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OGEgirl

Flight Time Vs. Air Time Personal Logbook

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Astars require a pilot at the controls, if the engine is running. FM-Limitations sections. Some other types have a similar limit. Like robbies.

FYI: That's no longer the case. It's nowehere to be found in Canadian AS350 Flight Manuals. I just double checked the latest revisions of the AS350 D, BA, B2 & B3 2B1.

 

Other Relevant Info:

 

Airbus Helicopters, released Safety Information Notice No. 2727-S-00 (Decemeber 15, 2014) advising that: Airbus Helicopters will remove the following wording from all applicable Flight Manuals: "Unless otherwise specified in applicable operational rules, one pilot should be at the controls as soon as the rotors turn until flight ends and rotors are fully stopped".

 

The Safety Notice also states: "Airbus helicopters, however, continue to believe that a qualified pilot should always be at the controls of the helicopter when the rotors start to turn until the flight ends and the rotors are fully stopped".

 

http://airbushelicoptersinc.com/images/safety/Ground-Ops-Pilot-at-Controls.pdf

 

Also relevant:

We currently have a Transport Canada approved procedure in our COM for "Aircraft Running with Pilot Seat Unoccupied". Under specific conditions (which are listed in COM), it is allowed if the pilot complies with all procedures listed.

 

One other risk factor that we identified is the change in aircraft C of G as a result of aircraft cargo loading. One of the requirements is that: No Aircraft Loading or unloading shall occur while the seat is unoccupied.

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No, thank you Rotor, along with everyone who has taken part in this open dialogue, and my e-mail survey. That goes for everyone, regardless of what your point of view is.

 

You have helped illustrate my point nicely.

 

You have also helped me formulate my response to the BS interpretation that We are waiting on. We all know it's coming.

 

We have since filed a report to Aviation Occupational Health Safety program citing this confusion as a danger to employees on helicopters nationwide.

 

We will be following up with a report to ESDC Occupational Health & Safety Officer next week.

 

Cheers

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E-mail to TC Aviation Occupational Heslth and Safety inspectors Lisa Witton and Janice Berling May 20, 2016:

 

Hi Janice and Lisa,

 

The purpose of this email is to confirm the applicability of the following CBAAC to skid equipped helicopter operations.

 

 

https://www.tc.gc.ca/eng/civilaviation/standards/commerce-circulars-ac0202r-1659.htm

 

CBAACNo. 0202R states:

 

2. For the purposes of the Canada Labour Code, Part II, an aircraft is in operation from the time it first moves under its own power, for the purpose of taking off from a Canadian or foreign place of departure, until it comes to rest at the end of its flight to its first destination in Canada. [subsection 128(5)]

 

The Transport Canada Aviation Occupational Health and Safety program position in this regard is that "aircraft in ground, or in the air. Therefore, an aircraft is considered to be "in operation" anytime it is flying in Canada or abroad, as well as anytime the aircraft doors are closed and the aircraft is moving on the ground, under its own power, for the purposes of taking-off or landing. An aircraft is not considered to be "in operation" when it is stationary on the ground, in Canada or abroad, either before, after, or between flights.

 

So since a skid equipped helicopter cannot "taxi" without becoming airborne, just about any time it is in contact with the earths surface it is not considered to be in "Operation" in accordance with the Transport Canada Aviation Occupational Health and Safety program position. Is this correct?

 

 

It would also be true that all matters of health and safety, on board a running helicopter, while in contact with the earths surface (and stationary) would fall under the jurisdiction of Labour Canada (and not Transport Canada AOHS). correct?

 

 

This would be true regardless of the aircraft RPM, the type of surface, location etc.

 

 

So if a skid equipped helicopter lands and takes off 10 times (in unprepared bush landing areas) in 1 hour, with 1 start and shut down, and remains at full throttle with M/R turning at 100% : during the time spent in contact with earth's surface the helicopter is not considered to be "in operation" and therefore not the jurisdiction of TC AOHS. correct?

