Pilot Opinion Survey Re: Changes to FDT Regulations

[All Sides]

Here is a summary of the proposed changes.

[Edo]

Thanks for the summary. I was surprised to see the note about split duty day as being limited to 702. The reg 700.16 (5) does not reference the standard and and standard only contains extra conditions for 702.

It seems to me that 703 704 705 could work a split as per 700.16 and 703 needs to follow the additional conditions in the standard

comments?

[spaner]

NAW, Naw, naw, you got it all wrong there guys. Too much bush flying..AKA "let's get'er done".
The premise here is that "neither the operator, nor the crew member, has the right to decide weather or not to fly while fatigued".

Some like the money, others want the time. Whatever it is that drives the individual towards their goal, and we know pilots are goal oriented, we can all agree on that. Who hasn't stayed up all night, or even for a few days, for the massive study session just prior to writing your A's. That's OK, nobody is going to complain or have concern about you writing your test while fatigued.
The rule of the law here, and has always been, you cannot operate as a crew member, while fatigued.
NOW,
If we can agree on that, and the fact that crew members are being pushed to operate while fatigued, because the current regs are too laxed, and the operators feel that to operate within the current regs, describes a condition of operation that cannot result in the condition of "fatigued"...then you're FOR the changes. If you're looking to fly fatigued anyway...(for the money or the time)...then you're AGAINST the changes.

Take the example of. YYZ EMS, OCC-RTE. (YYZ-YTS-YMO-YGK-YYZ)
Check the chart for a 2300 call-out; 4 leg routing.
You have 9.5hr duty to complete mission; 8:30am loc shutdown.
You bounce off YMO-to-YTS; missed.
You now require 6 legs to complete the mission; 9hr; 8:00am loc shutdown.
YTS fuel delay, YYZ @7:30 loc.
Reasonable, to me. Even for a call-out.

Under the current regs, the operation would expect you to continue until 14:00, 15hr YYZ shutdown.
Another YYZ-YTS-YSB-YYZ perhaps.
Is that too much for you, under the current regs?
WELL,
That's not the question, the question is, while conducting the ILS into YTS @09:45...are you impaired? Due to fatigue.
The science says YES.

The question of the reg changes, and the survey is, Do you agree that the current regulatory changes, that have been put forth, adequately address the necessary restrictions in operations to alleviate, or eliminate, the question of crew member fatigue, during air operations.

A big thanks to APCA, talk about carrying the cross...

AND, I do have to add, years ago, while operating up-north and bouncing of Thompson a few times on EMS in the middle of the night, and the middle of the winter, no days off, no time off, I awoke at the copilot controls, in the 15th hour, to a punch in the face from the captain. Apparently, at or about 7:30am he had awoke himself to find that all three crew members were conducting controlled rest within the aircraft. G.E. was our auto pilot...

[Bede]

Spaner,

good suggestions, but I'm not sure more rules are the way to go. As professionals, we have the obligation to remove ourselves from duty if fatigued. What needs to be done is the employer respects that decision. I have called fatigue and ended a given up a trip a couple times in my career.

[andystep]

Hi all,
Regarding all this . any one know of any time line? And how much lead time and or warning companies will have?
Thanks

[StudentPilot]

I think the varied duty day dependent on start time makes sense (although I imagine the science would support duty days based upon the past 7 or more days schedule, ie have you been working days and just switched to nights or vice versa?).

I find flying six, 20 mile legs less fatiguing (and more interesting) than one 120 mile leg, so I don't really get why the number of legs affects the duty day. Maybe they think I'm having too much fun.

[tbaylx]

I think the varied duty day dependent on start time makes sense (although I imagine the science would support duty days based upon the past 7 or more days schedule, ie have you been working days and just switched to nights or vice versa?).

I find flying six, 20 mile legs less fatiguing (and more interesting) than one 120 mile leg, so I don't really get why the number of legs affects the duty day. Maybe they think I'm having too much fun.

Try shooting 6 IFR approaches with deicing every time you land and dealing with ramp/boarding delays vs. one longer trip with one take off and landing and then you'll get why the number of legs affect the duty day.

[ReserveTank]

Try shooting 6 IFR approaches with deicing every time you land and dealing with ramp/boarding delays vs. one longer trip with one take off and landing and then you'll get why the number of legs affect the duty day.

+1

Just a random thought...Its interesting that the legislators and regulators who have 8 hour workdays seem fine with pilots working 14 hours a day.

[StudentPilot]

I find flying six, 20 mile legs less fatiguing (and more interesting) than one 120 mile leg, so I don't really get why the number of legs affects the duty day. Maybe they think I'm having too much fun.

