Pilot Opinion Survey Re: Changes to FDT Regulations

[Fred Lewis]

This survey is intended to measure the extent to which pilots agree with the changes to Canada’s flight and duty time regulations as proposed by the Canadian Aviation Regulation Advisory Council Flight Crew Fatigue Management Working Group. This report was published by Transport Canada on August 15, 2012.

Participants have the option of providing their name, email address and phone number or all or none of these as they wish. All results, anonymous or otherwise are tabulated. A preliminary survey indicated that 66% of potential participants would provide their names.

The survey software allows only one survey response per computer.

Participants are given the opportunity to specify their preferences on several aspects of the regulations to which change is proposed. These responses will be tabulated and compared with both the existing and proposed regulations on January 20, 2013.

Click here to take the survey.

[Northern Flyer]

Why don't you lay out the proposed changes.

[mbav8r]

Can't take a survey without knowing the changes, do you have a link to the proposed changes.
I spent 15 mins searching through various archives and found nothing specific.

[Fred Lewis]

Somewhere in TC's website there is a link to the report but it is difficult to find. The Helicopter Association of Canada has a copy of the draft report posted on their site that preceded the final report and the two are almost identical. As of the writing of this post the HAC website is not responding.

I have a copy of the report and will try to attach it but it is over 120 pages long and attachment may fail. (It did fail.)

Results from the survey are trickling in. 46% of respondents have volunteered their names, email addresses or phone numbers.

The results are interesting. I don't think anyone should be too concerned that the world will come to an end if these proposed regulations become law. Even those who agree with the proposals suggest times for the length of the duty day and tours of duty that are reasonable. In the interests of discouraging bias, the results of the survey are not immediately available to survey takers, but I will make the results available before the end of January, at which time comments on the Working Group report will no longer be accepted.

I think it is fair to say that both sides of the issue will be pleased with the results of this survey.

[All Sides]

Fred perhaps you could summarize the the specific highlights of the proposed changes.

There is a lot of opposition to the proposed changes on the rotary-wing side of the industry, it will greatly affect 703 operations on the fixed wing as well. Some of you guys might want to educate yourselves to the changes as it could have a major effect on your operations.

What are you proposing to do with the results of your survey Fred?

[CD]

CARAC NPA System: Technical Committee Meeting Details
2012-11-06

Report of the Canadian Aviation Regulation Advisory Council (CARAC) Flight Crew Fatigue Management Working Group
1.Appendix 6 - Working Group Member Submissions Following Final Meeting
2.Appendix 7 - Working Group Member Comments/Dissents

[Northern Flyer]

Unfortunately I do not care near enough to read that report. Ill wait for the Coles note version.

[JAllen]

.

[Edo]

Why do we really need a table to calculate max Flight Duty Day? Too complicated,when you have to cross reference reporting time and number of sectors planned vs length of sectors Come on now really.
So a series of trips works today but tomorrow the winds are high and the same segments take 33 mins instead of under 30 oops not enough time to fly home?

Whats wrong with saying max duty day 12 hrs??? or 10 or whatever.
Just because the panel could not come to a consensus....why create an enforcement trap for everyone else.

Kind of like the new segmented weights, customers dropped off in the Otter magically gain weight if the Beaver picks them up

[Northern Flyer]

I don't know, my initial response is it seems like a bunch of unionized pilots at a big airline trying to get out of as much work as possible. 1928 hours max time on duty in a year? Really? 2080 hours is a normal Monday to Friday job working 8 hours a day. I didn't really see anything in there that was pertaining to smaller operators. Though I did not look too hard, since these changes will not affect the operation I work for.

I personally think a 14 hour duty day is fine, I just think your time free from duty, or rest period should equil your duty day.

[All Sides]

Northern Flyer, you might want to look a little closer at the proposed changes if you are in a 703 operation in the bush. It really doesn't have an immediate impact on my present job, but potentially has huge implications for both rotary and fixed wing ops. Without knowing the exact proposed changes, I believe the duty day will be reduced to 11 hour sa day, 7-8 hours flying per day and 1 day off in 7. (or something like that)

Yes it is 704/705 unions are the driving force behind it.

[tbaylx]

Northern Flyer, you might want to look a little closer at the proposed changes if you are in a 703 operation in the bush. It really doesn't have an immediate impact on my present job, but potentially has huge implications for both rotary and fixed wing ops. Without knowing the exact proposed changes, I believe the duty day will be reduced to 11 hour sa day, 7-8 hours flying per day and 1 day off in 7. (or something like that)

Yes it is 704/705 unions are the driving force behind it.

