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Fred Lewis

Flight Duty Time Limitations In Other Jurisdictions

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I was just pointing out that the linked report was far from current. I suspect that the same situation exists today. I've now spent some time looking for more current information on the status of this, and not having much luck. It's downright painful, actually. I would be more than happy to make my opinion known to the people that matter, but can't seem to find out who that would be.

 

These regulatory changes are going to directly affect me, and many others, pilots and operators both. Yet the first I heard of them was here, while infrequently lurking. Finding out more information outside of this site has been not very successful. Perhaps if there was a more transparent rule changing system, and maybe some way of making our opinions known, there would be more involvement from the rank and file, the people who are going to have to deal with these changes on a day to day basis.

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I was also completely unaware of the proposed changes taking place in regards to FDT. Maybe I'm living under a rock (or in camp) but I do think it's pretty important because if changes are made they WILL affect all of us. It's clear we need some kind voice and HAC may be doing a great job attempting to do that but let's face it, working against some of the biggest unions in the country like ACPA isn't going to be easy if that is in fact the challenge. So a broader unified voice could go a long way.

 

There's been some good debate about whether the changes are good for us or not but I think many of us are nervous about expressing our opinions here. I believe to have an effect, as a group, the helicopter industry needs to keep expressing our concerns, and the more people involved the better. Maybe the site organizers could set up a yes or no poll on the site to test the waters as to what a larger scope of the industry need. Obviously the issue is deeper than that and internet polls are flawed but this could be a good way to get the ball rolling.

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I was also completely unaware of the proposed changes taking place in regards to FDT. Maybe I'm living under a rock (or in camp) but I do think it's pretty important because if changes are made they WILL affect all of us. It's clear we need some kind voice and HAC may be doing a great job attempting to do that but let's face it, working against some of the biggest unions in the country like ACPA isn't going to be easy if that is in fact the challenge. So a broader unified voice could go a long way.

 

There's been some good debate about whether the changes are good for us or not but I think many of us are nervous about expressing our opinions here. I believe to have an effect, as a group, the helicopter industry needs to keep expressing our concerns, and the more people involved the better. Maybe the site organizers could set up a yes or no poll on the site to test the waters as to what a larger scope of the industry need. Obviously the issue is deeper than that and internet polls are flawed but this could be a good way to get the ball rolling.

 

Jamhands I think you're onto something. If HAC needs some ammunition directly from pilots a relatively simple poll may help them. However it would have to be validated so this anonymous site would not facilitate it. The HAC site could conduct a credible electronic poll if pilots were prepared to identify themselves by license number. The cautions to this avenue will include the fact that it will not "be" through a unified voice but could ultimately "result" with a majority opinion which may stand as a unified position. Pilots will have to 1) take part willingly and 2) be prepared to live with the outcomes. The questions would have to be formulated carefully.

It would be interesting to hear HAC's thoughts...

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An interesting document on this topic is published by HAC is their Oil & Gas Land Exploration Best Practices and is viewable on their website. The FDT limits, detailed in chapter 9, are less onerous than those stipulated in the CAR.

 

On HAC’s home page this statement is made:

 

“The airlines and their unions have been discussing 28-day Duty Hour limits of 190 to 200 hours and 60-65 Duty Hours in seven days and 100-130 Duty Hours in 14 days. HAC will have nothing to do with this discussion. No consideration has been given to remote, seasonal or extended daylight Northern Operations. Imagine, flying two hours each day in a series of 7, 9, or 14 consecutive 14-hour duty days, and then explaining to your customer that the regulations say you are too fatigued to fly.”

 

The Best Practices document seems to be at odds with this as in fact some consideration has been given by HAC to “remote, seasonal or extended daylight Northern Operations.”. Perhaps HAC can clarify this apparent contradiction.

