Possible Changes To Pilot Flight Duty Regs

[drkrider]

HAC members received this email yesterday, I think everyone should read into this subject as it affects both the crew and operators if this goes through.

 

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For almost two years Transport Canada, HAC and a variety of other interested Labour Groups and industry associations have been meeting to discuss revisions to the Flight & Duty Time Regulations. The process has been largely driven by issues that have arisen in the airline world and by concerns raised by the airline pilot unions. Unfortunately, the helicopter community, the Business Aviation community and Fixed-wing Air Taxi and Commuter Operators have been sucked in to the vortex.

 

The Working Group has concluded its deliberations and the Working Group Chairs have generated a Draft Report, which is now available for your comments. [Read the Full DRAFT Report]

 

A Summary of the Working Group Chair’s Recommendations has been prepared by HAC, compared to the current Flight & Duty Limits [View the Matrix]. A full summary and an outline of the Recommendations can be found in Appendix 1 at page 83 of the full DRAFT Working Group Report.

 

HAC and other like-minded Associations will be making a joint submission to the Working Group Chairs, and a written dissent to the Final Report when it is tabled at the November 6 2012 CARAC Technical Committee meeting. We have already alleged an airline-specific bias in the process.

 

HAC has invested hundreds of hours in the Working Group’s deliberations, and the Working Group Chairs have prepared a draft Working Group report that contains complicated, one-size-fits-all proposals which are more suited to the airline community with their Crew Scheduling systems, Dispatch offices, and flight block systems. You will see that the proposals set out in the Draft Working Report would be difficult to administer in a self-dispatch environment.

 

Very little effort has been made to produce proposals that accommodate our unique operational circumstances. We have alleged that the Working Group’s Chairs have not made industry segment-specific recommendations that are sensitive to the operational requirements of the helicopter community. HAC has repeatedly reminded the Working Group members that the lion’s share of our industry consists of northern, Specialty, and seasonal operations, and we are challenged by the logistics of long distance crew changes, a short season and pilot self-managed limits.

 

We welcome your comments on the DRAFT Report, particularly as they relate to the operational impact of the proposals on your operation. All comments will be de-identified in the context of HAC’s written submission, but will add weight to concerns that we have raised. It may be that later in the process we will also have to rely on your written comments when the Working Group report has been tabled in CARAC. We may even ask you to enlist support from your local MP if cooler heads in the Transport system do not prevail. This report is bad for safety, but also bad for business.

 

 

If you take a few minutes to review the summary and the full Draft Report, I think that you will agree that the Working Group Chair’s recommendations would devastate our industry, but what’s more, they are simply not suited to our industry and will serve only to make it difficult for you to run your business without improving safety.

 

Please make your submissions directly to HAC’s President & CEO directly at fred.jones@h-a-c.ca by August 12 2012 in preparation for our next HAC submission on this subject.

[pilot5]

Can you please explain how this is bad for safety as stated in your post . I can see how it's bad for business . Is it your assertion that if operators have to staff additional crew or indirectly paying more for labour means they spend less on helicopter parts and maintenance?? I would assume that the losses as result of increased crew costs would come out off the top end - (after tax profits) have no effect on safety as per self monitoring SMS that helps increase safety when accountable executive is overseeing parts and maintenance costs?? I may have missed something here please explain ? The logic??

 

Please define the reduction in pilot fatigue vs safety ?

[drkrider]

You will note if you reread my post that I did not comment either way, but rather cut and paste what HAC emailed out. What I did say is it affects both pilots and operators which it does.

 

I posted this for those on here that don't get HAC emails so they know what's coming down the pipe.

 

Before you start putting words or opinions in my mouth please read the above post and understand what I said.

 

Sean

Can you please explain how this is bad for safety as stated in your post . I can see how it's bad for business . Is it your assertion that if operators have to staff additional crew or indirectly paying more for labour means they spend less on helicopter parts and maintenance?? I would assume that the losses as result of increased crew costs would come out off the top end - (after tax profits) have no effect on safety as per self monitoring SMS that helps increase safety when accountable executive is overseeing parts and maintenance costs?? I may have missed something here please explain ? The logic??

 

Please define the reduction in pilot fatigue vs safety ?

[pilot5]

Yes sorry it's the opinion of HAC that reduced pilot fatigue is bad for business and bad for safety! I will require a full explanation in less that 20 words without the bafflegab'.

[GoldMember]

My short answer is this, but it may be more than 20 words so I'll say sorry in advance: I don't need to be regulated in the same manner as a scheduled airline pilot. I'd be willing to give up the 42 day tour, and maybe get rid of the 14 hour duty day as well, but I don't need to have a day off every 6 and I really don't want to have my curative duty hours dictate when I need time off.

 

Kevin McCormick

[pilot5]

My short answer is this, but it may be more than 20 words so I'll say sorry in advance: I don't need to be regulated in the same manner as a scheduled airline pilot. I'd be willing to give up the 42 day tour, and maybe get rid of the 14 hour duty day as well, but I don't need to have a day off every 6 and I really don't want to have my curative duty hours dictate when I need time off.

 

Kevin McCormick

 

 

Good point..GM. kinda makes it hard to make hay when sunny too.. a 42 when the flying is a plenty can fill bank account fast...

 

Wish efforts were directed at fixing bigger problems... Like burnt out engineers that have no duty day... Not sure its safe to have an overworked engineer working on the office in low light doing lockwire..." to me this is a bigger issue that needs to be adressed..".I would sooned have a well rested and engineer fixing gear and not making any mistakes becuase he is tired!!!

