The Most Offensive Elements of the Proposed New Flight & Duty Time Regulations – and What Changes Could Mitigate the Damage they Would Cause

• The addition of new Start-Time and Sector-based limits on the Duty Day – Much shorter Duty Days will most adversely affect seasonal operations in Canada’s north during extended daylight periods;
• Maximum Tour-Lengths, reduced from 42 days, to 23 days – imposing a requirement for crew changes in remote areas two-to-three times more frequently;
• The addition of new Cumulative Duty Hour Limits. The concept was not supported by Transport Canada’s Fatigue Science expert, Dr. Greg Belenky, and the concept has little support otherwise in the fatigue related literature. This proposed addition to the Canadian Flight & Duty Time Regulations should be removed altogether;
• The reduction of the cumulative Flight Hours (for some industry segments) from 142 hours in 28 days to 112 hours in 28 days. There is no support for the proposition that, with adequate, regular sleep, that an individual cannot work no more than 4 hours, each day;
• New, more conservative Time Free from Duty Regulations;
• The elimination of the “Zeroing Provisions” in the current regulations – which allowed crew members who received extended periods of time free from duty (5 days) to return to work with their cumulative 30 and 90-day cumulative flight times “zeroed”. There is strong scientific support for the recuperative value of extended consecutive periods of time-off.

Northern, Remote, and indigenous communities will be hardest hit by the proposed new regulations – areas where air service is a lifeline for the community. Helicopter operators will be driven to hire 30-50% more pilots – in an environment where we cannot find enough experienced helicopter pilots in today’s regulatory environment. The cost of our services will rise, considerably – beyond the reach of some customers.

For helicopter operators, a few sample suggestions for change, follow:
• The elimination of Cumulative Duty Time Limits, altogether, for CAR 703 and CAR 704 Operators;
• The “zeroing provisions” should be re-instated for CAR 703 and 704 operators;
• The maximum length of a tour in deployed operations should be limited to 30 days (down from 42 days in the current regulations) rather than 23 in the Canada Gazette I version;
• Flight Crew members should have 10 hours in suitable accommodation to obtain 8 hours rest, whether they are at home base or away from base;
• The minimum number of days off to “zero” accumulated flight time, should increase as the tour length increases to provide a natural incentive for operators to provide more extended periods of time-off, the longer the tour-length.