 

It may be the case that while HAC resists the legislation of stricter FTD rules they do recognize that some helicopter operations are much more demanding than others and allowance must be made for this. It is likely that the considerable input of the ever-increasingly safety conscious oil and gas sector had a great deal to do with it. This would be a case of customer-driven safety initiatives. It should be the other way around. Helicopter operators, or better yet TC, should be the ones driving helicopter safety. Never the less, the FTD suggestions made in the HAC O & G best practices document is a welcome step in the right direction.

 

Another aspect of the best practices document demanding comment is the risk matrix detailed on page 47. While risk matrices may be a tool for stimulating discussion of safety issues, they are useless for determining risk in any kind of rational, quantitative way. It is guaranteed that insurance companies, who must accurately determine probability in a strict statistical way, will have nothing to do with these matrices. For those who are prepared to endure a bit of arithmetic, a piece entitled Risk in Aviation is attached.

 

Hi Fred, if I may respond to a couple of your points:

 

1. The HAC Best Practice for Land Based Exploration is a draft version that has been presented to the Board for comment and (if found acceptable) endorsement. That document's history is fairly long but many probably don't know it so I'll attempt to elucidate.

 

It began with the OGP (Oil and Gas Producers, an international association that all the major oil companies and most of the smaller ones belong to) attempt to regulate how activity in any field to do with Oil and Gas, mixed with aviation, is conducted anywhere in the world. The HAC Best Practice (BP) began as the OGP document known as 351. The OGP way of naming documents with numbers like that mystifies me but that's what they do. The OGP, in collaboration with some Operators who are vendors to the Oil and Gas industry, decided to take OGP 351 and make it into a Canadian BP.

 

This approach was very problematic because OGP 351 was written from the perspective of project management. So that an oil company representative, who may know nothing about aviation, could open the document and go about setting up an operation anywhere he might be in the world. It is a very prescriptive document and relies for most of its rules on JARs. 1 day off in 7, only 5 hours a day longlining, etc, etc. The Canadian version sought to reverse the perspective of the document and re-write it from the point of view of an Operator, while eliminating most of the anachronisms and making it workable across the broader Canadian industry.

 

For the last 3 years the Oil and Gas Committee of the HAC has met a couple of times a year to try and hammer out something workable. Most of the Canadian oil companies had representatives attend and the OGP was over-represented in my opinion. The original document was very heavily biased towards twin engine, two pilot, hugely reduced FDT limits, weather minima well beyond CARs, etc. The opening page of the document had the following statement (from memory), "Studies have shown that 20% of seismic accidents could have been prevented with the addition of a 2nd pilot into the cockpit". Well... Maybe... None of us that have flown many thousands of hours doing seismic had any idea what they could possibly be referring to but the latest version of OGP 351 is now called OGP 420 and that interesting and highly debatable statement has gone missing. I think they may have gotten tired of me bringing it up every time I saw anyone from the OGP anywhere.

 

Anyway, the HAC board is holding off on doing anything with the document right at the moment because the Board of the CAGC (Canadian Association of Geophysical Contractors) is reviewing it and intends to comment on it to the HAC Board. The CAGC represents the client base that helicopters serve when doing sesimic work in Canada, so there is little point in producing a document that won't actually be adhered to because it isn't workable.

 

Which brings me to one of your points.

 

2. You say above that customer-driven safety initiatives are the reverse of how it should be, which I tend to agree with, but this is the norm in reality. The fact is that if it's legal to do and a client is willing to pay, somebody is going to do it. If clients can be educated about what SHOULD be done, as opposed to what COULD be done, safety will triumph.

 

I'd like to provide an example from some initiatives of the HAC Oil and Gas Committee:

 

A Bell 205 is certified to fly 14 passengers with a single pilot. In the US there is a differentiation under the FARs with regard to whether you have 9 passengers or less, or 10 passengers or more. In Canada there is no such way to do things so any 205 in Canada that is operating under 702 or 703 can fly 14 passengers. I think we can safely say that the 205 is a pretty safe airctraft with over 40 year's worth of service to prove it. Unlike the AW139 but that's for a different thread - one on the hubris of aviation advisors that run around going on about some machine being the safest aircraft in the world before the **** thing's even flown! But I digress.