 

Thank you,

 

Reply received May 31/16:

 

Acknowledge receipt. We have a made a request for an interpretation on a couple of things with ESDC Labour Program with regard to language in our MOU. I will get back you.

Regards

Lisa

 

 

 

Lisa Witton

A/Technical Team Lead - Specialties

Received June 24/16:

 

Good Morning

 

Following discussions with Technical Advisors from Employment and Social Development Development Canada (ESDC) Labour Program and Aviation Occupational Health and Safety Standards, please see the response below:

 

 

The interpretations under the Canada Labour Code - Part II and the Aviation Occupational Health and Safety Regulations are the mandate of Employment and Social Development Canada (ESDC) - Labour Program, under the purview of the Minister of Labour.

 

CBAAC No. 0202R

 

The identified CBACC No. 0202R, referred to in your e-mail, was issued as guidance, primarily to assist aviation employers and employees in understanding their roles and responsibilities, in a situation where an employee has invoked their right to refuse dangerous work, as stated in the title EMPLOYER AND EMPLOYEE RIGHTS AND RESPONSIBILITIES, WITH RESPECT TO EMPLOYEES REFUSING TO WORK IN DANGEROUS SITUATIONS.

 

The interpretation of while in operation is to assist in establishing the jurisdiction of the investigator, be it a Delegated Labour Program Official (DLPO) with ESDC-Labour Program or Delegated Labour Program Official Extended Jurisdiction Transport Canada, Civil Aviation.

 

The interpretation provided by the Labour Program in CBAAC No. 0202R, published in 2004, regarding in operation was based on the Memorandum of Understanding (MOU) between the then HRDC and now ESDC and Transport Canada.

 

Memorandum of Understanding Between Employment and Social Development Canada and Transport Canada (January 05, 2015)

 

1. Purpose

1.1 The purpose of this memorandum of understanding (MOU) is to establish a joint administrative arrangement between Employment and Social Development Canada - Labour Program (ESDC-Labour Program) and Transport Canada (TC) for the application and enforcement of the Canada Labour Code, Part II (Code) in the federal transportation sector.

 

2. Definitions

 

For the purpose of this MOU:

 

delegated official means a person that has been delegated certain authorities by the Minister to perform activities related to the enforcement of the Code;

 

extended jurisdiction means authorization for TC to carry out the administration and enforcement of the Code on behalf of ESDC-Labour for certain employees in the federal transportation sector;

 

on-board employee means a person who is working on board an aircraft, a vessel (ship) or a train while in operation, as defined in Annex 1; and who is covered by OHS regulations specific to the mode of transportation made pursuant to the Code.

 

ANNEX 1

 

Annex 1 of the MOU between ESDC and Transport Canada was modified January 05, 2015:

Administrative Role of Transport Canada: Aviation Industry

 

1. Transport Canada Civil Aviation administers Part II of the Code and the Aviation Occupational Health and Safety Regulations in respect of occupational health and safety for employees employed on board aircraft while in operation and in respect of persons granted access to those aircraft by the employer.

a) For this purpose, in operation is described in paragraph 128(5)(B) of Part II of the Canada Labour Code. An aircraft is 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. As such, an aircraft sitting on a runway outside of Canada is considered to be in operation.

 

2. For greater clarity and delineation of responsibilities within the context of refusals to work, if the subject for the refusal of an employee relates to the airworthiness or safety of an aircraft while in operation the refusal to work will be investigated by TC Aviation.

 

Confirmation has been received from ESDC-Labour that for Aviation Occupational Health and Safety purposes, a helicopter would be considered to be in-operation the entire time its engines are running and blades are turning, for the purposes of taking off. As a result, the Aviation Occupational Health and Safety Program would have jurisdiction over the on-board employees during the entire time the aircraft is in operation and any occupational health and safety reporting requirements would come to the DLPO Extended Jurisdiction Aviation, responsible for the particular employer.

