Too tired for take-off (Globe & Mail)

[Rotten Apple #1]

And the thing is, unless TuThanhHa read a different report than was posted above by widow, he was able to turn the following quotation from the "Findings As to Causes and Contributing Factors":

3.The captain was not well rested before the flight. The effects of fatigue likely resulted in a degradation of his concentration and prolonged diversion of attention from monitoring of airspeed after power reduction. The airspeed was therefore allowed to fall below the targeted value.

into:

The problem? The captain, worn out from an irregular schedule and a fitful sleep...

An irregular schedule? Where is that in the report? I would note that the "Safety Action Taken" section of the report makes no recommendation about fatigue issues.

I'm pretty much finished on this one. It's one thing to get publicity on aviation issues. Quite entirely another thing to blow your wad at the wrong target.

[Widow]

Pilots question Transport Canada's stance on new fatigue guidelines

By Sarah Schmidt, Canwest News ServiceNovember 20, 2009 7:02 PM
StoryPhotos ( 1 )


OTTAWA — Airline pilots say Transport Canada didn't provide the whole picture when it told the international aviation safety body that 13-year-old Canadian standards to combat pilot fatigue meet new global rules.

The new directive for countries to have regulations to set flight and duty time limits and rest requirements for pilots based on science came into effect on Thursday — the same day Transport Canada sent a letter to the International Civil Aviation Organization saying that current rules in Canada satisfy the new requirement.

The Montreal-based United Nations body required signatory countries, including Canada, to file official "differences" by Thursday informing the group if the country wouldn't be able to comply.

"Canada has not filed a difference because current Canadian regulations are consistent with the ICAO's Standards and Recommended Practices (SARP)," Transport Canada said in a statement Friday.

The Canadian Federal Pilots Association, which represents pilots working at Transport Canada, and the Air Canada Pilots Association, the largest professional pilot group in Canada, both say this doesn't hold up.

Canada's regulations limiting pilot flying time, first instituted in the 1940s, were last updated with minor changes in 1996. The current federal rules do not distinguish between day-time flying and overnight flights, even though other countries acknowledge the physiological challenges of flying overnight.

The amended international standards introduce new definitions of "duty," "duty period," and "fatigue," and updates definitions of "flight duty period" and "rest period."

And "for the purpose of managing fatigue," regulations established by countries such as Canada should be based "upon scientific principles and knowledge, where available, with the aim of ensuring that flight crew members are performing at an adequate level of alertness," according to the updated international directive.

"I don't see how they can say that because to the best or our knowledge, there's no scientific basis for our duty regulations to being with. They were developed in the 1940s," Paul Strachan, president of the pilots' union at Air Canada, said Friday.

"Clearly, the body of science around this has advanced tremendously. For Transport Canada to say at this point that their flight duty regulations are consistent with the intent of the ICAO SARP — that's tantamount to saying literally that ownership of a sun dial is consistent with the intent of trying to tell time."

Strachan said other countries have updated regulations in recent years based on new research involving sleep and circadian rhythms.

"Is there a physiological difference between a Canadian pilot and an American pilot or a Kiwi pilot? No, there isn't. The data is there. Transport Canada has told us consistently that since there is no Canadian data, they can't move forward. Yet they haven't taken steps to collect any such data."

Daniel Slunder, who represents pilots working at Transport Canada as the national chairman of the Canadian Federal Pilots Association, said he's also confounded by Transport Canada's position.

He said Transport Canada meets the first ICAO test, which requires countries to have "regulations specifying the limitations applicable to the flight time, flight duty periods, duty periods and rest periods for flight crew members, but these in no way meet the second statement that they 'shall be based on scientific principles and knowledge.'"

Slunder says it's now in the hands of ICAO.

"It's not the first time Transport Canada failed to file a difference. There isn't much that anyone here can do about that. We can't force Transport Canada to file the difference, only ICAO can. ICAO will find out when it conducts its next audit of our system and then they will tell Transport to get with the program or file a difference. The issue remains that we don't meet the intent of the requirement."

When a country files a difference with ICAO, the information is shared with foreign carriers so they will know when entering that country's airspace.

http://www.canada.com/news/Pilots+quest ... story.html

[TuThanhHa]

Good evening jonny dangerous.
I wrote "irregular schedule" because, as far as most working people are concerned, having a job where you are on the road, arrive somewhere at 2 a.m. and check into your hotel at 3 a.m then go to work the next day, is not the norm.
It goes to the very complaint that several pilots and pilots' unions have told me, that the CARs don't address the fact that a pilot's life does not conform to a human being's normal circadian rhythms.

