New Fatigue Regulations

[Freewheel]

A much more effective Corrective Action would be to drop the on-size fits-all approach entirely, and quit trying to impose airline style rules, that came from collective bargaining, and not science. 

Most people in our industry were not opposed to modernization of these rules, but their approach is contrary to their own principles of SMS. They should have listened  to stakeholders from other sectors and creating specific rules for those sectors. Now TC regional authorities are scratching their heads.
These rules are far too cumbersome, and will likely lead to an increase in accidents, reduced safety levels. At the same time, they also have the potential to drastically increase costs and reduce services for northern communities, natural resource industries, massive infrastructure projects, critical mineral exploration, fire fighting and emergency response (many of which are ultimately funded by the government themselves).

When choosing to only listen to the airline sector, it appears their only consideration was the number of passengers that are moved, and direct industry revenues. They completely failed to recognize the size of the economic footprint that our industry has in this country.

Add the fact that the economy is on a very bumpy path, after they shut it down for 3 years, and it’s a recipe for disaster.

[Bee3]

18 hours ago, Freewheel said:

A much more effective Corrective Action would be to drop the on-size fits-all approach entirely, and quit trying to impose airline style rules, that came from collective bargaining, and not science. 

Most people in our industry were not opposed to modernization of these rules, but their approach is contrary to their own principles of SMS. They should have listened  to stakeholders from other sectors and creating specific rules for those sectors. Now TC regional authorities are scratching their heads.
These rules are far too cumbersome, and will likely lead to an increase in accidents, reduced safety levels. At the same time, they also have the potential to drastically increase costs and reduce services for northern communities, natural resource industries, massive infrastructure projects, critical mineral exploration, fire fighting and emergency response (many of which are ultimately funded by the government themselves).

When choosing to only listen to the airline sector, it appears their only consideration was the number of passengers that are moved, and direct industry revenues. They completely failed to recognize the size of the economic footprint that our industry has in this country.

Add the fact that the economy is on a very bumpy path, after they shut it down for 3 years, and it’s a recipe for disaster.

Hear Hear 👏🏿

[Freewheel]

On 12/23/2022 at 3:50 PM, November said:

 

“You go back to get all the rest of his crew and as they dont have to look at anything while enroute to the dropoff point, they would be classed as 703 and you cant do a hover exit with them.”  
 

For safety and situational awareness all members of the crews must take a look from above before being dropped off…. In your recurrent training you must be instilling that everyone that flys in the aircraft in this particular theatre (fires) become essential crew for the safety of the whole operation? From holding their gear down on the pad/lz to looking over aircraft from where they crouch for oil leaks, smoke, fire, open/broken cowlings closed cargo/tailboom doors etc etc 

Seems to be a no brainer (702) but maybe not nowadays..

 

I like your line of thinking. So let’s step out of the (fires) theatre. The essential tasks you are discussing could also apply to just about anytime you drop someone in the bush, particularly with rotors turning….agreed? There is some likelihood that someone could question whether all persons on board were essential, but I’ll play along…

What about fly drill jobs? I would say that flying the drillers out to the drill site (and back) in order to move the drill by external load is obviously 702. Agreed?

What about once the move is done and your just doing crew change and flying them back and forth to operate the drill between moves?

[simpleton]

18 minutes ago, Freewheel said:

What about fly drill jobs? I would say that flying the drillers out to the drill site (and back) in order to move the drill by external load is obviously 702. Agreed?

What about once the move is done and your just doing crew change and flying them back and forth to operate the drill between moves?

The exact wording of 722.16(c) says "to" an aerial work location, not "to and from"......Transport would say that to/from is implied (which I would agree with), yet it doesn't actually say that in writing.

All simple wording issues that they have had years to fix in the regs.

[November]

1 hour ago, Freewheel said:

I like your line of thinking. So let’s step out of the (fires) theatre. The essential tasks you are discussing could also apply to just about anytime you drop someone in the bush, particularly with rotors turning….agreed? There is some likelihood that someone could question whether all persons on board were essential, but I’ll play along…

What about fly drill jobs? I would say that flying the drillers out to the drill site (and back) in order to move the drill by external load is obviously 702. Agreed?

