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You may recall from a previous issue of the HAC Newsletter, that Transport Canada is looking for a number of operator-volunteers to participate in an FRMS Pilot Project.

Following the promulgation of the flight crew fatigue management regulations on 12 December 2018, Transport Canada has been preparing to undertake FRMS pilot projects with selected air operators reflecting a variety of flight operations conducted under Subparts 703 and 704 of the Canadian Aviation Regulations (CARs).

Air operators selected for the pilot projects will:

  • Implement an FRMS before the FRMS regulations come into force;
  • Continue to comply with existing flight, duty and rest requirements until the new prescriptive regulations come into force for 703 and 704 operators on Dec. 12, 2022; and
  • Develop a safety case(s) to justify varying from the specific flight, duty or rest requirements when those regulations come into force.

Lessons learned during the pilot projects will aid implementation by other air operators as the FRMS regulations come into force. 

Therefore, Transport Canada would like to identify a few CAR 703 or 704 helicopter air operator(s) interested in participating in an FRMS pilot project. Transport Canada will have limited capacity so they will be establishing selection criteria. The commercial helicopter community has a vested interest in ensuring that there is a broad spectrum of types of operations included in the pilot programs – particularly from non-scheduled Operators.  For the CAR 705 pilot program, a significant amount of time has been spent discussing “irregular operations”. HAC has noted “Ninety percent of our unscheduled Canadian operations consist of “irregular” or unpredictable day-to-day self-dispatch charter operations.” As noted above, one of the objectives will be to maximize Transport Canada’s scope of knowledge of FRMS examples for the drafting of future AC’s. As such, their selection criteria must include having a diversity of pilot projects. They do not want to have all pilot projects trying to exempt from the same regulation in the same way. The lessons learned during the course of the pilot projects will be shared with other parts of the industry. HAC may be in a position to lend some assistance to participating members.

Attached you will find DRAFT terms of reference for the pilot projects. These terms of reference will be modified to reflect the comments of CAR 705 operators already participating in trials and will be open for discussion with participating members of CAR 703 and 704 community.  The new airline regulations will come in to force before the new regulations affecting helicopter operators.  If you have any questions, please contact Kelly Babin at kelly.babin@tc.gc.ca or (902) 430-8392.