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OGEgirl

Flight Time Vs. Air Time Personal Logbook

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NZ, Canada, Australia, US, it’s all the same. You can invoice the customer whatever you like depending on the deal you make, Air time, flight time, lunch time is all irrelevant.

The law says in all countries you must record the time the aircraft is used in the tech log, it seems that in Canada that TC has conflicting information regarding which time to use hence the title of the thread.

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December 20/17 email to TC Ontario Region POI

“I’ve been discussing your “Flight Time” interpretation/compliance e-mail with some of my pilots and they’ve brought up some valid points as far as implementation. At their request, I am sending you this e-mail. As their liaison to TC, I look forward to providing them with clarity.

 As you are aware we employ pilots who live and work in several regions from coast to coast. As is quite common in our industry, some of these pilots work for several companies over the course of a year. Some of these pilots have been advised by other companies to interpret Flight Time differently from what you advised in their recent email interpretation. This is no surprise, as your e-mail was only distributed to 7 air operators in Ontario, and we know that other TC regions and inspectors have not been adhering to the interpretation established in Ottawa.

 These pilots are required to provide air operators with 700.15 Flight Records for ALL flying (including their Flight Times from  other companies). Unfortunately, if these times are not logged consistently from one operator to the next, then we know the records are not accurate. The only way for these pilots to provide air operators with accurate records for all flying would be to keep multiple (differing) sets of records to supply to each employer. Aside from being ridiculous, this clearly is not efficient and could be seen as suspicious. These pilots are concerned about these inconsistent company directives could lead to someone questioning their records after an accident.

 The other comment from pilots is that, as PIC, it is their responsibility to ensure accurate entry of Flight Time into the records you are discussing, not the company’s. This, I agree with, and it has been reiterated in a recent Occupational Health and Safety Tribunal (Black sheep Aviation). This interpretation needs to be directed to all pilots, not air operators.

 So, given these 2 issues, how do you suppose I deal with future non-compliances (with your e-mail interpretation) when they inevitably occur. After we distribute your interpretation to pilots, and future findings are made on pilot records, do I contact enforcement?

 We really don’t feel that an e-mail, from 1 inspector, to 7 Air Operators in Ontario, will correct the well-known ”disparity” that is the “Root Cause” of these types of findings. We also might not be comfortable taking punitive action (such as loss of “Performance Pay”). Particularly with the current conflict between TCCAs interpretation of Flight time and the ESDC Labour Program interpretation of “in operation” in the Canada Labour Code.

 Until there is advisory material at the National level, and an obligation on the part of inspectors and regions to adhere to policy that is established in Ottawa, there is unlikely to be any resolution of this problem.

 I know you said to give you a call, but I require a reply in writing. If you would like to discuss, I’m available.”

Dec 21/17 reply:

“I only sent out my email to the air operators for which I am the POI, other POIs have or will soon do the same. 

 It is the attached letter and email from Deborah Martin, Chief of Commercial Flight Standards that clarifies the interpretation nationally.  

 As it is a shared responsibility of the air operator and the air crew to maintain accurate records of Flight Time, it is expected that this information would be  transferred from the air operator to the air crew through training, Company Operations Manual amendment and any other method of information dissemination that the air operator may have in place.”

“The AOSH interpretation of “in operation” is in regards to AOSH regulations for AOSH purposes and cannot be transferred to the CARs to alter the definition of Flight Time”

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On 2018-01-03 at 7:22 AM, Freewheel said:

Dec 21/17 reply from TC POI:

“The AOSH interpretation of “in operation” is in regards to AOSH regulations for AOSH purposes and cannot be transferred to the CARs to alter the definition of Flight Time”

Dec 2117 reply to POI:

I understand that is TCs position, but both the Canadian Aviation Regulations and the Canada Labour Code are meant to be interpreted in plain language and they contain the exact same words and phraseology.

 I’m no lawyer, but I suspect that based on basic rules of interpretation, it is not reasonable for TC to suggest they have 2 different meanings.

