Cdn Duty Day Regs

[Trader]

http://www.cpac.ca/en/programs/headline-politics/episodes/61703566

 

Perhaps it is time for the Canadian unions to band together and hold their own press conference. This was frustrating to listen to!! G. Sugar, from Cargojet, even had the audacity to attempt to deflect the debate by claiming that they should be focusing more on alcohol and drugs among pilots.

[j.k.]

Should have been under the "Hard To Watch" thread... 

What a bunch of hot air in that panel...

I esp. like the part where they are complaining that we aren't harmonized with the FAA so the systems/software providers can't handle it...

I'll take FAA rules tomorrow so they don't have to worry about that.

A couple questions I would have liked to hear: 

"Why aren't the country's largest airlines up there with you?"

"Where is Air Canada/WestJet/Transat on this?"

[ng78]

It's also sad to see Mr. Sugar downplay the role of cargo pilots, insinuating that they shouldn't fall under the same rules as passenger pilots.  I wouldn't want to work for somebody like that.  

[j.k.]

He didn't seem to care about whatever gets passed, he just wants cargo out.

So much for supporting his associates.

[Guest]

33 minutes ago, j.k. said:

He didn't seem to care about whatever gets passed, he just wants cargo out.

So much for supporting his associates.

 

supporting his customers instead and thus the wages paid.  Not to say that duty time isn't a problem.

[J.O.]

Does any of you have direct knowledge of the work schedules of Cargojet’s pilots? 

[Zan Vetter]

Nights

[rudder]

This whole debate is the W.H.A.M. ideology in full force. Make all of the changes you want but just don’t make any changes that affect my operation.

This whole subject has been epic fail in terms of process, result, and implementation. The mess started with the Conservatives and has been further mismanaged by the current Minister of Transport.

[Bobcaygeon]

Cargo in the US is exempt and that is Cargojet's direct competition so why wouldn't he be concerned?

WJ/AC/Transat have their own lobby group, NAC

Am I incorrect in my understanding that flight & duty time for this event would comply with FAA and EASA regs. I believe it would have been in compliance.

All other things aside.

 

[Moon The Loon]

https://www.theglobeandmail.com/politics/article-proposed-rules-to-prevent-pilot-fatigue-could-hurt-service-to-northern/

Proposed rules to prevent pilot fatigue could hurt service to northern communities, transport group says

 

Gloria GallowayParliamentary reporter

Ottawa

 

Plus ca change...

[Kip Powick]

3 hours ago, Moon The Loon said:

https://www.theglobeandmail.com/politics/article-proposed-rules-to-prevent-pilot-fatigue-could-hurt-service-to-northern/

Proposed rules to prevent pilot fatigue could hurt service to northern communities, transport group says

 

Gloria GallowayParliamentary reporter

Ottawa

 

Plus ca change...

 

"Click on Link"

https://www.theglobeandmail.com/politics/article-proposed-rules-to-prevent-pilot-fatigue-could-hurt-service-to-northern/

[blues deville]

The regulations were based on the rules that exist in Europe where there is a completely different type of flying environment, he said. The distances between European destinations are shorter, the aviation infrastructure less rustic, the weather is more temperate, and there are fewer small carriers.

“We do feel that things need to change,” Mr. Hankirk said, “but consult with us. There has been no legitimate consultation process.”? 

Mr. Hankirk has a  valid argument in my opinion when it comes to northern ops and duty days. For anyone who has flown or spent any amount of time working in Canada’s North knows it does take a different work ethic and mind set. No two days are the same and working conditions can be incredibly harsh. There is no comparison to what an AC, AT, SW or WS flight crew does in a work day. Non-radar airspace, gravel strips, limited weather info, and in some cases much older and less sophisticated aircraft. 

 

[Vsplat]

Well, a few things. 

The consultation process has been nearly continuous since these rules were first conceived in the early 1990's.  I have lost count of the number of working groups, meetings, lobby efforts.  If this person thinks there hasn't been consultation, it's because they haven't engaged.

As for the north. Been there.  It is the way it is because of choice.  The long days, antiquated equipment and, frankly, lower level of safety are tolerated now in the north as they once were in the south.  Yes it is a different part of the world.  But flying in an exhausted state doesn't make a northern operation safe.

There is this circular justification cycle that NATA and ATAC use and it has to be called out for what it is.  Don't pay for infrastructure improvement because the cost will kill aviation.  Then use that crumbling infrastructure to justify special duty regs, because better duty regs don't fit with the infrastructure.  BS.

