New flight crew fatigue management (NPA)

[timel]

http://wwwapps.tc.gc.ca/Saf-Sec-Sur/2/N ... 1&lang=eng

[checkremarks]

I'd support a 12 hour duty day, it's about time we get pilots off min rest and min pay.

[Liquid Charlie]

As I speculated the 703 operators will be hardest hit -- that is a good thing since the guys who work the hardest can be worked to a point past where it is safe and still be within the regs -- I have no sympathy for 703 carriers - they abused the regs and now since they seem incapable of being safety conscious and limiting work days on their own it's going to cost them -- if I were an operator I would be gearing up for this now, slowly, to lessen the impact -- but we all know it doesn't work this way -- tsk tsk -- my only hope these rules are imposed sooner than later -- when I hear so many complaining about long duty days and being tired - the problem is as plain as the nose on your face -------

[goldeneagle]

I have no sympathy for 703 carriers - they abused the regs and now since they seem incapable of being safety conscious and limiting work days on their own it's going to cost them

You are painting everybody with the same brush, just because the OC is in the 703 category. There are bad apples in every barrel, it's just as easy to find 704 and 705 operations that have similar abuses of the system, and it's also easy to find 703 operators that run a tight ship, well within your percieved guidelines of what is and is not safe.

After a while, it gets really old and tiring the negative attitudes here toward 'the operator', as if that is some nameless, faceless, magic thing behind the scenes that yanks your chain in some attempt to make life miserable for you, the poor pilot. In reality, 'the operator' is your employer, the one that signs that paycheque every month. If you dont like it, then instead of moaning anonymously online like some hard done puppy dog, why not just let your feet do the walking, and leave, go somewhere else where the conditions are to your liking ? It should be real easy, there is a huge pilot shortage out there, must be, I read about it on AvCanada.

[timel]

After a while, it gets really old and tiring the negative attitudes here toward 'the operator', as if that is some nameless, faceless, magic thing behind the scenes that yanks your chain in some attempt to make life miserable for you, the poor pilot. In reality, 'the operator' is your employer, the one that signs that paycheque every month. If you dont like it, then instead of moaning anonymously online like some hard done puppy dog, why not just let your feet do the walking, and leave, go somewhere else where the conditions are to your liking ? It should be real easy, there is a huge pilot shortage out there, must be, I read about it on AvCanada.

703 duties and rests are not safe for IFR crews and some 702 ops, and by the way even India seem to have a lower maximum annual total flying. Canada is the worst.

But goldeneagle, when you wake up to do a 14-15 hours duty, you take-off before sunrise, land after sunset, make multiple approaches at minimums, fly with no auto pilot the whole day, because you don't have one, use some old tech to rely on, you have no dispatch to file your flight plans, some captains even have to call for rooms, accommodations, fuel and figure out for food.

Than get your so called "8 hours rest" that barely gives you time to drive home, shower, eat and start again, you just get all exhausted, and sorry but it is not safe. Operator won't make me cry either. They get their 9am to 4:30 pm days.

Yes operators don't all push pilots to it, or do it when they need to, but some can and do, and will keep on doing it if they can, to make it go low staffs, lower wages to pays, maximize human work.

Know what? All operators will have to change and adapt. Fair and safer for everyone.

[Liquid Charlie]

why not just let your feet do the walking, and leave, go somewhere else where the conditions are to your liking

-

I'm thinking that is what I said -- I wasn't really to hard on the operators -- it's their bottom line -- what I was alluding to is have the balls to shut it down when you are fatigued (not a little tired) and make sure you get the proper rest -- and if the carrier is petty enough to fire you -- wrongful dismissal is your protection -- usually people back down when they know you are right -- and if they don't -- you live to fly another day and hopefully with a company that cares about safety --

[Big Pistons Forever]

If this is actually the law of the land in less than 5 years I will eat my Cap Gen.

[timel]

If this is actually the law of the land in less than 5 years I will eat my Cap Gen.

Haha putting that in my agenda!

[timel]

http://skiesmag.com/news/article/FightingFatigue

Transport Canada is joining a number of other regulators in enacting changes to fatigue risk management regulations that are backed by scientific research. In a notice of proposed amendment (NPA) issued on Sept. 15, Transport Canada published a series of planned legislative changes that it claims will enhance flight safety by reducing fatigue-related errors in the cockpit.

It’s a known fact that fatigue reduces mental and physical performance and is a contributing factor to workplace accidents. In aviation, crew fatigue has contributed to countless accidents and incidents. Such was the case in January 2012, when the crew of a Boeing 737-700 flew a faster-than-normal visual approach into Fort Nelson, B.C., forgot to disengage the autothrottle system, and subsequently overran the runway by 230 feet. Fortunately, there were no injuries or damage to the aircraft; however, Canada’s Transportation Safety Board determined that fatigue likely contributed to the flight crew’s poor judgment and inability to identify and manage operational risk.

Fatigue has a significant impact on helicopter operations, too. In 2012, the U.S. National Transportation Safety Board made an industry presentation at HAI’s Heli-Expo that stated: “Fatigue can degrade every aspect of human capability,” reducing performance by 20 to 50 per cent or more. The presentation identified helicopter accidents in which fatigue had played a part, listed factors associated with pilot fatigue, and made a series of recommendations to combat the danger. Among others, the NTSB advised regulators to consider a science-based approach to scheduling hours of service, one that would provide for at least eight hours of uninterrupted sleep and consider such things as the circadian clock, disorders such as sleep apnea, and hours spent awake.

