Proposed Flight Crew Fatigue Regs

[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.

[Gilles Hudicourt]

https://www.tc.gc.ca/eng/civilaviation/ ... ns-745.htm

After all parties involved have agreed to a final version of the RIAS and the proposed amendment to the CARs, they are approved by TC executives, the Deputy Minister (DM), and the Minister, and are sent to the TBS to be presented to the Treasury Board Committee for approval. Once approved, both documents are turned over to the Canada Gazette where the proposed regulations and the RIAS will be published in Canada Gazette, Part I (CGI) for a consultation period of 30 days. The Canada Gazette is the official newspaper of the government of Canada. CGI presents proposed regulations, government notices, and appointments that are required by statute to be published so as to disseminate information to the public.

Comments or dissents to the proposed regulation are returned to the Regulatory Affairs Division, who will address them. The RIAS and proposed regulation will be amended to answer these comments and dissents, and sent one more time for approval by TC executives, the DM, and the Minister.

The proposed regulation is then returned to the TBS for re-approval by the Committee members, and then moved forward to be registered by the Clerk of the Privy Council, under the authorization of the Governor in Council. It will appear in the Canada Gazette, Part II (CGII) to give notice to Canadians that what started as an NPA, and became a proposed regulation, is now a regulation.

I am certain that all Airlines are attempting to dilute this NPA as I write these words. ALPA and ACPA are also probably in the thick of it. But ALPA and ACPA both represent 705 pilots only.

What about the rest of you ? Unless you speak up, no one speaks on your behalf.

[TCAS II]

I think this proposal is a great step forward in improving safety and reducing fatigue. It's about time Canada came inline with the rest of the aviation world.

By the way, ALPA doesn't only represent 705 ops, they also represent 704. I don't see why ALPA or ACPA would be wanting to fight a proposal that will improve the safety of its pilots...

[Gilles Hudicourt]

I think this proposal is a great step forward in improving safety and reducing fatigue. It's about time Canada came inline with the rest of the aviation world.

By the way, ALPA doesn't only represent 705 ops, they also represent 704. I don't see why ALPA or ACPA would be wanting to fight a proposal that will improve the safety of its pilots...

Your are correct about 704, my error.

For the rest, I misspoke or you misunderstood. I did not mean that ACPA or ALPA were fighting the proposal. I just meant to say that they were actively involved in the process and that pilots who were not represented by ALPA and ACPA or who are not operating in an environment for which ALPA and ACPA speak for, should strive to make themselves heard while its still time.

[timel]

Gilles is right, there is a window open to pilots, pass it on to your co-workers.


For pilots who wish to testify about their fatigue experiences:

CARRAC@tc.gc.ca

Hi,
Absolutely, we welcome personal experiences as part of the input we are collecting and have received a few personal testimonies from pilots to date. This email is the correct address and feel free to leave out your employer if that makes you more comfortable.

Regards,

Melanie


Mélanie Drouin
A/Manager, Civil Aviation Regulations Advisory Council | Gestionnaire par intérim, Conseil consultatif sur la réglementation aérienne canadienne
Transport Canada | Transports Canada
Place de Ville, 330 Sparks Street, AARBH
Ottawa, Ontario K1A 0N5
melanie.drouin@tc.gc.ca
Telephone | Téléphone 613-990-1415
Government of Canada | Gouvernement du Canada

[Flyboycanada80]

If anyone is curious to know what your companies think of this here is thier response sent directly to the minister:

http://www.cbaamatters.com/wp-content/u ... posal1.pdf


It's worth the read, the college of pilots need to get up off its ass and lobby the government and step up to support pilots. If they did anything that resembled work for us instead of just asking for members and fees they wouldn't have a hard time getting membership up.

[Flyboycanada80]

Here is what the companies are doing to fight this:

http://www.cbaamatters.com/wp-content/u ... posal1.pdf

This document was sent right to the minister. They are using every trick in the book to stop the changes.

[TCAS II]

The government should ask the pilot who've operated for these operations directly about duty changes to prevent fatigue. It's not these actual members of the association that are doing the actual flying while fatigued.

"ONLY suitable for 705 operations"? That's because most 705 operations would be closer to abiding by the new regulations to begin with. The 703/704 operators are the ones who also need the regulation to prevent businesses from exploiting their pilots. The operations might be diverse; however, the human bodies working in these 703, 704, 705 operations aren't. Pilots are human. How they can claim that fatigue isn't a safety issue? Geez.
Seems this article is simply a question of safety vs profit... The only damage to commercial and business communities is to their pocketbook.

