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OGEgirl

Flight Time Vs. Air Time Personal Logbook

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I hear you concerns loud and clear. This is one of the reasons we chose to publish our communications in a public forum; If TC choses to handle the situation in this fashion then they will do so in the public eye. I would suggest, however, that such an approach would only make our case stronger. It’s unfortunate that some of “the old guard” at TC may still think this is an acceptable way to proceed; we realize this is a possibility.

 

The fact that you (as an integral stakeholder in the industry) fear increased punitive action, for merely reporting an issue and insisting on using every means possible to receive answers (within a reasonable timeframe), says a great deal about what kind of safety culture that actually exists within our industry and Transport Canada. I would argue, that this is exactly why these issues never get dealt with; fear of repercussion from TC is likely why stakeholders rarely report (and follow through with) such issues.

 

Your concern that we may receive increased punitive action due to our persistence and use of media also implies that we must be doing something wrong. Punishment is for those who are breaking the law. I like to think our organization is above board. Don’t get me wrong, we are not perfect, but we do not knowingly condone breaches of the regulations. It is possible that we may receive findings in the future; however, we have no issue with this, as long as they are legitimate. We will do everything we can to prevent recurrence (just as we have done in this case).

 

I would also like to point out that we received a letter dated July 7, 2010 from the Regional Manager of Enforcement that states: “I am pleased to advise you that your company is considered a “Transitioning Enterprise” by Transport Canada, Civil Aviation. When a “Transitioning Enterprise” allegedly commits a contravention that is not intentional, Transport Canada will allow the certificate holders the opportunity to determine, by themselves, proposed corrective measures to prevent recurrence of a contravention, as well as the best course of action to help foster future compliance.” As was stated previously, we have done everything TC has asked of us, yet they have been very uncooperative when it comes to actually implementing measures to prevent recurrence and foster compliance. I guess they should have added the statement… “unless of course the root cause is found to be within TC’s organization.”

 

Another possible reason stakeholder rarely report these issues, is the knowledge that a stakeholder will have to expend a great deal of time and effort reporting, and ensuring TC follows through on the report with suitable corrective actions. This in turn costs the stakeholder a great deal of money. Many operators, would prefer to move ahead with running their business as opposed to allotting countless man hours to push TC for a response, even if it means continuing to operate in contradiction to the CARs.

 

Under SMS, the identification and reporting of this issue should be viewed under a positive light, unfortunately we feel all the individuals that we have dealt with at TC have chosen to view our persistence to get the point across in a negative manner.

Unfortunately, this is counterproductive to the National objective of implementing SMS.

 

Apparently, we are not the only ones concerned with TC approach to safety management. On June 14, 2012, the Transportation Safety Board of Canada added Aviation Safety Management Systems their watch list:

 

“TRANSPORTATION SAFETY BOARD OF CANADA

Added to WATCH LIST June 14, 2012 – FACT SHEET

Air safety management systems

Transport Canada does not always provide effective oversight of aviation companies transitioning to safety management systems, while some companies are not even required to have one.

Background

Implemented properly, safety management systems (SMS) allow aviation companies on their own to identify hazards, manage risks, and develop and follow effective safety processes. Canada's large commercial carriers have been required to have an SMS since 2005. However, for smaller operators, such as those which do aerial work or provide air taxi or commuter services,1 implementation has been delayed to provide additional time to refine procedures, guidance material and training. Yet together, this group incurred 91 % of commercial aircraft accidents and 93 % of commercial fatalities from 2002 to 2011. Transport Canada (TC) indicates that SMS will be implemented in all regulated civil aviation organizations by 2015.

The transition to SMS has proved to be challenging. A 2008 report by the Auditor General of Canada highlighted gaps in TC’s planning and implementation as well as oversight of SMS operators. In addition, recent investigations by the Transportation Safety Board of Canada (TSB) have highlighted difficulties faced by operators in transitioning from traditional safety management to SMS.

Until SMS are more broadly implemented within the aviation industry, the TSB remains concerned regarding the risks to Canadians, and will continue to monitor progress in this area.”

