AME Duty Time Limits

[dimit]

Hi,

My name is Dick Mitten (yes, really...) and I'm a helicopter pilot. You may know me from VertMag forums.

I'm concerned about the lack of AME duty time limits and have posted the following over at
VertMag. I invite you to become involved.


"I am sending the following letter to the officials listed. Please feel free to copy or modify the letter. I'm also sending a copy by email to all my helicoptering friends, and putting this post on the other Canadian helicopter forum.

If we are serious about safety and fairness, we must get AME duty time limits.

Thanks to Bullet Remington for the list of TC Standards officials.

Thanks to each of you who takes a couple of minutes to fire off a few emails to help make this happen.

Cheers,

Dick Mitten"


The DIRECTOR , STANDARDS is Don Sherritt. He can be reached at: Don.Sherritt@tc.ga.ca
Director General of Civil Aviation - Martin J. Eley; Martin.Eley@tc.gc.ca
Regional Director , Pacific Region - David Nowzek - David.Nowzek@tc.gc.ca
Regional Director, Prairie & Northern Region - Kate Fletcher- Kate.Fletcher@tc.gc.ca
Acting Regional Director, Ontario Region- Joseph Swalek - Joseph.Swalek@tc.gc.ca
Regional Director, Quebec Region- Diane Desmarais - diane.demarais@tc.gc.ca
Regional Director, Atlantic Region - Arthur Allen- arthur.allen@tc.gc.ca


"March 25, 2010

Dear ____________,

I am a commercial helicopter pilot, writing to encourage your support for aircraft maintenance engineer (AME) duty time limits.

Pilot duty times are regulated to avoid acute and chronic fatigue, which are well recognized as significant contributing factors to aircraft accidents. If we are to take the SMS approach seriously, we must recognize the importance of the AME in the safety chain, and ensure that the system supports the best outcome from the AME’s work.

When I strap myself into a helicopter and take responsibility for the lives of my passengers, the law requires that I have had ample opportunity for rest. I want the AMEs who worked on that machine to have the same opportunities.

Please do everything you can to support and move forward the introduction of duty time limits for aircraft maintenance engineers.

Sincerely,"

[sky's the limit]

And juuuuuust to get it out of the way right off the hop - as this is VERY worthy subject that demands attention, as in no hijacking - Mr. Mitten is a good friend of mine and is known industry wide as the "Love Glove." He is a fine human being, and one of those guys everyone loves to fly with.

Carry on....

stl

[Flybaby]

I'm not saying that I'm not for setting limits on how long an AME can work for, but just wondering if this is actually a common problem for AME's? I've lived with AME's in the past and I would say that I was more concerned with them working with solvents all day, then working long hours. Probably completely dependent on the shop.

[Widow]

AMEs have the same problem of "not my job" attitude from the federal/provincial jurisdictional debacle when it comes to the OH&S of all aviation workers.

On old but telling discussion AvCanada: Maintenance Duty Times? which links back to AvCanada: SATOPS - Airworthiness.

I believe the SCOTIC is about to have a few days of public hearings on Aviation Safety. This topic should be heard.

[Bede]

Good call. Did you know there is no CAR saying that AME's can't drink while working on aircraft? Sad but true.

[iflyforpie]

I'm not saying that I'm not for setting limits on how long an AME can work for, but just wondering if this is actually a common problem for AME's? I've lived with AME's in the past and I would say that I was more concerned with them working with solvents all day, then working long hours. Probably completely dependent on the shop.

This has never been an issue for my until my current job where I both fly and maintain the aircraft (and I use pilot duty times for all of the work). Pretty much every one of my other jobs has been, Monday to Friday, 40 hrs a week either straight days or swing-shift evenings and days.

Where I could see this helping is endless days (could you come in on the weekend, repeatedly) or double shifts (something broke and we need you to stay another 8 hours). Planes are mechanical and sometimes they aren't available no matter what you do. No flight is worth the risk of having something missed because of a fatigued mechanic.

AMEs should have the right to pull the fatigue card without retributions. I've done it numerous times but fortunately I have understanding employers. This is not the case for everybody...

