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Important - Tc Releases Draft Of New Flight Duty Time Regulations


Freewheel

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I'm not reviewing the proposed changes right now, but from I remember reading, there wasn't much change to suitable accommodations definition either. Meaning: no need for single occupancy accommodations (when such a room is not available). So, with more aircrew at site (and customers having less money because of increased aircraft/aircrew rates) you'll likely be asked (pressured) to spend this "time free from duty" in quarters with other aircrew ( or worse clients/passengers).

 

Of course, this would never dawn on an airline pilot (who rarely meets his passengers and stays in hotels) or union. That is why all other associations were in joint dissent with the working group (who mostly ignored what they had to say). These proposals were driven by airline union, who have no idea what you do. How could they assess the risks when making these rules without understanding our industry. This contrary to the principles of SMS and the mandate of the rule making process.

 

Here is the joint dissent document form ATAC, CBAA, HAC and others if you haven't seen it. It was released in Jan 2013 (prior to the proposed amendments)

http://www.cbaa-acaa.ca/en/component/jdownloads/finish/4/153

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You guys don't think much of your employers to give you your days off at work. If I was told i was taking time off on the job they would be looking for another pilot.

Look around you. In today's market, if you don't do it, another pilot or operator will. The fact is people need to pay their bills. That applies to both pilots and operators. I've said the before: the requirement to pay your mortgage and feed your family is a powerful thing.

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They did introduce a way to deviate from these regulations through FRMS, whereby operators will use science and risk assessments to allow an operator to demonstrate equivalent levels of safety...but wait we are not SMS operators by regulation so how does that work? We currently must be compliant with regulations.

 

also, Good luck trying to present alternate means and risk assessments to Transport Canada (who mainly have an airline mentality these days). Example: According to high ranking officials at TC you can't carry a purse or camera in the cabin of many helicopters...

 

http://forums.verticalmag.com/index.php?showtopic=21819

 

The co-chair of this committee Jacqueline Booth (Director of Standards) also insinuated most helicopter flights in Canada have 1 takeoff and landing per flight. See Flight Time Vs Air Time forum for official CAIRS response from J. booth.

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I'm not reviewing the proposed changes right now, but from I remember reading, there wasn't much change to suitable accommodations definition either. Meaning: no need for single occupancy accommodations (when such a room is not available). So, with more aircrew at site (and customers having less money because of increased aircraft/aircrew rates) you'll likely be asked (pressured) to spend this "time free from duty" in quarters with other aircrew ( or worse clients/passengers).

 

Of course, this would never dawn on an airline pilot (who rarely meets his passengers and stays in hotels) or union. That is why all other associations were in joint dissent with the working group (who mostly ignored what they had to say). These proposals were driven by airline union, who have no idea what you do. How could they assess the risks when making these rules without understanding our industry. This contrary to the principles of SMS and the mandate of the rule making process.

 

Here is the joint dissent document form ATAC, CBAA, HAC and others if you haven't seen it. It was released in Jan 2013 (prior to the proposed amendments)

http://www.cbaa-acaa.ca/en/component/jdownloads/finish/4/153

 

Actually, on page 12 of the proposed changes:

 

Suitable accommodation means, for the purpose of standby, split duty and minimum rest, a single-occupancy bedroom that is subject to a minimal level of noise, with sufficient ventilation and the ability to regulate temperature to a comfortable sleeping temperature and light intensity or, where such a bedroom is not available, accommodation that is suitable for the site and season, is subject to a minimal level of noise and provides adequate comfort, to obtain horizontal rest, and protection from the elements.

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Exactly...where such a bedroom is not available...

That's the caveat. Pretty much the same as current definition...isn't it?

 

I have had TC inspectors tell me that single occupancy is not req'd where such a room is not available. It happens quite frequently in our industry...(especially in remote camps) under current regs.

 

I have also had provincial forest fire agencies try to have me bunk with pilots from other operators...

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Seems that the majority of the opposition to new FDT regs is coming from the HAC which represents management and/or owners.

 

It will be a good thing to work less hours. It will be a good thing to have more time off. It will be a good thing to work in a safer environment.

 

Even with the changes that will have to be implemented over a 2 year period, Canadian pilots will still have some of the highest FDT limits when compared to other countries.

 

I believe the goal is to make this industry safer. Accident rates have remained the same for over a decade. The majority of accidents can be traced back to the meat servo which is very prone to fatigue.

 

Support for a petition to keep things the same and expect a different result at the end of the day is based on unsound science.

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