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Flight Time Vs. Air Time Personal Logbook


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I'm with you freewheel, it's crazy there can't be a simple answer.

 

But tomorrow say I start logging flight time I'll be the guy " padding his books" cause the AC logbook "airtime" and my flight duty and personal log won't match.

Says who?

 

Where does it say in CARs that your Flight Time records must match AIR TIME Column in Journey Log Book?

 

Do you think fixed wing guys worry about that?

 

Again, I guess it depends on who you ask. If you ask me you might be the guy "hedging" his hours to remain below Flight Time limits.

 

I'm thinking the Aviation Occupation Health and Safety inspector who lays charges under Canada Labour Code might agree with me.

 

FYI, these are the same AOHS inspectors who charged ORNGE with 17 violations to Canada Labour Code.

 

What's the easy answer? Our regulators need to acknowledge the confusion within the federal government, set a basic minimum standArd and enforce it equally. That's their job and responsibility.

 

Seems pretty simple to me.

 

HERE's the problem, no accountability...so you get to figure out after the accident and law suit.

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Reply e-mail sent to TC AOSH Personnel June 27/16:

 

Good Morning Andrew, Mary and Lisa,

 

Once again, thank you for the response last week.

 

After reviewing your Official Interpretation of in operation under the Canada Labour Code, Part II, we began circulating another e-mail to industry stakeholders and Transport Canada personnel. The e-mail contains one basic question. The 2 basic questions in my previous e-mail were multiple choice questions; it appears that Transport Canada had difficulty responding, so this time we went with True or False.

 

In the interest of compliance, I would appreciate if you would respond to the following True or False question. I have also forwarded this question to Joseph Szwalek, Aaron McCrorie, Michael Stephenson, Dave Laamanen, Jennifer Holmes, Dave White, Robert Freeman, and President of HAC, Fred Jones. Each of these people were included on Mr. Szwaleks interpretation bulletin on the definition of Flight Time. Based on past experience, I dont expect to receive a legitimate response from any of the TC personnel on this e-mail, so I would really appreciate if each of you would take part in this exercise.

 

In my opinion, anyone could answer this question, (whether they have aviation or Occupational Health and Safety expertise or not). For this reason, there should not be a need to consult with Headquarters or ESDC to formulate a response. Having very basic English language skills should be all that is required.

 

Applicable Definitions:

 

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)

 

 

So here's my question:

 

Based solely on the above 2 definitions (as written), is the following statement true or false for a domestic flight in a skid helicopter?

 

Time "in operation" = Flight Time

 

Your co-operation and participation would be appreciated,

Thank You,

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Appreciate the reply freewheel!

 

I want to be accurate and follow the rules and not stick to a norm that may be set out by my employer.

 

It's worth a discussion and appreciate the info.

I'm sure you realize that logging 6.0 hrs of air time (in your flight time records) on those 8 hr "in operation" per day jobs would put you at about 200 hrs (in 25 days) Good for the extra FLIGHT pay in slow times....and that is why some people prefer to allow the confusion to exist. I think some refer to that as flying under the radar...

 

It also means I need less pilots during busy season.

 

Is it safe? Not for me to say; but I don't think so.

 

Regardless there needs to be a true minimum standard set and applied the same way for everyone.

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I agree.

 

I just want to log time how I am supposed to. I wouldn't hesitate to log 8 if that was the rule. As it stands I am told to mirror what the aircraft flew as air time, that'd due to TC definition is "air time = flight time".

 

Hope we won't be left waiting too long for someone to say which rule we are supposed to follow.

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Don't hold your breath. This discussion has been going on for 20+ years. The issue is that TC would have to acknowledge they made a mistake somewhere. Unfortunate that EGO's would interfere with regulating and safety....but seems to be the case.

IF I were you I would stop depending on "guidance" from TC,read the rules and log the way you feel is the most defendable means under the CARS as written. Logging Flight Time accurately is the pilots responsibility; not your employers.

 

You are right that TC Civil Aviations latest interpretation is that flight time = air time.; but clearly FLIGHT TIME = Time in operation (or do you feel the answer to the question is false).TCs interpretation is also that " 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".

 

Maybe you should tell your employer that it stands to reason that it must also be TCs interpretation that "Air Time" (if flight time = time in operation) is "the entire time a helicopters engine is running and blades are turning for the purpose of take-off" (Meanwhile, we'll keep logging as time in the air only lol)

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