What a load of BS..it's years of actual fatigue data and the fact that Canada is still in the dark ages with regards to duty days that is driving this, not the unions. If you can't see why a 14 hour duty day extendable to 17 that starts in the middle of the night and does 6 legs is an issue, then you're a lost cause.
Everyone else on the planet differentiates what time of day your duty starts, how many legs you do and how much flight time is involved. Canada is an international embarrassment when it comes to fatigue and duty rest regulations, bout time we joined the rest of the world.

[Lost Lake]

I don't know, my initial response is it seems like a bunch of unionized pilots at a big airline trying to get out of as much work as possible. 1928 hours max time on duty in a year? Really? 2080 hours is a normal Monday to Friday job working 8 hours a day. I didn't really see anything in there that was pertaining to smaller operators. Though I did not look too hard, since these changes will not affect the operation I work for.

I personally think a 14 hour duty day is fine, I just think your time free from duty, or rest period should equil your duty day.

You obviously have a soft job NF. A 14 hr duty day combined with 6 plus hr of flight time makes a very long day. Or try medevac on day 5 of your rotation. I don't mind 14 hr, if I'm sitting around drinking coffee and doing my 4 X 30 min trips. There is a direct correlation between the duty time and hours flown. I will let smarter people than me figure out a good ratio.

[Edo]

SO how do other countries do it? Do they have a chart similar to the one in the proposal? I tried to cut and past it into a post but the cart loses table formatting, anyone else care to post it?

[Northern Flyer]

I don't know, my initial response is it seems like a bunch of unionized pilots at a big airline trying to get out of as much work as possible. 1928 hours max time on duty in a year? Really? 2080 hours is a normal Monday to Friday job working 8 hours a day. I didn't really see anything in there that was pertaining to smaller operators. Though I did not look too hard, since these changes will not affect the operation I work for.

I personally think a 14 hour duty day is fine, I just think your time free from duty, or rest period should equil your duty day.

You obviously have a soft job NF. A 14 hr duty day combined with 6 plus hr of flight time makes a very long day. Or try medevac on day 5 of your rotation. I don't mind 14 hr, if I'm sitting around drinking coffee and doing my 4 X 30 min trips. There is a direct correlation between the duty time and hours flown. I will let smarter people than me figure out a good ratio.

I guess I do now have a soft job. I am on duty 12 hours a day 7 days a week starting April 1st and I work straight through till around September 15th. I can put in for two six day periods off during the 5 1/2 months I work.

I did however have it a little less soft in the past including medevac operations 2 weeks on 2 weeks off for about six years straight, so I know what it is like. Quite frankly I would not like to do it again, but I didn't find it that bad at the time.

Honestly I hope the reforms work out for those who are pushing for it, but as I alluded to earlier I do not think they will have any effect on the operation I currently work for. If it is more safe and efficient so be it. I do however think it could have some major impacts on some if not all businesses. I personally would like common sense to prevail, I hate being regulated to death.

[tbaylx]

SO how do other countries do it? Do they have a chart similar to the one in the proposal? I tried to cut and past it into a post but the cart loses table formatting, anyone else care to post it?

Yes JAR ops (and all other regions that use JAR ops, such as the ME airlines) use a similar table based upon the time of day that you start, the number of sectors and the duty day. What is being proposed here in Canada is mostly a copy of the Euro regs, with a few modifications to make it more suitable for Canada.

[spaner]

Thank god....
Like a rubber band snapped back into place. Our current regs are a joke. Mostly because the operators are familiar enough with them that they know what run arounds they can do. A lot of feed back reporting requirements on this new stuff. Although, I'm still disappointed to see the section on pilot fatigue reporting still in place. If a pilot reports himself fatigued, and unable to report for duty, the first thing the operator is going to say is "are you sure about that?". In this day and age of human factors understanding and mitigation in risk factors, operators still consider a "fatigued call" the same thing as a 22 year old oil worker calling in sick after the derick-hand's birthday blowout bash. He expects you to "come in to work, with the MEN".
Sad; and you're also fired.
So, useless and a waste of paper. For all regulations, you have to make the person that is in charge, responsible, and that's not the crew member.

Obviously, I'm an advocate.
I've worked the 105hr 7 day periods. AND, yes they can run 15hr days by tracking 180periods and rotate on-call duty shifts through intelligent tracking processes manipulation. AKA; fix the paperwork after, and if you can't, lose it.