Try shooting 6 IFR approaches with deicing every time you land and dealing with ramp/boarding delays vs. one longer trip with one take off and landing and then you'll get why the number of legs affect the duty day.

I can't argue with that.

I was more thinking that six landings in good weather dropping off or picking up one passenger and a couple bags at each stop is pretty simple (ie my job).

Why is your situation more important than mine? Why are the regulations written for your job and not for mine?

[tbaylx]

I find flying six, 20 mile legs less fatiguing (and more interesting) than one 120 mile leg, so I don't really get why the number of legs affects the duty day. Maybe they think I'm having too much fun.

Try shooting 6 IFR approaches with deicing every time you land and dealing with ramp/boarding delays vs. one longer trip with one take off and landing and then you'll get why the number of legs affect the duty day.

I can't argue with that.

I was more thinking that six landings in good weather dropping off or picking up one passenger and a couple bags at each stop is pretty simple (ie my job).

Why is your situation more important than mine? Why are the regulations written for your job and not for mine?

They aren't..that's why the sector length/time factors in as well as the number of sectors. That way if you're only flying 20 min sectors (unlikely in a 705 op) then you can fly more. It addresses an embarrassing lack of adoption of international fatigue standards that Canada has demonstrated for years.

Quite simply the number of sectors, as well as the the time of day you start has a definite effect on how fatigued you are. A guy starting at 4am and doing 6 sectors in a 12 hour day will be far more tired than a guy starting at 9am and doing 2 sectors in a 12 hour day. Its basic human physiology and needs to be accounted for in the regs if we want to even pretend to be concerned about pilot fatigue in this country.

[beaverbob]

This cannot be good for the seaplane industry. There has to be a differentiating set of standards for strictly VFR flying from IFR / heavy transport flying. In our company we work 4 ten our duty days a week, plus 1 hour for lunch and overtime after the 10 duty hours. I might do 20 legs in a day, in only about 4 hours air time in a 10 hour day. Also the seasonality of our work requires the extra hour or 2 of overtime to maintain a descent annual income average. Especially in the colder climates, where the seaplane season is only about 5 months. I am glad to be nearing the end of a good career, because I think the fun is gradually been whittled away from our business 1 regulation at a time. If these times are reduced we will be forced to work a 5 day week and become even be more fatigued at the end of our work week.
Bob Bates

[tbaylx]

This cannot be good for the seaplane industry. There has to be a differentiating set of standards for strictly VFR flying from IFR / heavy transport flying. In our company we work 4 ten our duty days a week, plus 1 hour for lunch and overtime after the 10 duty hours. I might do 20 legs in a day, in only about 4 hours air time in a 10 hour day. Also the seasonality of our work requires the extra hour or 2 of overtime to maintain a descent annual income average. Especially in the colder climates, where the seaplane season is only about 5 months. I am glad to be nearing the end of a good career, because I think the fun is gradually been whittled away from our business 1 regulation at a time. If these times are reduced we will be forced to work a 5 day week and become even be more fatigued at the end of our work week.
Bob Bates

I'd have to look at the regs again, but pretty sure you'd still be able to do a 10 hour duty day with any number of sectors you want in it, so i doubt it would change that much for you. It may affect your ability to do overtime though.

I'm the last guy to support regulating the crap out of anything, but duty day changes are way overdue here in Canada. Way too many single pilots IFR guys flying 17 hour days under pressure from crap operators pushing every last minute out of their pilots cause they can.

[flyboynextdoor]

I'm all for pilots getting rest when they need it. Are there some operators that stretch duty time to a maximum and fly the bag out of some of us? I'm sure. Do the regulations need modernization sure..
But as a pilot who works way up north in an unforgiving environment I want the choice to say either "no I'm too tired", or "yeah I'm able go another leg" and make it home safe to the hangar, rediculously short duty day be damned. No way do I need to get stuck outside on some gravel strip in the middle of nowhere cause of what some chart says written for guys who can't make the choice on their own. Also I want the choice of having a rotation that allows me to get out of the frozen wasteland for an extended period and afford to live somewhere pleasurable for a valuable rest period off. If my rotation is regulated to 7 days on, guess how long my days off will be?? Maximum 7 days off!! Now my travelling expenses and time spent commuting will be double. Putting my life in danger in a completely different way (those highways!)My other options are to permenantly stay up north hating life in general because I can't leave long enough to justify it or stay down south earning a fraction of what I am now. So am I looking forward to theses new Regs?? Ah hell no. Give the pilots some ammunition against sweat shop labor practices but please Transport Canada, don't adopt these draconian rules!! There has to be a better solution that can let pilots who need rest get it without making the pilots who want to work a little more take the day off just cause some latte drinker in Montreal thinks its a good idea...
Rant over.