Tell your MP why fatigue rules are important

We are just under a week away from the new Canadian Liberal government announcing Justin Trudeau’s cabinet. When the cabinet is announced, it will be important to remind the new Minster of Transport, and your local MP, about how significant revisions to the current pilot fatigue rules are.

Just to recap, in September 2014 Transport Canada issued a Notice of Proposal Amendment regarding pilot fatigue management. I talked about these changes a few days after the proposal was published. Transport Canada based its recommendations on consultation with a whole slew of professionals and experts. They believed these changes would “reduce flight crew member fatigue related error and accident rates and thus enhance safety.”

In August 2015, a more finalized version of changes was published in the Canada Gazette, the official newspaper of the Government of Canada. This new version does contain some of the original recommendations. However, it has been vastly reduced to only a handful of changes.

[box]2014 Proposal vs. 2015 Proposal

Click the chevron to expand:[expand]Below is a table of the proposed changes from 2014. The right column shows the changes. The “X” means the change was removed. The “-” means the change was reduced. The “=” means the change was left as is. The “+” means additional changes were added.

September 2014 Proposal

2015 Canada Gazette Part 1

Definitions

times

Air Operator Responsibilities

times

Flight Crew Member Responsibilities

times

Prescriptive Fatigue Management Documentation

times

Nutrition – Providing the Flight Crew Member with Food and Drink Opportunities

times

Records of Flight and Duty Times and Rest Periods

times

Flight Duty Period

minus

Flight Duty Period – Aerial Application Operations

times

Extension of Flight Duty Period Due To In-Flight Rest

times

Unaugmented Long Range Flights

times

Ultra Long Range Operations

times

Unforeseen Operational Circumstances — Pilot-In-Command’s Discretion

times

Unforeseen Operational Circumstances — Short-Term Re-Planning — Pilot-In-Command’s Discretion

times

Delayed Reporting Time

times

Cumulative Duty Hour Limitations

times

Flight Time Limitations

Changes Reduced

Positioning

times

Split Duty

times

Standby

times

Airport Standby

times

Rest Periods

minus

Time Free From Duty

minus

Additional Rest Due To Disruptive Schedules

times

Additional Rest Due To Time Zone Differences

times

Consecutive Duties Infringing on the Window Of Circadian Low

times

Determining Flight Duty Period Table Start Time

times

Fatigue Management Training

equals

Controlled Rest on the Flight Deck

times

[/expand][/box]

One of the most significant holes is that the new rules would only apply to 705 (airline) operations. Smaller operations would still exist under the older, outdated, regulations until they can be updated at a later date. This is a double standard for aviation safety, saying the safety of bigger airlines is more important than smaller. Many Canadians don’t realize how important aviation is to so many northern communities. Smaller operators fly smaller aircraft all over the north, sometimes referred to as bush flying. The hours are long, labour intensive (no ground staff to load bags, give passenger briefings, clear snow off the wings), and at all hours of the day. Compared with the average airline pilot, there is a much higher risk of fatigue.

While operators are complaining about the cost of implementing these safety changes, it is important to note that Canada is one of the last major country to do so. We fall behind Australia, United States, India, United Arab Emirates, United Kindom, and the European Union. This has been a long time coming and should be no shock.

Duty Restriction by Country

Ironically, many of the bigger 705 operators already have internal rules that exceed the current and proposed fatigue regulations. So, if the rules as seen in Gazette do come into place, there will likely be little effect. The pilots of small operations that need the most protection will not see any changes in their rules unless the government blankets fatigue rules to all commercial pilots.

Write to your MP and the Minister of Transport

I encourage everyone to write to their MP and the Minister of Transport to explain why having science-based, internationally recognized, fatigue regulations is the right choice. For us pilots, we can all likely recount some fatigue-related moments in our careers and it is important to talk about. It is also important for to pilots stop ignoring the signs of fatigue and speak up.

How to contact your MP

You can find contact information of your MP here.

You can send letter mail to your MP, postage free, by using this address:

Name of Member of Parliament
House of Commons
Ottawa, Ontario
Canada
K1A 0A6

Contact information for the Minister of Transport will be available at a later date.

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