Other notable industry groups are also working to combat flight crew fatigue. The International Civil Aviation Organization (ICAO), the International Air Transport Association (IATA), and the International Federation of Air Line Pilots’ Associations (IFALPA) came together in 2011 to release a Fatigue Risk Management System (FRMS) Implementation Guide for commercial aircraft operations. The plan recommends an FRMS approach, which is a data-driven method of evaluating fatigue-related risk, based on both scientific principles and operational best practices. Such a system could be integrated into existing safety management systems, advised ICAO.

In late 2011, the U.S. Federal Aviation Administration similarly amended its flight, duty and rest regulations for Part 121 passenger operations. The changes recommended a systems approach whereby both carriers and pilots accept responsibility for identifying and preventing crew fatigue. The European Aviation Safety Agency has also implemented a series of changes in line with FRMS recommendations.

Transport Canada is the latest regulator to announce its support for the principles behind an FRMS approach. The proposed changes will bring Canadian rules in line with ICAO standards and recommended practices (SARPs), thereby improving flight safety by integrating the latest scientific principles into fatigue risk management.

Recommendations are derived from an August 2012 report from the Flight Crew Fatigue Management Working Group, convened by the regulator and comprised of industry stakeholders.

Essentially, operators will be able to choose between a prescriptive, legislated approach to fatigue risk management, or a voluntary systems-based FRMS. While FRMS system implementation will not be mandatory, Transport Canada indicates that the option is “available as an alternate fatigue management scheme.”

Among a list of recommended changes, operators will be required to provide a schedule that permits sufficient crew rest, closely monitor flight and duty time data, and require that crew members declare themselves fit for duty prior to beginning their shift. Crew members must use allocated time off to rest, while monitoring their own level of readiness for duty, and reporting if they become unfit at any time.

Read the full Transport Canada NPA here.

Industry has until Oct. 3 to submit written comments on the proposed changes to carrac@tc.gc.ca. After that date, the amendments will be drafted and published in Canada Gazette, Part 1, at which point there will be an opportunity to provide additional feedback.

Once the proposed regulatory amendments are finalized, changes will be immediately applicable to CAR 704 and 705 air operator certificate holders (commuter and airline operations), while 702 and 703 operators (aerial work and air taxi operations) will have two years to comply with the new regulations.

[TailwheelPilot]

http://skiesmag.com/news/article/FightingFatigue

Transport Canada is joining a number of other regulators in enacting changes to fatigue risk management regulations that are backed by scientific research.

Yet the proposed FDP is always longer than what the scientific NASA study suggests (according to their chart)...

My complaints with the NPA are that it is too complex (NASA says 10 hour or 12 hour FDPs, why not use that and be done with it?) and that modifying the FDP by sectors flown does not make sense to me given how much variation there is in Canadian aviation. Why do more five to seven sectors reduce the FDP if you start at 0900, but not if you start at 2300? Why is there no difference between 7 sectors and 17 sectors? Why is there no difference between a sector flown in bad weather and good weather? Turbulence and calm skies? 5 minute sectors versus 5 hour sectors? Why do non-scheduled VFR helicopter pilots not get fatigued after three landings, but scheduled helicopter pilots do? Why do non-scheduled VFR aeroplane pilots get more fatigued after three sectors? Why do aerial applicators have a different set of rules? Why not allow other operators to abide by those same rules if it fits their operation better since they are obviously sufficient to keep fatigue at bay and are backed by scientific research?

I noticed there is no way to reset times. Not a big deal, but I would think a block of days off would allow one to overcome fatigue.

I also noticed in the earlier working group paper it mentioned a scientist (I think) had told the FAA that limiting duty time is of more importance than limiting flight time as far as fatigue is concerned. Do we even need to limit flight times if we are limited by our duty time?

[Liquid Charlie]

I always maintained it would be far easier to legislate rest times -- meaning something like 12 hours off duty - then it becomes very simple -- have consecutive work day rules -- in a lot of ways back to the ability to have a 21 day cycle would add flexibility with concessions for extended deployment -- anything to stop the 17 hour duty day mind set of commercial ops and owners -- whilst they can not schedule you for that they feel you are obligated to take that 17 hours to finish the mission if necessary with no questions asked -- this goes right up to 705 operations - I have experienced this first hand - even to the extent of manipulating times to make a proposed day fit within legal scheduling periods and then readjust the times once you are launched and voila -- a schedule exceeding 14 hours -- funny how that happens -- so put all the fancy formulas aside and tell people when to stay home and not how long to work depending on the cycle of the moon -- how many days end in "y" etc etc -- the simpler the system the less someone can fuc_k with it --

[Big Pistons Forever]

If this is actually the law of the land in less than 5 years I will eat my Cap Gen.

Haha putting that in my agenda!

Quote

Once the proposed regulatory amendments are finalized, changes will be immediately applicable to CAR 704 and 705 air operator certificate holders (commuter and airline operations), while 702 and 703 operators (aerial work and air taxi operations) will have two years to comply with the new regulations

Unquote

So the new flight duty time regulations won't be fully enacted until 2 years after the amendments are finalized. Since they are at least a year away from the Gazette 1 publication and there is often up to 2 years before the Gazetting process is completed and then 90 more days for a new regulation to come into force, I don't think I will have to lay in extra any Tabasco to go with my CAP gen.

[timel]

So the new flight duty time regulations won't be fully enacted until 2 years after the amendments are finalized. Since they are at least a year away from the Gazette 1 publication and there is often up to 2 years before the Gazetting process is completed and then 90 more days for a new regulation to come into force, I don't think I will have to lay in extra any Tabasco to go with my CAP gen.

Hope you are wrong. But 703 lobbies and lawyers probably getting crazy on TC right now. They will push it the further they can until last day.


People crying about news regs: It is called evolution and developement for the better, everyone will have to upgrade, they might have to hire more crews to make it work.