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Freewheel last won the day on December 2 2017

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  1. Thanks for clearing that up. I think I understand your point of view: since your career predates the regulations and maintenance requirements, you get to pick and chose which one you comply with. You also clam up when someone raises a valid point that does not conform to your opinion. I think I’ll go with what the manufacturer says instead and insure my maintenance is completed in accordance with the regulations. Under the Flight Time = Air Time interpretation, It seems to me that for short flights in accordance with (B), all operators have a contractual obligation to inflate their Air time Q1. Engine Start Time/Blades turning: 754 Time Up Time Dn Air Time Starts Comments 800 804 4 min 1 CYMO – Lagoon 809 812 3 min 0 Lagoon – CYMO 816 819 3 min 0 CYMO – Lagoon 822 825 3 min 0 Lagoon – CYMO 829 833 4 min 0 CYMO – Lagoon 838 841 3 min 0 Lagoon – CYMO 844 847 3 min 0 CYMO – Lagoon 850 853 3 min 0 Lagoon – CYMO 855 858 3 min 0 CYMO – Lagoon 904 909 5 min 0 Lagoon – CYMO Engine Shutdown @ 912; Rotors Stopped @ 914 In accordance with the clause in the contract, For the above entries: The pilots calculated Flight Time and Air Time respectively, should be 1.2 hours Flight time and 1.2 hours air time Q2. Engine Start Time/Blades turning: 754 Time Up Time Dn Air Time Starts Comments 800 824 24 min 1 CYCN – CYTS Engine Shut Down @ 830; Rotors stopped @ 831 In accordance with the clause in the contract, For the above entries: The pilots calculated Flight Time and Air Time respectively, should be 0.4 hours Flight Time and 0.4 hours Air Time Airbus Helicopters indicates this recording Air Time as per the clause for short flights in succession is not in accordance with Master Service Manual or Maintenance Manual... “Good morning, I am doing ok here I hope you are also. Regarding your question yesterday on flight and air time please review the following. Airbus Helicopters is concerned with limitations expressed in Flight Hours (FH), Calendar time & Cycles. The definition of FH is given in both the Chapter 4 Airworthiness Limitations Section (ALS) and Chapter 5 Master Servicing Manual (MSM) both are available through TIPI and as part of the standard documentation for each model of aircraft operated. This definition of flight hours (not to be confused with Flight TIME) corresponds to Air Time as defined in CARs Section 101.01: Airbus Helicopters does not take into account running time (i.e. flight time by ICAO definition) for purposes of tracking limitations. So in answer to your two questions: A1: answer a. Flight Time = 1.3 / Air Time = 0.6 A2: answer Flight Time = 0.6 / Air Time = 0.4 (Note: rotors stopped at 0831) If you have any further questions regarding Airbus Helicopters requirements for tracking time please let us know. Best regards, Rod Rod TUPALA Technical Support (Ontario) Airbus Helicopters Canada Limited”
  2. Because I get the impression you think the “air time” limits in the maintenance manuals are all “Maximum limits”. There are manny maintenance tasks that are completed after a minimum number of “air time” hours. Unlike TC, the manufacturers are very clear that these limits are based on time in the air...not sitting on ground with blades turning. How about the many special inspections, torque checks etc. After component removal and installation? Generally I prefer my maintenance completed with strict adherence to manufacturer’s maintenance practices to reduce the likelihood of this type of failure. https://www.tc.gc.ca/eng/civilaviation/opssvs/civil-aviation-safety-alerts-2017-02.html If you are entering inflated air time figures in the journey log book it’s just a matter of time before these tasks are completed early (and contrary to required maintenance practices). Auditors should expect that operators and pilots execute to these standards.
  3. BM, just so we are clear, you are referring to a “clause” in contracts similar to this one found in one of the many provincial “standing offers”....correct? DETERMINATIONOFHELICOPTERFLIGHTTIME (A) Except as provided in subsection (B), the hours and minutes for which a charge is made shall be computed from the time the helicopter commences hovering or taxiing before take-off until it ceases to hover or taxi after landing. All times shown on Saskatchewan Daily Flight Reports and invoiced for must also be recorded in the Aircraft Journey Log as flight time where defined and required in C.A.R.s. (B) When operations involve a continuous succession of flights each of less than ten minutes duration, and the engine is not shut down between such flights, flying time shall be computed from the time the helicopter commences to hover or to taxi for the first flight until the helicopter ceases to hover or taxi after the final landing. All times shown on Saskatchewan Daily Flight Sheets, and invoiced for, must also be recorded in the Aircraft Journey Log as flight time as defined in C.A.R.s. And you have no concerns if the pilot is overstating his air time (from a safety standpoint)....correct?
