevac schedule. Why are they exempt?!?! Just hire some more damn pilots!!!
This would help a lot though:
700.116 (1) An air operator shall provide a flight crew member, at the end of a flight duty period, with a rest period of 10 hours plus the travel time to and from the place where the rest period is taken.

(2) An air operator shall provide a flight crew member with advance notice of the member’s rest period and its duration.
You might still have to work 14 hours, but at least you'll know when you'll be able to sleep. Much better than that rolling duty day crap some operators use at the moment, or the 24/7 on reserve. Looks like day/night shift might become mandatory if you want 24 hour coverage.
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Re: New duty regs are out

Post by valleyboy » Thu Dec 13, 2018 6:22 am

By the time the dust settles and people finish blowing smoke up everyone's asses there will actually be very little change for the end user. Just more paper generated, which TC loves. :smt021

It's the Canadian way. Look at all the approach ban crap and the stuff we almost need legal advise every time you shoot an approach and now this. The models were already out there and so easy to adapt and apply. It's just moronic.
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Re: New duty regs are out

Post by Liftdump » Thu Dec 13, 2018 9:57 am

So if the seat only reclines 37 degrees,does that mean I can only work 6 hrs ?
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Re: New duty regs are out

Post by Lightchop » Thu Dec 13, 2018 11:02 am

Curious how Air Transat is going to deal with some of their flying, as IIRC they throw their RP/FO#2 etc. in plus.

Also how about Rouge 767? They don't have sleepers, right? Are we going to start seeing some cargo sleeper pods AKA Lufthansa style in the future?
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Re: New duty regs are out

Post by schnitzel2k3 » Thu Dec 13, 2018 11:40 am

ACPA just put out a pretty heavy handed statement regarding their discontent with the new regulations and how it does not address current fatigue concerns due to operators not being requires to immediately implement the new regs, and that most operations will rely heavily on FRMS to circumvent the new regs.

Interesting to see TCs response.

I thought ACPA and the powers that be had a rather powerful voice when it came to these new regulations.

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Re: New duty regs are out

Post by fish4life » Thu Dec 13, 2018 11:48 am

I wonder if anyone even read the FRMS section, if the pilots feel
They are too tired they can say so and it dies I don’t see why people are so upset, grow a set and fill sms reports saying you are fatigued and it dies.
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Re: New duty regs are out

Post by WeatherMaster » Thu Dec 13, 2018 2:31 pm

And what about 604 operators?
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Re: New duty regs are out

Post by Redneck_pilot86 » Thu Dec 13, 2018 4:03 pm

fish4life wrote:
Thu Dec 13, 2018 11:48 am
I wonder if anyone even read the FRMS section, if the pilots feel
They are too tired they can say so and it dies I don’t see why people are so upset, grow a set and fill sms reports saying you are fatigued and it dies.
Thats always been the case.
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Re: New duty regs are out

Post by FOD_Vacuum » Thu Dec 13, 2018 4:25 pm

Am I understanding it right, that Medevac operations will not be subjected to the new regs, and will still be the 14 hour duty day? From experience, Medevac flying has been by far the most tiring flying job I have done, yet Medevac regs aren’t affected? Wow

And this timeline of 2 years for 705, and 4 years for 703&704 to comply seems way too long of a time to implement. I understand some airlines may have to hire more pilots and it takes time to hire and train, but not two years and certainly not four years at the bush league level.
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Re: New duty regs are out

Post by Redneck_pilot86 » Thu Dec 13, 2018 4:32 pm

Some of these laws seem silly to me:'

"700.37 An air operator shall provide a flight crew member with not less than 15 minutes every 6 hours within a flight duty period to eat and drink."
It would appear the pilot is not obligated to take this time? Personally, I snack all day in cruise, and never go anywhere without a travel mug full of coffee. I have no need nor desire to take a mandatory 15 minute break.


"700.40 (1) An air operator shall provide a flight crew member with the following rest periods at the end of a flight duty period:

(a) if the flight duty period ends at home base,
(i) either 12 hours, or 11 hours plus the travel time to and from the place where the rest period is taken, or
(ii) if the air operator provides suitable accommodation, 10 hours in that suitable accommodation; "
There are lots of seasonal pilots who live in a camper at the float base for the summer. It would seem that the title to the trailer determines the required rest period in such a case?
In my case, I own a house trailer but lease ground from the company, do I need 12 hours off every day, or 10?


"15 Section 703.98 of the Regulations is amended by adding the following after subsection (3):
(4) An air operator shall have a fatigue management training program for its flight crew members that contains
(a) personal fatigue management strategies relating to
(i) sleep hygiene,
(ii) lifestyle, exercise and diet, and
(iii) the consumption of alcohol and drugs;"
From Wikipedia: "Sleep hygiene is the recommended behavioral and environmental practice that is intended to promote better quality sleep."
We now need a training program to teach pilots how to be an adult?!?!

