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Old May 18, 2016, 6:37 am
  #1  
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flight and duty time regulations: ICAO vs Canada

This was posted on LinkedIn earlier today by Milt Isaacs,
Chief Executive Officer at The Air Canada Pilots Association.

"Almost every other jurisdiction around the world has implemented flight and duty time regulations to comply with science-based rules established by International Civil Aviation Organization (ICAO). Canada has not."

Full article: https://www.linkedin.com/pulse/canad...cle-title-like
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Old May 18, 2016, 2:38 pm
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ICAO is a a trade group. It does not promulgate rules or regulations. It made promulgate model rules or policies which governments such as Canada may choose to adopt.
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Old May 18, 2016, 4:23 pm
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"I think Canadian travellers would be shocked to know that only Canada, Bangladesh and India currently permit pilots 112 hours or greater flight time in 28 days."

So that would be what? 6x SE based on AQM? Something like that?
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Old May 18, 2016, 5:16 pm
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Originally Posted by Often1
ICAO is a a trade group. It does not promulgate rules or regulations. It made promulgate model rules or policies which governments such as Canada may choose to adopt.
You're thinking of IATA. ICAO is a UN agency, not a trade group.
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Old May 18, 2016, 5:16 pm
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Originally Posted by Often1
ICAO is a a trade group. It does not promulgate rules or regulations. It made promulgate model rules or policies which governments such as Canada may choose to adopt.
ICAO (International Civil Aviation Organization) is a UN (United Nations) agency. I believe you're referring to IATA (International Air Transport Association) which is the trade association for 250+ of the worlds airlines.

ICAO adopts standards and practices that each member state needs to make into rules (laws) which are them implemented by those same member states.
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Old May 18, 2016, 5:50 pm
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"I think Canadian travellers would be shocked to know that only Canada, Bangladesh and India currently permit pilots 112 hours or greater flight time in 28 days. This far exceeds the 100 hours/28 days maximum flight time in jurisdictions such at the EU, USA, Australia, UK, Hong Kong, China, Japan and many others. Countries who lead in this regard are Argentina, Brazil, Colombia and Mexico with a maximum threshold of 90 hours."

I would be very interested to know why Canadian pilots are permitted to fly 12% more hours per 28 days than and American, British or Australian pilots. Is there a scientifically-supported rationale used by Transport Canada to justify the difference?
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Old May 18, 2016, 6:04 pm
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Given that pilots are paid by the flight hour, I'm a bit surprised that the pilots union is advocating for a 12% cut in their members' monthly income. I'm assuming AC wouldn't jump at the idea of paying the same for flying less.

Then again a reduction in flight hours would require the airline to hire more pilots = higher union dues collected, so i suppose i shouldn't be surprised.

He points out that "Investigations into recent international aircraft accidents and incidents have cited pilot fatigue as a contributing factor." Unless all of those incidents happened in Canada, India and Bangladesh, presumably those "fatigued" pilots were working on a 100-hour monthly duty cycle, so not sure how much safer we'd be with the reduction.

I think what he really wants can be summed up here: "Where’s your third pilot".

Last edited by The Lev; May 18, 2016 at 6:15 pm
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Old May 18, 2016, 7:09 pm
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Originally Posted by The Lev
Given that pilots are paid by the flight hour, I'm a bit surprised that the pilots union is advocating for a 12% cut in their members' monthly income. I'm assuming AC wouldn't jump at the idea of paying the same for flying less.

Then again a reduction in flight hours would require the airline to hire more pilots = higher union dues collected, so i suppose i shouldn't be surprised.

He points out that "Investigations into recent international aircraft accidents and incidents have cited pilot fatigue as a contributing factor." Unless all of those incidents happened in Canada, India and Bangladesh, presumably those "fatigued" pilots were working on a 100-hour monthly duty cycle, so not sure how much safer we'd be with the reduction.

I think what he really wants can be summed up here: "Where’s your third pilot".
- I believe the U.S. rules changed after the Colgan crash. Since then, U.S. airlines carry 3 pilots on flights like east coast - FRA. AC doesn't and its pilots have been warning about this for years.

- The 2011(?) AC YYZ-ZUR incident was directly linked to pilot fatigue. Eleven pax injured.

- The CVR in the AI Express crash in 2010 recorded snoring and no conversation between the pilots for over an hour. Subsequent decision making errors = fatal accident.

... and that's just the countries you've mentioned.

