New 703 flight duty times

[DH Driver]

I hear little bits here and there about 'the new flight duty times'. I saw a report a while ago talking about possible changes and I think it had TC's name on it somewhere but haven't heard anything recently. Does anyone know of any upcoming changes to the flight and duty times preferably with links to TC? I tried to find an advisory circular but couldn't.

Thanks

[flyer 1492]

The draft can be found in Transport Canada under (CARAC) Flight Crew Fatigue Management Working Group. If that doesn't work pm and I can send you the draft.

Flyer

[atmos]

Spent an HOUR looking for the CARAC working group info on Fatigue management,, can you publish a link?

[DH Driver]

http://wwwapps.tc.gc.ca/saf-sec-sur/2/n ... g&m_id=240

Has anyone heard a proposed implementation time for this (if ever), it may require some forward thinking for pilots required.

[sky's the limit]

This is an enormous issue, please see below for the action the helicopter people are taking:

https://www.toofast.ca/takesurvey.php?SurveyID=7550


Ladies and Gentlemen, greetings.

I have contacted all of you with a matter of great importance. My apologies if I have reached the wrong people in some companies, but I went through the Vertical Magazine Operator’s directory and used the listed email addresses. I think I am going to have to ask Mike Reyno to use larger print in future additions, and could all the Newfoundland Operators please get new email addresses without all the dots and abbreviations? If those who have received this email in error could forward it to the right people that would be much appreciated.

The link above is a connection to a survey and petition that I, and a few other pilots, created over the last few weeks. I’m sure most people receiving this email are aware that Transport Canada is actively engaged in a process that will see new Flight, Duty and Rest Period regulations in Canada. I am writing this email because there are probably quite a few people who aren’t aware of this or are not aware of how close it is to reality and what the potential impact will be. In our company we sent out an informal alert to let people know that we had constructed this survey and petition and I was amazed at how many people had zero knowledge of the issue. Therefore I thought I would take it upon myself to contact as many operators as I could and ask that they (all of you) get the word out as time for dissension is rapidly disappearing.

In brief, a “Working Group” or “WG” was formed by Transport Canada almost two years ago to examine the current flight and duty times and to investigate any changes that might forward the cause of safety in this country. It was a good idea but in my opinion went so far off the rails from the perspective of the Canadian Helicopter Industry that no one on the train can even see the tracks anymore. Transport Canada refused to separate Airline Operations from small operators and the rotary wing industry. The meetings were like watching a company-union negotiation, as the airlines and their unions dominated every single aspect of the process with little to no regard for our (helicopter operators) unique challenges and circumstances. In my opinion there is so little in common between the day to day schedule and tasks that are performed by helicopter pilots as opposed to airline pilots that we should never be considered in the same breath. If changes are necessary for our industry then they should come as a result of studies that actually try to determine what we do, why we do it and what impact that has on safety. To simply lump all who fly in one basket as if they are the same is to miss completely the point of tailor-making specific solutions for specific problems.

I have attached the WG Report to this email for those with a great deal of spare time on their hands (and perhaps some insomnia) as well as a summary of the changes between what we are now allowed to do and what the new regulations would allow. Also, the Helicopter Association of Canada (HAC) engineered specific proposals that were ignored by the WG but I have included them here. HAC was the face of the rotary wing industry in the deliberations but not a single recommendation made by HAC even received a footnote in the final report. I believe it is relevant to this process that one of the chairs of the working group was the President of the Airline Pilots Association, which is not to say he didn’t try to be fair, but a more egregious example of perceived conflict of interest would be hard to find.

What we are trying to achieve with the petition is to provide a voice for helicopter pilots in Canada. Even pilots who prefer to work far less than what the law allows should not have restrictions forced on them that have no scientific basis and were designed for airline operations in Europe (from whence most of the WG recommendations came). We are demanding that Transport Canada cease and desist from further action to turn the WG proposals into legislation that would affect the helicopter industry. It appears the airlines and the airline unions are happy with the result, and I think they are probably right in feeling they are an improvement, but the proposals are not appropriate or even remotely workable for the helicopter industry. We are demanding we be treated with the respect that we deserve, which is to say that we do not want airline regulations to be applied to helicopter operations. There are almost no similarities between the two beyond the obvious use of air as our medium of transport.

