Proposed Flight Crew Fatigue Regs

[DBC]

Hell has finally frozen over and TC has put out their proposal.

Not as restrictive as some countries, but some massive improvements that should raise the bar.

http://wwwapps.tc.gc.ca/Saf-Sec-Sur/2/N ... x?id=10200

I want to say thanks to those involved with the CARAC process that pushed for this stuff.

[Krimson]

Thanks for sharing

[martinez]

Good to hear! I can't wait for these to show up in the gazette 2.



I would also like to suggest they add:

an air operator shall provide and extra 2 hours to the flight crew rest period if the flight crew is required to figure out if they are operating legally.

time spent figuring out if the flight crew is operating within the regulations set out in CARS 700.14 to CARS 700.41 will be considered part of the flight crews duty time.

[rudder]

Yes, very confusing. In the US they have come out with phone apps to help the pilots determine if they are legal........

I have heard that the impact on crew efficiency/required staffing will be as much as 17% at the sked charter airlines. Certainly appears that most pilots will be working more days and that many high time single day turns will no longer be permitted without augment.

I wonder when the realistic coming in to force date will be.

[whipline]

Thanks for the link. About time.

PS it's called the cap 371. Just adopt it. http://www.caa.co.uk/docs/33/cap371.pdf

[Lemon]

I love how it says 702/703 companies will have 24 months to comply after this is published in the gazette. So it looks like the medevac companies can rape us a little longer

[flyinhigh]

This NPA is going to have a dramatic effect on everyone, NOT just the operators. It's a joke.

Case in point is the fact that they want to limit the max 365 consecutive days to 1000 hours, well for some that is a direct hit to the amount overtime you are allowed to fly which now hits YOUR wallet.

I would be very interested how much OT a Westjet driver is going to miss out on, whether is is via hours or worked days.

Are the current regs out dated? Hell yes.

When something like this comes out that you need a lawyer, to tell YOU the pilot, that yes you can do that one last leg legally and not be in Violation of the FDP, than there is something fundamentally wrong.

[aerodude]

This NPA is going to have a dramatic effect on everyone, NOT just the operators. It's a joke.

Case in point is the fact that they want to limit the max 365 consecutive days to 1000 hours, well for some that is a direct hit to the amount overtime you are allowed to fly which now hits YOUR wallet.

I would be very interested how much OT a Westjet driver is going to miss out on, whether is is via hours or worked days.

Are you telling me a encore driver will need to fly more than a 1000 hours to make ends meet? That shouldn't be a 705 Op

[NotDirty!]

This NPA is going to have a dramatic effect on everyone, NOT just the operators. It's a joke.

Case in point is the fact that they want to limit the max 365 consecutive days to 1000 hours, well for some that is a direct hit to the amount overtime you are allowed to fly which now hits YOUR wallet.

I would be very interested how much OT a Westjet driver is going to miss out on, whether is is via hours or worked days.

Are you telling me a encore driver will need to fly more than a 1000 hours to make ends meet? That shouldn't be a 705 Op

That's a stretch.... nobody "needs" to work overtime, but it sure is nice to be able to make a little extra "scratch"!

[flyinhigh]

This NPA is going to have a dramatic effect on everyone, NOT just the operators. It's a joke.

Case in point is the fact that they want to limit the max 365 consecutive days to 1000 hours, well for some that is a direct hit to the amount overtime you are allowed to fly which now hits YOUR wallet.

I would be very interested how much OT a Westjet driver is going to miss out on, whether is is via hours or worked days.

Are you telling me a encore driver will need to fly more than a 1000 hours to make ends meet? That shouldn't be a 705 Op

I am not saying that, what I am saying is that it is no secret that every Westjet driver does some OT, and quite often usually. Regs like this will effect that, unless the company spends lots of money to put things forward on there own terms under the FRMS program.

[Gilles Hudicourt]

In Europe (EASA), the Max flight hours in a year is 900 hours. That's 75 hours a month on average.

[Stevo226]

So when will this Canada Gazette II be published?

[B52]

Canada has a long history of an apathetic approach to duty time and flight time limitations
that seem to be justified by the long summer days and seasonal work.

It's only a matter of time before that apathy results or at least
contributes to an accident.

[Mig29]

In Europe (EASA), the Max flight hours in a year is 900 hours. That's 75 hours a month on average.