While you might want to quibble on specifics of an anecdote in my story, I have received enough positive feedback from professional airline pilots today to trust that I have touched on an issue that is indeed worrying many in your community. I was also warned that it is a community that distrusts the media, where people might react passionately. Fair enough, but I didn't make up this problem. I interviewed many pilots, even if I could not quote all of them on the record.

I take note of a few people's observation that the problem is more acute with smaller operators. I was aware of that aspect but did not have the time and resource to flesh it out before the ICAO Nov. 19 deadline that triggered my story. People with more information about that situation can contact me at ha@globeandmail.com -- I will respect requests for anonymity.

Finally, jonny, I am happy to hear that you "can handle an(y) airline schedule in Canada." However what ACPA and ALPA people are telling me is that safety matters should be regulated, not left to the hardiness or contract-negotiating skills of pilots.

Regards,

Tu Thanh Ha

[Widow]

I find it very interesting that Peter Julian tabled the petition for judicial inquiry into oversight of Canadian air safety for the first time on the same day as the ICAO deadline.

[Widow]

Nice follow-up.

Transport Canada not updating pilot-fatigue rules, union charges
Regulations for flight and duty times aren't consistent with new standards of UN civil aviation agency, association says

TU THANH HA

Toronto — From Saturday's Globe and Mail
Last updated on Friday, Nov. 20, 2009 9:01PM EST


Transport Canada isn't taking new UN aviation standards seriously enough and is missing a chance to improve its rules on fatigue in the cockpit, says the country's largest pilot union.

“Clearly it's past time for us to have a look at our regulations and examine how they measure up against what we know today,” said Paul Strachan, president of the Air Canada Pilots Association.

He was reacting to Transport Canada's assurances that its regulations on flight and duty times are compatible with the standards of the United Nations civil aviation agency.

The International Civil Aviation Organization's new norms became effective this week.

In a statement to The Globe and Mail, Transport Canada said its regulations on flight and duty times are already “consistent with the intent” of the new ICAO standards.

“It's akin to saying that a sundial is consistent with the intent of telling time,” Mr. Strachan said. The new standards are more specific in defining flight time, fatigue and rest periods. In addition, ICAO says that regulations on fatigue should be based on scientific principles “where available.”

ICAO also has non-binding recommendations that say factors such as accumulated fatigue or circadian rhythms should also be considered.

Pilots note that Canadian regulations are of the one-size-fits-all approach, with no consideration for aggravating factors such as irregular shift work, multiple time zones or night-time work.

Daniel Slunder, national chairman of the Canadian Federal Pilots Association, which represents Transport Canada aviation inspectors and accident investigators, had worked at the department until this summer.

He said the aviation branch was too short-staffed to deal with the ICAO changes, which had been in the works since the early 2000s. “I can't fault the individual in charge of that section for not doing that work. He had nobody under him. He was a section of one.”

The debate about pilot fatigue comes on the heels of an Auditor-General report criticizing how Transport Canada has moved to a new oversight system. For a decade, Transport Canada has been busy transitioning to a sweeping new regulatory approach called Safety Management Systems.

The theory behind SMS has been embraced in many industries. However, its application in Canadian aviation has been contested.

In a report last year, the Auditor-General said Transport Canada failed to assess properly the impact of the SMS change on oversight activities., its risks and costs and the resulting changes in staffing.

Under SMS, rather than solely doing hands-on inspections, Transport Canada would focus on auditing the companies' safety systems. For example, instead of directly inspecting an aircraft's tires, Transport Canada would assess whether the airline has systems in place to ensure that tires are properly inflated.

Critics such as Mr. Slunder say that the change has opened the door to cost-cutting.

As it stands, passengers benefit from the fact that pilots for major carriers have collectively negotiated for more conservative work hours than the Canadian standards allow.

“Safety shouldn't be negotiated. It's up to the regulator to set the framework,” Mr. Strachan said.

http://www.theglobeandmail.com/news/nat ... le1372398/

[Rotten Apple #1]

Fair enough TuThanhHa.

[Rotten Apple #1]

And since I don't work for any organizations that are connected with ALPA or ACPA, I'll have to take your word for what they told you.

Now if you really wanted to see a two-step you should go back and ask those same ACPA guys and ALPA guys how they feel about including time spent commuting to work being included in duty day calculations. Now that I would want to read.

[dashx]

TTH:

I wrote "irregular schedule" because, as far as most working people are concerned, having a job where you are on the road, arrive somewhere at 2 a.m. and check into your hotel at 3 a.m then go to work the next day, is not the norm

I suggest you go out on the road one night at 2 or 3 am and see how many trucks you'll see out there. Maybe you can even interview the drivers when they stop off to get a coffee or buy fuel.

