Gazette Part 1 - New fatigue management regulations proposed

[Salt]

Transport has published the new fatigue management regulations in the gazette part 1. http://www.gazette.gc.ca/rp-pr/p1/2017/ ... ng.php#na5

Enjoy

[Jean-Pierre]

12 hour bottle to throttle. Thank you Estonia.

[dhc#]

Wow, gonna need a lawyer to decipher these new duty and crew rest regs..... leave it to TC to take a simple concept and make it rather confusing....seems they still are bending to industries needs vs safety

[AuxBatOn]

You want something 100% safe? Stop flying... if course it is a balance between operational requirements vs safety.

Rules for duty day cannot be simple since the possibilities are rather exhaustive (different types of operations, different flight length, different takeoff time, all of which have an effect on your body. After a first read, it seems pretty clear with not mich room for interpretation. It'll be easy for any programmer to make a program that will track this.

[DrSpaceman]

I thought we were already past the point of consultations?

[goingnowherefast]

They must think pilots binge drink. 8 hours is sufficient to metabolise a glass of wine with dinner. Now that might become illegal.

It is quite a bit to understand, but once I started to look at examples, it makes sense. These proposed regs will be a lot harder for the scummy operators to exploit.

[goingnowherefast]

They must think pilots binge drink. 8 hours is sufficient to metabolise a glass of wine with dinner. Now that might become illegal.

It is quite a bit to understand, but once I started to look at examples, it makes sense. These proposed regs will be a lot harder for the scummy operators to exploit.

['97 Tercel]

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

[stef]

It's going to be exhausting deciphering that.

[confusedalot]

Spent 5 years in the place after an industry meltdown and finally got out, couldn't stand the thinking anymore.........The canadian public service, as I can see, is still on a different planet as they have been for quite some time. They talk and navel gaze, and come up with irrelevant rules.

And then, as other posters have indicated, they assume everyone is a drunk and proceed with their knee jerk policies. And, some german went beserk, well, everyone pays with stupid rules.

TC was on the ball 30-40 years ago, what they said made sense at that time.

Today is a very different story.

[Big Bird Anonymous]

Spent 5 years in the place after an industry meltdown and finally got out, couldn't stand the thinking anymore.........The canadian public service, as I can see, is still on a different planet as they have been for quite some time. They talk and navel gaze, and come up with irrelevant rules.

And then, as other posters have indicated, they assume everyone is a drunk and proceed with their knee jerk policies. And, some german went beserk, well, everyone pays with stupid rules.

TC was on the ball 30-40 years ago, what they said made sense at that time.

Today is a very different story.

Actually, the regulation was the result of a recommendation from the NTSB following Colgan investigation. It was produced by the FAA and incorporated by TC following consultation...Inspector

[TailwheelPilot]

Am I missing something?

700.29 (1) No air operator shall assign a duty to a flight crew member, and no flight crew member shall accept such an assignment, if, as a result, the member’s duty time will exceed

(a) 2,400 hours in any 365 consecutive days; or
(b) the maximum duty time set out in column 1 of the table to this paragraph, if the air operator has provided the corresponding time free from duty set out in column 2 or 3 of that table.

So I can work 2,400 duty hours in 365 days without a day off since the table (x hours in 7/28 consecutive days) is optional?

(2) Items 1 and 3 of column 2 of the table to paragraph (1)(b) do not apply if suitable accommodation is available for the flight crew member’s time free from duty.

So confused. (3) makes sense, is this trying to say the same thing but regarding items 1 & 3? We always need suitable accommodation for flight crew member's time free from duty...so do items 1 & 3 never apply?

[HiFlyChick]

The 11 + travel time or 12 hrs free from duty after being on duty are concerning. My flying is extremely erratic, so if I am very well rested and do a split duty day, I will (a) never have 12 full hours off in the middle of the day (but maybe 8 or so), so (b) I can't have two long (but easy - only flying a bit in the morning and then in the evening) days in a row.

Regarding the FRMS, maybe it was because I was reading it late at night, but all I can say is...... WHAT?!

[tired of the ground]

The 11 + travel time or 12 hrs free from duty after being on duty are concerning.

Industry is the only one who has itself to blame for the restrictions that are coming down the pipe.

Everyone will pipe up "I only fly once a week for a good operator and can monitor myself and call in fatigued if it comes down to it.". The problem comes down to the fact that, for ANY regulation they come up with, some (many?) scummy operator will be flying to %100 of that limit. There will be consequences or the total inability to call in fatigued.

If the race to the bottom hadn't been so determined in the last 30 years, there would be a few bucks left over for airlines to not do stand ups. There would be a couple bucks left over so the F/O's don't have to work at starbucks. There would be a couple bucks left over so the airplanes aren't doing C checks in Asia.

The Corporate management companies are no better. If you keep telling the owners of Bizjets that pilots will work for peanuts you're going to have a shallow pool of candidates. There will be no pilots left who want to work with no schedule of days on or off.

Pilots, other than a select few with powerful unions, have had no voice and now Transport has had to step in and tell the children that they haven't been playing nice so here are the new rules.

