Hello Everyone,
This is a request to anyone who thinks that the length of duty times should be shortened.
In the same vein, this is also to anyone who thinks they are not being paid properly for the hours they are expected to be away from home when they put in maximum duty time most of the time.
Please PM me a letter, which may or may not have your real name, stating your concerns as far as duty times, fatigue, pay and any consequences you have witnessed as a result. Any near misses, etc. Mentioning a company name is also helpful, but not necessary.
It is my intention to get as many of these "statements" as possible and bring them as backup when I present these issues to Ottawa. I have already started discussions and they confirmed that if a lot of pilots have the same issues, the likelihood of something being done about it is greater. For the record, the personnel I have been talking to do seem very receptive.
I understand that not everyone shares my opinion that there is an issue here, and that is fine. But if you do share my opinion and would like to help do something about it, this may be an opportunity for it.
Thanks for your help.
Iris
Write a letter to make a change.
Moderators: North Shore, sky's the limit, sepia, Sulako, lilfssister, I WAS Birddog
Re: Write a letter to make a change.
I admire your effort, but you won't get anywhere. There unfortunately has to be a terrible tragedy in Canada directly blamed on fatigue brought on by our midieval duty time regulations before anything will be done about it. That isn't just rhetoric either, I know what I'm talking about.
Re: Write a letter to make a change.
Discussion on this thread too:
AvCanada: global report on pilot flight duty times
Also, as ICAO introduces changes to Annex VI requiring fatigue management systems (vs. prescriptive rules), here is a sample of what the future likely holds:
Fatigue Risk Management System for Canadian Aviation - FRMS Toolbox
AvCanada: global report on pilot flight duty times
Also, as ICAO introduces changes to Annex VI requiring fatigue management systems (vs. prescriptive rules), here is a sample of what the future likely holds:
Fatigue Risk Management System for Canadian Aviation - FRMS Toolbox
Re: Write a letter to make a change.
Eight PDF documents and one Powerpoint for dealing with fatigue. But nowhere in it will you find any mention of the flight and duty time regulations except that we should operate within them. Everyone is responsible except Transport Canada.
There are a number of ways to ensure
employees have been provided with sufficient
sleep opportunity within a schedule:
• operate within federal or provincial
hours-of-work rules
• use a computer-based fatigue modelling
package
• use a fatigue likelihood scoring matrix
Fatigue is widely recognized as a significant safety hazard, not just to you and your coworkers, but to the general public.
That's why Transport Canada commissioned a set of tools and guidelines to help the Canadian aviation industry set up fatigue risk management systems.
Fatigue risk management systems recognize that it's everyone's responsibility to manage fatigue risk. Employers should make sure that work schedules give employees adequate opportunities for rest between shifts. In turn, employees are responsible for making sure they use those opportunities to get the sleep they need to be fit for work.
An important part of any fatigue risk management system involves teaching employees and managers about fatigue as a safety hazard and how to better manage their own fatigue. This booklet can be used as an introduction to the more detailed, competency-based training workbook called Fatigue Management Strategies for Employees (TP 14573E).
There are a number of ways to ensure
employees have been provided with sufficient
sleep opportunity within a schedule:
• operate within federal or provincial
hours-of-work rules
• use a computer-based fatigue modelling
package
• use a fatigue likelihood scoring matrix
Fatigue is widely recognized as a significant safety hazard, not just to you and your coworkers, but to the general public.
That's why Transport Canada commissioned a set of tools and guidelines to help the Canadian aviation industry set up fatigue risk management systems.
Fatigue risk management systems recognize that it's everyone's responsibility to manage fatigue risk. Employers should make sure that work schedules give employees adequate opportunities for rest between shifts. In turn, employees are responsible for making sure they use those opportunities to get the sleep they need to be fit for work.
An important part of any fatigue risk management system involves teaching employees and managers about fatigue as a safety hazard and how to better manage their own fatigue. This booklet can be used as an introduction to the more detailed, competency-based training workbook called Fatigue Management Strategies for Employees (TP 14573E).
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co-joe
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Re: Write a letter to make a change.
