Gazette Part 1 - New fatigue management regulations proposed

[Jet Jockey]

I am OK with the 12 hours off duty between flights (we already use that).

12 hour off duty break down:

30 minutes after the flight to shut down the aircraft, paperwork, etc.
45 minute drive home.
8 hours of sleep.
45 minutes in the morning to shower, shave, eat and get ready.
45 minutes to drive back to work.
60 minutes prior to flight to get the paperwork, check the wx and get the aircraft ready.

All the above equals 11 hours 45 minutes.

Now our company will allow us to shorten that off duty time at home base only if the crew is willing to do it after they were advise of it much in advance, the DFO approves it and only if the crew is put up at a hotel at the airport, the crew is fed in the aircraft and someone competent on the aircraft usually another pilot gets the aircraft ready.

BTW this is easily done here in Canada (12 hours of duty) but once you start travelling to other countries around this world like China, 12 hours is a joke! To get things done in China you need a lot more time, sometime 90 minutes after a flight is required and I would not show up at the airport less than 2 hours prior to the flight if you want to leave on time so 12 hours is not an option.

[pelmet]

How will it affect people doing rotations of two weeks on, two weeks off?

[3HOLER]

you guys are all missing the "big picture" except for Dan. If your company has a functioning FRMS system in place they can apply to be exempt from the new rules... read 700.100 so any company in Canada that doesn't want to hire more crew or hire a team of schedulers to figure this document out will have a FRMS system in place. It's way cheaper to run a one day sleep school than it is to deal with this. Transport Canada has thrown us all under the Airbus.

[HiFlyChick]

...If your company has a functioning FRMS system in place they can apply to be exempt from the new rules...

Thanks for this - I really need to look at the proposed regs when I'm not so fatigued (and I'm actually not kidding)

Regarding Jet Jockey's 11:45 breakdown, that's fine for guys in the big cities and the big companies but I don't fly internationally, and live just a hair under 10 minutes from the hangar (and can get showered, dressed and out the door in 30 minutes ), which means that in my case I can shave 1:25 off of his time, so 10:20 is fine for me. I'm just saying that 12:00 is not required for everybody so I hope they don't hang us all on it...

[goingnowherefast]

Yes, you CAN get ready in 10 hours, BUT if you'd like to eat more than McDonalds for dinner and have a conversation with your significant other, then 12 hours off will be wonderful.

[cncpc]

Those 703 704 operators will have prob 5 years to prepare.

Customers may require "voluntary" implemention before that.

[ei ei owe]

12 hour bottle to throttle. Thank you Estonia.

What did Estonia have to do with that?

Sorry I meant Slovakia. The Sunwing pilot that drank a 26er of vodka halfway through his duty day specifically. Any that work around Eastern European crew knows that this is par for the course there. Now I won't be able to have a glass of wine with dinner if I have an early flight because they thought it was a good idea to let them fly Canadian aircraft.

Keep trolling.....

[whatsitdoingnow]

I can't believe there are people here that are against these new regs. Yes your current gig might be a little forward thinking or your schedule is so quiet that keeping current is more of an issue than fatigue and hopefully you have a long and happy career there. However, there are many operations out there that really do interpret the current regulations with comical results (something they are likely to do with the new ones). The only way to tackle these questionable operations is to have a blanket regulation. Maybe these same companies will figure a way to circumvent these new regs with fatigue management plans just like the SMS can be manipulated to favour those who probably need it most. So please lets stop the "I'm alright jack" attitude and look at the bigger picture.

We complain when TC bring out draconian rules, and now complain when they actually listen to us.
We really are our worst enemy.

[DanWEC]

I agree whatsit!

Those of you who actually think 12 hours rest is "excessive" are totally out to lunch.
Disregarding the lack of teeth that the proposed regs will have anyways due to exemptions, fatigue is a real issue, and mitigating it by SOP's and 2 crew is great but only masking the problem and slapping another piece of swiss cheese on the model.
I know personally, some hilarious things start to happen after 10 hours and 10 legs. Now repeat that for 6 days in a row with 8 hours (or even 10) min rest in between? C'mon. Maybe one day out many, but then it piles up.

I'm pretty sure almost any holding any other "normal" job on the planet would lose their marbles it if they were constantly expected to be back to work at 8 am after getting home at, say 10pm at night- Every, single, day. Doesn't generally happen anywhere else, why in aviation? It's called a "life" that we're living, not a "work".

People literally hold us responisble for their lives. It's a diabolical mistrust to be compromised in any capacity whatsoever, especially ones caused by the conditions of our own employment.

[The Hammer]

I can't believe there are people here that are against these new regs. Yes your current gig might be a little forward thinking or your schedule is so quiet that keeping current is more of an issue than fatigue and hopefully you have a long and happy career there. However, there are many operations out there that really do interpret the current regulations with comical results (something they are likely to do with the new ones). The only way to tackle these questionable operations is to have a blanket regulation. Maybe these same companies will figure a way to circumvent these new regs with fatigue management plans just like the SMS can be manipulated to favour those who probably need it most. So please lets stop the "I'm alright jack" attitude and look at the bigger picture.