[Siddley Hawker]

Johnny dangerous my post was ahead of the one with the incident report, which is why I assumed the autopilot was flying the aircraft. I'm a little puzzled that a pilot would reduce power in level flight to the point the stick shaker would activate.

[Rotten Apple #1]

Check that Siddeley Hawker. He reduced power in the same manner that the Colgan pilot did: distractedly.

And you were correct, the autopilot was flying the aircraft. It just wasn't in charge of the engine thrust settings, if I understand the CRJ set up (and I make no claim to). That would be a shared responsibility of the crew to set and monitor.

[The Old Fogducker]

I think he did a pretty good job for "an outsider" to the business.

He didn't fall into the Hollywood movie script writer category, and anything we can do to obtain press ink for regulatory change is good.

The problem is not so much in CAR 705 as in 703 or 704 operations where the staffing levels per aircraft are very low.

OFD

[Rotten Apple #1]

This is how one person (beresford) commented on the article at the G&M website:

The issue is more complex than the author has described it. At Air Canada the work rules are negotiated by the Air Canada Pilot's Association. The Union has contractual provisions that are less demanding than the Canadian Aviation Regulations. However, the Union also has an entrenched seniority system which doesn't not adequately share the work between its members. The junior members (not younger necessarily - just hired at a later date) carry the burden while the senior pilots (not older necessarily - just hired earlier) have an easy time of it. The regulations should change but before the union starts feather bedding it should take a good hard look at how its preference for an antiquated seniority system contributes to the fatigue of its own members.

[Rockie]

Transport Canada has studiously avoided action on the F&DT regulations for decades. Lame excuses like lack of scientific data are disengenuous in the extreme, and are designed solely to throw the press and travelling public off the trail. But we know better.

It also doesn't help when large pilot groups like Westjet oppose any change because it means they wouldn't get as many consecutive days off, or it would hurt the bottom line and thus the paycheque.

About 12 years ago ALPA's official position was that scheduling rules and fatigue issues were a "working condition", and should therefore be dealt with within a collective agreement. I actually had an argument with a senior ALPA executive about that stating that the proper place to address it was in the regulatory arena since it was a safety issue, not a labour issue. They have since changed their focus and are going after the FAA rather than the individual companies.

[Rotten Apple #1]

It also doesn't help when large pilot groups like Westjet oppose any change because it means they wouldn't get as many consecutive days off, or it would hurt the bottom line and thus the paycheque.

Exactly which proposed changes did you have in mind that would change WestJet's scheduling practices?

I received my monthly schedule that had me flying 79.5 hrs (all hard time I might point out) for the month of November. I promptly dropped three pairings leaving me (a total of 31 hours) via our online shift trading program. I then promptly picked up 1 straight time and 2 overtime pairings via this same system. That gave me 13 days in a row. I was also able to change/drop two of the staring/ending deadheads. I went as far as the Eastern time zone in that 13 days of work. (1 St Lucia layover and 1 Orlando layover, and a bunch of Edmontons and Torontos; not bragging, just the facts). The schedule suited me financially and commuter wise and rest wise. Now I have my 7 days off to get the winter tires on and the Christmas decorations up and rake the leaves, etc. All in preparation for my days off from the 20th to the 29th of December. Big White here I come.

Yeah. It's a great gig. And I'm grateful for it, not boastful. It's too bad if you guys at your outfit have some rest/fatigue issues. Perhaps your SMS will help to change your working conditions, if the union isn't able to.

[Rockie]

It also doesn't help when large pilot groups like Westjet oppose any change because it means they wouldn't get as many consecutive days off, or it would hurt the bottom line and thus the paycheque.

Exactly which proposed changes did you have in mind that would change WestJet's scheduling practices?

I received my monthly schedule that had me flying 79.5 hrs (all hard time I might point out) for the month of November. I promptly dropped three pairings leaving me (a total of 31 hours) via our online shift trading program. I then promptly picked up 1 straight time and 2 overtime pairings via this same system. That gave me 13 days in a row. I was also able to change/drop two of the staring/ending deadheads. I went as far as the Eastern time zone in that 13 days of work. (1 St Lucia layover and 1 Orlando layover, and a bunch of Edmontons and Torontos; not bragging, just the facts). The schedule suited me financially and commuter wise and rest wise. Now I have my 7 days off to get the winter tires on and the Christmas decorations up and rake the leaves, etc. All in preparation for my days off from the 20th to the 29th of December. Big White here I come.

Yeah. It's a great gig. And I'm grateful for it, not boastful. It's too bad if you guys at your outfit have some rest/fatigue issues. Perhaps your SMS will help to change your working conditions, if the union isn't able to.