Does it count if my "near miss" was due to falling asleep at the wheel on McKnight Blvd on my way to work on another min rest/max duty day?
Re: Write a letter to make a change.
I believe that those documents are generic in nature for a number or reasons, including that the concept is not unique to aviation. You will also not find any mention of flight and duty time regulations as only flight crew have prescriptive measures. None of the other employees in aviation (maintenance, cabin crew, ATC, etc.) have any duty time limitations. As well, as I suggested above, ICAO is moving away from recommending prescriptive limitations (which everyone seems to agree do not work well) toward fatigue management.Rockie wrote:Eight PDF documents and one Powerpoint for dealing with fatigue. But nowhere in it will you find any mention of the flight and duty time regulations except that we should operate within them.
FRMS for maintenance is in the regulatory pipeline now and from what I understand, flight and cabin crew will be next.
Re: Write a letter to make a change.
Transport Canada is the regulator that doesn't regulate. They put the entire responsibility for safety, standards and now fatigue management on the employer and employee, and absolve themselves of any culpability whatsoever. Their ongoing agenda of making everybody responsible except them is rapidly making them officially irrelevant instead of just effectively irrelevant.
Let's just shut them down now and save the taxpayers a lot of money.
Let's just shut them down now and save the taxpayers a lot of money.
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Chuck Ellsworth
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Re: Write a letter to make a change.
The enforcement of the Aeronautics Act and CAR's could be turned over to the RCMP, a regulator who are trained to police the law.
The most difficult thing about flying is knowing when to say no.
After over a half a century of flying I can not remember even one trip that I refused to do that resulted in someone getting killed because of my decision not to fly.
After over a half a century of flying I can not remember even one trip that I refused to do that resulted in someone getting killed because of my decision not to fly.
Re: Write a letter to make a change.
Just about anybody who accepts responsibility would be better than Transport Canada who accepts none.. . wrote:The enforcement of the Aeronautics Act and CAR's could be turned over to the RCMP, a regulator who are trained to police the law.
edit
Dammit, now my dander is up and it's time for a lesson in leadership 101 directed at Transport Canada.
Authority and responsibility are two sides of the same coin and cannot be separated however much you try. One cannot exist without the other.
By foisting all responsibility for every aspect of aviation onto the operators Transport Canada is forfeiting their authority as well and have made themselves irrelevant. They should be shut down.
Re: Write a letter to make a change.
.:The enforcement of the Aeronautics Act and CAR's could be turned over to the RCMP, a regulator who are trained to police the law.
Interesting point, however although the RCMP is responsible to enforce all federal laws, very few members have any knowledge of the Aeronautics act, their legal powers within the act, and generally speaking, what’s going on with aircraft and pilots.
In reality, when the RCMP encounters an aviation enforcement related issue, they contact TC for assistance in accordance with the Memorandum of Understanding (MOU) within the two organizations. (There are several former peace officer/investigators with TC enforcement branches, some RCMP, some other forces). And FYI life ain’t much better within the RCMP either these days, you know…
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Chuck Ellsworth
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Re: Write a letter to make a change.
Interesting subject this enforcement of federal law.
Seems that no one is responsible anymore, so why don't we just ignore the law and do what ever we feel like?
Seems that no one is responsible anymore, so why don't we just ignore the law and do what ever we feel like?
The most difficult thing about flying is knowing when to say no.
After over a half a century of flying I can not remember even one trip that I refused to do that resulted in someone getting killed because of my decision not to fly.
After over a half a century of flying I can not remember even one trip that I refused to do that resulted in someone getting killed because of my decision not to fly.
Re: Write a letter to make a change.
Here is a little known piece of trivia. Until about 2002, anyone violated under the act had to be charged in criminal court.Putting the burden of proof as beyond reasonable doubt
TC, bless their little hearts, used an "administrative penalty" including license suspension. Burden of proof is then lessened to a balance of probability. Finally someone took them all the way up through the federal courts and had it overturned.