 

Regards

Lisa

 

 

 

Lisa Witton

Civil Aviation Safety Inspector - Cabin Safety / Aviation Occupational Health and Safety

Inspectrice de la sécurité de laviation civile - Sécurité dans les cabines et Santé et sécurité au travail dans laviation

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Based solely on these 2 definitions (as written):

 

"in operation" is described in paragraph 128(5)(B) of Part II of the Canada Labour Code. An aircraft is "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.

 

"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)

 

Is there anyone who would argue, that for a domestic helicopter flight, the following statement isn't true?

 

Time "in operation" = Flight Time

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so am I correct in my understanding that if an aircraft runs for 8 hours, air time is 6, and that it is running for the intent of flying for the entire 8 hours then the pilot logs 8?

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That depends on who you ask. Transport Canada civil aviation's latest interpretation states Flight Time always equals air time.

 

Transport Canada Civil Aviations Official interpretation Flight Time provided by Joe Szwalek, (Transport Canada Regional Director) is the following:

 

"As per my commitment to provide you an official interpretation of air time vs. flight time as applicable to skid equipped helicopters, please note the following.

 

As per CAR 101.01, air time commences when the aircraft lifts from the surface and continues to the point of landing. Flight time occurs when the aircraft first moves under its own power for the purpose of take off and continues until it comes to rest at the end of the flight., skid-equipped helicopters don't normally ' ground taxi', and all movement/manoeuvring is done while in flight because landing and coming to rest at the end of the flight are the same action. Manoeuvring at an aerodrome at low speed and low altitude is referred to as "air taxi", but in any event, the aircraft is still flying (taxi time on the ground is non-existent).

Since, as previously mentioned, the definition of 'flight time' is the time from the moment an aircraft takes off until the moment it comes to rest at the end of the flight, .. Since flight time equals air time

In summary, given that the CARs definitions of flight time and air time are the same in the context of skid-equipped helicopter operations, Transport Canada' s official interpretation is that flight time equals air time for purposes of Journey Log entries.

 

You may consider this interpretation Transport Canada' s final position on the matter. Please note that this interpretation has been disseminated within Transport Canada nationally and has been added to the National Aviation Safety Information System (NASIMS). I trust that this will resolve your previous requests for information on this subject. I encourage you to work with the Helicopter Association of Canada (HAC) if you have concerns about the applicability of this interpretation on your operations...."

 

That's why I asked if anyone believed it was possible that this statement isn't true:

 

Time in operation = flight time

 

TC Aviation occupational Health and Safety Program and ESDC Labour program interpret time in operation in the Canada Labour Code (which seems to have exact same definition and wording) to mean:

 

"a helicopter would be considered to be in-operation the entire time its engines are running and blades are turning, for the purposes of taking off"

 

Clearly their nterpretation is that in-operation is not the same as Air Time as defined in the CARS.

I hope we can agree: the definition of air time is quite clear. Temps dans les air stranslation: Time in the air.

 

"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)

 

So How can flight time be the same as Air Time? Flight time is the same as in-operation, but in-operation is not the same as air time. This is just plain silly. Do you believe that an aircraft sitting on a runway or helipad while running should be logging air Time?

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Haha wow!

 

I'll keep going with whatever goes in the AC logbook as airtime goes in my personal log.

 

Hard to mix that up if anyone ever wanted to verify my hours

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Haha wow!

 

I'll keep going with whatever goes in the AC logbook as airtime goes in my personal log.

 

Hard to mix that up if anyone ever wanted to verify my hours

And here's the next question that always come up when someone says that:

 

Do you also use air time in your Flight time records when monitoring against flight time limits under CARs 700.15?

 

At 8 hours per day you would reach 150 hours in 18.75 days while at 6 hours a day it would be 25 days. What if they decide you've overflown the 700.15 limits after an accident on day 24 because you were under stating your flight time?

 

What about 700.16 duty limit which allows for a 15 hr duty day if flight time is below 8 hrs..etc?

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And of course, what about your licence?

 

Did the Flight Training Unit where you trained actually give you 100 hrs of air time? Most don't. So did you meet min requirements for your licence?

 

Training req'd for ratings etc. Same question...

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