If you're trying to dispute my statement above you're not doing a very good job. In fact you're proving it.

[Rotten Apple #1]

Rockie, if your airline has a problem with fatigued pilots, then by all means do something about it. That's why I'm glad I'm no longer flying around in the A310 (Royal)/A330 (Canada3000). I'm not tired anymore, save for the odd redeye, or YYT/YHZ early wakeup. In any case, you can make what you will of my schedule. Or me. I couldn't give two rats. Hmmm, a selfish pilot,...noooo!?!

I know I got it way better than I did after Canada 3000 shutdown and I painted walls and renovated for a year and a bit. (I know, that story probably gets old for some of you).

Anyway...beer's on me.

John Swallow

[Rockie]

Jonny

Does the WJPA agree with and support ACPA and ALPA in their effort to have Transport Canada update the F&DT regulations?

If they do...why?
If they do not...why not?

[snaproll20]

There is an interesting book written by a Vancouver researcher which clearly identifies that sleep deprivation is a cumulative state. Flying an aircraft on duty times, odd hours, circadian challenges, etc. is only one facet of sleep deprivation which modern society engages in. If we find something we MUST do which will take 30 minutes, we either go to bed 30 minutes later, or get up 30 minutes earlier to cope.
The result is that most of society is sleep-deprived and living on time-overdraft.

[Mig29]

The problem is not so much in CAR 705 as in 703 or 704 operations where the staffing levels per aircraft are very low.

OFD

That is very true, and I think the majority of incidents/accidents do fall into that category...We can't compare fatigue levels of a senior 777 pilot flying 3-4 overseas trips a month to a KingAir or Dash-8 guy doing up to 8 approaches in marginal IFR weather with minimum turns that don't suffice even for basic physiological needs and all that with short rest times between pairings.

[ivanhoe]

Does'nt sound like this guy is losing any sleep...



I've been on the A320 for the past 7 years. For the last couple of years, this is my typical pairing:

I do an early morning deadhead from Toronto to Varadero, Cuba. I then sit two days on the beach, followed by a 6+ hours flight to Calgary. Short layover in Calgary, and deadhead back to Toronto. Repeat again the following week, with the occassional Barbados layover thrown into the mix.



Point is...ya gotta take the good with the bad. Its always been that way in this business due in a large part to the contracts negotiated by the pilots themselves. It seems a little disengenuous to me that those same pilots complain about working too hard and long.

[Rockie]

There's always someone with a good schedule. Air Canada has some guys who by virtue of their seniority work monday, wednesday and friday from 9 AM to 5 PM. Does that make our regulations safe because they don't have to work to them?

This is a safety issue and it is completely legal not only to schedule a two person crew for 14 hours and 6 sectors starting at midnight, but that same crew can extend to 17 hours if they wish. I have done some ferociously bad all nighters in my time where I was not safe even halfway through it. But it was completely legal. There is absolutely no consideration given to human factors, or just plain common sense in Canada's F&DT regulations.

[CD]

AvCanada: Fatigue Research

[moreccsplease]

Unfortunately, the only unions/associations that you ever hear comment about making safety better for ALL Canadian pilots in this entire Canadian aviation industry is ALPA (Air Line Pilots Association, Int'l), ACPA (Air Canada Pilots Association), and CFPA (Canadian Federal Pilots Association). Sadly, WJPA (Westjet Pilots Association) doesn't seem to want to join in and help with making this industry safer by standing up for all pilots by changing the CARs, representing pilots in the media, and funding studies on safety... or at least we never hear about it.

I challenge the WJPA to stand up and unite with ACPA, ALPA and CFPA, all four together represent, what, 6,000 pilots in Canada... or more? All three together could force positive change for every pilot in this country by way of lobbying for better regulations.

I want to add that I said the above comments with respect to the WJPA... any group that represents pilots as a whole is better than none, but all of us together are unstoppable.

[corytrevor]

The author (media) finally gets it right. Thank you. To any of you who dispute that pilot fatigue happens, wake me up, then ********.

[Rockie]

More deafening silence from the Westjet crowd on this issue. I am not on a WJ bash here, but pilots in this country have been struggling to no effect for decades trying to get our non-regulating regulator to do something about our archaic F&DT regulations. Westjet pilots have been a non-participant in that struggle and I think it's about time they took ownership for it, because on this issue if you aren't helping then you are part of the problem by enabling TC's inaction.

So once again here is a chance for Westjetters to clear the air and either advocate change or stand up proudly for Canada's current regulations.

Does the WJPA agree with and support ACPA and ALPA in their effort to have Transport Canada update the F&DT regulations?

If they do...why, and what are they doing about it?
If they do not...why not?