TC's response. To try and change the act and regs. I am not sure of where it stands now, but immediately prior to the court case, TC was still using the "administrative" route, knowing full well that it was illegal...or at least their legal department did...the enforcement people, like all good cult followers simply ignored the legality of what they were doing.
I would be interested in how many people were violated and a penalty imposed, and then when they appealed it to the tribunal suddenly had the violations dropped for....lack of proof.
The root problem is that TC enforcement types tend to be ex mounties that could not cut it in the RCMP, and a bunch of wannabe Columbos..They are ignorant of the law recieve only the barest training in it, and bunch together like a herk of water buffaloes and attack anyone who challanges their beliefs.
What we need is a completely independent body to assess TC's enforcement practices. Everything from having the FSS people either report a violation or be violated themselves, to the practice of inspectors sending any possible contravention to enforcement.
Was hoping for a majority government that would clean out the top level TC beauracrats who fly around first class and have seemingly unlimited, tax payer funded expense accounts, while cutting back on inspectors overtime and demands for a fairer wage.
Glad I am not in Canada. Sometimes these thrid world countries actually have more respect for personal rights and freedoms.
My rant for the day.
TC, bless their little hearts, used an "administrative penalty" including license suspension. Burden of proof is then lessened to a balance of probability. Finally someone took them all the way up through the federal courts and had it overturned.
TC's response. To try and change the act and regs. I am not sure of where it stands now, but immediately prior to the court case, TC was still using the "administrative" route, knowing full well that it was illegal...or at least their legal department did...the enforcement people, like all good cult followers simply ignored the legality of what they were doing.
I would be interested in how many people were violated and a penalty imposed, and then when they appealed it to the tribunal suddenly had the violations dropped for....lack of proof.
The root problem is that TC enforcement types tend to be ex mounties that could not cut it in the RCMP, and a bunch of wannabe Columbos..They are ignorant of the law recieve only the barest training in it, and bunch together like a herk of water buffaloes and attack anyone who challanges their beliefs.
What we need is a completely independent body to assess TC's enforcement practices. Everything from having the FSS people either report a violation or be violated themselves, to the practice of inspectors sending any possible contravention to enforcement.
Was hoping for a majority government that would clean out the top level TC beauracrats who fly around first class and have seemingly unlimited, tax payer funded expense accounts, while cutting back on inspectors overtime and demands for a fairer wage.
Glad I am not in Canada. Sometimes these thrid world countries actually have more respect for personal rights and freedoms.
My rant for the day.
Accident speculation:
Those that post don’t know. Those that know don’t post
Those that post don’t know. Those that know don’t post
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Chuck Ellsworth
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- Location: Always moving
Re: Write a letter to make a change.
trey kule:::::
I would have sworn that I wrote that.
You have no idea how satisfying it is to see that there are still people in aviation who understand the problems in Canadian civil aviation and the oversight thereof...or rather the lack of oversight.
There is always another way to force TC to do their duty and that is to charge them with failure to enforce Federal Law...but that gets tricky and is very difficult to do.
I was successful in 1975 when I was chief pilot for Air West Airlines.
The most interesting experience that effort produced was having the DGCA try and intimidate me in an effort to stop me from bringing charges against TCCA.
I guess these top civil servants are all the same.
By the way I am difficult to intimidate as he found out.
I would have sworn that I wrote that.
You have no idea how satisfying it is to see that there are still people in aviation who understand the problems in Canadian civil aviation and the oversight thereof...or rather the lack of oversight.
There is always another way to force TC to do their duty and that is to charge them with failure to enforce Federal Law...but that gets tricky and is very difficult to do.
I was successful in 1975 when I was chief pilot for Air West Airlines.
The most interesting experience that effort produced was having the DGCA try and intimidate me in an effort to stop me from bringing charges against TCCA.
I guess these top civil servants are all the same.
By the way I am difficult to intimidate as he found out.
The most difficult thing about flying is knowing when to say no.
After over a half a century of flying I can not remember even one trip that I refused to do that resulted in someone getting killed because of my decision not to fly.
After over a half a century of flying I can not remember even one trip that I refused to do that resulted in someone getting killed because of my decision not to fly.
