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Canada’s All New Fatigue Risk Management Regulations & its Impact on Air Operators

It is recognized that fatigue has a significant, detrimental impact on health and behavior. Fatigue negatively affects memory, concentration, reaction time, decision making, risk perception and emotions. For flight crews, fatigue can degrade performance and lead to piloting errors that may have major consequences, including aircraft damage or loss, and injury or death.

There is evidence that, after 12 hours of work, human performance begins to exponentially degrade. After flying for an extended period during the night, the impairments a pilot experiences, landing a plane at 5 a.m., are equivalent to having a blood alcohol level of 0.08.

We cannot deny the fact that flight crew fatigue has been a contributing factor in a number of accidents and incidents in the past like:

On February 12, 2009, a Colgan Air aircraft, crashed into a house in New York, U.S., after experiencing an aerodynamic stall killing all 49 people onboard. NTSB (National Transportation Safety Board) stated that “the pilots’ performance was likely impaired because of fatigue.” 

On October 14, 2004, an international cargo aircraft crashed while attempting to take off from Halifax International Airport, and seven crew members were killed, and on January 14, 2011, a passenger aircraft dropped 400 feet in altitude over the Atlantic Ocean then rose 800 feet before levelling off at the assigned altitude, resulting in injuries to 16 people. 

In fact, a survey conducted on 1,906 pilots found that 56% of pilots reported that sleep occurred on the flight deck on their last pairing, and that 1 in 5 pilots reported that sleep on the flight deck was involuntary or unplanned. On average, the surveyed pilots experience fatigue on 36% of their duty days, and report fatigue on only 3% of duty days (and did not work). Furthermore, 82% of pilots believe that pilot fatigue is a major or moderate safety problem, 41% believe the problem of fatigue is getting worse, while just 4% think it is getting better.

Yes, there exists human factor regulations in aviation industry but Transport Canada, the federal institution responsible for developing regulations, policies and services of road, rail, marine and air transportation in Canada has taken a step ahead and released additional regulations coming into force this December 2022. The new TC regulations now mandate Air Taxi operators (subpart 703), commuter Operations (subpart 704), Airline Operations (subpart 705) and Medevac flights to comply with the Fatigue Risk Management regulations i.e., An air operator under (section 703.98, 704.115, 705.124) should have a fatigue management training program for its flight crew members that contains

(a) personal fatigue management strategies relating to

  1. sleep hygiene,
  2. lifestyle, exercise and diet, and
  3. the consumption of alcohol and drugs;

(b) the impact of fatigue on aviation safety;

(c) sleep requirements and the science relating to fatigue;

(d) the causes and consequences of fatigue;

(e) how to recognize fatigue in themselves and in others;

(f) sleep disorders, their impact on aviation safety and treatment options; and

(g) human and organizational factors that may cause fatigue, including

  1. sleep quality and duration,
  2. the impact of shift work and overtime, 
  3. the circadian rhythm, and 
  4. the effects of changes of time zones.

Definitely these amendments will result in a reduction in accidents, with benefits to passengers, flight crew members, air operators, and the Government of Canada. These amendments will also result in unquantified benefits for flight crews, due to an improved quality of life.

Now the real question is how do Air operators take care of this new regulation? Well, the answer lies in the technology landscape they use to manage their flight operations. A system should have a robust risk assessment mechanism based on which it categorizes risk factor of pilot and allow them to take flight or deny.

Failing to have a robust system in place can land you in many fatigue hazards like long duty periods, company extended duty periods, sleep deprivation, sector workload which will in turn affect the crew performance by reducing alertness, degraded reaction time, transient fatigue, errors, slips, increased automation dependency, reduced communication, impaired decision making, and even mood.

Worried about managing the new requirements under the CARs Part VII operating rules implementation under Subpart 703, 704 and 705? Don’t worry, we’ve got you covered.

We have been enhancing safety within flight operations by improving the human performance of flight crew members, by reducing their levels of fatigue, recording, and tracking flight duty limitations and rest periods, reducing gaps between the operations and regulations and ensuring better alignment with jurisdictions around the globe.

Want to know how? Contact us at contact@ramco.com or leave your details below.