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Transport Canada Clarifies the Application of the New Fatigue Management Regulations

As you may recall, CAR 702 Operations are excluded from the requirement to comply with the new Fatigue Management Regulations. Transport Canada has recently made it clear that the transportation of crews to/from the Aerial Work site will also be excluded from the application of the new regulations. For example, flights to move firefighters from the airport or townsite to the fire will be considered Aerial Work operations for the purpose of the new rules. Flights being used to move Powerline patrol or Aerial Construction workers to the work site will fall into the same category.

While HAC has always supported the exclusion of Aerial Work Operations from the application of the new regulations, we have argued that the distinction will create significant tracking issues in an industry that often flip-flops between CAR 702 and 703 operations multiple times in the same day. The new rules became law on December 12 of 2018, but will not come in to force until December 12, 2022. 

HAC is continuing to oppose certain elements of the new regulations as being inconsistent with the fatigue-related science, while at that same time working with Transport Canada to find a variant of Fatigue Risk Management Systems (FRMS) that will allow HAC and other Associations to develop Template FRMS for certain key fatigue-related principles.