[SeptRepair]

Good call. Did you know there is no CAR saying that AME's can't drink while working on aircraft? Sad but true.

Funny you bring this up. When we maintenance guys go for a Friday lunch we all order ice tea/Coke/Pepsi etc. Not one of us drinks and we talk that there isnt a CAR prohibiting this action. Heck is there any rule for that matter, prohibiting the consumption of alcohol during working hours other than what may be printed in a company employee policy manual?

[SeptRepair]

So nudging this topic back to where it originated. Are there actually any companies currently mandating unrealistic duty times on maintenance staff? We have all worked long hours at times, but in all situations we knew when we were exceeding our limitations and went home for some sleep or had a fresher person over look our work when finished. We have never had to have it legislated. As well I have never heard of, or have been personally reprimanded for leaving when tired whether the aircraft was ready or not. Maybe I've been lucky through my career and there is really a problem I am unaware of.

[sky's the limit]

So nudging this topic back to where it originated. Are there actually any companies currently mandating unrealistic duty times on maintenance staff? .

I know of one helicopter company that does impose pilot duty on AME's, no trouble.

The shop aspect in rotary is not so much the issue, unless you're at a very busy base, but out in the bush/camp, it just gets stupid. That said, I've worked at many companies where AME's pull 24hrs at a go, occasionally 36hrs - not cool at all.

This is a huge problem that continues to go unaddressed.

stl

[brownbear]

As said above it isn't the normal. Bush yes sometimes. Larger companies do not have this issue. Rotary and small charter companies is where the crazy OT would be.

I've worked the 24 hr shift, yes I still can perform in that shift if need be, But where I want to see rules changed is not in how long an AME can work, but at what point does it become illegal to provide a maintenance release.

I want the regulations changed to put 14 hours as the max shift an ACA can legally perform a maintenance release.

So if an AME worked a 20 hour shift to get a plane ready, he could not sign it out. An independent person would need to come in to perform it. Or the ACA would need 8 hours of rest. Which after that rest period the AME would then re-inspect the work before releasing.

Like all rules, they are pointless if they cannot be enforced. If TC doesn't start enforcing, why bother having rules.

Fatigue management is coming down the pipe. But like SMS it will be a lofty goal, and not so cut and dry.

We already train Human fackers in every AMO in Canada, and I feel everyone gets it (understands).

I'd like to see the stats that show accidents attributed to maintenance error caused by fatigue. I bet it's very low, to almost non-existent.

Put the limit on the Maintenance Release, not the duty time. We don't want operations to suffer, just want to increase safety.

[brownbear]

Duty time would also fail for AME's because an operator cannot know where we work when we are on personal time. Probably half of AME's in busy areas of the country work two jobs for extra dough as a contractor from time to time.

[Bulawrench]

There is some fatigue management documents that transport has put out. It may be coming down the pipe.I know from human factors training that a 12 hour shift is the same as having two beer. I would rather have two beer.Personally i have worked in the past 4 years a 17 hour or longer shift and it is brutal. Most small operators think of the AME as a bottom feeder and Pilots are gods. I know i am sick of this attitude and these companies with these cultures will be identified in future with audits like PVIs. Not to say anything will change. I agree with the post and i aggree that a good working environment lends itself to good maintenance. Not late night outside in the dark with a flashlight in your mouth.

[Cranium]

Transport probably won't touch this. They'll pass it off as a Canada Labour Code issue: A company is [u]not allowed[/u] to permit their workers to work more than 48 hours in a week without written permission from the minister. If the Labour Board won't enforce it, the companies will continue to ignore it.

[AME 283]

Nice to finally see this topic, on Av Canada. There are lots of studies in the United States, that cover not only duty times, but shift work, split shifts human factors and working in adverse conditions. Did you know that typically rotary wing AMEs and Airline AMEs typically work the most hours ??
The problem is if TC makes a regulation it will be something that none of us can live with. Operators have to step up to the plate on this issue, and the regulator has to make whistle blowing acceptable similarily with the right to say no. We are all individuals and one rule will not fit all, plus AMEs are their own worst enemy as we default to getting the job done !!
Companies should step up to the plate and develop their own rules for their own company, and in theory this should be part of SMS (if only the regulator would allow it to develop and mature prior to making dictations. The other issue is how does one regulate "common sense".