There are some good things in here, but a lot of clarity is needed.
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Re: New duty regs are out

Post by Heliian » Thu Dec 13, 2018 5:59 pm

Redneck_pilot86 wrote:
Thu Dec 13, 2018 4:32 pm
Some of these laws seem silly to me:'

"700.37 An air operator shall provide a flight crew member with not less than 15 minutes every 6 hours within a flight duty period to eat and drink."
It would appear the pilot is not obligated to take this time? Personally, I snack all day in cruise, and never go anywhere without a travel mug full of coffee. I have no need nor desire to take a mandatory 15 minute break.


"700.40 (1) An air operator shall provide a flight crew member with the following rest periods at the end of a flight duty period:

(a) if the flight duty period ends at home base,
(i) either 12 hours, or 11 hours plus the travel time to and from the place where the rest period is taken, or
(ii) if the air operator provides suitable accommodation, 10 hours in that suitable accommodation; "
There are lots of seasonal pilots who live in a camper at the float base for the summer. It would seem that the title to the trailer determines the required rest period in such a case?
In my case, I own a house trailer but lease ground from the company, do I need 12 hours off every day, or 10?


"15 Section 703.98 of the Regulations is amended by adding the following after subsection (3):
(4) An air operator shall have a fatigue management training program for its flight crew members that contains
(a) personal fatigue management strategies relating to
(i) sleep hygiene,
(ii) lifestyle, exercise and diet, and
(iii) the consumption of alcohol and drugs;"
From Wikipedia: "Sleep hygiene is the recommended behavioral and environmental practice that is intended to promote better quality sleep."
We now need a training program to teach pilots how to be an adult?!?!

There are some good things in here, but a lot of clarity is needed.
- it means they can't force you to work without a break.

- that's your own accommodation. If the company has a proper crew rest area as defined by the regulations then its 10

-after decades of sleep studies, yes, generally people are ill informed about healthy sleep habits. It's a training component that goes hand in hand with the practical side of things.

They are just laying down the legal framework, there is still lots of time to adjust.

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Re: New duty regs are out

Post by 5400AirportRdSouth » Sat Dec 15, 2018 8:08 am

Nothing would warm my cold dead heart more than seeing the SMS inboxes of every carrier attempting the FRMS end run to get filled with fatigue reports on Day One.

Thats all it would take to completely kill the FRMS bypass.

All it would take is for pilots to grow a set and stand up together against this BS...call it a national sleep-out.

I cant even decipher the FRMS section, lots of words and zero substance. The synergies and dynamics in the data collection, review and procedural collaboration between stakeholders, will allow us to maximize efficiencies.
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Re: New duty regs are out

Post by digits_ » Sat Dec 15, 2018 8:14 am

Redneck_pilot86 wrote:
Thu Dec 13, 2018 4:32 pm
Some of these laws seem silly to me:'

"700.37 An air operator shall provide a flight crew member with not less than 15 minutes every 6 hours within a flight duty period to eat and drink."
It would appear the pilot is not obligated to take this time? Personally, I snack all day in cruise, and never go anywhere without a travel mug full of coffee. I have no need nor desire to take a mandatory 15 minute break.

One of the goals of the new rules are to force the worst operators to treat their pilots in a humane manner. As an airline pilot you could have plenty of time to snack, but the guy flying a 206 single pilot 14 hours straight, afraid to lose his first job, might not have that time or luxury. So it is good that these new regulations make it mandatory to give pilots at least a 15 minute break every 6 hours. How can you even complain about that. You could work 12 hours with only a 15 minute break in the middle and that's too much of a break for you :?:
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Re: New duty regs are out

Post by ehv8oar » Sat Dec 15, 2018 9:14 am

I really hope I am incorrectly interpreting these new regs!! Apparently Medevac operators are basically exempt from all the new regs and can continue to go for 14hrs!?!?!?!?! HAHAHAH that is just silly. Out of all of the jobs I have had, I was the most fatigued while operating on a 24hr on-call medevac schedule. Why are they exempt?!?! Just hire some more damn pilots!!!
Exactly, it's just ridiculous.
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Re: New duty regs are out

Post by AuxBatOn » Sat Dec 15, 2018 9:28 am

Don’t forget that the rules are meant to address operational risks to the general population (not to pilots/crew). That’s why 702 is less restrictive than 703 and 703 is less restrictive than 704 and 704 is less restrictive than 705. The exposure of the population is progressively greater from 702 to 705. The effects of a catastrophic accident in a Medevac operation are fairly minimal when compared to the same catastrophic accident in an Airline operation. Therefore, the probability of a catastrophic accident happenning can be higher in a 702 operation and can still have the same level of risk as a 705 operation where the probability is minimized through more restrictive rules.
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Re: New duty regs are out