What about once the move is done and your just doing crew change and flying them back and forth to operate the drill between moves?

Yes good question/scenario. The last program I was on 12 years ago had day and night shifts and someone had to catch my hook after crew moves to hook me to samples that needed delivery to geo at core shack - but yes we can pick fly #### out of the pepper all day and it’s almost needed.

[Freewheel]

1 hour ago, simpleton said:

The exact wording of 722.16(c) says "to" an aerial work location, not "to and from"......Transport would say that to/from is implied (which I would agree with), yet it doesn't actually say that in writing.

All simple wording issues that they have had years to fix in the regs.

Yes. I’m aware of the exact wording. I can also attest that not everyone at Transport Canada would say it’s implied. This has been brought by some at TC  in RECENT discussions. I wholeheartedly agree with you that it is implied. My response to that was that it was not reasonable to imply that a 702 could fly essential persons to an aerial work site in the bush, but not from aerial worksite, and out of the bush. They didn’t necessarily disagree, and seemed to be able to work with that concept. With that being said, who knows what will be publishing in the AC, or what 1 inspector to the next will say. Either way I have no issue operating this way. I figure in a courtroom it would sound as silly, regardless of what the expert TC witness said. 

I’m more interested in whether anyone would consider crew change to the drill and back to be 702?
I’m sure you are aware: While the vast majority of hours flown on drill jobs are the actual moving of the drill by external load, sometimes they don’t move the drill for days and twice a day you still need to make the short crew change flight, from the camp to the drill and back, to switch out the drillers while the drill is in operation….

[Pool pilot]

26 minutes ago, Freewheel said:

Yes. I’m aware of the exact wording. I can also attest that not everyone at Transport Canada would say it’s implied. This has been brought by some at TC  in RECENT discussions. I wholeheartedly agree with you that it is implied. My response to that was that it was not reasonable to imply that a 702 could fly essential persons to an aerial work site in the bush, but not from aerial worksite, and out of the bush. They didn’t necessarily disagree, and seemed to be able to work with that concept. With that being said, who knows what will be publishing in the AC, or what 1 inspector to the next will say. Either way I have no issue operating this way. I figure in a courtroom it would sound as silly, regardless of what the expert TC witness said. 

I’m more interested in whether anyone would consider crew change to the drill and back to be 702?
I’m sure you are aware: While the vast majority of hours flown on drill jobs are the actual moving of the drill by external load, sometimes they don’t move the drill for days and twice a day you still need to make the short crew change flight, from the camp to the drill and back, to switch out the drillers while the drill is in operation….

To add to your response to the moving of the crews when not actually doing a drill move are the crew not preparing the drill to be moved? Even if they are 2 days away from being ready to do the move?

I personally include in my briefing that all passengers are to be watching for other aircraft and to NEVER assume I have seen it. So my question is once given this task doesn't this make them essential crew as they now have task to do?

This could have saved lives in Australia would be my argument in a court of law. No idea if it would stand up.

This can be twisted in many ways as we are reading on this topic. And heaven forbid two TC inspectors can agree. On anything. 

[simpleton]

I would say, by the letter of the law, that if the crews need to be bumped out for the day to the drill location, but the drill or support gear is not actually scheduled to be slung that day, then it is not a flight tied directly to active aerial work, and thus would need to be flown under 703 rules to bump the crews in and out in that particular scenario. Any particular legs flight rules are dependent on it's intended purpose.

A drill support job is not likely to be considered aerial work 100% of the time for all possible flight scenarios.

[Bee3]

What a #### show this is. 
 

As Lahey would say “ it’s a shitacane coming Randy”

[Pool pilot]

25 minutes ago, Bee3 said:

What a #### show this is. 
 

As Lahey would say “ it’s a shitacane coming Randy”

I agree