Shortage of experiences pilots?That's because who would stay under outdated working conditions? There isn't a shortage of pilots, their argument doesn't stand. Train new pilots and experience will come.

The effect on competition in Canada? I don't think so. These changes will have an improved effect on domestic operations. How are US carriers going to be providing services for northern, remote and Aboriginal commutes, domestic air operators, aerial application, natural resources, MEDEVAC etc... they aren't!

Shouldn't holes in the "Swiss cheese" model leading to accidents be filled? Isn't fatigue a factor that should be considered? Safety vs profit.

[A346Dude]

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".

An 8 hour duty day? How would that possibly work in Canadian aviation?

There are tons of trades in safety-sensitive environments that work 12 hour shifts (hell, some firefighters work 24 hour shifts). I could certainly see reducing down to 12 hours, but to me 8 is just a total non-starter.

[AirMail]

Here is what the companies are doing to fight this:

http://www.cbaamatters.com/wp-content/u ... posal1.pdf

This document was sent right to the minister. They are using every trick in the book to stop the changes.

I like how the companies are using a doom and gloom tactic. Basically painting that all aviation activity will cease. Well dear companies, you've paid those poor pilots crap wages and conditions as there is always someone to take the bait. I say to you that if you can't do the flying your operation employs upon, I'm sure there is a company who will fulfill that void you've left driving you out while they too continue to pay poor wages and condition. Circle of aviation life.

But in all honesty, it isn't hard to get the clients/passengers/contracts changed/amended to reflect the change in regs. Instead of wasting resources on fighting regulation, how about using those resources on improving safety and working conditions. Maybe you'll find there's profit to be made when not having to dole out money to repair or replace aircraft due to fatigue.

[intake]

A346 Dude, Why is CAN Aviation different to other parts of the world where 8 duty limits are the norm. Not only is 8 hrs the limit but they get 2-3 times the salary for it. Just saying......

[ahramin]

I see that BC Aviation Council signed on there. A search of their member directory includes:

Vancouver Airport Authority
Abbotsford Int’l Airport
Aeroinfo Systems, A Boeing Company
Air Cadet League of Canada
BCIT Aerospace
Fraser Valley Regional District
Nav Canada
University of Fraser Valley Aerospace Programs
Pacific Flying Club
Victoria Flying Club

I'm planning on asking several of these organizations why they want to keep Canadian aviation fatigue rules in the dark ages. If you know someone at some of these organizations I would suggest doing the same.

[TrailerParkBoy]

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".

An 8 hour duty day? How would that possibly work in Canadian aviation?

There are tons of trades in safety-sensitive environments that work 12 hour shifts (hell, some firefighters work 24 hour shifts). I could certainly see reducing down to 12 hours, but to me 8 is just a total non-starter.

How often do you start your day at 4am and fly 6 legs in a 12 hr day? Try doing it 4 days in a row!

[A346Dude]

A346 Dude, Why is CAN Aviation different to other parts of the world where 8 duty limits are the norm. Not only is 8 hrs the limit but they get 2-3 times the salary for it. Just saying......

Well we're obviously a lot more spread out. I don't know if that makes the difference but it is certainly a factor.

I can't imagine being essentially timed out after a leg as short as YYZ-YVR. It would require a significant increase in number of days worked per month, hotel stays, and probably more crew bases. The cost increases would be substantial and the flying public already complains enough about high airfares.

I guess I just don't buy the idea that there's a steep drop off in competency after only 8 hours. It's really not that long a time and in my opinion the cost increase would be harmful to the industry.

[teacher]

WOW!!! That submission is so full of bullshit it's unreal!!!!!! Competitive disadvantage? Union rules applied to non union carriers? Aren't the Canadian rules less restrictive than the Europien and Amercian flight and duty time regulations?

These companies have gotten away with near murder for years. Garbage pay, crazy long hours archaic duty time rules NOT based on science and they wonder why there's less pilots to fill the seats. Pay properly and don't grind them until they can't stay awake, seems like a simple concept.

There will be a level playing field for all players with these rules. The doom and gloom is completely inaccurate.

[Rockie]

WOW!!! That submission is so full of bullshit it's unreal!!!!!! Competitive disadvantage? Union rules applied to non union carriers? Aren't the Canadian rules less restrictive than the Europien and Amercian flight and duty time regulations?

It's the same tried and true bulls**t they use every time there are proposed amendments to the F&DT regulations. Nothing new here because it always works. The last time there was any kind of change to the regs was 16 years ago, and they amounted to pretty much nothing despite the optimism accompanying the proposed changes before industry got their hands on them.

The optimism this time around is equally misplaced in my realistically jaded opinion.