New Fatigue Regulations

[TopFuel]

Exactly,

The "spirit of the regulation" was meant to be....

Fatigue is a safety issue, period.

The hammer will drop at some point. Be prepared. 

[Freewheel]

On 1/13/2023 at 11:39 AM, simpleton said:

. So the only let in that scenario is 722.16(c), and they are not actually being taken to an aerial work site to be dropped off.

 

For clarity, I don’t see anywhere in 722.16(c) that says they need to be “taken to an aerial work site to be dropped off”, just that they need to be carried to an aerial work site. 

Being carried  to an aerial work site, does not mean they need to be dropped off at the aerial worksite.

Under the traditional interpretation you refer to, many persons have been allowed to be carried to aerial worksites, under 722.16(c), without being dropped off.

[simpleton]

8 hours ago, Freewheel said:

For clarity, I don’t see anywhere in 722.16(c) that says they need to be “taken to an aerial work site to be dropped off”, just that they need to be carried to an aerial work site. 

Being carried  to an aerial work site, does not mean they need to be dropped off at the aerial worksite.

Under the traditional interpretation you refer to, many persons have been allowed to be carried to aerial worksites, under 722.16(c), without being dropped off.

Next time quote what I actually said in it's full context....especially since I was referencing a very specific scenario provided earlier in the thread, not making a blanket judgement as per your statement above.

 

[Freewheel]

15 hours ago, simpleton said:

Next time quote what I actually said in it's full context....especially since I was referencing a very specific scenario provided earlier in the thread, not making a blanket judgement as per your statement above.

 

I wasn’t looking to debate whether hover exit was aerial work, or whether the carriage of on board persons other than crew members was a type of aerial work. As stated, my assertion was simply to ensure clarity.

I doubt there will be a next time, this thread has served it’s purpose.

Thanks for your engagement on the subject.

Fly Safe.

[Actuality]

This advisory circular was sent to me by a friend. 
 

thoughts?

ADVISORY_CIRCULAR_700-XXX_CARRIAGE_OF_PERSONS_DURING_AERIAL_WORK-_DRAFT_ADVANCE_COPY.pdf

[Rotorhead205]

So this a leaked Transport Canada draft copy? ... Or someones personal interpretation of 707 - 703? 

 

This says that Loaded Patrols are 703, but working on actual fires is 702.

[Pool pilot]

1 hour ago, Rotorhead205 said:

This says that Loaded Patrols are 703, but working on actual fires is 702.

I wonder if the MOT will stop sending us out on the afternoon nap for the fire crew patrols and use more planes.

My guess is the MOT will cut the daily mins down from 4 hours a day.

Or demand double crews.

Should be interesting this year.

[Icewind]

On 3/29/2023 at 9:34 AM, Rotorhead205 said:

So this a leaked Transport Canada draft copy? ... Or someones personal interpretation of 707 - 703? 

 

This says that Loaded Patrols are 703, but working on actual fires is 702.

Its real.

[Freewheel]

On 3/29/2023 at 10:42 AM, Actuality said:

This advisory circular was sent to me by a friend. 
 

thoughts?

ADVISORY_CIRCULAR_700-XXX_CARRIAGE_OF_PERSONS_DURING_AERIAL_WORK-_DRAFT_ADVANCE_COPY.pdf 213.35 kB · 80 downloads

Just when I thought I was done with this thread, the TC Standards Branch pipes up 😂 

Well, the first paragraph is accurate at least “This AC on its own does not change, create, amend or permit deviations from regulatory requirements, nor does it establish minimum standards.”

thankfully this document is merely Advice, as the title asserts. Poorly worded advice.

Quite a bit of overreach, by the bureaucrats . Particularly in their efforts to re-write the regulations on Aerial Inspection through Guidance Material. That puts standards in non-compliance in my books. Convenient that they left the ACTUAL CARs definition out of the AC, isn’t it.?

No mention of the requirements for technical inspection, trained personnel or  to collect imagery and make a report in the CARs definition. 

And loaded patrol, flights that are intended to inspect the forest for smoke or fire is clearly aerial inspection, as per the ACTUAL CARs definition.

flights outside the forest fire area, where all persons on board meet the requirements of 722.16 (c) are also aerial work (whether they are firefighters or not).

aerial inspection means the inspection from an aircraft of crops, forests, livestock or wildlife, the patrolling of pipelines or power lines, a flight inspection or any other operation of a similar nature; (inspection aérienne)

yup sounds like loaded patrol to me..

I’ve already advised Standards and our inspectors that I won’t be complying with this Guidance Material, (when I submitted comments as requested at the end).

 

[Torque Split]

If you take off on a patrol and land back at the same location, it is 702 because you have not transported them between two points as is stated under the definition for 703 Air Transport