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Fred Lewis

Flight Duty Time Limitations In Other Jurisdictions

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Attached are excerpts from the Official Journal of the European Union, HAC’s submission to the Co-Chairs of the Fatigue Working Group, British Rules, New Zealand Rules, Indian Rules, Australian Rules, and rules from an unknown source regarding Flight Duty Time Regulations.

 

HAC’s submission raises arguments that demand comment. It uses the word ‘plenary’, defined as the part of a conference when all members of all parties are in attendance, several times. Unfortunately, pilots involved in unscheduled VFR operations, which includes helicopter pilots, are not represented. This is a significant group whose voice will not be officially heard during these discussions. Had HEPAC survived, helicopter pilots and engineers would have a seat at the table.

 

HAC declares that the present regulations need not be supported by science and yet they insist that any new regulations, if they are to be adopted, be so validated. The implication is that present regulations are not scientifically based and that HAC is struggling to grasp any straw that might retain the present FDTL structure.

 

HAC wants to pick and chose the science involved in this debate and use only science to decide. There are other realities that will help settle the issue. Two of these are existing FDTL regulations in other countries, movement of helicopter clientele towards safety management systems and common sense.

 

Examination of the attached FDTL in other countries shows that there are numerous other sets of rules that differ significantly from those Canadian. Some, if not all of these, are based on science. Pilots working in these other jurisdictions are physiologically identical to Canadians and fatigue science that applies to them applies equally to us. To declare that Canadians are somehow tougher than everyone else and can work longer hours and for more days than anyone else is a dangerous attitude.

 

Some helicopter clientele are requiring sub-trades to prove they are safety conscious by, for instance, complying with ISO 9001 standards. These sorts of companies will likely applaud any revision of the FDT rules as they are certain to question the ludicrous practice of pilots standing duty for 42 consecutive 14 hour days.

 

It is likely that the FAA will also change their FDT rules in the near future. When this happens in Canada, it will affect all operators in equal measure and the field will still be level in that regard.

FDTL in other.PDF

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Thanks for the info, Fred. Here are some of my concerns as a driver, errr, pilot:

 

Would it be fair to say that geographically and climatically Canada differs considerably from the countries whose regulations you've cited? The geographic isolation of many jobsites and the highly seasonal nature of work are important components of the Canadian helicopter work environment. While these factors don't change the fatigue performance characteristics of the basic homo sapiens ver. 1.0, I would argue that they are nonetheless important considerations for regulating our work.

 

How would it work on a drill job in Bathurst Inlet if the pilot had to take off 1 day every 7? Would it then be a 2 pilot job? So the pilots will make 1/2 the money and spend half their time sitting around? And will they then never go home during the summer because they: 1/ Can't afford it; 2/ Have so many days off that the operator and client won't see the value in some time at home? Are days spent sitting around a drill camp really "days off"?

 

What does the science say about overcoming cumulative stress? Surely sleep is not the only factor in recovering from a period of work? Reduced income and additional time away from my family will considerably increase my stress, rendering me less able to fly safely.

 

How do you think the regulations can be shaped to consider these realities?

 

Thank you,

 

Dick Mitten, bush pilot

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The field may remain 'level,' Fred, but that doesn't mean operators will be as able to do business economically, let alone profitably.

 

If you don't think HAC, whose membership representation is predominantly comprised of pilots, can speak for us, why do you think some g.d. union could ever be more effective? Do you believe an association/union like any other, totally lacking in those who have had the moxie and the smarts to succeed in business, could more effectively represent the real interests of the industry?

 

Whatever your views about those thoughts, surely you can't believe that what amounts to forcing airline requirements on helicopter charter operators is senseless.

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The field may remain 'level,' Fred, but that doesn't mean operators will be as able to do business economically, let alone profitably.

 

If you don't think HAC, whose membership representation is predominantly comprised of pilots, can speak for us, why do you think some g.d. union could ever be more effective? Do you believe an association/union like any other, totally lacking in those who have had the moxie and the smarts to succeed in business, could more effectively represent the real interests of the industry?

 

Whatever your views about those thoughts, surely you can't believe that what amounts to forcing airline requirements on helicopter charter operators is senseless.

 

If the field remains "level", would that not be a cost to pass on to the client?

 

Ask yourself when the bank and insurance are charging you more fees, are you raising your own rates? "Yourself" could be the entire industry. I definetly don't know it all, so constructive feedback is welcome.

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If the field remains "level", would that not be a cost to pass on to the client?

 

Ask yourself when the bank and insurance are charging you more fees, are you raising your own rates? "Yourself" could be the entire industry. I definetly don't know it all, so constructive feedback is welcome.

To 'level' the playing field sounds like a fairly simple solution but other factors come into play when we all collectively 'raise the rates'. Many clients find using helicopters for work is a cost they can just barely justify. If our services become too costly, you will see customers using ATV's, airplanes, boats, snow machines, cranes, hiking boots and anything else you can imagine that we as an industry compete with.