Re: Write a letter to make a change.
Yes.Does it count if my "near miss" was due to falling asleep at the wheel on McKnight Blvd on my way to work on another min rest/max duty day?
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Chuck Ellsworth
- Rank 11
- Posts: 3074
- Joined: Sat Sep 22, 2007 6:49 am
- Location: Always moving
Re: Write a letter to make a change.
I agree completely, of course it does.
The most difficult thing about flying is knowing when to say no.
After over a half a century of flying I can not remember even one trip that I refused to do that resulted in someone getting killed because of my decision not to fly.
After over a half a century of flying I can not remember even one trip that I refused to do that resulted in someone getting killed because of my decision not to fly.
Re: Write a letter to make a change.
co-joe...
As Iris and . indicate, fatigue prior to/during/following work should all be taken into account. So a situation such as you describe definately fits, imo.
Since we're on the topic...
As Iris and . indicate, fatigue prior to/during/following work should all be taken into account. So a situation such as you describe definately fits, imo.
Since we're on the topic...
AeroSafety World - October 2008
The Science of Fatigue
Regulators see a larger role for non-traditional methods of mitigating pilot fatigue and preventing fatigue-related accidents.
Moving toward a systems approach to preventing fatigue in aviation operations, the U.S. Federal Aviation Administration (FAA) says that, like other civil aviation authorities, it is going beyond traditional programs that limit the number of hours worked in favor of more comprehensive plans to help operators identify fatigue and mitigate its risks.
"While fatigue may not have been called out by name, it's been ... lurking in many of the accidents we've faced over the years," acting FAA Administrator Robert A. Sturgell told a fatigue safety forum convened by the agency in June to consider "new ways to manage fatigue."
The FAA characterized the safety forum as an early step in its development of a new approach to handling fatigue and its revision of existing policies, which have been in effect with relatively few changes for 50 years.
"Even with an outstanding safety record, we're not where we need to be when it comes to understanding and dealing with fatigue," Sturgell said.
The solution is not necessarily "adopting prescriptive criteria for fatigue risk abatement," he said, adding, "We need to address all levels of fatigue and put appropriate mitigations in place - mitigations that are proportionate to the risk."
Plans call for the proceedings of the symposium to be published in late 2008 in an effort to widely disseminate information about fatigue and fatigue mitigation.
The FAA's plans - outlined in August, in response to safety recommendations by the U.S. National Transportation Safety Board (NTSB) - are to "educate the industry on the reality of fatigue and ways to effectively mitigate its dangers." The FAA said it would first develop guidance for fatigue management in ultra-long-rang (ULR) operations - flights longer than 16 hours - and then apply that guidance to other flight profiles.
ULR fatigue-management guidance currently exists in the form of recommended guidelines published in 2005 by the ULR Crew Alertness Initiative, sponsored by Airbus, Boeing Commercial Airplanes and Flight Safety Foundation.
Complete 5-page article here...
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Captain CADORS
- Rank 2
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- Joined: Tue Nov 14, 2006 4:36 pm
Re: Write a letter to make a change.
Another reason for fatigue during "on duty" times may be a result of insufficient time sleeping during days off. Entering a tour with 4 hours of sleep deficit (perhaps working too hard renovating the house...) is our own mistake - not our employers/ regulators. Just a thought.
CADORS
CADORS
Re: Write a letter to make a change.
A great thread!
We should all be jumping on this.
Wouldn't it be easier to to start a petition though?
A good start would be to get the rest and duty requirements between 703 to 705 rules standardized with each other. Maybe some of those great pilot associations of Canada can help out. Like the CFPA, ACPA, SKPAC, ALPA,...Good luck with that though.
The 703 world needs some serious help.
We should all be jumping on this.
Wouldn't it be easier to to start a petition though?
A good start would be to get the rest and duty requirements between 703 to 705 rules standardized with each other. Maybe some of those great pilot associations of Canada can help out. Like the CFPA, ACPA, SKPAC, ALPA,...Good luck with that though.
The 703 world needs some serious help.