 

Montreal Gazette Arcticle:

 

“The federal transport safety watchdog said Thursday she has seen "little or no change" in critical air-safety issues

The federal transport safety watchdog said Thursday she has seen "little or no change" in critical air-safety issues

Wendy Tadros, chairwoman of the Transportation Safety Board, first flagged these issues in 2010 when the board released its inaugural safety watchlist. They remain on this year's watchlist alongside a new issue highlighting Transport Canada's weak oversight of smaller aviation companies while they transition to safety-management systems (SMS), with "some companies not even required to have one," the report says.

Under SMS, companies are supposed to identify hazards, manage risks and develop and follow safety processes, while the regulator is charged with making sure the internal systems are being followed and are working.

"What's needed, what we're calling for today, is more action. We want a concerted effort — more of a concerted effort — from Transport Canada and from our marine, rail and aviation industries. At the end of the day, they're the people who can make the most difference, and so we want to them to take immediate steps to address both these new and persistent issues," Tadros told reporters.”

 

It seems to me that even the TSB is calling for operators (like ourselves) to do something about this issue. This is exactly what we are trying to do.

 

In my opinion, the biggest issue that TC faces with regards to SMS implementation is internal issues within their organization and a lack of commitment to SMS from senior management. This CAIRS demonstrates this fact tenfold. Just as it is a fact, that a successful SMS at an organization requires an Accountable Executive who demonstrates an active commitment to the system, as the regulatory authority for our industry, they too must demonstrate this same commitment. As someone who has been following this issue: Do you believe they are demonstrating this commitment (and leading by example)?

 

I’ll apologize in advance for the length of this post, but it needs to be said.

 

Listed below a several exerts from Transport Canada’s own Guidance Materials and documents. I invite you to review these documents in their entirety; in the meantime Consider CAIRS IB 8718 as a case study and evaluate TC’s approach to this issue (along with their performance and organizational culture).

 

• TP 14636 - Civil Aviation Issues Reporting System (CAIRS)

 

Transport Canada Civil Aviation Wants to Hear From You!

The Government of Canada aims to provide the highest quality of service to the public and is moving towards achieving this by modernizing government management…

To meet these commitments, Transport Canada Civil Aviation (TCCA) is implementing an Integrated Management System (IMS) to promote a well-performing public sector to serve Canadians. It is of note that the principles of IMS are similar to those of a Safety Management System (SMS); for example, an effective reporting culture is a necessary component of both Through the IMS, TCCA will address its long-standing priority of improving access to services and improving stakeholder satisfaction.

The CAIRS was launched on May 3, 2005 and made it possible for TCCA’s internal and external stakeholders to raise a wider range of issues (concerns, complaints, compliments or suggestions for improvement) with management. The key principles of the CAIRS are to foster a respectful work environment through the prevention, effective management and prompt resolution of issues at the lowest possible level in the organization; as well as to provide a basis for a reporting culture within the aviation industry. Such a reporting system creates a work environment where issues are seen as opportunities to continually improve the way TCCA does business.

 

The CAIRS provides the means to track issues, ensuring that no issue is left unattended. It is expected that all issues will be responded to in a timely manner. Service standards for addressing CAIRS issues have been established and provide a structured and consistent approach to all issues.

 

Receiving feedback on how services may be improved is far more important than assigning blame. Individuals are encouraged to use the CAIRS as it gives TCCA the opportunity to continually improve while responding to stakeholders and their needs.

 

• CAIRS – A Guide for the Public

 

A progressive organization wants its external stakeholders to raise issues (concerns, complaints or compliments) and suggest improvements to the way the organization operates. The organization can use this information to root out problems and improve how the organization functions.

Transport Canada - Civil Aviation has recognized the benefits of an issues reporting system. It has put in place the Civil Aviation Issues Reporting System (CAIRS) as a means for external stakeholders to raise and resolve issues at the lowest possible level before initiating a formal established redress mechanism.