 FYI: 

I will likely be including the definition of  CLC definition of “in-operation” in the COM amendment that I submit to you for approval. Our current intention is to advise pilots that TC AOHS jurisdiction applies to “in-operation”. It will also advise to bill clients and pays pilots based on the time the aircraft is “in operation”, as per TC AOH and ESDC’s interpretation.

 I envision an amendment something like this:

 “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)

 "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)

 “in operation” An aircraft is defined as being "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

 Note: 

“Air time” and “Flight time” are interpreted to be the same in skid equipped helicopters, this applies to all skid equipped helicopter operations.  Therefore there should be no difference in values entered in the Journey Log Book air time column from those entered into Flight and Duty Records, Pilot Training Records (CAR Subpart 7 operations) and Pilot Training Records (PTRs – CAR Subpart 4 operations) or any other regulatory requirement to record “Flight Time”. Air time and Flight Time are the time spent in the air only. Any time that the aircraft is in contact with the supporting surface, shall not recorded as Flight Time or Air Time.

A helicopter is considered to be “in-operation”the entire time its engines are running and blades are turning, for the purposes of taking off. Pilots should enter this figure in the “OPS Time” Column in the Journey Logbook, Flight Reports and Pilot Time sheets. Transport Canada Aviation Occupational Health and Safety Regulations apply the entire time the aircraft is in operation. Transport Canada Occupational Health and Safety Program has jurisdiction throughout this time “in operation”.

 Sorry, but this doesn’t pass the sniff test to me. TC guidance says it does, however.

 To the point: 

either TCCA  is interpreting Flight Tine in the CARS incorrectly 
 
Or
 
TC AOHS & ESDC Labour program is interpreting “in operation” incorrectly in the Canada Labour Code
 
It’s that simple. 
 
Unless someone would like to try and debate that these definitions are different in some way, this is undeniable.
 
I’ve cc’d the TC AOHS inspectors.
 
We will also be taking this up with our ESDC Labour program rep.

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On 2017-12-30 at 12:32 PM, Blackmac said:

I believe I made a comment about this years ago and as a contracting officer with PWGSC and responsible for trying to clarify how aviation charters should be billed to all department of the Federal Government, I had a clause inserted in all Contracts and Standing Offers issued to companies on how to bill:

Fixed Wing: rate per mile from A to B and return, including allowable charges as agreed. 

Rotary Wing: Hourly Rate from takeoff to final landing. i.e. depending on the requirement and type of work where the engine was not shut-down, it would be considered a continuous flight. The same would apply to fixed wing doing surveys.

Gravity Survey in the James Bay Hydro Electric Project: A normal day was approximately 120 landing and take-offs, on floats. Do you think the battery or engine could manage such stress with the cool down and start-ups 120 times. 

This would apply to both types of aircraft, charges should only apply when the aircraft is in flight mode, ceases when the aircraft lands. This IS referred  to as "AIR TIME".

The entry of "AIR TIME" is the TRUE COST to the operator and is reflected in the overall maintenance life of the aircraft. "Flight Time" should be  removed from the Journey Log Book as it serves no purpose other than to HAVE THE DISHONEST OPERATORS USE IT FOR BILLING.

DO YOU THINK THE OPERATORS ARE GOING TO MAKE A STINK ABOUT,  HA, HA

All the Auditors have to do is cross check the invoice for any given flight and the entry in the journey log and the tech log, you will be surprised.

As stated before, I am a trained "auditor" trained by transport Transport Canada" and the United States Air Force.

 

BM,  just so we are clear, you are referring to a “clause” in contracts similar to this one found in one of the many provincial “standing offers”....correct?

DETERMINATIONOFHELICOPTERFLIGHTTIME


(A) Except as provided in subsection (B), the hours and minutes for which a charge is made shall be computed from the time the helicopter commences hovering or taxiing before take-off until it ceases to hover or taxi after landing. All times shown on Saskatchewan Daily Flight Reports and invoiced for must also be recorded in the Aircraft Journey Log as flight time where defined and required in C.A.R.s.
(B) When operations involve a continuous succession of flights each of less than ten minutes duration, and the engine is not shut down between such flights, flying time shall be computed from the time the helicopter commences to hover or to taxi for the first flight until the helicopter ceases to hover or taxi after the final landing. All times shown on Saskatchewan Daily Flight Sheets, and invoiced for, must also be recorded in the Aircraft Journey Log as flight time as defined in C.A.R.s.