Yeah,
I had a quick scan over the page that relates to airline ops, and we are pretty much on par or worse with others but no where do we step ahead and lead the regulations. Pretty sad I have to admit for a G7 nation not to be an example in aviation safety.

[B52]

I notice the TC exams show few questions on this subject. In other countries
you have to know it backwards. Canada seems to allow almost anything under
special permissions that would not likely be granted in other jurisdictions.

I've seen close on 150 hours in less than two weeks and it's hard to not to see
how fatigue sets in with hours like that.

Emergency situations are one thing but it tends to become accepted and normal.

I recall taking turns to sleep to keep one of us awake and how that was frowned on etc but
at least it was the safest thing to do at the time.

Don't expect to read about that in a TC exam question soon.

[spaner]

As usual,

The fundamental dissertational, disputational premises here, is this,

That the people in the know, the professionals on the front lines of the conflicting agendas, were not consulted in the determination of end points that were desired by oversight (governmental committees), representing the gereral publics' interests, in Canadian aviation operational safety.

If general, and specific, operational data is desired, to make insighful and restrictive determinations; should that data not come from the very people making these determinations everyday, every-shift, every segment; these professionals, having to make determinations outside of the current regulations. Sometimes, wholly in the name of self-preservation; those who did so, were fired, those that did not, died.

Unfortunately, determining regulation, has always been, and will always be, about the MONEY. Money, property, taxes, and commission. Committees get paid, and the flow of money is indirect in its' influence, and so, can not be attributed to partiy lines. True, because its' influence is not along party lines. It's bigger than that, and is the reason for lobbyists in our current system; the truth, it means very little, really.

If it did, if the truth of fatigue VS performance ment anything in the real world of Canadian aviation regulation; pilots would be legislated, restricted, to working an 8-eight hour day. Not a Flight-Duty-Day, Not Duty-Hours, but a "WORK-DAY".

Firstly, cut out all the smoke and mirrors bull-shit; you start work, you finish work, that's a work day, that's the restricted day, and that's the day that you get paid for.

The only reason things get complicated in regulation, is so that those making the money can sneek in that which makes them MORE money; regulation, under the guise of safety. That which is simple to understand, costs them money and is too safe. If everyone could understand the rules, then anyone could stand up and shout "HEY, THIS IS UNSAFE"...Not so, this is not possible, because no one can understand the rules, the regulation.

Even the front-line professional, is unsure of his position in the regulation, and relys on his employer for reassurance, that he is at the very least, operating with in the regulation; dead tired, walking zombie, but that does not matter, as long as he is operating within the regulation, and is "legal". The general public...forget about it, they don't have a clue that their flight crew is in their 15th hour of "flight-duty-time", and are sector-legal, even though neither one of them has slept in 27 hours...
Approach to minimums, Rwy-23-CYYZ...good luck..

Colgan changed nothing. "They" know what the problems are, and "they" know what it is that should be done to fix those problems. So, why, why are the obvious solutions to the problems NOT being put forward to solve this obvious problem?

M_O_N_E_Y


The general public, an informed decision...
"Risk management" of operational fatigue effects in Canadian Aviation,
Not even remotely possible in this current system of bureaucracy and politics in the aviation sector.

Rant Master---OFF

[anona]

I think a lot of folks are get EVAS'd.

[spaner]

Funny (smoke), but maybe, just maybe it's time to take notice of the actual problem, and cease the intelligent banter that deflects acknowledgement of the associated frustration,
The frustration experienced by the intellligent professionals, working hard, to come up with a solution, to an obvious problem, only to have those solutions rebuffed by task oriented individuals in positions of power (and money-to-power); all too often, resulting in a continued condition of resignation by those that throw the dice, and do the dying.

There was a time, that I myself described my professional position as being,
"Comming up with a last minute solution, to an impossible problem, created by an incompetent person"
The long term solution, of course, was to get rid of the incompetent person; which was never an option. The best you could do, was to promote them out of your department; and hopfully, right into the airlines, with the best of glowing recommendation.

The current recommended solutions, to the fatigue problem, follows the same lines of bureaucracy.
"The Solution" required attributes,
1) something is being done; delay,
2) what is being done, no one can understand; ensure,
3) hire, and secure, the opinion of experts, to ensure that what is being done, is good, and of benifit, to "the problem",
4) down play the obvious costs, and restrictions,
5) up play the expected results and cost savings, over "the long term",
6) delay, any and all actions until the next federal election, bolster electoral votes for the minister,
7) continually ask, and provide for, input of those affected by and about the pending decisions,
VIII) never commmit, to the acceptance of any recommendations by any, but the government retained experts,
9) submit, a lengthy report for conideration, to a "committee" for consideration, preferably federal, and requested by the governor general as urgent, for consideration,
10) after the press has died down and all results are in, deem the results to be "inconclusive", and drop the matter back to the senate committee for consideration of lack of aviation sector interest.