[tbaylx]

12 hour bottle to throttle. Thank you Estonia.

What did Estonia have to do with that?

[DanWEC]

Well, it's a general lawn dart in the approxomately correct direction, mostly.

New proposed duty rules, but not really because if your company can prove that their pilots arent fatigued you won't have to follow them. Cool, on what criteria? Not asleep in the seat?

So since that actual progressive change is moot, so let's do something else to make the federal office look marginally productive...12 hours bottle to throttle? Sure, well, one dude from Slovakia drains a 26er an hour before the flight and stumbled his way into the cockpit despite several interventions from ground workers and flight crew. But since the general public thinks all pilots are binge drinkers, and despite this being a quite literal one-in-a-million occurance, tacking on an extra 4 hours based on zero physiological evidence should absolutely defintely likely probably stop that kind of behavior. There, did we earn our funding?

Oh wait, it's 5pm on Friday? Lets push this out and head to Milestones!

[DrSpaceman]

I'm not sure I understand the purpose of the FRMS. Will it allow crews at companies that implement them to bypass the new rules? If so then what is the point of this change in regulation?

Also, one more useless annual "training"...

[TailwheelPilot]

The 11 + travel time or 12 hrs free from duty after being on duty are concerning. My flying is extremely erratic, so if I am very well rested and do a split duty day, I will (a) never have 12 full hours off in the middle of the day (but maybe 8 or so), so (b) I can't have two long (but easy - only flying a bit in the morning and then in the evening) days in a row.

700.40 (1) An air operator shall provide a flight crew member with the following rest periods at the end of a flight duty period:

(a) if the flight duty period ends at home base,
(i) either 12 hours, or 11 hours plus the travel time to or from the place where the rest period is taken, or
(ii) if the air operator provides suitable accommodation, 10 hours in that suitable accommodation; and
(b) if the flight duty period ends away from home base, 10 hours in suitable accommodation.

Sleep in a crew bunkhouse at your home base, rather going home to your own bed, and you only need ten hours rest. Wait....what!?!?!?!

Does it count as 'provided by the air operator' if you rent a room at a company crewhouse?

[Jean-Pierre]

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.

[confusedalot]

It's going to be exhausting deciphering that.

Exactly. The more complicated the system, be it mechanical, electronic, regulatory, the more humans will be prone to error and misinterpretation.

Looks good around a conference table, prone to fall apart in real life applications.........

Crew scheduling software programmers rejoice, lots of work coming down the pipe.

[valleyboy]

12 hour bottle to throttle. Thank you Estonia.

For certain Sunwing had nothing to do with the rule, I suspect that they already had the rule in their COM. These proposed regulations were already going to print by then. Most airlines had already put that rule in their COM years ago. I would think they considered the 12 hour rule a good enough idea to make it industry standard.

FRMS makes this workable for companies to adapt the rules for their particular operation under FMS. Pretty progressive and logical. It's good to see one shoe fits all. It's hard to convince youth and "dinosaur" operators but eventually they learn fatigue is real.

[confusedalot]

Fatigue is real. Dinosaurs, of which I am a member, know this through hard experience. Luckily, I have survived the tribulations.

The best regulations I had encountered, way back in the 90's were, of all places, the British. Circadian rhythms, human limits, were all taken into account.

The dinosaurs have always looked for a better way to handle this existential problem, so the blame is misplaced.

As for the young guys and gals, well, I dunno.......Perhaps it would be good to look into history and come up with some more appropriate solutions.

[HiFlyChick]

...Sleep in a crew bunkhouse at your home base, rather going home to your own bed, and you only need ten hours rest. Wait....what!?!?!?!

I thought that was odd at first, too, but I guess the rationale is that if you're home your family is demanding your time, you're doing housecleaning, whatever.... But that then doesn't give you credit for getting a better quality of sleep in your own little bed. On a recent vacation to Cuba, by the end of the week I was getting pretty sleep deprived from becoming more sore each night sleeping on a hard bed (which my husband thought was great). While I was sad to get back to the snow, I was sure happy to see my pillow-top mattress!

I still think that 12 is a bit extreme - 8 hrs of sleep is still adequate, but some people haven't been allowing enough for the "of sleep" part. 10 hours would still be lots. That's only if people try to get the 8 hrs, but for those that don't care about adequate sleep, making them take more time off still doesn't mean they won't just spend longer doing other things.

[mato]

Say goodbye to commuter friendly schedules and 15 days off a month... looks like we will just work short days and work 20 days a month to compensate for the credit.

[goingnowherefast]

I'd say this is even more commuter friendly. You can do 4, 13 hour days in a row, 11 hours travelling to and at the hotel. It will really rack up your 192 duty hour limit and you'll be regulated to more time off than present.

192 hours in any 28 consecutive days

(a) 1 single day free from duty in any 192 consecutive hours; and

(b) 4 single
days free from duty in any
672 consecutive hours

Translate from legalese and it means 1 day off within every 8 days and 4 days off 28 day every block.

Or there's this option if you are on a rotation. 5 consecutive days off within every 21, so basically 16 on, 5 off rotation.

120 consecutive hours in any consecutive 504 consecutive hours