We complain when TC bring out draconian rules, and now complain when they actually listen to us.
We really are our worst enemy.

I don't work at an AC or WJ where they are scheduled for 16 days a month (soon to be shorter days) and this likely won't change. If I have to work 1 or 2 more days a month just so the commuter from Barrie gets his 12 hour time free from duty (which actually doesn't give him 8 hrs prone anyway by the time he drives to/from work, parks in employee parking, hikes to/from gate/crew rooms, etc) when I live 10-15 minutes from work then I'm getting screwed especially if my work days are short and the cycles are low. I can be home quicker than some airline crew on a 10 hr turn who stands besides a pole at T3 in YYZ waiting for the airport shuttle.

I will support an FRMS that will give me more days off with my family. I don't want a setup that will encourage my employer to keep me on the road vs in my bed because they can utilize me more on less rest. I know where I sleep better. There's no one size that fits all. There never has been, there never will be. That's why we have 703, 704, 705 in the first place. The safest course would be everyone operate under 705 regs right?

[Rowdy]

How about this, hold the employers/chief pilots/ops managers responsible for infractions of duty and rest periods. Make the regs black and white. Non compliance on more than a few counts and they get suspended from their position etc. Fine the CP/ops mgr. Not the company or pilot. Shit would change INSTANTLY!

I know of a couple of those individuals who always pushed crews to 'make it work' or 'get the job done'.. knowing that if and when the pilots got caught, it wasn't their own ass on the line.

I haven't perused the new changes.. but anything that helps eliminate some of the fringe ridiculousness.. Like, stand ups! Split duty days on cargo ops that push even the splits? How about those 12 leg days? red eyes that last 12 hrs? GIANT breaks in the middle of a 7 leg day..

I don't know about you, but I live an hour and a half from the airport because the cost is out of reach to live closer and have a house to raise my family in.. Its not a one size fits all proposition right? 12hrs between shifts is BARE MINIMUM! it should be 8hrs PRONE REST! with at least an hour either side for physiological needs (food/shower/etc) Plus the commute. That puts us smack dab at the 12hr mark.. Some of us wouldn't even have time to iron a shirt on those or throw the laundry in etc.

[The Hammer]

How about this, hold the employers/chief pilots/ops managers responsible for infractions of duty and rest periods. Make the regs black and white. Non compliance on more than a few counts and they get suspended from their position etc. Fine the CP/ops mgr. Not the company or pilot. Shit would change INSTANTLY!

I know of a couple of those individuals who always pushed crews to 'make it work' or 'get the job done'.. knowing that if and when the pilots got caught, it wasn't their own ass on the line.

I haven't perused the new changes.. but anything that helps eliminate some of the fringe ridiculousness.. Like, stand ups! Split duty days on cargo ops that push even the splits? How about those 12 leg days? red eyes that last 12 hrs? GIANT breaks in the middle of a 7 leg day..

I don't know about you, but I live an hour and a half from the airport because the cost is out of reach to live closer and have a house to raise my family in.. Its not a one size fits all proposition right? 12hrs between shifts is BARE MINIMUM! it should be 8hrs PRONE REST! with at least an hour either side for physiological needs (food/shower/etc) Plus the commute. That puts us smack dab at the 12 hr mark.. Some of us wouldn't even have time to iron a shirt on those or throw the laundry in etc.

The population of the GTA and Richmond and Stats Canada don't reflect what your saying. I'm pretty confident everyone living in Richmond isn't commuting and doesn't earn well above the average or median household income for Canada. Flight crew's decision to choose quality of life over sufficient rest will occur no matter how long min time free from duty is legislated at. I love doing the red eye type flights with guys who tell me about all the $hit they got done that day before they came to work.

[M.Caribou]

Would someone be willing to explain to me how a Fatigue Risk Management Program would allow a 705 carrier to be exempt from these new proposed rules? Seriously?

I have taken part in a Fatigue Risk Management course where they explain all the obvious things a human being already knows about sleep. Don't drink coffee before bed, exercise, get deep REM cycle sleep, blah blah blah.

Coffee and 8 hours rest isn't going to make the 12 sector milk run you did today any less fatiguing when you have to be back in 9 hours to do it all over again and again.

[tdawe]

So if you apply for and receive approval to operate under an FRMS you can submit any schedule you want and have to count on your regional TC rep to approve it? Does that mean a company in one region might be operating under a schedule that a company in another region was denied?

Also, what happens if you happen to work for an organization where the duration of your flights is not scheduled in advance? If I work for a medevac operation and don't know how long my flights will be until my phone rings do the tables in 700.28 just not apply since they all reference "the average duration of all scheduled flights is less than 30 (or 30-50, or 50+) minutes?

[The Hammer]

I doubt few of your medevac flights/routes are new so you should be able to develop an FRMS using past data and then apply it going forward. Ie stages lengths etc


For those that think these rules are great wait until you start switching shift cycles. Work until midnight on Tuesday, you get Wednesday off but then you can't work before 0730 on Thursday because you haven't recieved your "normal night's rest, 2230-0730" to meet some of the time free from duty rules even though you just have had 30 hrs off.

This will affect anybody that hopes to work stretches in a row.