A Dire Course
Draft Fatigue Management Regs Could Cripple the Industry
For almost seven years, the Helicopter Association of Canada (HAC) and others industry associations have been consulting on the content of Transport Canada’s (TC’s) draft for new fatigue management regulations. And with the exception of input provided by the National Airline Association of Canada (NACC), the proposals and input made by HAC and the various associations have been largely ignored.
While TC has made a few changes since the rules were originally presented in the Fatigue Management Working Group Report, the most damaging elements remain in the draft that was published in Canada Gazette I on July 1. (www.gazette.gc.ca/rp-pr/p1/2017/2017-07-01/pdf/g1-15126.pdf) Sadly, while TC has steadfastly proclaimed that, “These regulations are based on science,” with a few notable exceptions, this is simply not true, and in many cases TC has applied hard-numbers using soft-science. More than 30 years in Ottawa has taught me “It’s never over-’til-its-over,” however if the draft regulations published on July 1 move forward to become law in their current form, it will cause irreparable harm to the commercial helicopter community – and HAC would argue that it will not improve safety. Set out below, is a description of the most damaging elements of the new regulations, insofar as the Canadian commercial helicopter community is concerned.
The maximum tour length would be 23 days (down from 42 days) – and some conditions apply – such as no early duty, late duty, or night duty; no assignment of a flight duty period that is longer than 12 hours; and the maximum duty time is 24 hours in any consecutive 48 hour period.
Removal of the “zeroing” provisions
The current five-day-zeroing standard has been in place for many years, to the benefit of non-scheduled CAR 703 and 704 operators and flight crewmembers – but particularly to operators conducting deployed operations. Industry perceives that the zeroing provisions have been removed in the draft regulations in spite of the scientific evidence that supports them – not because of it.
New cumulative duty hours
Cumulative duty time is an entirely new concept in the CARs and will require flight crew to track their duty time in the same way that they track flight time. The proposed new limits are: 210 hours duty in 28 days (actually 210 hours in 23 days if – as most helicopter operators will – they are using option 3 for time free from duty at 23 days “on” and five days “off”).
Cumulative flight time limits
112 hours in 28 days. Actually, it’s 112 hours in 23 days (owing to the time free from duty requirements, above) or an average of 4.8 hours/day (down from 142 hours in 28 days).
Probably the most damaging part of the new regulations occurs as a result of the “stacking” or cumulative effect – when the different parts are read together. Read in combination, a deployed flight crewmember will only be able to fly an average of 4.8 hours each day, in the context of a 9.1-hour average duty day. Sure they can have a longer duty day (up to 13 hours), but their average duty day cannot exceed 9.1 hours.
Yes, in a single-pilot operation, you can fly up to 8 hours in a day, but their average flying day cannot exceed 4.8 hours. There is no science that says flying more than 4.8 hours each day, or being on-duty more than 9.1 hours each day is unsafe.
What this means is, operators will be driven to supply two pilots on every job, or run shorter tour lengths (14 or 15 days, rather than 23 days). The saddest and most frustrating part about this whole experience is that, with few exceptions, these regulations will not have the effect of improving safety in our industry. HAC and the eight other associations will continue to fight these oppressive new regulations in the run-up to the consultation deadline – between their publication in Canada Gazette I and Canada Gazette II.
Fred Jones is the president/CEO of the Helicopter Association of Canada and a regular contributor to Helicopters magazine.
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