 

• Civil Aviation Integrated Management System Standard (TP 14693)

 

“Organization” means the Civil Aviation Service Line of Transport Canada.

 

1.2 Applicability

The Civil Aviation Integrated Management System Standard (Figure 1) applies to all Civil Aviation personnel. All personnel have a measure of responsibility and accountability for ensuring that key processes fulfill their intended purpose.

 

5.1 Stakeholder Focus

The organization shall establish procedures for communicating with stakeholders. These procedures shall provide program information, response to inquiries and feedback from stakeholders.

The organization shall use stakeholder information to develop and monitor standards in its activity areas for the purpose of service improvement.

The organization shall promote a reporting culture through the establishment and maintenance of formal processes that encourage Civil Aviation personnel and persons external to Civil Aviation to proactively report issues and concerns.

 

• Advisory Circular (AC) 107-001

 

3.5 The Accountable Executive and Corporate Culture

1. For a SMS to be effective there has to be a champion; someone with the authority to commit the resources required to implement, maintain and take responsibility for the SMS.

2. An effective implementation strategy for SMS will involve changes in processes and procedures and will almost certainly involve a shift in the corporate culture. The safety culture of an organization is defined as “…the product of individual and group values, attitudes, perceptions, competencies and patterns of behaviour, that determine the commitment to, and the style and proficiency of, an organization's health and safety management.” Simply put, it is quite literally the way things are done. Every organization has a culture, good or bad, safe or unsafe, the corporate culture is reflected in the mode of operation throughout the organisation. Typically, the tone of the culture is established from the top down. If the accountable executive is committed to managing safety risks then the way that organization operates will reflect this philosophy.

3. Managing safety risks, however, involves more than a personal commitment to make safety one's primary obligation. It often requires an expenditure of capital and resources to achieve a safer operating environment. That's why the proposed amendments to the Canadian Aviation Regulations define the accountable executive as “…the person [who] has full control of the financial and human resources required for the operation's authorized to be conducted under the operations certificates”

4. In an SMS environment, the accountable executive and all senior managers are accountable for safety. The dedication and involvement of top management towards safety and safety practices should be clearly visible. It is important that senior management is seen to provide a strong and active leadership role in the SMS. This includes a commitment to provide the resources necessary to attain the strategic safety objectives established by the organization. The following is a list of activities that demonstrate top management’s active commitment to SMS, these include:

1. Putting safety matters on the agenda of meetings, from the Board level downwards;

2. Being actively involved in safety activities and reviews at both local and remote sites;

3. Allocating the necessary resources, such as time and money, to safety matters;

4. Receiving and acting on safety reports submitted by employees;

5. Promoting safety topics in publications, and (probably most important of all); and

6. Setting personal examples in day-to-day work to demonstrate unmistakably that the organization's commitment to safety is real and not merely lip-service, and by clearly and firmly discouraging any actions that could send a contrary message.

5. The ideal safety culture embodies a spirit of openness and demonstrates support for staff and the systems of work. Senior management should be accessible and dedicated to making the changes necessary to enhance safety. They should be available to discuss emerging trends and safety issues identified through the System. A positive safety culture reinforces the entire safety achievement of the organization and is critical to its success.

 

7.6.2 Corrective Action Plan

1.Once a safety event report has been investigated and analysed, or a hazard identified, a safety report outlining the occurrence, and if available, the results of a hazard assessment, should be given to the appropriate director for determination of corrective or preventative action. The functional director should develop a corrective action plan (CAP), a plan submitted in response to findings, outlining how the organization proposes to correct the deficiencies documented in the findings. Depending on the findings the CAP might include short-term and long-term corrective actions. As an example, TC's oversight documentation defines these in the following manner

 

1. Short-Term Corrective Action - This action corrects the specific issue specified in the audit finding and is preliminary to the long-term action that prevents recurrence of the problem. Short-term corrective action should be completed by the date/time specified in the corrective action plan.