Hey, I don't think operators would for a second do everything to the letter, in a more robust regulated system. BUT, you can only manipulate so much, only bend or break, so much.
Tighten up the above board regs...and the back office will have to do the same...

table.JPG (98.07 KiB) Viewed 2881 times

[Beefitarian]

Pretty simple if transport Canada was worth a nickel. They would set up a phone number. Fatigued pilot phones third party who then contacts operator to letter know the pilot is unavailable for duty. If the pilot is fired the operator is fined $75000. 50 to the pilot 25 to defer costs of the system.

[spaner]

Oh, and wanted to add the obvious solution, above my pay grade, but I'm asked to do so often.

Two men working two different 8hr shifts, IS the same as one man working a 16hr shift.

AND, I am one of the guys that does NOT want to work 15hr back-to-back shifts for 14days in a row. Been there, done that, quit.
I even asked the boss to hire another 8hr guy, I'd even split my pay with him.
Well, hopefully, they'll no longer have the choice to be reasonable.

Like (included) "after 6hr of DUTY, provide opportunity for food and drink".
How is this unreasonable? I never got that consideration...well, maybe from the OCC, but you still had to ask..

1-800-Stick-it-up-your...

I LIKE IT!

[Cap'n Tripps]

I completed the survey, but there was a problem with question 7. Every time I selected the appropriate number it reset to default.

Good Luck!

[Northern Flyer]

Oh, and wanted to add the obvious solution, above my pay grade, but I'm asked to do so often.

Two men working two different 8hr shifts, IS the same as one man working a 16hr shift.

AND, I am one of the guys that does NOT want to work 15hr back-to-back shifts for 14days in a row. Been there, done that, quit.
I even asked the boss to hire another 8hr guy, I'd even split my pay with him.
Well, hopefully, they'll no longer have the choice to be reasonable.

Like (included) "after 6hr of DUTY, provide opportunity for food and drink".
How is this unreasonable? I never got that consideration...well, maybe from the OCC, but you still had to ask..

1-800-Stick-it-up-your...

I LIKE IT!

This is just not practical for some operations.
"Ok fella's in six hours time go ahead and land on the nearest esker and roast yourself up a ptarmigan."
Haha, that might not be too bad actually.

[trey kule]

Unfortunately I do not care near enough to read that report

ah, the mark of a professional...

The problem is that employers consider the maximum allowed pretty much as the minimum they want.
In larger companies non flying time (re accountants) look at how to get the lowest "unit" cost from the regulations.. Fatigue is nothing but lip service. In the very small companies, the owner says "look at me..I work every day for 14 hours...so should you"
So unfortunately, regulations are required, and I am really not a regulation loving pilot.

As to your suggestion Beef, it is also a bit more complicated. Some pilot decides to try and demonstrate the difference between a pilot and a pig and gets zero sleep. Not fit to fly the next morning...Should the company be responsable to replace them? There is some responsability here on the flight crew to insure that they get the necessary rest...to fine a company that has a certain pilot book in "fatigued" the day after every major football game is a bit unfair.

Like everything else when humans are involved, there are different agendas..The regulations are necessary.

It would be nice to see that for pilots rest time must exclude any other duties...To many northern and small operators used to feel a day off (read...bad weather) was time to do other duties...You simply cannot work 14 hours a day continuosly and be on your A game if it is required.

The helicopter folks also present a different perspective...Pilots like the money so will work tired.
Companies dont want to have to do rotations...They are not going to like the regulations.
The whole reason they have not been upgraded until now is the pressure from the operators.

Glad to finally see a change.

[ant_321]

To be honest I'm not sure how I feel about these changes. At the operation I work at we fly long days but only work between 7-15 days a month. If our max duty day is cut back we will certainly be working many more days a month. So as I'm laying in bed on my days off I am against the change. On the last leg of a 14 hour duty day maybe I would have a different opinion.

[trey kule]

The question is will you perform better working more days but less hours in a day?
The general attitude of pilots is to cowboy up when they are tired...Not a good thing to be tired when something does not go as planned and you need 100% of whatever brain cells have evaded death by alcohol.

It is that attitude that the regulations address. None of us seems to be very good at self analysis.....

Lots of companies pay lip service to things like rest but when it comes down it , they want the job done first...

[ant_321]

I'm certainly not going to argue your point as it is valid, on the other hand I love my current schedule. Maybe after a few years ill prefer te shorter days. Haha. I find the first couple of hours of an early morning much worse than the last few hours of a 14 hour day.