Canada ftdt (npa) module 1 v1.0

Canada FTDT (NPA)A Generic Interpretation

Understanding Canada FTDT (NPA)

Flight and Duty Time Limitations and Rest Requirements.

Version 1.0

Copyright © 2014 Understanding Canada FTDT (NPA) – A Generic Interpretation All rights reserved.

Disclaimer

The documentation is provided “AS IS” and is solely intended to provide a general understanding of the author’s interpretation of the Proposed Canada FTDT as amended on 15-September-2014.

The author makes no representations and disclaims any and all responsibility for the completeness or accuracy of the documentation.

The author reserves the right, at his discretion, to change or modify the documentation as deemed appropriate.

Copyright © 2014, Understanding Canada FTDT (NPA) – A Generic Interpretation. All rights reserved.


Module 1:

Introduction


IntroductionFlight Duty – Length of Basic Flight Duty Period (FDP): The current regulations allow for a daily 14 hour flight duty period at any time of day. The science suggests a maximum FDP of 12 hours would be effective in managing flight crew fatigue. A maximum FDP of 12 hours provides sufficient time to obtain rest, limits performance degradation over the course of the FDP, and provides adequate time for nutrition, hydration, hygiene, and social requirements. It was felt that the maximum duration FDP of 13 hours would be appropriate when considering a schedule with weekly time free from duty and the layering of the other requirements. Research has shown that fatigue increases as shifts increase in length, with associated increases in accident likelihood. Studies have found a transient increase in risk after 2-4 hours with much larger increases observed after 9-10 hours and 12 hours on shift. A near two-fold increase in likelihood of incident or accident has been found following 10 hours compared to 8 hours on shift. A three-fold increase in accident likelihood has been found to occur after 16 hours. A study from the United States found that working at least 12 hours per day was associated with a 37% increased hazard rate. The science does not support a 14 hour flight duty period. FDP Reduction For Window Of Circadian Low (WOCL) Infringement: Human performance is degraded during the WOCL (duty that occurs between 2 am and 6 am). This is due to the body’s drive for sleep. Studies that looked at overnight operations, reached the conclusion that the duty period should be restricted to no more than 10 hours through the night. This was due to the fact that flight crews working through the night showed performance degradation expressed in slower response times and increased sleepiness.


Introduction


FDP Reduction For Sectors Flown: The workload of the flight crew also effects fatigue. There have been several studies conducted that have found that fatigue increased with the number of sectors flown. One study found that the increase from one to a 4-sector duty was equivalent to the effect of an additional 2.77 hours duty or approximately 55 minutes duty per sector. Three other studies found that the most important influences on fatigue were the number of sectors and duty length. Cumulative Duty Limitations – The current regulations do not have cumulative duty limitations. There are many studies that have found that long hours of work (> 48 hours per week) have negative effects on performance. During a study of medical interns, the weekly scheduled hours were reduced from an average between 77 to 81 hours to an average of between 60 to 63 hours per week. This reduction of weekly work hours had a marked effect on diagnostic errors. Interns made 5.6 times as many serious diagnostic errors during the longer work week than during the shorter work week – fatigue negatively affected their decision making abilities. Another study showed that working at least 12 hours per day was associated with a 37% increased hazard rate and working at least 60 hours per week was associated with a 23% increased hazard rate. The current flight time limitations (40 or 60 flight hours per 7 days) result in a range of duty hours of 60 to 90 hours. The low end of this range is the maximum for most authorities.

Introduction


Rest Periods – the current regulation provides for an opportunity to obtain 8 hours sleep. Studies have shown that an 8 hour opportunity for sleep does not sustain performance. Eight hours of sleep does sustain performance; however it requires 9 hours in bed to achieve the 8 hours of sleep. Dr. Belenky indicated that it takes a person 12 hours off duty to get 8 hours of sleep taking into account commuting and the necessities of living. The NPA proposes to require 10 hours at the rest facility when away from home base, and a 12 hour rest period when at home base. Time Free From Duty – The current requirements for Subparts 704 and 705 are close to what the science supports. Only minor changes are required to meet the current science. A weekly rest period is essential to allow the dissipation of the cumulative fatigue that has been scientifically established to build up over consecutive periods of duty. It is well established that fatigue and risk show a cumulative build up over consecutive duties. 2 sleep opportunities (at night) with the intervening day in between free from duty are required each week. For deployed operations longer than 1 week in duration (not using weekly time free from duty), Dr. Belenky cited the experience of the United States Army and professions such as oil rig workers who are able to safely sustain 12 hours on, 12 hours off schedules for periods of up to 2 weeks. Subparts 702 and 703 are not close. I.e.: 3 periods of 24 consecutive hours free from duty every 30 consecutive days; or 42 consecutive days of duty followed by 5 days free from duty. No science supports these patterns.

Introduction


Consecutive Night Duties – The current requirements do not restrict the number of consecutive night duties that may be flown. The science shows that there is an exponential increase in risk over successive nights. When compared to the first night, the risk is 6% higher on the second night, 17% higher on the third night and 36% higher on the fourth night. There is already a 30% increase in relative risk when a night duty is compared to a day duty (8 am start). This risk compounds over successive nights – a significant decrease in performance. Other proposed changes are in support of these major changes above or are supported by the science. Such as Additional Rest For Time Zone Differences – jet lag; Additional Rest Due To Disruptive Schedules – transitions from early to late or night duty; the rules around scheduling standby duty and consequent flight duty.

Weekly Flight Hours

Limitation

Weekly Duty Hours Limitation

28 Days Duty Hours

Limitation

28 days Flight Hours

Limitation

365 days Flight Hours

limitation

Current 40/60 n/a n/a 112/140 1200Propose

d n/a 60 190 112 1000

Intent of this presentation


To summarize the following sections of CAR (NPA).700.20 Flight Duty Period (FDP).700.22 Extension of FDP Due To In-Flight Rest700.23 Unaugmented Long Range Flights700.24 Ultra Long Range Operations700.25 Unforeseen Operational Circumstances — PIC’s Discretion700.26 Unforeseen Operational Circumstances

Short-Term Re-Planning — PIC’s Discretion700.27 Delayed Reporting Time700.28 Cumulative Duty Hour Limitations700.29 Flight Time Limitations

Intent of this presentationTo summarize the following sections of CAR (NPA).700.30 Positioning700.31 Split Duty700.32 Standby700.33 Airport Standby700.34 Rest Periods700.35 Time Free From Duty700.36 Additional Rest Due To Disruptive Schedules700.37 Additional Rest Due To Time Zone Differences700.38 Consecutive Duties Infringing on the WOCL700.39 Determining FDP Table Start Time (Table 1 – 700.20)


Not included in this presentationThe following sections of CAR (NPA).

700.14 Flight Crew Fatigue Management700.15 Air Operator Responsibilities700.16 Flight Crew Member Responsibilities700.17 Prescriptive Fatigue Management Documentation700.18 Nutrition700.19 Records of Flight and Duty Times and Rest Periods700.21 Flight Duty Period – Aerial Application Operations700.24 Ultra Long Range Operations700.40 Fatigue Management Training700.41 Controlled Rest on the Flight Deck


Canada FTDT (NPA)A Generic Interpretation

Understanding Canada FTDT (NPA)

Flight and Duty Time Limitations and Rest Requirements.

Version 1.0


Education

Canada ftdt (npa) module 1 v1.0