Should duty hours also cover ground handlers, counter staff, admin staff, flight attendants, company management ?? I know of a few Directors of Maintenance and even presidents that work very long hours.

Now saying all of that we all have to take personal responsibility about what we do on our down time. I can sleep very well in an aircraft seat, but not so well if it is too hot. We all have different tolerances, and no one knows us better than ourselves and our kids. So we all have to take some responsibility. If you have an Ignorent employer find another one, and learn to say "no" I need some rest.

My 2 cents on a Friday

[dimit]

This is certainly a problem in the rotary world where many of us work in the bush: AME is awake all day hot fueling the machine and catching naps in the truck, then stays up most of the night doing the DI and fixing snags. Repeat ad nauseum. Not good. Can`t speak for the rest of the aviation world.

Thanks for your interest, anyone gonna send some emailsÉ

Dick

[ybp]

Definitely and interesting topic.... It will be interesting to see what regulation if any, ever comes out.

We have all started a simple task, ie change an altimeter in a KA 100, should take only an hour. But then the static leak fails and we spend 6 hrs trying to find the leak. If the duty day runs out in the middle of the troubleshooting process, what are we supposed to do? Lock our tool box and leave??

Here, we have set out 'critical maintenance tasks'. (Rigging landing gear, flight controls and engine control, etc) These are not to be done if you have worked more than 12 hrs, and need to be looked over by another AME. We must also print out the procedure from the maintenance manual and initial the steps as they are completed.

I'm not sure how one could effectively regulate AME duty times....

[jetdoc]

This is a quote from a research paper published recently. Although I agree with it, basically, there does need to be much more emphasis given to the effects of shift work on individuals. There are companies, and indeed countries who recognize the scientific data that there are times when people are not at there best and mistakes can happen.

Everyone who works shift work has either fallen asleep on the drive home, or knows someone who has, may even know someone who has died as a result.

Japan Airlines, I understand has many rules about what task's can be performed and when, and has sleeping facilities for its shift workers. The employee's are encouraged, even expected to take a nap in order to mitigate fatigue accidents.

The whole area of Human Factors is, beyond the same old TC crap that is mandated, is full of information and educational resources that all AME's should take seriously, indeed management should take it seriously.

"Pilots versus Mechanic Duty Limits
The NTSB feels that mechanics should be held to duty time limitations the same as pilots. The writer disagrees with this. Pilots flying an aircraft cannot go take a break. They are literally stuck in their work environment. Weather changes constantly create challenges. Pilots also must be alert enough at all times during flight to implement any one of hundreds of contingency actions in a split second. Duty time limitations are warranted easily if these circumstances are taken into consideration.
Mechanics, on the other hand do have the option to take a break at any time. They normally are not working in conditions where contingency actions are required instantaneously. Mechanics need an awareness and education about how fatigue can potentially lead to inadvertent unsafe acts."

[coldandwet]

I too am glad to see this thread appear although I too am skeptical of change as there are dwindling numbers in the new ame ranks.......for good reason. I hope it improves and will do my part to help. I have been an engineer for 23 years now in the arctic, on heavies, regional stuff, rotary and can say except for Air Canada it is a problem everywhere. As far as the impaired thing goes, I was once pulled over on the way home from a shift of 27 hours and was suspected of being impaired....I was given a 24 hour from the officer who explained although I had no blood alcohol I was still impaired and was a danger to the rest of the driving public. When he asked what i did for a living he shook his head in disbelief!!!!! We are all responsible for our own level of fatigue when it gets to the dangerous level MAKE THE RIGHT CHOICE......

[Tiger Moth]

Good call. Did you know there is no CAR saying that AME's can't drink while working on aircraft? Sad but true.

Pilot Rule: 8 hours Bottle to Throttle.

