New Fatigue Regulations

[GrayHorizons]

I prefer to go by the accident stats per flying hours. That's a more accurate representation. Otherwise a year with one hundred accidents and a million hours differs than a year with fifty for the same hours flown. Still unacceptable  in my opinion, but the drama disappears over the 100 if you get my drift. You cannot directly compare 20yrs ago to today accurately unless you break it down this way.

I think safe working hours is very subjective to the situation. It cant be fixed based on a standard approach designed for one segment of the industry. What affects me, may not affect you. And conversely the fix for my fatigue is not the fix for yours.

If you think I dont like you, I would prefer to inform you I'm only challenging your statement. Your reaction is what determines whether I like you or not. 

[Heli500]

None of these graphs take into account average hours per pilot or how many pilots accounted for the hundreds of thousands of hours. In a 100000 hours the accident rate would be different if it was flown by 100 plots or 500 pilots. It also does not take into account pilot skill/experience level. Toral hours flown. Accidents with 10000 hour pilots vs 600 hr pilots

Going straigt up hours to accidents doesn't really tell the story. If this is what the new regs are based of in my oppinion it will not make a difference. The same number of accidents to flight hours will remain the same. It is really up to the company to realize a guys ability to perform the job vs safety and recognize when to pull them early from a shift or know when to pull then self. Everyone has a limit to the amount of work/stress there brain and body can handle.

[GrayHorizons]

Can you imagine a graph that took every item of interest into account to display the data? I'm not sure theres enough colors in the spectrum to make all the lines.

When you see companies requiring minimum hours as per demand from their insurance companies, you know someone was logging that data. Mr Insurance has. 

I know as I get older, I know when to pull the pin and be in bed by 8pm. Instead of burning the candle at both ends and staying up to 9. 

[Bif]

9, you maniac!

I blame the Netflix. 

[Freewheel]

On 12/12/2018 at 5:31 PM, Bif said:

So if this applies to 703 but not 702, how is a 702/703 operator to manage the FDT Limits of a pilot who flies either or both on any given day? I would imagine we should see Ops Specs related to this in pretty short order?

 

On 12/13/2018 at 12:18 PM, Twin Helix said:

At the end of the day the fires are going to need to burn during business hours only, self extinguish for weekends and gently smolder on stat holidays.  It's not that hard to interpret.

 

On 12/13/2018 at 6:28 AM, freck said:

Once again Transport Canada has proven that they are completely incompetent. Freewheel is going to have a field day with them on this one.

Well it looks like the time has come. Might be time for a frank discussion on what constitutes a 702 Aerial Work flight vs a 703 Air Taxi flight, In accordance with the CARs. . According to our regional authorities, TC is working on an Advisory Circular on just that topic, however recent discussions that we have had with them indicates they might not be clear on the  difference, (particularly with regards to helicopter operations in relation to the CARS/CASS). They also seem particularly confused as to what helicopters do on forest fires.

I’d be curious to hear what other regional authorities are saying. Apparently the Advisory Circular is currently on the back burner, until TC’s audit by ICAO is complete.

[freck]

11 hours ago, Freewheel said:

 

 

Well it looks like the time has come. Might be time for a frank discussion on what constitutes a 702 Aerial Work flight vs a 703 Air Taxi flight, In accordance with the CARs. . According to our regional authorities, TC is working on an Advisory Circular on just that topic, however recent discussions that we have had with them indicates they might not be clear on the  difference, (particularly with regards to helicopter operations in relation to the CARS/CASS). They also seem particularly confused as to what helicopters do on forest fires.

I’d be curious to hear what other regional authorities are saying. Apparently the Advisory Circular is currently on the back burner, until TC’s audit by ICAO is complete.

Having read the 703 rule changes one would have to be a rocket appliance to figure it out. Well done TC You took on this task when you can't define air and flight time

[Bee3]

So what you are telling me is I can’t move a drill at 3am anymore…

 

[Freewheel]

Forest Fire 702/703

Clearly the scope, and discussions, surrounding helicopter aerial work nationwide, and from one operator to another, could be quite broad; but one thing almost all of us do, from coast to coast is  Fire Fighting, and Forest Fire Management.  Most of us do it in numerous TC regions. Given this fact, I think it would be the best place to start the discussion.

One thing that came up during recent discussions with TC regional managers, was the distinction between 702 and 703 flights, while on Forest Fire Hire. While I believe the wording of the CARs and supporting TC guidance, historically classifies  almost ALL flights on fire hire as 702 aerial work, they disagreed.  

Our TC Technical Team Lead went as far as to assert that transportation of Forest Fire personnel to and from a forest fire would be considered “air transport service”, and therefore a 703 air taxi flight. Is anyone else hearing this interpretation from TC , or does anyone believe this interpretation  to be correct? If so, feel free to elaborate and provide reference to CARs, CASS or supporting documents.

If I were be so bold as to state that ALL flights on Forest fire hire, are 702 flights, would anyone agree, or disagree? 

Again, please feel free to elaborate, and reference the CARs. I’d really appreciate some examples of what types of fire hire flights that you feel would not qualify as 702, and are 703; as well as a discussion as to why…

Not looking for an fight or argument, just a healthy debate/discussion.

[Freewheel]

22 hours ago, freck said:

Having read the 703 rule changes one would have to be a rocket appliance to figure it out. Well done TC You took on this task when you can't define air and flight time

Perhaps the ICAO audit will catch the difference between TCs definition of flight time for helicopters, and ICAO’s.

Under the agreement, I believe ICAO member states, must publish the regulatory differences from ICAO annexes.

Coincidentally, Director of Standards Jaqueline Booth, showed her ignorance towards heli ops in 2011, when she provided us guidance on helicopter flight time, and again when she co-chaired the working group that came up with these New Fatigue Rules.

While they claim these new fatigue rules were implemented to align with ICAO, that also seems to be incorrect, as I don’t believe most ICAO country’s have applied such complex and restrictive rules to sectors such as 702/703 helicopter operators. They mainly apply rules like this to airlines only.

Perhaps this lack of heli ops knowledge could turn out to a positive. Regardless of what TC thinks about how these rules should be applied to to fire fighting, we only need to comply with the rules as written. Advisory Circulars are simply advice, as their name asserts.

[Cirrus]

On 12/20/2022 at 5:16 PM, Freewheel said:

Forest Fire 702/703

Our TC Technical Team Lead went as far as to assert that transportation of Forest Fire personnel to and from a forest fire would be considered “air transport service”, and therefore a 703 air taxi flight.

Correct me if I am wrong, but I don't believe there's any allowance for hover exit under 703. Under my current AOC, hover exit is only permitted under 702 so I'd love to see their resolution for that.