Let's avoid turning this into a union issue and give the EU, U.S., Aussies and UK credit for being more than Union hacks. There are scientific rationales for what they're doing. The reality is that Transport Canada's aviation policies ...generally don't tend to be up to date.

I know the current dogma is that AC can do no wrong on safety, but - let's be honest - they can choose to adopt more stringent EU/US/UK standards than current Canadian regulations require. AC (and WS and TS I expect) have chosen not to.

When is the YHZ report due?
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Old May 18, 2016, 10:17 pm
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Originally Posted by yulred
I know the current dogma is that AC can do no wrong on safety, but - let's be honest - they can choose to adopt more stringent EU/US/UK standards than current Canadian regulations require. AC (and WS and TS I expect) have chosen not to.
Wrong. ACPA has long ago negotiated mainline rules far more conservative than what TC would allow. It is Transat and other charter carriers (who all operate on 14-hr max duty day 2 crew) which prompted Rouge to match operating to TC maximums to compete on cost, as in the article's Athens example.

This 112-hour or greater flight time is also a bit of a red herring. Most AC pilots are around the 80-hour mark, guaranteed something only in the 70-hr range. I'd be interested to know when the last AC pilot ever flew over 100 hours in a month.
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Old May 19, 2016, 3:51 am
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Originally Posted by DrunkCargo
"I think Canadian travellers would be shocked to know that only Canada, Bangladesh and India currently permit pilots 112 hours or greater flight time in 28 days."

So that would be what? 6x SE based on AQM? Something like that?
And I often will do all 3 in a 36-48 hour time period :P
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Old May 19, 2016, 5:40 am
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Originally Posted by winnipegrev
Wrong. ACPA has long ago negotiated mainline rules far more conservative than what TC would allow. It is Transat and other charter carriers (who all operate on 14-hr max duty day 2 crew) which prompted Rouge to match operating to TC maximums to compete on cost, as in the article's Athens example.

This 112-hour or greater flight time is also a bit of a red herring. Most AC pilots are around the 80-hour mark, guaranteed something only in the 70-hr range. I'd be interested to know when the last AC pilot ever flew over 100 hours in a month.
If you say so, although I will point out that:

- By you own account, safety considerations evidently take a backseat to financial considerations on Rouge. Blame it on TS or whoever, but that's akin to saying there's nothing wrong with AC adopting AI rules if it competes with AI. Not confidence-inspiring from a safety perspective; and another reason to reconsider flying Rouge.

- Mainline AC vs US carriers to FRA, ZRH etc... the latter carry 3 pilots; AC 2 pilots. Can't blame that on competitive pressure.

ACPA can negotiate whatever it wants with AC, but it doesn't amount to much if the agreed rules (based, presumably, on lessons learned in similar jurisdictions) are only applied where cost considerations permit.
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Old May 19, 2016, 6:23 am
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Originally Posted by yulred
Mainline AC vs US carriers to FRA, ZRH etc... the latter carry 3 pilots; AC 2 pilots. Can't blame that on competitive pressure.
I suspect the time difference is quite small. While Ac might be using 2 pilots to ZRH, if i recall correctly they use 3 from ZRH (and MUC and FCO).
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Old May 19, 2016, 7:22 am
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Originally Posted by The Lev
I suspect the time difference is quite small. While Ac might be using 2 pilots to ZRH, if i recall correctly they use 3 from ZRH (and MUC and FCO).
I have no reason to disagree, but worth noting that:

- the AC ZRH investigation linked the incident to the red eye nature of the flight.

- the ZRH incident likely wouldn't have taken place if the pilot hadn't been sleeping in the cockpit.

- Rouge is operating much longer flight segments with 2 pilots. If YYZ-ATH is 2 pilots, I suspect YYZ- HNL is 2 as well. The TS argument doesn't apply there. The U.S. competitors are bound by FAA regulations.

Suffice it to say, safety is clearly secondary to profit in these cases. Until regulation addresses it, anyway.
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Old May 19, 2016, 8:07 am
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Originally Posted by The Lev
I suspect the time difference is quite small. While Ac might be using 2 pilots to ZRH, if i recall correctly they use 3 from ZRH (and MUC and FCO).
Airport ground delays also effect crew hours, which major US airports have these ground delays often.
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Old May 19, 2016, 2:32 pm
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Originally Posted by Wpgjetse
Airport ground delays also effect crew hours, which major US airports have these ground delays often.
Is it only block time that accrues towards this limit? Not sure how it works actually...
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