Yet, control the matter for consideration and do not let the matter become an incumbent vs proponent electoral deficiency.

AND, the people keep dying,

How's that for funny...


We actually are waiting for more people to be killed before we can do something that makes sense. We don't kill enough people in aviation to merit regulatory changes.

— Deborah Hersman, former US NTSB chairwoman, explaining to USA Today newspaper why the FAA doesn't change old regulations. 20 June 2014.


Disneyland takes something that's safe and gives you the illusion that it's dangerous. We take something that's dangerous and give you the illusion it's safe.

— Canadian Aviation, and the sector saftey record VS industry standard performance, WWP,

...

[TFTMB heavy]

Gazette II will be as early as January 2016.

[805ITT]

I work for a 705/704 company that schedules 15-16 days a month which gives pilots, what I feel is the best work life balance. The days are usually 11-13 hour duty days with 6-7 of hours flying and 7 to 8 segments to get to 85 credits per month. Under this proposed NPA, to get to 85 credits pilots are going to be working 8-10 hours a day and 19-20 days per month. I am still going to have the same amount of time free from duty but now it is going to be more spread out and will spend more time commuting and away from home.

I agree with reducing duty periods for working overnight, but feel it would be much simpler with just 4 start time categories (Bankers hours, early duty, late duty and WOCL duty). I like the clearly defined rest periods (however just make it a flat 10 hour regardless of home base or 12 if you are based at a Class 1 airport like YYZ or YVR where the commute times are longer.) I like the stand-by language and 6 hour break rule. I like the cumulitive duty time limits, that is a huge improvement. The definition of a day free from duty including two local nights rest is great.

I disagree with the definition of a segement as just just a take-off and landing, that is far too simple, and would suggest using the TC definition for a Line Indoc segment to include T/O, LDG and a cruise portion of 50 nm. I think that starting to limit the duty time at 4 segments should be moved to a least 6 segments for regional operators given our stage lengths and we don't regularly cross numerous time zones. Of the 10 entities that were on the Fatigue Risk Management Working Group, 5 represented carriers that have international operations that span many time zones and there wasn't an adequate representation for the rest of aviation. The definition of suitable accomodation is far to loose, "when is a bedroom not available?"

Don't get me wrong, I am all for the improvements, I believe that the effort should have been spent more at 703 level where it is definately time for an overhaul because regular 15 hour duty days, 12 days off in 90 days, min rest and 900 hours in 6 months is rediculous. We haven't even seen what the Ops Specs for the proposed regulations are going to be.

[TFTMB heavy]

Camps are where a bedroom may not be available.

Did anyone else get the impression that FA and maintenance would be subject to duty times as well? I need to read it again...

[CD]

Did anyone else get the impression that FA and maintenance would be subject to duty times as well? I need to read it again...

This proposed change does not apply to any others... so FA, maintenace, ATC, etc. still have only Part III of the Canada Labour Code or individual union contracts as limts.

[TFTMB heavy]

[quote]This proposed change does not apply to any others... so FA, maintenace, ATC, etc. still have only Part III of the Canada Labour Code or individual union contracts as limts.
/quote]

Thanks, I read it again last night and come to the same conclusion. I'm not sure why I thought that the first time I read it?

[coldandwet]

More time restrictions will definitely hurt the smaller operator since the pool of pilots keep shrinking.I work for an operator that uses split duty days and I can tell you that there's are definitely not resting when they should....shopping walking around town...etc..It seems that everyone wants the most time off with the least amount of work. The whole industry is really getting to me after 26 years. And the lack of time restrictions for maintenance is comical...no amount of clear decision making by the rested crew is going to help when the engineer after 30 days straight of 12-14 hour days forgets to tighten something up because he is being distracted by a new wonderpilot hitching be has to work a. 2 day pairing.........rant over LOL.

[florch]

I see pros and cons. It will reduce fatigue, and it will shift the supply demand curve in favour of pilots.

On the other hand it could wreck some high credit flying that isn't that fatiguing because you have lots of days off per month. This will result in more layovers and less productive rosters.