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New Fatigue Regulations

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A CARAC board member once told me that (way back) the idea of duty limits for engineers was thrown around. IN 2005, when they began the.implementation of SMS on all sectors, it was decided that this compliance based mindset was contrary to  SMS principles. Under SMS, companies would be able to assess the risks at their organization and set their own limits and it would ultimately lead to de-regulation.

The FRMS is based on these principles. Here is the problem, it’s 14 years later and they TC still haven’t been able to ensure implementation of  SMS in most sectors and air carriers in Canada. I’m guessing FRMS will go about as smoothly as SMS.

I also doubt that the average TC inspector, with no helicopter experience will understand the risks in our operations, so getting approval for deviations will likely be a nightmare. I also suspect that regional disparity will be rampant, whereby one operator can receive certain approvals, but others won’t. 

I for one think that AME’s should have Duty limits in the CARs. It’s a safety sensitive position and they work mostly at night. The “science” suggests they would be prone to fatigue.

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I spent more than a few tours working on 204-205 when the company I worked for was strapped for an engineer.I can say that I never had to pull an all nighter...not once. That being said I would always be up very early in the morning doing whatever I could do as long as the ship was ready to go on short notice. By 8 it had to be ready to go. The pilots that I worked with were quite fine with that arrangement.During the day I would always be going over the ship whenever I could... again it had to always be ready to go as it would be on red alert.Usually by 9 in the evening it would be okay to start working on the ship again.I was usually horizontal by 11 or midnight.I would say that most of the guys that I worked with did the same routine. You could get a bit of rest when the ship was out but I fined it hard to sleep once I get up. Lets say the coffee pot was always fresh. Also if the ship went out early enough I would catch a few hrs of sleep. Never seemed to be a problem. That being said I am sure others have found it to be more difficult...all depends on how much flying is being done. The ship that I looked after in the summer of 1995 was flying around 5 hrs a day so it wasn't too hectic .My only complaint was I got very little time off.

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6 hours ago, DGP said:

I spent more than a few tours working on 204-205 when the company I worked for was strapped for an engineer.I can say that I never had to pull an all nighter...not once. That being said I would always be up very early in the morning doing whatever I could do as long as the ship was ready to go on short notice. By 8 it had to be ready to go. The pilots that I worked with were quite fine with that arrangement.During the day I would always be going over the ship whenever I could... again it had to always be ready to go as it would be on red alert.Usually by 9 in the evening it would be okay to start working on the ship again.I was usually horizontal by 11 or midnight.I would say that most of the guys that I worked with did the same routine. You could get a bit of rest when the ship was out but I fined it hard to sleep once I get up. Lets say the coffee pot was always fresh. Also if the ship went out early enough I would catch a few hrs of sleep. Never seemed to be a problem. That being said I am sure others have found it to be more difficult...all depends on how much flying is being done. The ship that I looked after in the summer of 1995 was flying around 5 hrs a day so it wasn't too hectic .My only complaint was I got very little time off.

Let’s face it, flying a 14 hour duty day and wrenching for 3 hours after that is ridiculous. 

I’ve worked with a lot of great AME’s on mediums on fires and other op’s, most of them just work their own program. Some like to work after the machine is shut down at night, others like getting up early in the morning. From what I have seen, it’s the operator that determines the workload. The progressive operators try and anticipate components coming due versus the work coming up in the busy season. Having said that, AME’s  deserve protection from fatigue just as much as pilots. I’m not sure how you get there, the business is so fluid. 

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Only had one component to replace on that ship...the swashplate. Didn't happen until almost the end of the season.Started pulling it at 8 in morning and was flying again by 4 in the afternoon. Had help from a good apprentice. Heard from him years later and he told me he had to replace a swashplate on a 205 and said he remembered helping me out and said he was glad to have learned from what I had shown him...we had a lot of fun together.He wrenches on mediums out west now.

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As far as ridiculous goes the worst was spraying...try getting up at 3:45 and go do 8 hrs of spraying .That was really a pain. Did that for more years than I want to remember.

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the biggest thing for me as far as fatigue went,  as a field engineer, was the fluctuation in the work times and duration.

If you did the same routine all the time it was easy to get used to, whether it was a 3am start time or a 3am finish time...you do it consistently then your body adjusts.

However, that was never the case for many reasons. Whether it be schedule conflicts, or unplanned events, it was near impossible to follow any time line that allowed you get proper rest. As a general rule, or out of respect, we always let the pilot sleep, even though many times we would have loved to wake him/her up at 3am for that leak check so we could go to bed and stay in bed until we got all the rest we needed.

 

 

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As I had said what pissed me off was the lack of time off.I worked for 4 months with 7 days off. Any thanks...not likely... I ended up pulling the pin the following spring but little changes from one company to the next only the faces. I have mentioned in another post on here that I pulled that 205 completely apart that I was working on and then said syanarha folks.

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Well, with regards to slinging mud at the old generation...kinda sound like a melinuim child.   That generation figured out the hard way everything we know today. Many died along the way. All that training our generation gets, mountain courses, longline, not to mention extremely powerful, high performing machines....Everything our generation is taught came from that generation, have some respect.  

As far as the regs,  Most good companies are doing 2 and 2 anyways, it’s only the bottom feeders raping for the 42 and 5.   HAC should do somthing about the pathetic rates and then companies might be able to afford another crew change. I just came back from over seas, it was a real eye opener to see how good it can be for everybody when the rates are proper, beautiful aircraft,  excellent, endless training and good pay along with sched/rotation. I really see how bad it is in Canada when going over seas, , it’s such a shame, especially for the good operators out there.  HAC has their panties all tied up in a knot about the new regs,  I say untie them and deal with the rates.

 

HAC is for operators, not pilots.

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On 12/19/2018 at 12:44 PM, GrayHorizons said:

I thought it was because bureaucrats loved paperwork and hiring their friends/family to fill the spots to shuffle file and sort all that paperwork.

Dammit, it's really about the accidents? 

Lets ignore the obvious discrepancy of the year 2007, but both those graphs came from the same report....In general, you can see a gradual decline over the years....20 yrs in fact. Ive been in the industry for 30, So my generation has been a part of the decline, however slight it may actually be. 

So you may want to sling mud Mr Swinger and blame others, but you're comments dont hold much weight because there is no definitive line that can be drawn for one generation to the next. 12 accidents per 100000hrs down to 10 over a  20yr period  hardly seems worthy of mention.

 

ss07_figure_1.gif

ssea-ssao-2017-figure-01.png

Sorry for hurting your feelings.  

So correct me if I’m wrong,  the way I read your fancy transportation safety board graphs is 380 ish accidents in 1998 to 190 ish in 2017,  that seems pretty significant actually almost 200 less reportable accidents per year over 20 years not to mention anyone who has been in aviation for 20+ years knows accidents/ incidents were not reported like they are now.  Period.

But anyway I could go on and actually sling some mud but I won’t,  just not sure what your point is?

 Are you against the new fatigue regs?   Do you think pilot/ engineers working 16 hours a day is safe?

Are just really sensitive and now you’re mad at me because of my opinion? 

It’s based on personal experience.

 

 

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