 

And you have no concerns if the pilot is overstating his air time (from a safety standpoint)....correct?

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Because I get the impression you think the “air time” limits in the maintenance manuals are all “Maximum limits”. There are manny maintenance tasks that are completed  after a minimum number of “air time” hours. Unlike TC, the manufacturers are very clear that these limits are based on time in the air...not sitting on ground with blades turning. How about the many special inspections, torque checks etc. After component removal and installation?

Generally I prefer my maintenance completed with strict adherence to manufacturer’s maintenance practices to reduce the likelihood of this type of failure.

https://www.tc.gc.ca/eng/civilaviation/opssvs/civil-aviation-safety-alerts-2017-02.html

 If you are entering inflated air time figures in the journey log book it’s just a matter of time before these tasks are completed early (and contrary to required maintenance practices). Auditors should expect that operators and pilots execute to these standards.

 

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4 hours ago, Freewheel said:

Because I get the impression you think the “air time” limits in the maintenance manuals are all “Maximum limits”. There are manny maintenance tasks that are completed  after a minimum number of “air time” hours. Unlike TC, the manufacturers are very clear that these limits are based on time in the air...not sitting on ground with blades turning. How about the many special inspections, torque checks etc. After component removal and installation?

Generally I prefer my maintenance completed with strict adherence to manufacturer’s maintenance practices to reduce the likelihood of this type of failure.

https://www.tc.gc.ca/eng/civilaviation/opssvs/civil-aviation-safety-alerts-2017-02.html

 If you are entering inflated air time figures in the journey log book it’s just a matter of time before these tasks are completed early (and contrary to required maintenance practices). Auditors should expect that operators and pilots execute to these standards.

 

AIR TIME is applicable to all components on a helicopter or aircraft that have a lifetime between overhaul or life span be scrapped and destroyed. What is so difficult about understanding that? 

If an operator wishes to inflate the air  time, he is the one who pays the bill.

All pressurized aircraft, life of the fuselage is based on the amount of cycles on the airframe due to pressurization.

Due to the fact that you seem to question everything that is applicable to aviation, I would suggest that you actually get a job with Transport or if you are an owner, try H-A-C and maybe they could enlighten you. For your information I was in aviation before Marc Garneau or the people that are working for him.

Thanks for the opportunity to converse with you, but this is the last you will hear from me on this subject.

Cheers, Don   

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9 hours ago, Blackmac said:

Thanks for the opportunity to converse with you, but this is the last you will hear from me on this subject.

Cheers, Don   

I wish...but I doubt it.

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22 hours ago, Blackmac said:

AIR TIME is applicable to all components on a helicopter or aircraft that have a lifetime between overhaul or life span be scrapped and destroyed. What is so difficult about understanding that? 

If an operator wishes to inflate the air  time, he is the one who pays the bill.

All pressurized aircraft, life of the fuselage is based on the amount of cycles on the airframe due to pressurization.

Due to the fact that you seem to question everything that is applicable to aviation, I would suggest that you actually get a job with Transport or if you are an owner, try H-A-C and maybe they could enlighten you. For your information I was in aviation before Marc Garneau or the people that are working for him.

Thanks for the opportunity to converse with you, but this is the last you will hear from me on this subject.

Cheers, Don   

Thanks for clearing that up. I think I understand your point of view: since your career predates the regulations and maintenance requirements, you get to pick and chose which one you comply with. You also clam up when someone raises a valid point that does not conform to your opinion.

I think I’ll go with what the manufacturer says instead and insure my maintenance is completed in accordance with the regulations. 

