In response to flawed Transport Canada regulations, which fail to harmonize Canada’s outdated pilot fatigue rules with accepted fatigue science and neighboring jurisdictions including the United States, the Safer Skies coalition of pilot associations is appealing directly to Transportation Minister Marc Garneau to use his power to fix the rules before it’s too late.
“Our pilots have been very clear – aviation is terribly unforgiving,” said Unifor President Jerry Dias. “Fatigue is a type of impairment. It causes reduced alertness, degraded physical and mental performance, and you cannot self-diagnose that impairment. That’s why we’re calling on Minister Marc Garneau to put in place safer fatigue rules that apply equally to all pilots.”
Today, the Safer Skies coalition of pilot associations representing 8000 commercial pilots submitted advice to Transportation Minister Marc Garneau, calling on him to personally fix the flawed regulations, including by taking the following steps:
1. Pilots on all sizes of aircraft – whether they carry passengers or cargo – should have the same protective fatigue limits, implemented at the same time;
2. Address pilot fatigue on long-haul flights at night by limiting duty periods that begin after 1700h to 10 hours (or 8.5 hours of flight time) – in line with NASA research findings; and,
3. Ensure that any Fatigue Risk Management System relies on science-based prescriptive limits as a foundation, requiring independently verifiable data and stringent Transport Canada approval and oversight.
The science is clear: after 8.5 hours of flight time at night, fatigue degrades performance. This is based on research that measured brain wave activity and micro-sleeps in actual flight operations at night. However, NASA recommendations were not reflected in the draft regulations released by Transport Canada on July 1.
“Transport Canada’s regulations would ask Canada’s pilots who begin their duty at 9 p.m. to fly for a full two hours longer than science recommends. As pilots who are responsible for the safe operation of our flights, and based on our extensive firsthand experience – that is just not good enough,” said ACPA Captain Matt Hogan. “Our American friends learned the tragic way, only updating their fatigue rules after a flight crashed in Buffalo, New York in 2009, when 50 people perished. Fatigue was found to be a critical factor in this tragic accident.”
“There is still time for Transport Minister Marc Garneau to get this right and help continue Canada’s reputation as a leader in aviation safety,” said ALPA President Captain Dan Adamus. “Unless the draft regulations are fixed, Canada will continue to have weaker pilot fatigue rules than the rest of the world. Pilot fatigue is cumulative, yet the draft regulations allow 112 hours of flight time in less than 28 days, when the global standard is 100 hours or less. This is unacceptable.”
The Safer Skies coalition is made up of 8,000 of Canada’s commercial pilots – represented by the Air Canada Pilots Association, Air Line Pilots Association, Unifor, the International Association of Machinists and Aerospace Workers, and the Office and Professional Employees International Union.