AME Rule: 8 feet bottle to throttle

[plainfixer]

One of my AME licences has duty time limits written in legislation(CARs). It is a time limit for certifying AME of 16hrs per shift, 7 days in a row, and on the 8th day you must have a 24hr stand down. Now if you are not certfying, you can work as long as the drugs will keep you awake.
Sounds great dosen't it, but wait, its from when you walk in the door at work. Not when you get out of bed. So just add your travel time on top of the 16hrs. I have worked this rotation for about a month. I never went back to that shop.

Now in Canada, KFC has a duty time in its policy manual. It limits the certifying AME to 16hrs, and it is regulated by....HR! The payroll department picks up on this, and if your shift is over 16hrs, then permission to pay you is required from the Director of Maint.

So you work the shift, 2 weeks later, you find your pay docked because permission was not/ has not yet been given, to pay you those extra hrs.

Really nice feeling when you open your payslip. Another jab in the ribs from the industry.
The aircraft got airborne, did its revenue run, company earned money, you get docked in your payroll!!! really nice.

plainfixer

[donnybrook]

In an era of increasing personal liability for the AME, this subject will hopefully become a topic made moot by intelligent legislation of some sort. However I can't see a blanket duty time limitation being effective in all circumstances, as seen by the rotary/fixed contributors. I personally know rotary AMEs who make the current system work by utilizing phase inspection, or something along the same lines, and who know when they need to take some time to re-group. The caveat is that this is bush work where there are no management types to call the shots. Speaking from a rotary perspective "you gotta do what you gotta do" sometimes. There is no way that any self respecting AME will call the 16 hour duty day and let the helicopter sit U/S on the ramp/muskeg in the middle of a fire flap. Pride first of course, but wallets will also motivate.

[lupin]

Some things to think about.

You should be striving for 8 hours of uninterrupted rest and not 8 hours between shifts. You need to factor in driving time, showers, meals etc.

Most rules end up going through CARAC. CARAC is staffed by the industry players. Last time an attempt at legislating duty days was tried, Westjet opposed the project. Do some research and you can find the transcripts for the CARAC meetings and all the concerns. The CAMA web site might have some interesting material on this subject and the necessary links to find the CARAC transcripts.

In issues such as this many have a tendency of only seeing the practical side of the legislation. We too often forget the multinational companies with rich lobbying budget to assure that no government intervenes to restrict their capabilities. It is noble to think that companies value safety first but in the end, they are out to make a buck and will cut any corner they can to achieve their goals.

[skydrolboy]

Now in Canada, KFC has a duty time in its policy manual. It limits the certifying AME to 16hrs, and it is regulated by....HR! The payroll department picks up on this, and if your shift is over 16hrs, then permission to pay you is required from the Director of Maint.

So you work the shift, 2 weeks later, you find your pay docked because permission was not/ has not yet been given, to pay you those extra hrs.

Really nice feeling when you open your payslip. Another jab in the ribs from the industry.
The aircraft got airborne, did its revenue run, company earned money, you get docked in your payroll!!! really nice.

plainfixer

There is provision in the KFC policy manual to work longer than 16hrs under certain circumstances, but you are required to have a certain number hours of rest before returning to work. Also they haven't been docking your pay for working over the limit for quite a few years now.

[AME 283]

My question is why would one want to work more than 16 hours ?? My biggest fear as an AME is being a contributor to an accident where some one is killed. I know we all want to get the job done and the aircraft out the door, but as AMEs we do have to take some responsibility for our own actions !!!

[dstechnical]

Who would enforce these limits. For example spent all day in a human factors course.,(is that not ironic) then drove 8hrs and spent all night doing blade change, balance and strobe. How many of the 12 deadly sins did we break that day?
Over the years I have spent many 4hhr maintenance session., barely able to keep my eyes open. the customer must be educated as well. The OMNR for instance has penalty clauses for down time in their helicopter contract. At one time they used to build in maintenance days, but not anymore. There own maintenace staff would never be subject to such a work schedule. the companies will never change and transport only seems to pay lip service to human factors.