Under the Flight Time = Air Time interpretation, It seems to me that for short flights in accordance with (B), all operators have a contractual obligation to inflate their Air time 

Q1. Engine Start Time/Blades turning: 754

 Time Up    Time Dn     Air Time    Starts    Comments

800           804              4 min             1      CYMO – Lagoon

809            812             3 min             0    Lagoon – CYMO

816             819             3 min           0      CYMO – Lagoon

822             825             3 min           0      Lagoon – CYMO

829             833             4 min           0      CYMO – Lagoon

838             841             3 min           0      Lagoon – CYMO

844             847             3 min           0      CYMO – Lagoon

850             853             3 min           0      Lagoon – CYMO

855             858             3 min           0      CYMO – Lagoon

904             909             5 min           0      Lagoon – CYMO

 Engine Shutdown @ 912; Rotors Stopped @ 914

 In accordance with the clause in the contract, For the above entries: The pilots calculated Flight Time and Air Time respectively, should be 1.2 hours Flight time and 1.2 hours air time

Q2. Engine Start Time/Blades turning: 754

 Time Up    Time Dn     Air Time    Starts    Comments

800             824             24 min           1      CYCN – CYTS

 Engine Shut Down @ 830; Rotors stopped @ 831

 In accordance with the clause in the contract, For the above entries: The pilots calculated Flight Time and Air Time respectively, should be 0.4 hours Flight Time and 0.4 hours Air Time

Airbus Helicopters indicates this recording Air Time as per the clause for short flights in succession is not in accordance with Master Service Manual or Maintenance Manual...

Good morning,

 I am doing ok here I hope you are also.

 Regarding your question yesterday on flight and air time please review the following.

Airbus Helicopters is concerned with limitations expressed in Flight Hours (FH), Calendar time & Cycles.

The definition of FH is given in both the Chapter 4 Airworthiness Limitations Section (ALS) and Chapter 5 Master Servicing Manual (MSM) both are available through TIPI and as part of the standard documentation for each model of aircraft operated.

This definition of flight hours (not to be confused with Flight TIME) corresponds to Air Time as defined in CARs Section 101.01:

 Airbus Helicopters does not take into account running time (i.e. flight time by ICAO definition) for purposes of tracking limitations.

 So in answer to your two questions:

 A1: answer a. Flight Time = 1.3 / Air Time = 0.6

A2: answer B) Flight Time = 0.6 / Air Time = 0.4 (Note: rotors stopped at 0831)

 If you have any further questions regarding Airbus Helicopters requirements for tracking time please let us know.

Best regards,

Rod

Rod TUPALA

Technical Support (Ontario)

Airbus Helicopters Canada Limited”

 

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On 2017-12-16 at 8:53 AM, Freewheel said:

At least 1 TC Ontario inspector disagrees. This was sent out to 7 Ontario Helicopter operators last week:

Gentlemen

 Please see the email chain below and the attached official interpretation of “air time” versus “flight time” for skid equipped helicopters.  To the point, air time and flight time are interpreted to be the same in skid equipped helicopters, this applies to all skid equipped helicopter operations.  Therefore there should be no difference in values entered in the Journey Log Book air time column from those entered into Flight and Duty Records, Pilot Training Records (CAR Subpart 7 operations) and Pilot Training Records (PTRs – CAR Subpart 4 operations) or any other regulatory requirement to record “Flight Time”.

 Please comply with this interpretation from receipt of this email  if you have not already done so.

Received this from HAC preident on Saturday. Sounds like TC has agreed that pilots can record “flight time” and “air time” anyway they want ...for now. Not sure how it relates to the above  email from an Ontario inspector sent to several commercial operators. Apparently Fred attended a meeting on this itopic; Director of Standards Robert Sincennes, Cheif of Standard  Deb Martin, Robert Freeman from HQ, Serge Côté and a new licensing inspector named John were in attendance. 

“they agreed:
 
1. They would not enforce against operators using the ICAO definitions of flight time and air time, for now;
2. They would not reject licence applications which used the ICAO definitions, for now;
3. They would engage with HAC and others, to resolve this issue, going forward.
 
Cheers,
 
Fred”

 

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This is just stupid.  

If you guys are having trouble maybe its because "flight" and "air" mean the same thing, since you cannot be "in flight" unless you are "in the air"!

If you're concerned about "engine run time", or "blades spinning time", vs. "skids up to skids down (air) time", then change "flight time" to one of the first two.

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