Important - Tc Releases Draft Of New Flight Duty Time Regulations

[GoldMember]

I agree Bob, and Paul, no one is right and no one is wrong when it comes to pilots and owners wanting different levels of involvement. I guess my attitude about work is why I'm not an owner and never wanted to be. I make a good living doing what I do, how I want to do it. Again, my issue is with the process.

[skullcap]

Again extremes. I feel that one can make an argument for any regulation they do not like. I have been stressed out in a few days listening to a customer who is telling me what to do as his 23 year old boss 2000 miles away wants it done that way(illegally). We can all find bad examples. Personally have worked many tours away from home for months and it is all how you approach things. Some owners like myself look at the job like a farmer who makes hay when the sun shines and a break when it doesn't. Oh I know that not how most in the industry approach the job and have lives to live. But we are discussing flight duty times for flight safety not a lifestyle. This is the reason it is so difficult to regulate. Our aviation history has proven itself to be one full of pioneers and thus we find ourselves trying to move forward into a world where the number one goal of the day is to cover your butt and ensure the proper boxes are checked. Thus references to the usfs requirements are not irrelevant, as they want to ensure their are restrictive limits on aircrew, they do not nor should not care where the crew takes a day off. Thus if you have issue with long tours doing a forestry contract am pretty sure you negotiate with your company not the government regulations. Otherwise the regulations become a bargaining point with your contract which really are there for safety not lifestyle.

[Freewheel]

You are right Skully, it's about safety and reducing risk. But gold member has a valid point when he says the process is flawed. Ignoring input from all sectors except for airline sector is contrary to co-operative rule making and performance based regulations which CARAC And CARS are based upon. It's also anti-SMS and contrary to National objectives.

 

So is there any evidence that these changes will refuce risk and improve safety in our sector? Is it possible, that by not being knowledgeable about our sector, they have unknowingly increased overall risk? I say it's quite likely. That is the reason for emphasis on involving industry and field personnel when creating policy under SMS principles and co-operative rule making. They generally have a good idea of the implementation challenges, and often have the best ideas as to solutions.

 

Did you know: Many occupational health and safety studies and labour boards state: "Workers new to a job are three times more likely to be injured during the first month on the job"

 

Considering no helicopter job is alike...I'd argue that every time a helicopter pilot gets sent to a new job (with new specialized duties and new people to work with and new hazards) there is a similar adjustment period and risk of incident goes up

 

airline pilots generally do very similar duties on every job

 

Increased crew changes will increase the amount of "new jobs" a pilot goes on and therefore increase this risk

[Freewheel]

You are right Skully, it's about safety and reducing risk. But gold member has a valid point when he says the process is flawed. Ignoring input from all sectors except for airline sector is contrary to co-operative rule making and performance based regulations which CARAC And CARS are based upon. It's also anti-SMS and contrary to National objectives.

 

So is there any evidence that these changes will refuce risk and improve safety in our sector? Is it possible, that by not being knowledgeable about our sector, they have unknowingly increased overall risk? I say it's quite likely. That is the reason for emphasis on involving industry and field personnel when creating policy under SMS principles and co-operative rule making. They generally have a good idea of the implementation challenges, and often have the best ideas as to solutions.

 

Did you know: Many occupational health and safety studies and labour boards state: "Workers new to a job are three times more likely to be injured during the first month on the job"

 

Considering no helicopter job is alike...I'd argue that every time a helicopter pilot gets sent to a new job (with new specialized duties and new people to work with and new hazards) there is a similar adjustment period and risk of incident goes up

 

airline pilots generally do very similar duties on every job

 

Increased crew changes will increase the amount of "new jobs" a pilot goes on and therefore increase this risk

[Freewheel]

How often does an airline pilot work with people from outside of his organization?

 

They rarely even meet there passengers and their safety briefing consists of how to fasten the seat belt and emergency exit locations. A proper safety briefing for a helicopter pilot on most jobs in Canada is more like a training session where you may be training people you've never met to prepare sling loads, load your aircraft, hover exit, use the radio, Marshall, clear landing pads, and maybe check your tail rotor in a tight confined. These people are more like crew members who you live with on the job. Many have never even been in a helicopter before.

They could be the client or another 3rd party contractor who also works for the client (ie. drill company).

I think switching out a pilot too often increases unfamiliarity in an environment where familiarity and good communications is paramount.

[Cambox]

I guess like the old adage, the only thing constant is change. Change is coming to our industry whether we like it or not, some we will appreciate, some we won't. But, it is coming .... We can accept that and plan for it or we can fight it and in the end have to adapt and try to catch up to those who were early adopters.....

 

The change might not come with this PROPOSAL, but change of a sort will no doubt come. You and I may not like the way of the future, but we will have to live it.

