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When Size Matters

Last spring, the fatigue-risk-management working group concluded its deliberations before issuing its final report to the Canadian Aviation Regulatory Advisory Council Technical Committee in November 2012.


March 8, 2013
By Fred Jones

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Last spring, the fatigue-risk-management working group concluded its deliberations before issuing its final report to the Canadian Aviation Regulatory Advisory Council Technical Committee in November 2012. Ironically, it’s HAC’s view that the report focuses less on fatigue and risk, and more on the needs of the large scheduled international air carriers represented by the National Airlines Council of Canada (NACC), and their pilots’ unions. What started out as an effort to update the Canadian Aviation Regulations (CARs) in light of the latest available fatigue-related research, turned into an airline-centric overhaul of the Canadian regulations.

“Pilots are pilots,” as they say. We all get fatigued. But we get fatigued in different ways because we do different jobs. In terms of our respective job descriptions, airline drivers and helicopter pilots share the sky . . . but that is where the similarity ends.

Helicopter pilots operate largely in an unscheduled, VFR, self-dispatch, seasonal environment, and in some of the most remote areas of the country.

We generally operate without crew-scheduling or dispatch offices. Airline pilots have their “pairings” and “blocks” weeks in advance. Helicopter pilots frequently don’t know what they are doing tomorrow morning.

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In their respective fatigue-risk management working group processes, the Europeans and Americans concentrated on the commercial and business aviation communities first to consider and implement regulatory solutions sensitive to the needs of these segments. This is something the co-chairs in the Canadian working group steadfastly refused to do. Instead, they focused on developing rules of broad application with a few small variations, which were ill-suited to the industry segments they were developed to accommodate.

The working group co-chairs relied heavily on controversial European Aviation Safety Agency recommendations, the new U.S. Federal Aviation Regulations and International Civil Aviation Organization Standards And Recommended Practices (SARPS) – all of which were only intended to apply to large airlines.

The working group co-chairs have recommended a series of new and significantly more restrictive changes to the current regime of flight and duty time limitations set out in the CARs which would apply to helicopter operators. These include:

  • cumulative duty hour requirements, completely new to the CARs
  • sector limits requiring a reduction in the flight duty period, completely new to the CARs (The more landings and takeoffs you do, the shorter your flight duty period. This new limit, according to the recommendations in the report would apply only to scheduled and medevac helicopter operations)
  • new, more conservative seven-day (down from 70 to 56 hours) 28-day (down from 140 to 112 hours) and 365-day (down from 1,200 to 1,000 hours) cumulative flight time limits
  • new, less-flexible rest period requirements that impose a 10- or 12-hour minimum rest period (depending on whether the pilot is deployed or at home-base), rather than imposing a requirement on the air operator to ensure eight-hours of uninterrupted sleep is protected
  • new, maximum daily flight duty periods that vary depending on when the flight crew member starts his/her day – new to the CARs
  • removal of the current industry segment-specific standards which applied to non-scheduled and helicopter operations and to heli-logging operations
  • new more conservative time free from duty requirements for rotational crews, down from a maximum of five days off after 42 consecutive days to five days off after 15 days!
  • new, and lower, maximum flight duty period, down from 14 hours to 13 hours
  • in spite of strong scientific evidence that multiple consecutive days free from duty will serve to significantly reduce fatigue, the co-chairs eliminated the “zeroing” of accumulated flight time for five days-off – without even mentioning the issue in the report

In the final analysis, nine associations came together to reject the recommendations contained in the working group report. The bottom line? “One-size-does-NOT-fit-all,” Minister Lebel. It’s time the needs of helicopter operators are taken into consideration in this critical issue.


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


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