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FRMS Was Never Intended to be Imposed at Gunpoint

A Fatigue Risk Management System (FRMS) was conceived as an appendage to an SMS.  That is, Fatigue is another risk in any operation – just like any other risk to be managed. It has been over 12 years, now, and Transport Canada cannot make SMS “scalable to the size and complexity” of helicopter operations - or any other CAR 703 or 704 operation, for that matter.  Nobody really understands how SMS is intended to apply to small operators – but that doesn’t stop Inspectors from insisting upon it, or Third-Party Auditors from making findings; or the TSB from being critical of an operator’s “sub-standard” SMS in accident reports.  To add insult-to-injury, however, now Transport Canada has passed new regulations that, in many ways, cannot possibly “fit” the helicopter industry, and claim that we need only implement FRMS to find relief from these oppressive new regulations. 

These regulations, in many ways, are not “science-based” as Transport Canada has claimed, but operators will be driven to seek relief from a number of its thorniest elements through the use an FRMS.  Does industry have any reason to believe that Transport Canada will be any more successful at making FRMS “scalable to the size and complexity” of small operators than they have been at making SMS, scalable?  Furthermore, FRMS was conceived as mechanism to provide relief from selected elements of the regulations (let’s call them tweaks) – and not as a way to find wholesale relief from its major elements – Cumulative Duty Times; the restoration of the Zeroing provisions; or relief on some terms from a requirement for one-day free from duty in every seven, for example. 

Each FRMS application will need a significant investment of time and effort, and while Transport Canada has indicated that they are open to Template FRMS applications made through Associations, it is becoming clear that each one will be costly and time-consuming to produce, and will still need to be validated inside each individual operation.  You association continues to engage with Transport Canada on this important subject, and we are still cautiously optimistic that we can find a more agreeable way forward.