[Brian Jenner]

Here's what Fred Jones has to say (so far):

 

Presidents Message

Flight & Duty Time Update

 

Initial indications are, that the new regulations would increase crew costs by about 35% - in the

absence of any evidence that the new rules would actually enhance safety. Certainly too much of

an increase for any operator to absorb, in an industry whose margins are already paper-thin.

Thats 35%, IF we could find more experienced helicopter pilots in Canada to hire And dont

even get me started on how this could affect the Temporary Foreign Workers debate.

.

 

To suggest, that treating helicopter pilots and their passengers to the same safety regulations as the rest of the world would increase helicopter crew costs by 35% is, to say the least, a gross exaggeration. But one needn't argue the degree of exaggeration to find the truth about the real impact of the proposed FDT regulations.

 

If, just for the sake of argument, you translate the spector of a "35%" increase in helicopter crew costs into a % increase in total cost of helicopter services to customers, the scare mongering loses its punch.

 

To do that, calculate the cost of pilots per hour (for those without a clue, take a look at the contract pilot thread on this site) as a percentage of the total cost of leasing helicopters (the clueless can use the Alberta Forest Service hourly lease rates - described by many "35%'s" as unspeakably low and so anything but exagerated for comparison sake). Then do the same with a 35% increase in the cost of pilots. The diffrence in the two results gives the total increase in lease rates attributable to the new FTD rules and the cost to consumers for the safety advantages of treating Canadian helicopter pilots like the world class pilots they are.

 

As for suggesting that industry can't afford to "absorb" the cost increase for treating helicopter pilots like pilots in third world countries like Europe, USA, etc because of already "paper thin" margins, I have great news for the Gang of 9! With the notable exception of the Bad and the Ugly, not one of the Good operators will absorb the cost of new FDT rules - they will pass that cost along to their customers, just as they do every other structural cost.

 

When everyone's costs go up by "35%" or 3.5% or whatever, because of new FDT rules, everyone increases their prices by as much, plus whatever % profit they usually add to the cost of their services. Basic economic principle dictates that industry wide increases in cost, actually increase gross profits, for everyone, except, in this case, the Bad and the Ugly.

 

Their margins will suffer or their unfairly low rates wiill increase to the level of everyone else's, because they will no longer be able take advantage of Canadian regulatory laxism to push pilots harder than the Good operators. How much of an advantage will the Bad and the Ugly lose? Well, if you follow the reasoning of the Gang of 9, it should be something approaching 35% of the cost of crewing their helicopters.

 

By tightening FDT regulations to the point that every operator has to treat pilots the way everyone would like them to be treated, no one can any longer gain a competitive advantage by treating Canadian helicopter pilots like second class citizens.

 

Scare mongering aside, FDT rules that treat helicopter pilots like the world class pilots they are, actually comes at a very low cost increase to customers - something akin to the CPI, on a good year - that is to say, an increase in cost that the whole world takes for granted - EVERY YEAR - FOR EVRYTHING. Hardly the "sky is falling" predicted by the Gang of 9.

 

"And dont even get me started on how this could affect the Temporary Foreign Workers debate." Well said! I concur! When the time is right, I suggest someone apply basic economics to that issue too.

[Freewheel]

What makes you so certain that this will create a level playing field and stop operators from pushing pilots? These rules were obviously written with Airlines in mind and they will try to apply them to our industry (or massage them to work for heli's as you've suggested).

 

As we 've discussed the definitions for Airport Standby, suitable accommodations, home base (and lack of definition for) flight time for helicopters are all examples of this. Since these rules require "massaging" to apply them to our industry and TC lacks an effective Management System to ensure regs and standards are applied equally from region to region, it's quite likely (IMHO) we'll end up with a variety of interpretations being enforced accross the country (even from one inspector to the next). I know you've spent some time trying to deal with these "regional disparity" issues in the past (as I have read some of your past press releases). Would it not make sense to create rules that actually apply to us without the need for "massaging"? With the complete withdrawal from our industry, and lack of good helicopter people at TC anymore, this problem is getting worse.

[Freewheel]

By the way, I already consider my self a "real pilot". No need to be lumped in with airline pilots to justify my existence. I am a real HELICOPTER pilot". No stiff wing envy here lol.

[Helilog56]

 

Not sure with this Freewheel....there are good people at TC, and it's not their fault that the government has budget cut so deep in their ranks that they are to blame. I recently spent a huge amount of time helping restore an OC for a local operator, and what I came to learn that the POI's are mostly from the fixed wing side trying to do more with less as it was suggested by being forced by their employer to the rotary wing side.....and by their admission, knowing very little. The POI actually wanted us to register a complaint with his superiors....the point is, the system is broken, not the people. It was refreshing too hear that from an inspectors side that he ( and she) wanted the input and assistance from us, to expedite the OC reinstatement as quickly and easily as possible.

The point is too try and work with them, and not against.

Cheers