The deadline for dissension from the WG Report is January 31st and from what I understand it then moves to Gazette 1 and will be very hard to alter or escape at that point. By completing the survey and the petition (through the link above) you will be adding support to our quest to stick with the current regulations for now and form our own Working Group in the future. If as many people on this email as possible can get the word out within your respective organizations that would be a huge step forward. In our company (GSH) we simply sent out a company-wide memo detailing what the WG had recommended and asked our pilots to complete the survey and petition any way they wanted to. We are not trying to influence anyone to put their name to something they don’t believe in, just asking that pilots who feel they should have a say in the regulations that affect them to join us in our quest.

The survey and petition are being conducted by a 3rd party and all the data and information will be held privately. Neither I, nor anyone other than Dr. Booke (she’s a professor at a University in Alberta), will be able to see who anyone is, nor how they responded to the survey and petition. The petition will close in about a week to allow time for data processing and then will be submitted to Transport Canada as a dissent from the WG Report.

Currently (as of Tuesday at 12:00 MST) we have well over 200 pilots signing the petition but we would like to get that to 1000+

Thanks very much for your time and assistance,

Corey

Corey Taylor
General Manager
Great Slave Helicopters Ltd

[flyer 1492]

Speaking to the people in the know, they figure it should be in place by next summer. The FAA adopt their new rules Jan1, 2014.

[I WAS Birddog]

This is a subject that deserves emense discussion on here.
I hope it goes through many pages and a positive outcome will result because of it for the sake of safety.

iWbd

[DH Driver]

Speaking to the people in the know, they figure it should be in place by next summer. The FAA adopt their new rules Jan1, 2014.

is next summer considered 2014?

[Meatservo]

It's good that helicopter pilots are getting active on the subject. However, I think it wold be a mistake to separate the interests of pilots along rotary versus fixed lines. Instead, it would be better to focus on the regulatory category, as in 703 vs 705, etc. Not that I am accusing the helicopter pilots of being partisan or anything, rather, it would do some fixed-wing pilots some good to pay attention to this too. There are helicopter pilots who are "Airline" pilots, and there are fixed-wing pilots flying in camps, seasonally, or on rotation to remote bases, who have a lot in common with their counterparts on small "bush" type helicopters and nothing at all in common with airline or commuter pilots. There are even some pilots, helicopter and aeroplane, who find themselves using the same machine to provide airline-type service one day and bush-type service the next at the same employer. Admittedly they are few, but these guys need to understand what, if any, effect the new regs would have on their bottom line, regardless of what kind of wings their aircraft has.

[Marinth]

Any more recent word on how the new duty times are coming along? Someone mentioned summer, but that was back in 2013.

[Liquid Charlie]

Unfortunately all opposition to change is based on the bottom line and not safety -- fatigue is the same for anyone no matter what they are doing -- the laws are out of date and need to be changed -- if a company thinks they have a situation where crews can work longer let them address it under a FRMS model and make sure it is acceptable and safe instead of working pilots until they drop or even worse have an accident - give the operators too much input and we end up with a dog's breakfast like the existing approach ban legislation -- all they had to do was adhere to ICAO standards and life would be far simpler today -- but no, it will evolve into a great big cluster fck because operators are worried about hiring more pilots --

[mattjvancouver]

And new info on duty times changing in canada? More in line with the US?

[Rockie]

Time for a bit of realism...

Transport Canada working groups (WG's) have been around for a long time studying all kinds of things including applying duty time regulations to flight attendants as far back as the early 90's. Nothing was done about that issue in all that time because operators are vociferously opposed at CARAC since it will cost them money. Recommendations to change pilot F&DT regulations are nothing new but it never happens either, and it never will happen until government embarrassment overcomes corporate opposition.

This government is not embarrassed. Furthermore it is too easy for operators to paint reduced duty times as a working condition rather than a safety issue, and we all know how the Harper government is hostile to labour.

[skidz]

Hi folks !

Anyone who's in general aviation, and in particular bush pilots, need to take notice of the new proposed FDT regs being pushed through.

Here's the document released yesterday (September 15, 2014):



http://wwwapps.tc.gc.ca/Saf-Sec-Sur/2/n ... 3&lang=eng

There's a call for comments at the end of the document. We have until October 3 to send our comments to carrac@tc.gc.ca . I think we all need to send notices of opposition to this thing ASAP.

