A CARAC board member once told me that (way back) the idea of duty limits for engineers was thrown around. IN 2005, when they began the.implementation of SMS on all sectors, it was decided that this compliance based mindset was contrary to SMS principles. Under SMS, companies would be able to assess the risks at their organization and set their own limits and it would ultimately lead to de-regulation.
The FRMS is based on these principles. Here is the problem, it’s 14 years later and they TC still haven’t been able to ensure implementation of SMS in most sectors and air carriers in Canada. I’m guessing FRMS will go about as smoothly as SMS.
I also doubt that the average TC inspector, with no helicopter experience will understand the risks in our operations, so getting approval for deviations will likely be a nightmare. I also suspect that regional disparity will be rampant, whereby one operator can receive certain approvals, but others won’t.
I for one think that AME’s should have Duty limits in the CARs. It’s a safety sensitive position and they work mostly at night. The “science” suggests they would be prone to fatigue.