More Naps? Flight Crew Fatigue Policy Takes Off in Canada

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By Peter Menyasz

Canadian pilots could be adding naps and flying time limitations to their flight plans under a new policy Transport Canada proposed March 25 in the Canada Gazette, Part I.

The new policy would require companies to integrate annual flight time and flight duty time limitations and rules on rest periods and time free from duty. It would also require fatigue risk management systems, as well as tougher “fit for duty” requirements. The rules would be implemented through amendments to the Canadian Aviation Regulations, which are expected to be published for public comment later this year, Transport Canada said March 25 in their notice of intent.

But many in the industry say parts of the proposal don’t appear to reflect the compromises that were reached among various industry sectors and players. Some elements of the chart showing the proposed duty day for pilots were changed without corresponding changes to other parts of the proposal, according to Capt. Dan Adamus, president of the Canadian arm of the international Air Line Pilots Association.

“For us, it’s starting to get watered down,” Adamus told Bloomberg BNA. Further analysis will be needed, but it also appears some proposals that were previously all-encompassing have now been limited, he said.

The pilots group, which has championed the need for more stringent rules, is also pushing for faster implementation times among smaller airlines.

Major carriers will implement the fatigue management rules within 12 months after the regulatory amendments are finalized, according to Capt. Dan Adamus, president of the pilots group. But smaller carriers will not have to implement the rules until 48 months after they are finalized. A 24-month delay for smaller carriers would be more appropriate, Adamus said.

Adamus suggested that some industry groups don’t support all of the proposed changes, as they’re looking at the potential impact of the changes on their costs rather than the need to boost operating safety.

However, the National Airlines Council of Canada commended the government for the fatigue management initiative, as safety is the “number one priority” for its members, Grant Dingwall, the association’s manager of research and public affairs, said March 29.

“We can’t comment on the specific proposals at this time, as we are still reviewing the details and what they mean for our carriers, but we look forward to continuing to consult with Transport Canada on this important file,” Dingwall told Bloomberg BNA in an email.

Based on a meeting between industry representatives and Transport Canada officials on March 24, it seems likely that the detailed proposals published with the notice of intent are nearing a final version, Adamus said. It seems likely the regulations will be published in draft form in June 2017 and finalized by late fall, he said.

Consultations Started in 2010

Transport Canada said it first engaged industry on the issue of flight crew fatigue management in 2010 by establishing a working group to review the requirements introduced under International Civil Aviation Organization standards in 2009.

Their August 2012 final report’s recommendations, alongside an internal Transport Canada technical committee, led to a notice of proposed amendment that was subject to a review process conducted by the Canadian Aviation Regulation Advisory Council.

Stakeholder feedback led to the proposal of a two-phase approach to bring Canadian rules into line with scientific fatigue principles and international standards—the first involving rules for major airlines and the second phase to all other operators, it said. Further feedback led to a decision that proposed amendments would be introduced for major airlines, commuter airlines and air taxi operators, but would not apply to private operators, it said.

The Transport Canada notice is open to public comment through April 24.

To contact the reporter on this story: Peter Menyasz in Ottawa at

To contact the editor responsible for this story: Larry Pearl at

For More Information

The notice is available at

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