Overview of the new regulations on flight crew fatigue management

Backgrounder

All flight crew experience the detrimental effects of fatigue, whether they are flying cargo or passenger planes, short-haul or long-haul. To ensure the safety of passengers and crew, the Government of Canada sets limits to the amount of time a crew member can be on the job.

The changes to flight crew fatigue management include two essential elements:

  • New prescribed flight and duty limits that are grounded in modern science and better manage the length of time that a crew member can be on the job (see table below); and
  • Fatigue Risk Management Systems that will allow operators the flexibility to vary from the prescribed limits based on their unique operations if they can demonstrate that alertness and safety will not be affected.
New prescribed flight and duty time limits (subparts 705, 704, and 703 of the Canadian Aviation Regulations)

Flight time
Previous regulations (1996)
  • 1,200 hours in any 365 consecutive days
  • 300 hours in any 90 consecutive days
  • 120 hours in any 30 consecutive days
  • 40-60 hours in any 7 consecutive days
New regulations
  • 1,000 hours in any 365 consecutive days
  • 300 hours in any 90 consecutive days
  • 112 hours in any 28 consecutive days
Flight duty period
Previous regulations (1996)
  • 14 hours (aerial workers and air taxi operators) or
  • 13 hours, 45 minutes (commuter operations and airline operators)
New regulations
  • Maximum 9-13 hours – based on start time of day/sectors flown
Rest periods
Previous regulations (1996)
  • 8 hours plus time for meals, personal hygiene, and travel to and from suitable accommodation
New regulations
  • At home– 12 hours or 11 hours plus travel time, or 10 hours in suitable accommodation provided by the air operator
  • Away from home – 10 hours in suitable accommodation
Time free from duty
Previous regulations (1996)
  • 36 hours / 7 days; or
  • 3 days / 17 days; or
  • 3 periods x 24 hours / 30 days
  • 13 periods x 24 hours / 90 days.
New regulations
  • Option 1:
    • 1 single day free from duty per 7 consecutive days
    • 4 single days free from duty per 28 days
  • Option 2: 5 days off per 21 days
Consecutive night duties
Previous regulations (1996)
  • Not applicable
New regulations
  • Maximum of 3 nights of duty in a row without a rest during the night
  • If a rest is provided during the night, up to 5 consecutive nighttime duty periods
Fatigue Risk Management Systems
Previous regulations (1996)
  • No Fatigue Risk Management Systems option
New regulations
  • Option to use Fatigue Risk Management Systems
Coming into force
New regulations
  • 24 months for major Canadian airline operators (subpart 705)
  • 48 months for smaller and regional operators (subpart 704 and 703)

Fatigue Risk Management Systems

Transport Canada is committed to improving the safety of Canadians and to reducing fatigue for all flight crews.

The new regulations recognize that a one-size-fits-all approach may not work for everyone or under all circumstances. They include an option for operators to develop and implement a Fatigue Risk Management System to identify and minimize the sources of fatigue and manage fatigue risk in an operation.

A Fatigue Risk Management System is an overall risk management approach in which air operators:

  • identify hazards;
  • assess risk;
  • develop mitigation strategies;
  • provide fatigue management training and education;
  • use fatigue monitoring systems; and
  • improve processes to reflect changing circumstances and feedback.

A Fatigue Risk Management System provides an alternative for operators that may have constraints meeting the prescribed flight and duty time limits due to the unique nature of their operations (e.g., ultra‑long haul flights or flights serving northern and remote communities).

Example:

A cargo operator regularly flies from A (home base) to community B to off-load a large amount of supplies and then returns to A. There is a long layover at community B while supplies are being off‑loaded by airport employees. The entire route is in the same time zone. Including the time required for loading and unloading, the total duty time for the crew is 14 hours from start to finish.

Possible mitigations under Fatigue Risk Management System that may provide the operator to be exempted from prescribed flight duty time could include:

  • Providing a napping/rest facility where the pilot may rest during off loading and loading operations;
  • Limiting the number of consecutive shifts;
  • Providing a minimum of 2 days off duty each week; and
  • Avoiding schedules with early starts and late duties;

Over the next four years, Transport Canada specialists will support and work in close collaboration with northern and remote operators to help them develop and implement their own Fatigue Risk Management Systems.

Transport Canada will continue to work with operators to develop and refine guidance material, and build common tools to support their operations. This will be led by a Transport Canada Fatigue Risk Management System Special Advisor and in collaboration with industry through focus groups, workshops, and pilot projects.

The use of a Fatigue Risk Management System requires an organizational culture whereby fatigue risk management becomes as much a part of day-to-day operations as pre-flight checks and keeping pilot log books. A positive and supportive safety culture recognizes fatigue as an operational issue, and encourages open and honest reporting of fatigue and fatigue hazards.

This approach intersects with safety management systems, so air operators who already have Safety Management Systems in place can adapt their processes to manage fatigue-specific risks.

Transport Canada will review all systems to make sure they meet regulations. An air operator will only be allowed to operate flights under a Fatigue Risk Management System if the operator can demonstrate that safety is not affected.

December, 2018




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