Safety & Training
Standards & Regulations
A healthy perspective – We need to define what “fit to fly” means
January 2, 2018 By Walter Heneghan
Am I fit to fly? There has been a considerable volume of debate over the past five years or so about Transport Canada’s move towards harmonizing the Canadian regulatory framework with the rest of the world. But what does all this mean to those of us “at the coal face”? What can I and what must I do to stay safe?
Well let’s start with the notice posted to the Canada Gazette earlier this summer. The proposed amendments to the Canadian Aviation regulations offer a new definition for the concept “fit for duty “It reads “. . . in respect of a person, means that their ability to act as a flight crew member of an aircraft is not impaired by fatigue, the consumption of alcohol or drugs or any mental or physical condition . . . ”
Simple enough, yes? Not so fast. In fact, this definition builds on the existing regulations detailed in Part VI of the CARs – prohibiting reckless or negligent operation of an aircraft that endangers life, operating aircraft while fatigued or under the influence of drugs or alcohol, or otherwise unfit to be a crew member. These duties are clear: don’t operate an aircraft if you are unfit to do so. The rub? Who decides “fitness”?
Much of the recent discussion in the Canadian helicopter industry has centered on flight duty time. I will not attempt to address those issues in any depth; others more versed on the topic are arguing this point. Suffice to say, the big air carriers are pushing much more restrictive and proscriptive solutions and the heart and soul of Canadian aviation – the smaller carriers and the helicopter companies are looking for a fit-for-purpose industry friendly response. (For more, see, “A Dire Course, October Helicopters pg. 34). From my perspective and experience, we also need to do some soul searching.
There will always be a tension between the operations/production managers and the operators/producers (read pilots and AMEs). Companies want to maximize the use of their staff, to get the best bang for their dollar. And for the most part, pilots and AMEs are willing participants in this dance. Most aviators I know and have worked with are fully prepared to work hard and to put in the hours necessary to be part of a successful business. However, I posit that neither the companies nor the pilot are the best people to determine fitness for duty. This is simply due to the fact that each has vested, subjective interests and cannot separate these biases from safe decision-making.
Consider emergency checklists. In the calm detached setting of the manufacturer’s flight test facility, emergency procedures are developed that consider the best flow of actions in the event of, say, an engine failure. These steps are tested, refined, tested some more and then codified in the checklist or Quick Reference Handbook (QRH). They are then taught and practiced until mastered.
This process has been accepted for decades, yet when it comes to determining fitness for duty, objective measurements are cast aside for either operational pressures or checking with pilots to ask – are you OK to fly? Why would we design a system that accepts such subjective inputs into such a safety critical decision-making process?
In the past three years, the number of reported impaired pilot-in-the-cockpit events has increased. This may be due to increased vigilance and reporting or it may be due to other factors in play.
But what is clear, however, is that whatever system was in place at the time, the pilot made a subjective decision, just prior to the start of his duty period, to go to work. In addition, there have been several close calls and actual accidents recently whereby the pilot either reported that he did not feel competent to accept the tasking or was on standby and felt too tired to accept the duty assignment, yet reported to duty anyway. In these cases it needs to be asked: did production pressures win the day or was it the sole responsibility of the pilot?
In any event, the system failed to protect the travelling public. This is why fitness for duty questions need to be answered well in advance, using research and science and completed with the collaboration of the operations managers, CEOs, pilot and AMEs. Asking a pilot – are you good to go – can no longer be an acceptable checklist item.
Walter Heneghan is an experienced and well-travelled pilot who has served as the top safety professional at Canadian Helicopters and Summit Aviation. He is currently working with CHC Helicopter in Kazakhstan as an SMS development specialist. He is a regular contributor to Helicopters and Wings magazines.