In the mean time, we have these northern operator/owners driving their pilots until fatigue causes a failure, then blaming/firing the pilots involved for screwing up.  It's a coal mining mentality that lost relevance in the last century.

Transport has to get off their duff and show some leadership.  This passed embarassing a decade ago.  Now it is just sad.

All just my opinion.

Vs

[blues deville]

I guess I was lucky in that I never experienced working until the point of extreme fatigue but I’m sure they are those that have had that situation. Of course I was much younger then and could handle the hard work in one time zone. But I was also careful of where I would accept a job. Not always an option for new pilots starting out their flying careers. However, several years later I found it more tiring during and after a pre-CARS 15 hour duty day BGI turn with a fully automated, auto-land capability aircraft that I didn’t have to load.

While I agree these duty day rules are long overdue, my point is they cannot be applied across the board due the unique geographic nature of Canada. I think our varied types of flight operations is one of the main reasons for this never ending review. 

[Vsplat]

I agree that a one size fits all approach is bound to fail.  It's to easy to create a gridlock of reasons for and against based on corner cases on each pole.

I can't argue with your comment on the difference in the type of fatigue an airline operation attracts.   I think we've all experienced hanging in the straps at the end of a transcon redeye or a long, rough crossing.  The automation is both threat and mitigation, but to me, there has been a long, insidious creep toward more risk, based on the assumption that high tech aircraft are easier to fly, so you should be able to do more with them.   The promise was more safety for the same operation, but in fact the operations have been extended based on about the same (or subjectively similar) appetite for risk.   So crews run into more than one limiting condition, tired, carrying multiple MEL, optimized fuel and a complex approach, maybe in heavy weather or limiting terrain, running complex equipment where dispatch or automation hide problems until they can't be hidden further.

The continuous loop can only be ended with a referee's whistle.  Instead, crickets from Tower C.  Hmmmmm

Vs

 

 

 

[J.O.]

I suspect part of the delay is because there is disagreement among the folks in Tower C as to what they should and shouldn't implement. At a course I attended recently, I saw evidence that they're struggling to define what is needed for an approvable and effective FRMS that would allow things like ULR ops to continue under the proposed regulations.

It's my opinion that fatigue needs to be part of a larger discussion on "fitness to fly". Like it or not, there's more recent evidence of incidents and accidents being traced to a pilot's fitness to fly than ones that have been linked to fatigue. Some promising research has been done on fitness to fly and simple and effective tests have been developed to determine it. But here's the rub - would operations managers and individual pilots be willing to accept (and work within) a process that could define a person's fitness to fly when it could result in a pilot requiring replacement at the start of a duty period if they failed the test?

[Vsplat]

I think 'fitness to fly' has relevance, but due to the long context with the medical side and the lengthy suspension procedures, it would be a tough stretch.  Fitness for a specific duty period might be more adpatable.  I was fit yesterday, not today, but will be tomorrow.

As for a specific test, that would be the holy grail.  Having an objective test would, I think, be embraced by both sides as it would be much easier and would rule out opportunities for abuse on both sides.

Trouble is, I could be flying with an individual less than half my age.  Fatigue would present and progress very differently between us.  I might know that, although I feel pretty good right now, that reassignment from the 5 hour duty day I was expecting to a 13 hour run into my planned rest time isn't going to work.  But for the younger, more fit pilot, it might not pose any issue at all.

Vs

[Bobcaygeon]

4 hours ago, Vsplat said:

Well, a few things. 

The consultation process has been nearly continuous since these rules were first conceived in the early 1990's.  I have lost count of the number of working groups, meetings, lobby efforts.  If this person thinks there hasn't been consultation, it's because they haven't engaged.

As for the north. Been there.  It is the way it is because of choice.  The long days, antiquated equipment and, frankly, lower level of safety are tolerated now in the north as they once were in the south.  Yes it is a different part of the world.  But flying in an exhausted state doesn't make a northern operation safe.

There is this circular justification cycle that NATA and ATAC use and it has to be called out for what it is.  Don't pay for infrastructure improvement because the cost will kill aviation.  Then use that crumbling infrastructure to justify special duty regs, because better duty regs don't fit with the infrastructure.  BS.

In the mean time, we have these northern operator/owners driving their pilots until fatigue causes a failure, then blaming/firing the pilots involved for screwing up.  It's a coal mining mentality that lost relevance in the last century.