 

2. Long-Term Corrective Action - Long-term corrective action has two components. The first component involves identifying the contributing factors of the problem and indicating the measures the responsible manager will take to prevent a recurrence. These measures should focus on a system change. The second component is a timetable for implementation of the long-term corrective action. Long-term corrective action should include a proposed completion date.

 

2.Some long-term corrective actions may require periods in excess of the organization's established acceptable timeframe, for example, where major equipment purchases are involved. Where applicable, the organization should include milestones or progress review points not exceeding the established timeframe leading up to the proposed completion date. Where the short-term corrective action taken meets the requirements for long-term corrective action, this should be stated in the long-term corrective action section on the corrective action form.

 

 

7.6.4 Information Dissemination

1. All safety related information should be disseminated throughout the organization. Keeping current on safety provides better background for understanding aspects of the organization's safety condition and developing novel solutions to difficult problems. This can be accomplished by subscribing to safety related programs, making relevant Transportation Safety Board (TSB) reports available, and encouraging staff to participate in safety related training, seminars and workshops. Manufacturers can also provide important safety information and reliability data related to the organization's specific needs.

 

2. Another aspect of information dissemination is feedback on safety reports submissions. Employees should be notified when a safety report is received or when a potential safety threat is discovered. Further information should be provided pursuant to investigation, analysis and corrective action. Information dissemination can also be achieved through the publication of a corporate magazine or through the organization's website. The organization should endeavour to inform all employees as to where safety related information can be found. In this way, the entire organization becomes aware of safety issues and understands that the organization is actively seeking to address these issues.

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Here's another document that was recently published by TC; it's from the Honourable Minister himself:

Minister Lebel issues statement about safety management systems

No. HS008/11

For release - November 21, 2011

 

OTTAWA — "The television segment 'Putting Airline Safety at Risk?' produced by Radio-Canada's Frédéric Zalac and aired on CBC's The National on November 9, and scheduled to air on Radio-Canada's Enquête on November 17, is misleading about Transport Canada's aviation safety oversight program.

 

"Transport Canada was the first civil aviation authority in the world to implement SMS, and now it is a global standard. The International Civil Aviation Organization has recognized Transport Canada as a world leader in safety management systems implementation.

 

"By implementing safety management system (SMS) regulations for commercial air carriers, Transport Canada is strengthening the safety culture of these organizations. SMS require that companies implement safety policies and procedures that identify potential safety problems, and deal with them before accidents happen. And, contrary to the claims made in this television segment, this process is in addition to Transport Canada's robust inspection activities for all sectors of the air transport industry.

 

"An effective safety management system empowers aviation companies to address aviation risks before they lead to incidents. This moves Canada from a responsive, top-down system where actions were taken in response to safety incidents, to a proactive system that aims to prevent accidents from happening in the first place.

 

"Through SMS, Transport Canada has also expanded its inspection activities, conducting more than 10,000 inspections a year on companies big and small. In fact, 70 per cent of the aviation safety budget is dedicated to inspections.

 

"SMS assessments and traditional inspections should not be thought of in isolation or as opposites. They are complementary parts of one of the safest aviation safety systems in the world — one of which we can all be confident.

 

"Transport Canada introduced the first set of SMS regulations in 2005, and we have seen a drop in the accident rate since that time. In 2009, the total number of accidents was the lowest recorded figure in 10 years. This evidence shows that we are doing the right thing.

 

"Captain Dan Adamus, president of the Air Line Pilots Association's Canada Board, said, 'SMS programs ensure continuing safety by combining the appropriate levels of incentive for front-line employee reporting, internal auditing and regulatory oversight.' He added that 'Canada is a world leader in adopting SMS programs and ALPA is proud to be part of that effort.'

 

"Our government is committed to continuing Canada's tradition as a leader in aviation safety. Canada has one of the safest aviation systems in the world, and Transport Canada is unswerving in its drive to further aviation safety by modernizing the way we do things."

 

Sincerely,

 

The Honourable Denis Lebel

Minister of Transport, Infrastructure and Communities

 

I am not sure what type of incentives for reporting he is discussing. Does anyone feel empowered as stakeholders?

