On Monday, the Canadian Transportation Safety Board (TSB) added aviation and marine fatigue to its 2018 Watchlist. Fatigue in the rail mode already existed on the TSB Watchlist. HAC and others have acknowledged that the pilot hours-of-work regulations are in need of adjustment to bring them in to line with the fatigue-related science however, HAC believes that there is little support in the fatigue-related draft regulations currently under consideration. These regulations are ill-suited to the helicopter community – and more suited to the large, scheduled international carriers. Our regulatory structure was founded on different regulations for different industry segments. There are hundreds of examples in the CARs. What’s more, the Regulatory Impact Analysis Statement (RIAS) has fallen woefully short of demonstrating the negative impact on our industry. Transport Canada staff have no idea of the ruinous implications of these proposed regulations. The current regulations are stalled at Treasury Board, while its ministers consider whether or not the consultation process and economic analysis has been full and fair. HAC believes that the addition of fatigue in the air mode, to the TSB’s 2018 Watchlist, highlights the importance of “getting it right”, so that any new regulations will truly enhance safety, rather than simply harm our industry.
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