Post by digits_ » Sat Dec 15, 2018 9:56 am

AuxBatOn wrote:
Sat Dec 15, 2018 9:28 am
Don’t forget that the rules are meant to address operational risks to the general population (not to pilots/crew). That’s why 702 is less restrictive than 703 and 703 is less restrictive than 704 and 704 is less restrictive than 705. The exposure of the population is progressively greater from 702 to 705. The effects of a catastrophic accident in a Medevac operation are fairly minimal when compared to the same catastrophic accident in an Airline operation. Therefore, the probability of a catastrophic accident happenning can be higher in a 702 operation and can still have the same level of risk as a 705 operation where the probability is minimized through more restrictive rules.
Then they should have made special rules for 703 or 704, not specific medevac rules. Which makes you wonder what is so special about medevac. Until you start thinking a bit deeper, and you realize who the patients/passengers are on board the medevac planes vs the fancy charter planes on 703 or 704 operations which have better rules...
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Re: New duty regs are out

Post by fayuyang » Sat Dec 15, 2018 11:33 am

+1 Medevac pilots are machine, we can fly all day long so we can exempt from all regs :twisted:
nwopilot wrote:
Wed Dec 12, 2018 9:48 am
I really hope I am incorrectly interpreting these new regs!! Apparently Medevac operators are basically exempt from all the new regs and can continue to go for 14hrs!?!?!?!?! HAHAHAH that is just silly. Out of all of the jobs I have had, I was the most fatigued while operating on a 24hr on-call medevac schedule. Why are they exempt?!?! Just hire some more damn pilots!!!
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Re: New duty regs are out

Post by Anthropomorphized » Sat Dec 15, 2018 4:47 pm

How many management systems do we need really?

If the fatigue problem hasn't been addressed by SMS, how do they figure adding another 'system' on top of that is going to be beneficial in any way? I would say, if the operator can hide fatigue in their SMS program, I feel confident they'll be able to hide it in their FRMS program as well.
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Re: New duty regs are out

Post by fayuyang » Sat Dec 15, 2018 6:07 pm

When we legalize cannabis in Canada it was enforced on the same date;
When it comes to new flight/duty time reg. that's related to public safety it takes 2-4 years until it's enforced.....sigh
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Re: New duty regs are out

Post by The Hammer » Sat Dec 15, 2018 8:54 pm

Large 705 carrier have stated it will take 2 years to train enough pilots. Considering AC already has plans to hire 450 in 2019 this is fully believable for sim time alone.
Large airline's management has accepted the changes and will work with them so it's a reasonable tradeoff vs TC having AC/WJ lobbying hard politically against the changes.

As for medevac I'm think that because in many provinces and territories medevac flights are to isolated reserves with poor heath care facilities and long distances this would be a political hot potato.
They probably could have made an exemption for "limited access" sort of like they have for many DG items.

I can think of a few parts of this country that it would be tight to get a patient to a southern hospital on a single duty period if they started at the middle of the night. Usually wheels up is 60 minutes headed north before headed south with the nurse going in to the nursing station (25-30 minute drive each way in the winter) plus time to stabilize the patient which is usually the case if your getting a 0300 call. Not a skedevac. IMHO
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Re: New duty regs are out

Post by The Hammer » Sat Dec 15, 2018 9:12 pm

5400AirportRdSouth wrote:
Sat Dec 15, 2018 8:08 am
Nothing would warm my cold dead heart more than seeing the SMS inboxes of every carrier attempting the FRMS end run to get filled with fatigue reports on Day One.

Thats all it would take to completely kill the FRMS bypass.

All it would take is for pilots to grow a set and stand up together against this BS...call it a national sleep-out.

I cant even decipher the FRMS section, lots of words and zero substance. The synergies and dynamics in the data collection, review and procedural collaboration between stakeholders, will allow us to maximize efficiencies.
You can complain about FRMS but it might work out for the pilots too, especially jobs that aren't particularly stressful. I'd rather work 10 day-time sked days in a row and go home for more time days off then work 6, sit in a bunkhouse for 36 hrs to meet the new regs to reset my clock, an then work another 6. It all depends on the job conditions and schedule.
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Re: New duty regs are out

Post by ehbuddy » Sun Dec 16, 2018 7:00 am

It will just take an accident or another SFO incident and Trump will ban all Canadian Airlines flying into the States. Ban will be enforced until proper crew rest rules have been implemented.
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Re: New duty regs are out

Post by digits_ » Sun Dec 16, 2018 7:23 am

ehbuddy wrote:
Sun Dec 16, 2018 7:00 am
It will just take an accident or another SFO incident and Trump will ban all Canadian Airlines flying into the States. Ban will be enforced until proper crew rest rules have been implemented.
I was going to write that such a thing would be ridiculous, and then I realized that nowadays this is actually completely possible...
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Re: New duty regs are out

Post by Heliian » Sun Dec 16, 2018 7:38 am

Medevac operators are not exempt but have a different threshold.

There are also provisions for on call and standby.

Its your company's job to sort it out and implement it, it's your responsibility to show up rested and to recognize fatigue.

You have the right to refuse work.
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