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If Rotars are turning it's log able plain and simple............. otherwise stick a capable checked out Monkey at the controls. Us pilots just show up when it's time to pull some pitch!?!?!?!?!??!!? Give me a break!

 

I've always argued this...... how do think most Young Pilots starting out built their time........ Maintenance/ground runs....that's how...... breaking skids or not. I can almost guarantee every guy out there has these early hours logged.

 

Are there any engineers out there today in Canada that are checked out to do ground runs and their insurance company is aware of this? I new of one but it was a Military contract and insurance not required..... it's the Military..... they don't have insurance on anything.

 

Air time? Component time? TT straps on a BH06, brand new, Calendar date started. Now run the machine for 40 days and 40 nights hot fuelling it but never break skids. Any FT on those........?...... no,..... but?

 

Best

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If Rotars are turning it's log able plain and simple............. otherwise stick a capable checked out Monkey at the controls. Us pilots just show up when it's time to pull some pitch!?!?!?!?!??!!? Give me a break!

 

I've always argued this...... how do think most Young Pilots starting out built their time........ Maintenance/ground runs....that's how...... breaking skids or not. I can almost guarantee every guy out there has these early hours logged.

 

Are there any engineers out there today in Canada that are checked out to do ground runs and their insurance company is aware of this? I new of one but it was a Military contract and insurance not required..... it's the Military..... they don't have insurance on anything.

 

Air time? Component time? TT straps on a BH06, brand new, Calendar date started. Now run the machine for 40 days and 40 nights hot fuelling it but never break skids. Any FT on those........?...... no,..... but?

 

Best

I can't say I agree with your interpretation of the flight time definition from the CARS. The CARs definition states: "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;.Clearly ground runs without lift off would not be consired flight time as per the CARs definition. Would it?

 

But wait a second, what about the ICAO definition (which Transport Canada advised us to use from 2005 to 2011 in General Aviation Policy Letter 2005-02 )? Annex 1, Chapter 1of the ICAO convention sets out different definitions for airplanes and helicopters. "For helicopters, flight time is the Total Time from moment the helicopter's rotor blades start turning until the moment the helicopter finally comes to rest at the end of the flight, and the rotor blades are stopped". By this definition, I am not so sure that your interpretation (which calls ground runs Flight Time) is such a stretch.

 

I can say that your interpratation does not surprise me and it further demonstrates the confusion that exists industry wide. We have seen a wide variety of interpretations used throughout the industry (as demonstrated in the various posts on this forum).

 

Again I ask, what is the "root cause" of this confusion?

 

Something else that interests me in your comments is: "I've always argued this...". Do you mind if I ask who these arguments were with? Have you ever discussed this issue with TC? What level of TC did you bring this to? Your inspector? Headquarters? If so, What was the response you received? If the inspector was not able to answer your questions directly, did he take it to a higher level?

 

Has anyone reading this forum identified these issues in the past? Have you ever brought this issue of "interpretaing Flight Time" to any level of TC? If so, what type of response did you receive? Did you receive unnecessary delays in response? Resistance? Conflicting responses from different TC employees? If you did not receive an adequate response, why did you not continue to pursue the issue?

 

I'm pretty sure many stakeholders in our industry have been aware of this issue for many years. I am also sure many have discussed this with TC. So why has it taken this long to rectify?

 

The answers to these questions go directly to the larger concern I have identified in my recent posts. Organizational and Cultural Issues at TC. If they are truely promoting a reporting culture, whereby they see reporting of these issues as an opportunity to improve their organization (and our industry), why hasn't this issue been corrected?

 

I recieved my licence in 1996 (right around the time the CARs came out), as a student who was desparately trying to build hours, I wondered about the definition then. Espescially since the COM at my school said "Flight Time and Air Time are the same...". I have also read numerous magazine arcticles over the years that discuss this confusion. I don't think the issue with definition was a secret to anyone in our industry. When GAPL 2005-02 came out in 2005, I figured TC had finally identified this as an issue and were taking steps to rectify it. Somehow, the issue got completely dropped and no corrective actions were ever implemented. Here we are today 16 years later and many of us still aren't sure about how to log flight time. How did this happen???Root Cause???