 

In Ontario they have taken the initiative to stop using the sideways facing seats in the 205 and to only haul 10 passengers with the machine (if anything I say is incorrect somebody let me know). I think this is a great initiative. I have spoken to several of the other Province's aviation people and have found widespread support for adopting the same rules. Perhaps some are doing it as well. The HAC Oil and Gas committee is really pushing the same rules with the seismic clients. The reason why you need to drive this from the client side is simple. If I have a 205 available and a client wants to put 14 people in it and go fly around in the mountains, and the charts and limitations allow it then we're going to do it. Because if we don't then someone else is going to. This is an irrefutable fact. An individual operator will not refuse to do a legal job because of a perceived increase in safety to do otherwise. Furthermore, except in extreme circumstances you will not get Operators to stand together and provide a united front to the clients, who simply want to do what they've always done. The only way to drive change like this is to have client buy-in. When the clients all say "a 205 will only haul 9 or 10 passengers" then the playing field is level and no Operator can compete unfairly by hauling more than anyone else. So the HAC O & G committe is taking that approach on this issue and a host of others with a great deal of success.

 

3. Your comment about the risk matrix is debatable but I do tend to agree. The one that is currently in the draft version of the BP came from one of the oil companies. In fact we're producing a new one as we speak that will (hopefully) provide a much better framework for assessing risk than any others we have seen. We actually have a few guys with letters after their names, who also fly helicopters, working on these initiatives so it's not just a bunch of dumb pilots expressing their opinions.

 

Anyway, I hope this helps. I can provide a lot more info to anyone that wants it but I'm a two fingered typist so it's not that easy to do so in print.

 

HV

 

P.S. I liked your earlier statement about two Freds being better than one. I think two HVs are better than one too.. But I bet most of my friends would be lacking in support on such an initiative!

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Are you serious that d - a - m - n, in this day and age, is a swear word and needs to be edited??? Come off it. Use reason please...

 

HV

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Well, it's Sunday and I can't find my Farraday Cage suit, therefore I won't risk stepping into a church anywhere so have a few minutes of spare time.

 

Speaking of risk, I see that 10 people have downloaded the document that Fred linked in his post of May 5th. It's an interesting read and more or less in line with what the HAC Oil and Gas Committee is trying to do, if only a tiny part of it.

 

I need to make one comment:

 

The calculation of incident rates or anything else to do with operating of an aircraft by 100,000 flight hours, or 1,000,000 flight hours, as the OGP does, is an invalid metric. It has been standard for so long that no one ever seems to question it but just a few questions around where it came from and why it's in use show that a new method needs to be found.

 

If you want to calculate the failure rate of a turbine engine, then the number of hours in operation is a good place to start. If you let one run in a steady state and change the oil on a regular cycle, they will last for a very long time. Of course aviation engines do not run at a steady state all the time so cycles of acceleration and deceleration, plus heating and cooling, need to be factored in.

 

When an engine is certified for aviation applications the failure rate is calculated and then expressed as so many per 100,000 hours, or so many per (varies) cycles. It's more complicated than that but in a nutshell that's what happens. So obviously it's natural to calculate the "failure rate", which is what we're trying to do with incident and accident rates, of the operating aircraft by the same metric right? I would have to say this is wrong.

 

What this approach fails to consider, especially when comparing helicopter statistics with the airlines or other aviation activities, is the actual exposure to risk that arises from the "mission" being conducted. NTSB airline dats shows that roughly 80% of all accidents occur during landing or taking off (landing by far is the most dangerous normal activity for any aircraft statistically), which comprises well under 50% of the total time in the air. So it doesn't take rocket science to see that the safest aircraft by far are long haul, trans-oceanic airliners (unless you're on one that forgets to fuel up before departure - sorry Air Transat). Is this because of their procedures? Their training? Their two-pilot cockpits? Their snazzy uniforms? The 6 days a month they work for twice what any of us get paid annually? No, it isn't.