[vrrotate]

There's a call for comments at the end of the document. We have until October 3 to send our comments to carrac@tc.gc.ca . I think we all need to send notices of opposition to this thing ASAP.

It's 2014. Time to admit our FDT regs are pretty archaic. Just because it's always been done this way doesn't mean we should keep doing it this way. I for one welcome the changes.

[skidz]

If you're in the airline industry, or don't fly out of remote places, sure, it's probably a good change for you. Unfortunately, this one-size-fits-all approach just won't work...

[NotDirty!]

It's 2024. Time to admit our FDT regs are pretty archaic. Just because it's always been done this way doesn't mean we should keep doing it this way. I for one welcome the changes.

You write to us from the future, and this is what you want to talk about? Couldn't you just give us some lottery numbers or something???

[Rockie]

If you're in the airline industry, or don't fly out of remote places, sure, it's probably a good change for you. Unfortunately, this one-size-fits-all approach just won't work...

Absolutely correct. In fact operators are using that reasoning as one of the pillars of their opposition to changing the regulations at all. They like them just the way they are and are putting up the usual fight, and will most likely be just as successful. Also integral to their opposition is their contention that there is no science supporting any reductions to F&DT regulations. Repeat a lie enough times with absolute sincerity and it becomes fact...

Until regulations are much more specific to roles it is too easy for the whole thing to be shot down which I have no doubt will be again this time. And it will take another 50 years for them to get around to creating regulations containing that kind of detail.

Until the Canadian government of the day is embarrassed into it there will never be any substantive change to the duty time regulations.

Edit: I'm slightly encouraged by TC's issuance of the NPA on September 15th, but it still has to survive this:

"Recommended Consultation Stream

 The Flight Crew Fatigue Management Working Group met on 14 separate occasions (43 days in total) over the course of an 18 month period. The Working Group put forward a Report that was presented to a special technical committee meeting of the Canadian Aviation Regulation Advisory Council (CARAC) open to industry and members of the public.

 Further to the analysis of the Flight Crew Fatigue Management Working Group Report, TC is proposing changes to the CARs and associated standards.

 As per the new CARAC process, industry comments will be sought through this Notice of Proposed Amendment. Comments will be considered as TC proceeds with drafting the amendments to the regulations and standards.

 TC will then proceed to publication in the Canada Gazette, Part I where industry and Canadians will have the opportunity to provide additional comments."

[vrrotate]

If you're in the airline industry, or don't fly out of remote places, sure, it's probably a good change for you. Unfortunately, this one-size-fits-all approach just won't work...

Yes I fly a jet crossing time zones. However the time of my career where I flew most tired was 703. Which statistically has a high percentage accident rate. Not that FDT reg changes will be a cure all but it's time for some positive changes at least.

Like Rockie said it's not too likely to go through anyway. I'm sure your boss is fighting against it like many other non 705 operators are.

[TR]

" Complexity is your enemy. Any fool can make something complicated. It is hard to make something simple." -Richard Branson

Comes to mind as I read the NPA.

[flyinhigh]

This NPA is brutal.

This is waaay worse than the 604 regs. I cannot imagine a single pilot being part of this working group and signing off on this.

[NotDirty!]

This NPA is brutal.

This is waaay worse than the 604 regs. I cannot imagine a single pilot being part of this working group and signing off on this.

but it is based on science!
how can you argue with science?

[flyinhigh]

This NPA is brutal.

This is waaay worse than the 604 regs. I cannot imagine a single pilot being part of this working group and signing off on this.

but it is based on science!
how can you argue with science?

That's like saying evolution is true..

[bcflyer]

This NPA is brutal.

This is waaay worse than the 604 regs. I cannot imagine a single pilot being part of this working group and signing off on this.

I have to admit that I haven't fully read the document yet but I'm genuinely curious what it is that you find brutal and why.

[duCapo]

I hear that pilots will have regular work hours, pre rest periods, where they can put their jammies on, post rest periods where the company must supply said pilot with the latte of choice while they browse facebook and check their text messages and oh yeah, after 6 hours of duty time, (not work) pilots have a 7 course meal supplied by the company. How do you like it so far???