UAV's will be our competition in the future. Mark my words.

If limiting duty times is going to change our accident rate in Canada, I'm curious how the change will be felt..less accidents or more. How can we maintain pilot currency and proficiency while reducing duty times?? More simulator time in Bathurst Inlet? Of all of the accidents in Canada, how many are truly fatigue related?

I'm with Grasshopper and dimit on this one.

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I am not taking any "sides" on this issue. All aspects though have to be looked at. Yes some clients may have to find alternate means to accomplish their tasks, but there is lots of work that require helicopters. The possibility of a FDT change is real and how are operators going to deal with it? Skullcap brought up some good points about this from his perspective as an operator, in another topic. Those costs need to be absorbed somewhere and most other industries bill it to the end user. Let the pro's and con's roll...

 

Regardless, i'd prefer more profit and less toil.

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Just my 2 cents...I worked overseas in an unnamed country,,,its pretty simple there,,equal time on/off,,,28 day tours in country,28 off,you travel on your own time. If you chose to live in country 1 day off in 7. The operators there seem to be able to survive...(might have something to do with not giving aircraft away for 2/3rds or less of the going rate) Maybe its time the Canadian operators started to rethink their business plans. I also should mention that the going rate is annual salary based, over $110,000.00 plus travel costs. So if they can do it there why not here. I thought it was great, the equal time portion, and the pay was good too. One was able to have a life. (I dont recall what the duty time was but I think it was 12 hrs, only part I had issue with was the long line restriction,,if you put a line on for as little as 15 min you were restricted to 6hrs total flight time per day.

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Attached are excerpts from the Official Journal of the European Union, HACs submission to the Co-Chairs of the Fatigue Working Group, British Rules, New Zealand Rules, Indian Rules, Australian Rules, and rules from an unknown source regarding Flight Duty Time Regulations.

 

HACs submission raises arguments that demand comment. It uses the word plenary, defined as the part of a conference when all members of all parties are in attendance, several times. Unfortunately, pilots involved in unscheduled VFR operations, which includes helicopter pilots, are not represented. This is a significant group whose voice will not be officially heard during these discussions. Had HEPAC survived, helicopter pilots and engineers would have a seat at the table.

 

HAC declares that the present regulations need not be supported by science and yet they insist that any new regulations, if they are to be adopted, be so validated. The implication is that present regulations are not scientifically based and that HAC is struggling to grasp any straw that might retain the present FDTL structure.

 

HAC wants to pick and chose the science involved in this debate and use only science to decide. There are other realities that will help settle the issue. Two of these are existing FDTL regulations in other countries, movement of helicopter clientele towards safety management systems and common sense.

 

Examination of the attached FDTL in other countries shows that there are numerous other sets of rules that differ significantly from those Canadian. Some, if not all of these, are based on science. Pilots working in these other jurisdictions are physiologically identical to Canadians and fatigue science that applies to them applies equally to us. To declare that Canadians are somehow tougher than everyone else and can work longer hours and for more days than anyone else is a dangerous attitude.

 

Some helicopter clientele are requiring sub-trades to prove they are safety conscious by, for instance, complying with ISO 9001 standards. These sorts of companies will likely applaud any revision of the FDT rules as they are certain to question the ludicrous practice of pilots standing duty for 42 consecutive 14 hour days.

 

It is likely that the FAA will also change their FDT rules in the near future. When this happens in Canada, it will affect all operators in equal measure and the field will still be level in that regard.

 

 

 

Fred

 

The harsh reality is that until the rank and file pilots and engineers have some form of representation we will continue to have no say in anything that pertains to our well being and future. To suggest that HAC represents our interests is disengenuous.

 

As far as the duty time hours are concerned even in countries in Africa the rules are much more restrictive. Here I can only fly 105 hrs per month and require 1 day off in 7.

 

Please also see:http://www.youtube.com/watch?v=tKQJx3L_CDQ Its what Walter says in his interview that hits home. If you add in the cost of living here in Canada we are not far off.

 

P5

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change is coming....like Hazy said we better prepare ourselves. This has been circulating from TC, just to share their opinion on this.

 

As way of introduction and for the purpose of this Sub Group discussion, I feel that you should be aware of Transport Canada’s concerns with regard to fatigue, flight and duty time, and the regulations as they apply to CAR 702 and 703 operations.

 

 

 

As you know, the current CARS were published in October 1996. In the months previous to that, there was a lot of pressure to complete the draft regulations to meet the proposed publishing date. We missed the first proposed date of June, 1996, and everything slipped to the second proposed date in October. Although many of the regs were still in a rough draft, we were denied any further delay. Management decided to release them anyway, with the intent to repair them at the subsequent CARAC meetings.

 

 

 

For the Flight and Duty Time deliberations, there were several working groups, much the same as today, for airline, commuter, air taxi and aerial work. Some of the deliberations were done in plenary sessions, and some in sub-groups. As now, the airlines were well-represented by management and unions. Also, as now, the 702 and 703 representatives were mostly industry and associations. There were few pilot representatives, and they were not always available on a regular basis, as they had to pay their own way.