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If Rotars are turning it's log able plain and simple............. otherwise stick a capable checked out Monkey at the controls. Us pilots just show up when it's time to pull some pitch!?!?!?!?!??!!? Give me a break!

 

Uh...if you're not getting paid a base salary and your flight pay is minimal, then you're probably not working for a legitimate company.

 

I've always argued this...... how do think most Young Pilots starting out built their time........ Maintenance/ground runs....that's how...... breaking skids or not. I can almost guarantee every guy out there has these early hours logged.

 

How much does it count towards a pilot's required 100 hrs for a licence? Why not just sit on the ground idling away to build up hours? Would save on training school costs and people wouldn't be going 40K into debt to get a licence.

 

Are there any engineers out there today in Canada that are checked out to do ground runs and their insurance company is aware of this? I new of one but it was a Military contract and insurance not required..... it's the Military..... they don't have insurance on anything.

 

That would be sweet. One person could get the pilot's flight pay and the AME's flight pay for the same ground run. It all counts as logable 'flight time', right?

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I can't say I agree with your interpretation of the flight time definition from the CARS. The CARs definition states: "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;.Clearly ground runs without lift off would not be consired flight time as per the CARs definition. Would it?

 

^^ Your bold...

 

But wait a second, what about the ICAO definition (which Transport Canada advised us to use from 2005 to 2011 in General Aviation Policy Letter 2005-02 )? Annex 1, Chapter 1of the ICAO convention sets out different definitions for airplanes and helicopters. "For helicopters, flight time is the Total Time from moment the helicopter's rotor blades start turning until the moment the helicopter finally comes to rest at the end of the flight, and the rotor blades are stopped". By this definition, I am not so sure that your interpretation (which calls ground runs Flight Time) is such a stretch.

 

^^ My bold...

 

I'm still not sure where the confusion arises. Both definitions are linked to the act of flight (which is ultimately what we are in the business off), so a ground run in which there was no actual take off would not be logged as flight time.

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^^ Your bold...

 

 

 

^^ My bold...

 

I'm still not sure where the confusion arises. Both definitions are linked to the act of flight (which is ultimately what we are in the business off), so a ground run in which there was no actual take off would not be logged as flight time.

 

While I agree with you that "a ground run in which there was no actual take-off would not be logged as flight time", it's obvious that "letitsnow" is confused. As to "where the confusion arises" is exactly what I am asking. How did we get to a situation where so many conflicting interpretations are in use within our industry?

 

letitsnow is not the only person who has made this argument about the interpretation; some other posters on this forum have insinuated similar interpretations.

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Are there any engineers out there today in Canada that are checked out to do ground runs and their insurance company is aware of this?

 

 

 

Yes.

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Good Morning Ms. Nash,

I am writing to you for an update on progress with CAIRS IB-8718. It has now been 469 days since the CAIRS was first submitted April 27/11, and 69 days since you acknowledged that my “concerns were valid and substantiated”. You advised that you were “coordinating with various branches and the region to address the misconceptions experienced.”

In 69 days, have you not (at the very least ) been able to create a short term corrective action plan? Since you acknowledge that we experienced “misconceptions” which led to regulatory findings against our company that were incorrect as per the Director of Standard and Chief of Standards e-mail interpretations (received 322 days ago – Sep 20/11); what is the delay in correcting these findings?

While I understand that it “will take some time to complete a thorough review and establish a way forward to ensure consistent communication when interpreting regulations”, you can’t deny the level of service we have received through the CAIRS system is well below the TC service standards. Again, I have to say that this, in no way, promotes a reporting culture in our industry. Do you honestly believe that it is satisfactory to have a CAIRS report (of this nature) open for 469 days without providing an adequate response?

 

 

Yours Truly,

Chad Calaiezzi

Operations Manager

Expedition Helicopters Inc.

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