 

If you want to be as safe as possible in an aircraft you have to try and not land very often.

Well, since that isn't doable in our business let's talk about what we face. Helicopters are shortfield aircraft. We are providing services where airplanes generally don't go except to bring passengers to a central location for disbursement. We land in places that no one ever landed before. We face weather conditions that vary from mile to mile with no reliable forecast other than one's eyes and experience. And how often do we face the awful risk of landing? Well, a lot to be honest.

 

Take off and landing are the riskiest things we do because often we hit things we don't see, but also because other things that happen, if they happened in cruise flight, could be dealt with. There is precious little time to even compose the first line of a haiku when something, anything occurs out of the ordinary when a machine is close to the ground.

 

What about longlining? You pick up a load out of the trees and take it somewhere hanging 150' below you and insert it in the trees again. Often your skids are barely above the trees. In seismic, when you run an automatic bagrunner, you are maneuvering a helicopter in order to maneuver a toboggan sized contraption on the ground, which takes very exaggerated movements of the helicopter to effect the appropriate response from the ground based device, further amplified by the intense concentration it can take to perform this task. We won't even get into how much time is spent in the centre of the shaded area of the H/V curve (Height Velocity, not Harmonic_Vibe - I have no curve named after me... yet).

 

There is general agreement amongst all stakeholders that landing and takeoff (Ground-Air-Ground or GAG) are the most dangerous phases of flight, but we believe that the type of work you're doing when performing vertical reference (drill moves, seismic, bucketing, etc) also need to be factored in if you want to measure safety.

 

The HAC Oil and Gas Committee has coined the term "Ground Proximity Events" or GPEs to aid in calculations. At least we think we coined it. Maybe somebody said it in one meeting and we just thought we invented it. So apologies if we're stealing somebody's terminology.

 

Anyway, most helicopter types require the recording of landings AND lifts in the journey logbooks so there is data available to properly measure the exposure when conducting various operations. We (the committee) looked at a sample of over 50,000 hrs, spread over various types, and calculated the GPE's and GAG's to give us a comparative factor. A rough number, at least for that sample size, is 12 GAG's/GPE's per hour. If a helicopter was simply moving slashing crews it would have GAG's of around 6-7 per hour, a Bell Medium moving heli-portable seismic drills would have GAG's of about 1 per hour but GPE's of perhaps 20 per hour.

 

I don't want to bore anyone so the point is that an airliner that may have 1 GAG per 6 hrs flown, will look pretty DARN good (will darn get edited too I wonder?) on paper compared to a Bell 205 moving seismic drills at 20+ GPE's per hour, when a rate per 100,000 flight hours is used to assign the likelihood of an accident.

 

Where we need to go from here is to formalize and establish proper metrics for aviation incident rates. I advocate the GAG/GPE system. Then, when properly applied we will be able to see where the real risk lies and can focus on those areas. We must eliminate the current trend towards applying fixes across mission types. Oil company advisors will say that the North Sea accident rate is so much better than land based exploration (which is debatable if using the GAG/GPE system to calculate rates but is true when using the per 100,000 hrs system) so we need to do what they do in the North Sea to ge the rate down. That's where they then use logical fallacies and mistake correlation with causation, and you end up with satements about 2 pilots and 2 engines and IFR training to fly in the mountains in winter. It's a well-intentioned but WRONG approach.

 

I hear bells so it must be safe to go outside now...

