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Flight & Duty Time – It’s Not Over, Yet

Your association has been actively investigating our options, since the new Flight & Duty Time regulations were brought in to law on December 12 2018. The new rules will come in to force for our industry segment on December 12 2022, but bad news never gets better with time, as-they-say. Your Board and your President & CEO are actively considering options that are available to industry. Notwithstanding that a Fatigue Risk Management System (FRMS) is supposed to provide relief from the thorniest parts of the regulation, it appears that is requirements are still largely beyond the reach of small operators to implement – even through the use of an HAC-sponsored FRMS Template. An HAC FRMS template will entail a significant cost to HAC – and also impose significant costs on individual operators to validate the template inside their own operation. There will also be significant ongoing subscription costs, according to a proposal recently received by HAC’s Board. FRMS for small operators will be a challenge for the regulator, in the same way that regulating a SMS that is “scalable for the size and complexity of small operator”, has been a problem. After all, FRMS, at its heart is only SMS for fatigue-related risks. It’s been 13 years, and Transport Canada still can’t regulate SMS for CAR 703 and 704 operators.  What’s more, FRMS was never intended to overhaul oppressive regulations – but only to tweak them, to smooth out their roughest edges. In many areas, we continue to believe that the regulations are unsupported by the fatigue related science – specifically where the removal of the zeroing provisions; Cumulative Duty Hours; and Tour Lengths, are concerned. Stay tuned to the Newsletter, as your association continues to work with Transport Canada on this critically important issue, to find a solution that can work for the Canadian helicopter industry.