Transport has to get off their duff and show some leadership.  This passed embarassing a decade ago.  Now it is just sad.

All just my opinion.

Vs

The consultation process has been continuous and the industry has been involved but nothing has changed at all, nothing. It's been "one-size-fits-all" from the get go.

It's not "consultation" when the proposed plan looks exactly like it did 10 years ago. 
even after all this time TC's response to questions is "We know there's a problem with the way the regs and guidance material is written but we'll fix it afterwards." 

No ones needs regulations that leave the interpretation to each individual inspector and region. We already have that problem with 22 year old regs.

[Zan Vetter]

2 hours ago, Vsplat said:

I think 'fitness to fly' has relevance, but due to the long context with the medical side and the lengthy suspension procedures, it would be a tough stretch.  Fitness for a specific duty period might be more adpatable.  I was fit yesterday, not today, but will be tomorrow.

As for a specific test, that would be the holy grail.  Having an objective test would, I think, be embraced by both sides as it would be much easier and would rule out opportunities for abuse on both sides.

Trouble is, I could be flying with an individual less than half my age.  Fatigue would present and progress very differently between us.  I might know that, although I feel pretty good right now, that reassignment from the 5 hour duty day I was expecting to a 13 hour run into my planned rest time isn't going to work.  But for the younger, more fit pilot, it might not pose any issue at all.

Vs

Uh oh age has entered the picture. I thought this was a no go topic, insofar as being too old to fly. Are you suggesting different, lower duty limits based on age? I know you’re not, but perhaps being able to work a full duty period, per CARs, is a BFOR. One size fits all indeed!

 

[Vsplat]

Well. it's been my view that political correctness and the inability to speak truth unto power has killed its fair share of aviators and their passengers.  The Challenger accident is one of the more vivid examples that comes to mind.

Is it politically incorrect to comment that the older one gets, the more easily one tires?  I haven't seen too many 80 year old marathon winners lately.  Must be just the channels I watch.

To be clear, yes, if we are serious about applying science to this topic, then we have to apply all of it, not just those elements that pass the squirm test.    Age is one criterion, mild sleep apnea might be another, a whole host of things would likely factor in.  

As for being 'too old to fly', that's its own political campaign.  This particular discussion isn't about competence or cognition, but alertness and endurance. 

Vs

[Zan Vetter]

Alertness and endurance. If licensed pilots, of any age, can’t demonstrate those qualities at the start of every pairing, they are unfit. Might be acute, might be chronic. Age is a factor, no doubt. Now, if we are going to eliminate age as a disqualifying factor to hold an ATPL, better we ensure that all license holders are accepting work within their capability to perform. Lower FDT’s definitely extend the age to which one would be able to work a full day, be that 13, 12 hrs, 10 hrs overnight or whatever. I’m 40 and working 14 hrs is difficult, as it was at 25.

BTW, claiming northern work is for young men is...false. There is no age limit, ergo the FDTs have to assume a 64-yr-old doing the flying. I mean, this is the entire basis of all aeronautical certification- consider the worst case scenario and add a margin! Why it’s different with FDTs is an enduring shame on our regulators.

[Bobcaygeon]

15 hours ago, Zan Vetter said:

BTW, claiming northern work is for young men is...false. There is no age limit, ergo the FDTs have to assume a 64-yr-old doing the flying. I mean, this is the entire basis of all aeronautical certification- consider the worst case scenario and add a margin! Why it’s different with FDTs is an enduring shame on our regulators.

No it isn't just worst case. Certification is often based on number of bums in the seats. 703, vs 704, vs 705 aircraft all have different aircraft and pilot certification requirements.

[DEFCON]

With respect; pilot talk is cheap, just as it's always been.

Everyone that matters is well aware that no matter the issue and in spite of all their ranting, pilots will tuck their tails and comply with the direction of the suits.

 

 

[Guest]

42 minutes ago, DEFCON said:

With respect; pilot talk is cheap, just as it's always been.

Everyone that matters is well aware that no matter the issue and in spite of all their ranting, pilots will tuck their tails and comply with the direction of the suits. 

 

 

A common reframe is to blame the "Suits" or indeed those with a MBA for almost everything.   Blaming them for everything is a little like saying "the devil made me do it"  Isn't it about time for pilots to stand up and be counted?

 

[Seeker]

The MBAs certainly take credit and richly reward themselves when something/anything goes right so I see no foul in giving them the "credit" when things don't go right.