 

HV

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HV thanks for the comprehensive discussion. Agree the GPE system would be innaccurate across a number of mission profiles within our VFR industry. Particularly repetitive lift long-line work including firefighting. A realistic matrix would have to recognize the exposure periods where an extra engine and pilot would equate to additional weight at the point of impact. (and no the world is not about to go CAT A for all external load work)

 

But it does bring out a devil's advocate question regarding your earlier statement:

 

"The reason why you need to drive this from the client side is simple. If I have a 205 available and a client wants to put 14 people in it and go fly around in the mountains, and the charts and limitations allow it then we're going to do it. Because if we don't then someone else is going to. This is an irrefutable fact. An individual operator will not refuse to do a legal job because of a perceived increase in safety to do otherwise. Furthermore, except in extreme circumstances you will not get Operators to stand together and provide a united front to the clients, who simply want to do what they've always done. The only way to drive change like this is to have client buy-in. When the clients all say "a 205 will only haul 9 or 10 passengers" then the playing field is level and no Operator can compete unfairly by hauling more than anyone else."

 

So if the aircraft is being flown within its charts and performance envelopes legally why would a client or an operator driven reduction get any traction? Why should it? If the answer is to provide a broader safety margin I could get on side. But how could we make that a BP while we are still prepared to spend day in and day out in "your" (you deserve to take ownership!) shaded HV curve? Also what is the magic number...10% below gross? 15%? but the biggest question we would face is will this be applied completely across the board of all mission profiles?

 

As I said I am fully respecting the discussions and insights you are providing and I am hoping to maybe broaden the thought process with an eye to some well based resolutions. We just need to be cognisant of the big picture of consistency and how that will be perceived by a customer or operator driven decision.

 

Thanks HV....great stuff

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But it does bring out a devil's advocate question regarding your earlier statement:

 

"The reason why you need to drive this from the client side is simple. If I have a 205 available and a client wants to put 14 people in it and go fly around in the mountains, and the charts and limitations allow it then we're going to do it. Because if we don't then someone else is going to. ... The only way to drive change like this is to have client buy-in. When the clients all say "a 205 will only haul 9 or 10 passengers" then the playing field is level and no Operator can compete unfairly by hauling more than anyone else."

 

So if the aircraft is being flown within its charts and performance envelopes legally why would a client or an operator driven reduction get any traction? Why should it? If the answer is to provide a broader safety margin I could get on side. But how could we make that a BP while we are still prepared to spend day in and day out in "your" (you deserve to take ownership!) shaded HV curve? Also what is the magic number...10% below gross? 15%? but the biggest question we would face is will this be applied completely across the board of all mission profiles?

 

As I said I am fully respecting the discussions and insights you are providing and I am hoping to maybe broaden the thought process with an eye to some well based resolutions. We just need to be cognisant of the big picture of consistency and how that will be perceived by a customer or operator driven decision.

 

Thanks HV....great stuff

I’m glad you asked!

 

The whole point of approaching clients and having them agree that load reduction is a positive step is to prevent unfair competition based on inconsistent standards.

 

If I tell a client that my 205 is only going to fly 10 passengers because a single engine aircraft, in the event of an engine failure, is much safer with more margin between what it “could” carry and what it “will” carry, and you tell them that your 205 can carry 14 passengers and is legal to do so, then we have both told the truth and the client is left to decide what he’d like to do.

 

If no clients are willing to pay more per person (the result of load reduction) for the helicopter, then soon the company that is trying to be safer is out of business.

 

However, if we can convince the broad spectrum of clients that this initiative is positive and will greatly increase safety while reducing risk, we all win.

 

When an Operator tells a client that he can save them money by hauling more than anyone else and the client turns that around into removing that operator from their approved list, we all win.

 

We are free to compete at the level of service, but on a level playing field, when some initiatives that will certainly make things safer are considered.

 

As for the number for load reduction you inquired about, whether 10 or 15% or? This is confusing I think. You see 10% in some client standards and I have even seen 15%, but 10 or 15% of what? Hook weight? Gross weight? Ambiguity reigns! And I only like ambiguity in certain Thai bars… but I digress!

 

Personally, I think there should be no reduction for jettisonable external loads, but I would like to see 10% of payload (HOGE weight – Empty weight = payload) reduced for internal loads. Power off performance is a large factor in aircraft certification and I would really like to see some more margin there. Rather than rushing towards twins as you read in so many publications.

 

My 10%

 

HV

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