- NoseDraggers Suck
Re: Write a letter to make a change.
Stearman,
Thanks for the encouragement.
Individual letters (as opposed to a petition) have been requested by Ottawa to support my discussions with them. The more letters I receive, the better backup I will have.
Unfortunately, I haven't received near enough letters to make an impression. With all the passion and discontent in these forums, I didn't think it would difficult to get the backup I require.
Please, if you feel strongly that we need change, PM me.
Thanks.
Iris
Thanks for the encouragement.
Individual letters (as opposed to a petition) have been requested by Ottawa to support my discussions with them. The more letters I receive, the better backup I will have.
Unfortunately, I haven't received near enough letters to make an impression. With all the passion and discontent in these forums, I didn't think it would difficult to get the backup I require.
Please, if you feel strongly that we need change, PM me.
Thanks.
Iris
Re: Write a letter to make a change.
Iris
If you don't mind my asking, who is it in "Ottawa" that you are having these discussions with? Also what exactly are the nature and mutually agreed upon outcome these discussions are supposed to achieve?
The reason I ask is because I don't think you realize the iceberg sized bureaucratic inertia you are trying to overcome, and the publicly silent but immence political influence behind it that does not want the duty times in this country to change. The "Ottawa" you refer to could recieve a letter from every single licenced pilot in this country and it wouldn't make a damn bit of difference. This change will have to be forced, and the only thing that will do that is for the Minister and the Government to be horribly embarrassed by the current regulations. As I said before only deaths will achieve that because the official party line is "We have adequate regulations in Canada which are reflected in our excellent safety record".
I don't mean to belittle your effort. I really do admire your idealism and wish I still had some of my own. But reality has pushed it aside because I know how many people have fought this battle before with zero success.
If you don't mind my asking, who is it in "Ottawa" that you are having these discussions with? Also what exactly are the nature and mutually agreed upon outcome these discussions are supposed to achieve?
The reason I ask is because I don't think you realize the iceberg sized bureaucratic inertia you are trying to overcome, and the publicly silent but immence political influence behind it that does not want the duty times in this country to change. The "Ottawa" you refer to could recieve a letter from every single licenced pilot in this country and it wouldn't make a damn bit of difference. This change will have to be forced, and the only thing that will do that is for the Minister and the Government to be horribly embarrassed by the current regulations. As I said before only deaths will achieve that because the official party line is "We have adequate regulations in Canada which are reflected in our excellent safety record".
I don't mean to belittle your effort. I really do admire your idealism and wish I still had some of my own. But reality has pushed it aside because I know how many people have fought this battle before with zero success.
Re: Write a letter to make a change.
.
Last edited by B-rad on Sun Nov 30, 2014 4:26 pm, edited 1 time in total.
My ambition is to live forever - so far, so good!
Re: Write a letter to make a change.
Rockie,
I would more than happy to explain what I'm doing if you are interested in taking part.
Maybe we can establish a common frame of reference. What measures have you employed in the past? Have you written letters to TC, Gov't? Maybe you've emailed or phoned representatives? Did you stand up to an employer and refuse to wait an extra 2 hours for charter passengers to finish shopping because you didn't consider it 'unforseen circumstances' and it would run you into your 15th hour? Maybe you've demonstrated to the Labour Board that flying charters or quick turns all day, resulting in logging 8 hours flight time on a 14 hour duty day, really is grounds to be compensated in overtime pay?
I'd love to hear specifically what you have tried before, so I can change my approach if I'm doing exactly the same thing you've tried before.
Thank you for your interest and feedback.
Iris
I would more than happy to explain what I'm doing if you are interested in taking part.
Maybe we can establish a common frame of reference. What measures have you employed in the past? Have you written letters to TC, Gov't? Maybe you've emailed or phoned representatives? Did you stand up to an employer and refuse to wait an extra 2 hours for charter passengers to finish shopping because you didn't consider it 'unforseen circumstances' and it would run you into your 15th hour? Maybe you've demonstrated to the Labour Board that flying charters or quick turns all day, resulting in logging 8 hours flight time on a 14 hour duty day, really is grounds to be compensated in overtime pay?