 

 

 

Deliberations for these Sub Parts were mostly negotiations between the operators and their associations and Transport personnel. There was no science applied to the derived numbers. Simply put, the operators took the previous F&DT numbers, (from the old Air Regulations/ Air Navigation Orders) stated that they were not adequate, and more or less dictated the increased limits that we have today.

 

 

 

Although some of the TC representatives thought these numbers were excessive, we had no pilot representation to counter that argument. In the interest of getting something on paper for the CARS deadlines, the Operator / association numbers stood.

 

 

 

The one important point to remember is that the existing F&DT limits in 702/703 are not based on any science – only the perceived requirements of the operator as negotiated in 1994-96.

 

 

 

Fast forward to today. The F&DT limits for air taxi and aerial work are the most lenient in the CARS for all Sub Parts. That should raise some eyebrows. 702/703 aircraft, for the most part, are single pilot, single engine, with limited redundancy in systems. They are often flown at low level, in all weather, in remote areas, under pilot self dispatch, and in technically demanding roles, such as external load, fire fighting and so on. They work out of minimally prepared areas, and land and depart from confined areas, mountain peaks and other areas where many times, not even a windsock is available. Finally, many of these operations are conducted out of camps where creature comforts are minimal, where there are often numerous people sharing the sleeping facility, and constant noise and discomfort are part of the lifestyle. I know. I’ve lived in them all.

 

 

 

None of this would matter, I suppose, except that the overwhelming majority of the commercial aircraft accidents today occur in Sub Parts 702 and 703. It can be stated that fatigue has yet to be proven to be a factor, but common sense says that flying a technically challenging tasking, in a remote area, alone, for an extended period of time in a tent cannot be anything else but fatiguing.

 

 

 

In my time in the bush, I saw quite a number of pilots become “bushed” and act impulsively and foolishly. Some of them had tragic accidents. When I became Chief Pilot, I changed our rotation schedule to a maximum of four weeks from the traditional six, amongst other measures. It was a start, and we saw a reduction in incidents.

 

 

 

To sum up, we have to ensure that our operators are able to survive economically and any imposed limits are supportable and necessary. However, we also have to ensure the safety of our pilot community, and I don’t believe that the current limits provide adequate protection for them, for the reasons previously stated.

 

 

 

Given the current situation, and latest accident rates from the TSB, an argument could be made that 702 and 703 F&DT limits should be reduced below the airline numbers.

 

 

 

In my opinion, pilots are pilots and everyone suffers from fatigue . No one is immune.

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Change is coming,,,yeah probably but hopefully not in the method of the pendalum theory,,,you know, go to the opposite extreme then find a happy place.

 

Some of the comments are interesting, but find things sometimes are taken out of text, firstly I interpret that HAC would like to see scientific proof as to why there are changes required, and to provide scientific reasoning to institute new regulations,,,seems relevant to me.

 

To provide a couple of many different scenarios:

 

A medevac pilot assigned to a 14 hour duty day but flies 50 hours per year, this person will be staring at the clock and at hour 12 will probably start to be quite stressed that if a call comes in he may not have enough duty time to finish the call, hoping the crosshift will be there soon as there is an overlap. Too bad we weren't working 10 hour duty shifts so the overlap wasn't so critical...

 

A vfr pilot on fire standby who is assigned to sit a chip lakes strip from 10 am to 10 pm, dry, dusty,,,nothing to do, what a bore, nothing to stimulate your senses, hope there is a little action, least there is a smoke patrol,,,,duty day should be limited to 12 hours max so that do not have to be in this dry dump so long.

 

A vfr drill pilot who has moved his drillers and geos onsite at 7 am, slung a few loads to/from the drill then is fishing a lovely salmon filled stream, gone back to camp, cleaned the machine, had lunch, done some paperwork, picked the geos up, then goes out to switch out the drillers at 7 pm,,,maybe does a bit of fishing after that and machine is packed up. 14 hour duty day,,,no problem,,,can do that indefinatly.

 

So maybe different rules for different ops are necessary or perhaps some common sense is necessary. This is probably why foresty does have some more restrictive rules in some places and would wholeheartedly agree with the pilots in all the above scenerios as have lived them or watched them from across the hanger. I find that waiting for: weather, customers, fires, parts, are all part of waiting and as a pilot, waiting can be what you make it. Many people cannot handle waiting and they are the ones normally driving the stress levels higher. If you do not make yourself busy then it will be one long shift after another. I watched the complete crew changes of a medevac machine requiring two pilots and the two pilots who worked together the most and were the happiest were the ones I saw IN the hanger, cleaning, looking, talking to other pilots, the rest of the crew would come out to do a flight looking like something the cat drug in and about as happy.

 

But I digress, if a change is required hopefully it is sane and not as outlined by cumulative duty time.

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