  4. Dec 2117 reply to POI: I understand that is TCs position, but both the Canadian Aviation Regulations and the Canada Labour Code are meant to be interpreted in plain language and they contain the exact same words and phraseology. I’m no lawyer, but I suspect that based on basic rules of interpretation, it is not reasonable for TC to suggest they have 2 different meanings. FYI: I will likely be including the definition of CLC definition of “in-operation” in the COM amendment that I submit to you for approval. Our current intention is to advise pilots that TC AOHS jurisdiction applies to “in-operation”. It will also advise to bill clients and pays pilots based on the time the aircraft is “in operation”, as per TC AOH and ESDC’s interpretation. I envision an amendment something like this: “air time” - means, with respect to keeping technical records, the time from the moment an aircraft leaves the surface until it comes into contact with the surface at the next point of landing; (temps dans les airs) "flight time" - means the time from the moment an aircraft first moves under its own power for the purpose of taking off until the moment it comes to rest at the end of the flight; (temps de vol) “in operation” An aircraft is defined as being "in operation" from the time it first moves under its own power for the purpose of taking off in Canada, until it comes to rest at a destination in Canada Note: “Air time” and “Flight time” are interpreted to be the same in skid equipped helicopters, this applies to all skid equipped helicopter operations. Therefore there should be no difference in values entered in the Journey Log Book air time column from those entered into Flight and Duty Records, Pilot Training Records (CAR Subpart 7 operations) and Pilot Training Records (PTRs – CAR Subpart 4 operations) or any other regulatory requirement to record “Flight Time”. Air time and Flight Time are the time spent in the air only. Any time that the aircraft is in contact with the supporting surface, shall not recorded as Flight Time or Air Time. A helicopter is considered to be “in-operation”the entire time its engines are running and blades are turning, for the purposes of taking off. Pilots should enter this figure in the “OPS Time” Column in the Journey Logbook, Flight Reports and Pilot Time sheets. Transport Canada Aviation Occupational Health and Safety Regulations apply the entire time the aircraft is in operation. Transport Canada Occupational Health and Safety Program has jurisdiction throughout this time “in operation”. Sorry, but this doesn’t pass the sniff test to me. TC guidance says it does, however. To the point: either TCCA is interpreting Flight Tine in the CARS incorrectly Or TC AOHS & ESDC Labour program is interpreting “in operation” incorrectly in the Canada Labour Code It’s that simple. Unless someone would like to try and debate that these definitions are different in some way, this is undeniable. I’ve cc’d the TC AOHS inspectors. We will also be taking this up with our ESDC Labour program rep.
  5. December 20/17 email to TC Ontario Region POI “I’ve been discussing your “Flight Time” interpretation/compliance e-mail with some of my pilots and they’ve brought up some valid points as far as implementation. At their request, I am sending you this e-mail. As their liaison to TC, I look forward to providing them with clarity. As you are aware we employ pilots who live and work in several regions from coast to coast. As is quite common in our industry, some of these pilots work for several companies over the course of a year. Some of these pilots have been advised by other companies to interpret Flight Time differently from what you advised in their recent email interpretation. This is no surprise, as your e-mail was only distributed to 7 air operators in Ontario, and we know that other TC regions and inspectors have not been adhering to the interpretation established in Ottawa. These pilots are required to provide air operators with 700.15 Flight Records for ALL flying (including their Flight Times from other companies). Unfortunately, if these times are not logged consistently from one operator to the next, then we know the records are not accurate. The only way for these pilots to provide air operators with accurate records for all flying would be to keep multiple (differing) sets of records to supply to each employer. Aside from being ridiculous, this clearly is not efficient and could be seen as suspicious. These pilots are concerned about these inconsistent company directives could lead to someone questioning their records after an accident. The other comment from pilots is that, as PIC, it is their responsibility to ensure accurate entry of Flight Time into the records you are discussing, not the company’s. This, I agree with, and it has been reiterated in a recent Occupational Health and Safety Tribunal (Black sheep Aviation). This interpretation needs to be directed to all pilots, not air operators. So, given these 2 issues, how do you suppose I deal with future non-compliances (with your e-mail interpretation) when they inevitably occur. After we distribute your interpretation to pilots, and future findings are made on pilot records, do I contact enforcement? We really don’t feel that an e-mail, from 1 inspector, to 7 Air Operators in Ontario, will correct the well-known ”disparity” that is the “Root Cause” of these types of findings. We also might not be comfortable taking punitive action (such as loss of “Performance Pay”). Particularly with the current conflict between TCCAs interpretation of Flight time and the ESDC Labour Program interpretation of “in operation” in the Canada Labour Code. Until there is advisory material at the National level, and an obligation on the part of inspectors and regions to adhere to policy that is established in Ottawa, there is unlikely to be any resolution of this problem. I know you said to give you a call, but I require a reply in writing. If you would like to discuss, I’m available.” Dec 21/17 reply: “I only sent out my email to the air operators for which I am the POI, other POIs have or will soon do the same. It is the attached letter and email from Deborah Martin, Chief of Commercial Flight Standards that clarifies the interpretation nationally. As it is a shared responsibility of the air operator and the air crew to maintain accurate records of Flight Time, it is expected that this information would be transferred from the air operator to the air crew through training, Company Operations Manual amendment and any other method of information dissemination that the air operator may have in place.” “The AOSH interpretation of “in operation” is in regards to AOSH regulations for AOSH purposes and cannot be transferred to the CARs to alter the definition of Flight Time”