[Fred Lewis]

The CARAC Flight Crew Fatigue Management Working Group Draft Report recently made available by HAC addresses an issue that has demanded attention for some time. A rational and considered attempt has been made to arrive at proposed regulations that are humane to those most affected, pilots.

 

Arguments advanced by Working Group members, of which HAC is one, are constrained by an important principle which is that recommendations will be based on scientific data. To this end the Working Group engaged the expertise of Dr. G. Belenky whose impressive list of credentials includes his current position of Research Professor & Director of the Sleep and Performance Research Center of Washington State University in Spokane. All of the members of the Working Group vetted Dr. Belenky.

 

HAC’s website makes claims about the draft report which, contrary to the spirit of the report, lack any science to defend them.

 

HAC states, “You will see that the proposals set out in the Draft Working Report would be difficult to administer in a self-dispatch environment.”. Administration may by difficult but not likely impossible.

 

HAC states, “We have alleged that the Working Group’s Chairs have not made industry segment-specific recommendations that are sensitive to the operational requirements of the helicopter community.”. Where are these “operational requirements” defined? What they must mean is “operational environment”. Requirements are like CARs to which operators must adhere. Environment is an evolving thing and in a business sense, it is an entity to which successful businesses quickly and readily adapt when it changes.

 

HAC states, “We may even ask you to enlist support from your local MP if cooler heads in the Transport system do not prevail.”. Things got a bit heated did they? Perhaps the HAC heads got red as well.

 

HAC states, “This report is bad for safety, but also bad for business.”. The science behind the claim that the report is bad for safety will be interesting to read and will presumably be forthcoming. As for the report being bad for business, where is the crystal ball that allows HAC to determine the future? It may well be bad for business, but it is far from a sure thing.

 

The purpose of the effort to revise the arcane flight and duty time regulations is to ensure the safety of the flying public and to normalize the physiological and psychological lives of pilots.

[GoldMember]

Mr. Lewis,

 

You have once again missed the point. I guess we should all just bow down to anyone with an impressive list of credentials that can produce scientific evidence that results in a series of decisions made to serve the interests of one specific group of people. Science has never been wrong or biased before.

 

Why is it so bad to be concerned about making money? Do you think that a reduced cash flow won't cause stress? Maybe after all these new regs are put in place I can take a part time job on my time off to supplement my income, rather than work for a month straight before I take 2 fantastic weeks off to enjoy my life.

 

Kevin McCormick

Equipment Operator (Pilot, Not Scientist)

[Grasshopper]

The CARAC Flight Crew Fatigue Management Working Group Draft Report recently made available by HAC addresses an issue that has demanded attention for some time. A rational and considered attempt has been made to arrive at proposed regulations that are humane to those most affected, pilots.

 

Arguments advanced by Working Group members, of which HAC is one, are constrained by an important principle which is that recommendations will be based on scientific data. To this end the Working Group engaged the expertise of Dr. G. Belenky whose impressive list of credentials includes his current position of Research Professor & Director of the Sleep and Performance Research Center of Washington State University in Spokane. All of the members of the Working Group vetted Dr. Belenky.

 

HAC’s website makes claims about the draft report which, contrary to the spirit of the report, lack any science to defend them.

 

HAC states, “You will see that the proposals set out in the Draft Working Report would be difficult to administer in a self-dispatch environment.”. Administration may by difficult but not likely impossible.

 

HAC states, “We have alleged that the Working Group’s Chairs have not made industry segment-specific recommendations that are sensitive to the operational requirements of the helicopter community.”. Where are these “operational requirements” defined? What they must mean is “operational environment”. Requirements are like CARs to which operators must adhere. Environment is an evolving thing and in a business sense, it is an entity to which successful businesses quickly and readily adapt when it changes.

 

HAC states, “We may even ask you to enlist support from your local MP if cooler heads in the Transport system do not prevail.”. Things got a bit heated did they? Perhaps the HAC heads got red as well.

 

HAC states, “This report is bad for safety, but also bad for business.”. The science behind the claim that the report is bad for safety will be interesting to read and will presumably be forthcoming. As for the report being bad for business, where is the crystal ball that allows HAC to determine the future? It may well be bad for business, but it is far from a sure thing.

 

The purpose of the effort to revise the arcane flight and duty time regulations is to ensure the safety of the flying public and to normalize the physiological and psychological lives of pilots.

 

 

I don't know what industry, or segment of aviation, you live in but, as far as the majority of the helicopter operating segment, you're probably either living under a rock or harboring some anti-business agenda to have so unrealistic a perspective about the breadth of operations existing there.

 

Certainly, there are elements of that segment that operate much like airlines and would probably logically require their flight duty time to be regulated similarly. The rest, however, both in terms of the needs of their varied users and the economics that make them viable (sometimes) demand greater flexibility and common sense (too often singularly lacking among 'scientists').

 

In addition to your seemingly warped perspective, I think your overall tone is particularly offensive and, if you need to talk down to people, as you've demonstrated a number of times on these forums, perhaps you should try it in person

[skullcap]

The drafted recommendations are biased against anyone wishing to operate without 2 people to decipher the matrix as to the length of duty day or number of hours able to fly. It is completely a waste of time to argue against anyone who thinks this doctor actually is not a quack. His double talk and second guessing are not followable. Do I need 5 off in 20? Maybe after reading this thread ha ha. Go to the hac website read thier reports with an open mind and go from there.