I'd love to hear specifically what you have tried before, so I can change my approach if I'm doing exactly the same thing you've tried before.
Thank you for your interest and feedback.
Iris
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Chuck Ellsworth
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Re: Write a letter to make a change.
Iris, your concerns are justified, however you are up against a stacked deck and your chances of bringing about changes are somewhere around zero.
To better understand the issue you should Google Zimbawbe under Robert Mugabe.
That will give you some insight into the form of democracy at work in Canada.
Another good read is the front page of the October COPA and carefully think about the efforts of Kevin Psutka the president of COPA in trying to represent his membership plus all of those who do not belong to COPA......
.......when you finish get back to us and let us know if you think Canada is a true democracy or a dictatorship.
To better understand the issue you should Google Zimbawbe under Robert Mugabe.
That will give you some insight into the form of democracy at work in Canada.
Another good read is the front page of the October COPA and carefully think about the efforts of Kevin Psutka the president of COPA in trying to represent his membership plus all of those who do not belong to COPA......
.......when you finish get back to us and let us know if you think Canada is a true democracy or a dictatorship.
The most difficult thing about flying is knowing when to say no.
After over a half a century of flying I can not remember even one trip that I refused to do that resulted in someone getting killed because of my decision not to fly.
After over a half a century of flying I can not remember even one trip that I refused to do that resulted in someone getting killed because of my decision not to fly.
Re: Write a letter to make a change.
I'm not prepared to say what I've done to bring about change because this is an anonymous forum. But I will tell you it was large, organized, involved several different organizations and institutions and cost a lot of money.
Over the decades there have been no less than 150 scientific studies that measure the detrimental effect fatigue has on performance and cognitive abilities. There has also been studies that collated all the available information from all the other studies and summarized them in easy to read reports that all say exactly the same thing. This is not something that requires further study to determine what every human being over the age of 16 instinctively already knows.
And still nothing has ever been done about the flight and duty times because this is political.
The only way Transport Canada is ever going to change the rules is if the Minister of Transport is embarrassed enough to do something about it. I'm sorry to say you will not be able to do that. The collective wrath of every professional pilot in the country will not be able to do that. Embarrassment will do it. Figure out how to shame TC into changing the rules and you might (very big might) get somewhere. But be warned no one has been successful yet and it hasn't been for lack of trying.
Over the decades there have been no less than 150 scientific studies that measure the detrimental effect fatigue has on performance and cognitive abilities. There has also been studies that collated all the available information from all the other studies and summarized them in easy to read reports that all say exactly the same thing. This is not something that requires further study to determine what every human being over the age of 16 instinctively already knows.
And still nothing has ever been done about the flight and duty times because this is political.
The only way Transport Canada is ever going to change the rules is if the Minister of Transport is embarrassed enough to do something about it. I'm sorry to say you will not be able to do that. The collective wrath of every professional pilot in the country will not be able to do that. Embarrassment will do it. Figure out how to shame TC into changing the rules and you might (very big might) get somewhere. But be warned no one has been successful yet and it hasn't been for lack of trying.
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Chuck Ellsworth
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- Joined: Sat Sep 22, 2007 6:49 am
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Re: Write a letter to make a change.
The best yardstick to measure the power of TCCA top bureaucrats is go back and read what success that M.P. had when he alledgedly accused Merlin Preuss of being in contempt of Parliament.
Can someone convince me I am wrong thinking that either the fix is in so deep in the political arena or Preuss has more power than our elected officials.......or maybe no one really gives a fu.k what they do anyhow.
Can someone convince me I am wrong thinking that either the fix is in so deep in the political arena or Preuss has more power than our elected officials.......or maybe no one really gives a fu.k what they do anyhow.
The most difficult thing about flying is knowing when to say no.
After over a half a century of flying I can not remember even one trip that I refused to do that resulted in someone getting killed because of my decision not to fly.
After over a half a century of flying I can not remember even one trip that I refused to do that resulted in someone getting killed because of my decision not to fly.
