Safety & Training
Standards & Regulations
A Misguided Approach
By Corey Taylor
I was told an inaugural address, even in the form of a magazine column, should reflect issues of current debate and discussion to set the tone for future columns and their potential impact on the readership.
By Corey Taylor
I was told an inaugural address, even in the form of a magazine column, should reflect issues of current debate and discussion to set the tone for future columns and their potential impact on the readership. With that in mind, I know of no issue with a greater potential to shake the helicopter industry than the current Notice of Proposed Amendment regarding changes to Canada’s regulations around Flight and Duty periods (FDT). Not even the current malaise seeming to affect a large portion of the helicopter industry has garnered as much attention and controversy as this potential new law.
Having attended a couple of the meetings of the Working Group formed to study and address the FDT rules in Canada, I feel close to the issue, but not so close as to lack objectivity. The stated goals of the undertaking were seemingly acceptable to all parties at the start of the exercise, so how did it go so far off the rails from the perspective of the helicopter industry? There are many reasons, but I believe that the heart of the issue can be found in one of the opening paragraphs, in section 1.2 entitled “Principles”:
Intrinsic to this Working Group Report is the principle that fatigue affects all flight crew. As such, the Working Group Chairs were given direction from the Canadian Aviation Regulatory Committee (CARC) that, to the extent possible, the proposals should apply to all flight crew members and air operators.
This innocent sounding statement trapped the participants into almost a year-and-a-half of acrimony and frustration that may take longer yet to sort to some degree of widespread satisfaction. The problem is that no attempt was made to understand the roles and responsibilities, not to mention the work schedules and tasks, of any of the people whose lives were being discussed. As the airlines dominated the discussions, it was simply a given that all pilots face roughly the same schedules and fatigue inducing events. So much time was spent discussing “Sectors” and their effect on fatigue, I found myself embarrassed that I had no idea what a Sector was (it’s a takeoff and landing in fixed wing, big iron jargon). No discussion of how much fatigue a helicopter pilot might feel at the end of a day spent hanging out the bubble window, pulling redline torque while moving drills in the mountains, or putting water on fires, ever took place or was even contemplated.
One of the items with perhaps the greatest potential to impact the helicopter industry was the discussion around Duty vs. Flight Time with regard to fatigue. A large portion of the discussion was spent determining that Duty Time was just as fatiguing as Flight Time. I thought this was obvious for an airline pilot and find it unfathomable that anyone could argue. Sitting in a cockpit is fatiguing regardless of whether the aircraft is on the ground or at 35,000 feet. There’s the rub. When a helicopter pilot is on duty (generally – I know differences exist within our industry as well) he or she does not sit in the helicopter for the full period waiting on the client. I learned to fly-fish (poorly) while on duty, but got pretty good with a bull whip in the highlands of Ethiopia!
Without getting into the fine detail of the NPA, it is glaringly clear that the process was flawed, at least from the perspective of the helicopter and small airplane industries. I have seen comments in the media from operators and others that state we won’t have enough pilots or we won’t be able to afford the new rules, but I make a point of avoiding all of those “commercial” arguments. The fact is, it makes little sense to adopt big airplane, scheduled flight, airport-to-airport operational rules for small operator, air taxi, aerial work type of operations. I believe the closest analogy that exists is the difference between taxicabs and long haul truckers. Their work is similar, they drive vehicles on the same roads but their rules are vastly different. I know helicopter pilots will sometimes get insulted when they’re compared to a taxi driver, but the fact is, what we do is very close to that. Of course, with some crane and excavator operating thrown in for good measure!
The only real solution to this seeming dilemma is for another working group to convene – one that will determine what it is that people do and consider what the fatigue impacts are. To have a discussion where we simply debate whether, “Duty” is fatiguing without ever attempting to define and understand what Duty is – and whether it’s the same for all parties – is a glaring failure of the Working Group to fulfill its mandate, at least if that mandate was about safety.
Corey Taylor is VP, Global Business and Product Development for Great Slave Helicopters. This is his inaugural column for Helicopters.