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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 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 is seeking your assistance in identifying 703 or 704 air operator(s) interested in participating in a FRMS pilot project. I would like to note that we will have limited capacity so we will be establishing our selection criteria. As noted above, one of our objectives will be to maximize our scope of knowledge of FRMS examples for our AC’s. As such, our selection criteria will include having a diversity of pilot projects. By this I mean, we would not want to have all pilot projects trying to exempt from the same regulation in the same way.

See the attached Terms of Reference

HAC has raised a variety of concerns relating to the Terms of Reference, and we are appealing to Transport Canada to meet with the Associations and selected operators to resolve them, before proceeding with the pilot project.  Transport Canada has indicated a willingness to consider Association-sponsored Template FRMS relief from the prescriptive new regulations, that would then be validated by individual operators.

Interested operators should contact fred.jones@h-a-c.ca