  6. Not much to debate there Doesn’t seem to have much of of an effect on the flow of out of province helicopters into Ontario Precisely why it’s Federal Jurisdiction
  7. Our regional TC authorities raised concerns that a letter published in June 2015 by Airbus and provided to operators could not “override the AS350 B2 Manual (which had not been amended). They were also not aware that several operators had resumed Class C(In several regions including their own). Airbus advised the letter was meant to “clarify” statements in the FM.,not override. The B2 Manual was officially approved Nov 29/17 and is currently being distributed. Even with the amendment, our inspectors advised that the wording was vague and raised concerns that the AS350 not certified for class C.They sought clarification from standards and certification branches of TC The following e-mail was sent to our inspectors Dec 18/17; it wa forwarded to us the same day I was in Illinois all last week and out of the loop (no laptop carriage to the States due to new TC policy). I am sorry I didn’t know about the Class C issue. As mentioned below, we had an accident with an AS 350B2 with a Class C load in 2015 and TSB subsequently raised an issue with TC concerning the AS 350 RFM external load supplement wording in their Recommendations and Safety Action. I just spoke to Andy Stirzaker who will be in a telecon this morning with Airbus Helicopters. The letter from Airbus dated 18 June 2015 (attached) makes it clear that Class C loads can be carried legally on the AS350. Airbus was supposed to make changes to the text in the RFM and the cockpit stickers. It doesn’t appear that has been accomplished. Andy’s call will be to see the status of the paperwork and to light a fire under AB if necessary. In the meantime, based on the previously issued AB letter, you can tell “the company” that Class C loads are approved for the AS350. If there is any progress on the RFM wording, we will pass that along to you as well. Best regards: Rob Rob Freeman Program Manager, Aerial Work, Air Taxi and Commuter Operations Commercial Flight Standards Transport Canada / Transports Canada 330 Sparks Street,Tower C Ottawa, Ontario K1A 0N5 Tel: 1-613-990 1017 Fax: 1-613-990 -6215 robert.freeman@tc.gc.ca
  8. At least 1 TC Ontario inspector disagrees. This was sent out to 7 Ontario Helicopter operators last week: Gentlemen Please see the email chain below and the attached official interpretation of “air time” versus “flight time” for skid equipped helicopters. To the point, air time and flight time are interpreted to be the same in skid equipped helicopters, this applies to all skid equipped helicopter operations. Therefore there should be no difference in values entered in the Journey Log Book air time column from those entered into Flight and Duty Records, Pilot Training Records (CAR Subpart 7 operations) and Pilot Training Records (PTRs – CAR Subpart 4 operations) or any other regulatory requirement to record “Flight Time”. Please comply with this interpretation from receipt of this email if you have not already done so.
  9. A bad system will beat a good person every time.
  10. It is a good read. I’ve reviewed it extensively. You mean the one that says: “Findings as to risk: If approved flight manual supplements are not complete and clear, there is a risk that operators will unknowingly conduct operations that are not approved.” 2.5 Year’s later and TCCA still isn’t clear what the Flight Manual Supppement means. Good thing we cleared that up. LOL SAFETY FIRST!
  11. I’m aware. But the question still remains: are there any operators currently approved. The B3 manual and B2 VEMD manual have been amended; B2, BA and D model haven’t. airbus claims they received approval for B2 November 24 in the form of a letter from TC Certification, but TCCA says they haven’t and the Airbus revision status on their website does not show this amendment as approved. Even with the amendment, there seems to be some confusion with TCCA as to whether the aircraft is certified for class c. Our TCCA authorities are unclear as to what “approval from the responsible authority in accordance with the applicable operational regulations.” Means.
  12. Is there anyone in Canada currently approved for conducting Class C / pulling line in an AS350? either on the hook, or using Mack-pull or other optional equipment....
  13. The MNR might want to confirm their pilots meet the minimum contract requirements for flight time. In this case at least, it appears that might not have been happening.
  14. Maybe someone should let BC region know. Despite being advised by HQ that the Flight Time = Air Time interpretation has been distributed Nationally through the TC Natiinal Aviation Safety Information Management System (for years), I don’t think they got the message: https://www.canlii.org/en/bc/bcsc/doc/2016/2016bcsc2214/2016bcsc2214.html?searchUrlHash=AAAAAQCO4oCcYWlycGxhbmXigJ0gT1Ig4oCcYWlybGluZeKAnSBvciDigJxoZWxpY29wdGVy4oCdIE9SIOKAnEF2aWF0aW9u4oCdIE9SIOKAnGFpcmNyYWZ04oCdIE9SIOKAnGFpcndheeKAnSBPUiDigJxhaXJwb3J04oCdIE9SIOKAnGFpciBzZXJ2aWNlc-KAnQAAAAAB Maybe the Suoreme Court of BC judge would appreciate being advised that it appears his ruling might be flawed; it seems he based it on erroneous information and interpretation of the law provided by TC regional authorities. Interesting that this case involves a BC operator to sending a pilot to conduct and Ontario MNR contract. Again regional disparity rear’s it’s ugly Head and Safety is reduced.