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The Heat is On – Again

It has been over a year since the Helicopter Association of Canada (HAC) and eight other associations made their final submissions to the Fatigue Risk Management Working Group Report. Since then, Transport Canada (TC) senior management has been reviewing the report and multiple written dissents thereto.

The Working Group Final Report in reality is a report generated by the Working Group’s leaders (http://www.h-a-c.ca/F&DT_WG_Final_Report.pdf), in this case, by a TC employee and the president of the Airline Pilot’s Association Canada Board (ALPA – Canada). In fairness to them, it was their best effort to bring together the views of the Working Group’s members around a single report that no one completely agreed with – but some groups more than others, it would be fair to say. HAC believes that the report is biased in favour of the large scheduled international airline community.

Virtually everyone in the operational commercial and business aviation communities – except the members of the National Airlines Council of Canada (NACC) and their unions, were signatories to a single dissent. We were so disturbed by the content of the report, that our nine associations jointly made one submission. The report’s recommendations advanced a one-size-fits-all regulatory structure – with some minor variations available to some segments of the commercial aviation community. The report’s recommendations, if they were to be implemented in their current form, would devastate Canada’s commercial helicopter community. Let me refresh your memory with a short summary of the Final Report’s proposed changes. You can decide for yourself what the effect would be on your operations:

Time Free from Duty

• Current (720.19) – five days off before a 42-day tour and five days off afterwards
• Proposed – (Option 1) one day off in eight and four days off in 28 or (Option 2) five days off in 20 for deployed operations (15-day tours)

Cumulative Duty Hours

• Current (None)
• Proposed – 1,928 hours in any 365 days; 190 hours in any 28 days (average of eight hours/day Duty Time); and 60 hours in any seven days if using Time Free from Duty (Option 1 above) or 70 hours in any seven days if using Time Free from Duty (Option 2 above)

Flight Time Limitations

• Current (720.15) – 60 hours in seven days; 150 in 30; 210 in 42; 450 in 90; 1,200 in 365; 30, 42, 90-day Flight Times “Zeroed” after five consecutive days off
• Proposed – Single pilot eight hours in any 24-hour period and 112 hours in any 28 days (down from 140 in 28 currently), 1,000 hours in any 365 days. Also, “Zeroing” Provisions would be Deleted

Flight Duty Period Limits

• Current – 14 or 15 hours (with nine hours daily rest and a daily flight time limit of eight hours)
• Proposed – Reduction in the FDP for early morning and late-day starts; 13 hours maximum but available only for FDPs starting between 07:00 and 12:59 local; Reduced progressively for early morning and late day starts using a matrix

Rest Periods

• Current – eight hours
• Proposed – 12 hours between FDPs at home to accommodate family-related responsibilities; 10 hours away from home base (or where the employer provides accommodation)

One of the things I believe that the Working Group leaders did right was to focus on the latest fatigue-related science. Unfortunately, much of the fatigue-related science is either inapplicable to helicopter operations or it is ambiguous – that is, there is conflicting science – and HAC believes the Working Group Leaders strayed in to dangerous territory. Once you stray outside a very short list of unambiguous anchor points in the scientific literature, there are studies on both sides of most issues.

HAC has been engaged in an advocacy campaign on this subject for over two years now. I believe it is the single most important regulatory issue on the horizon for the Canadian commercial helicopter community. If you are not an HAC member, I suggest you join the Association and get your proverbial oars in the water on this subject, as the next stage in our advocacy efforts spin-up.

Fred Jones is the president/CEO of the Helicopter Association of Canada and a regular contributor to Helicopters magazine.