Canada’s commercial pilots play an essential role in safeguarding their passengers, crew and the public;
Scientific research has established that fatigue impairs cognitive ability and performance for all – including pilots;
Other jurisdictions, including the U.S., have updated pilot fatigue rules to manage the risk of fatigue;
Canada’s current pilot fatigue rules are more than 20 years out of date;
The government’s proposed updates to Canada’s pilot fatigue rules do not adequately align with fatigue science, especially for long-haul night flights, or with limits established in other jurisdictions; and
The proposed fatigue rules would permit air operators to bypass these fatigue limits by introducing weak Fatigue Risk Management System (FRMS) provisions that lack adequate regulatory oversight, pilot input, and enforcement provisions.
We, the undersigned, residents of Canada,, call upon the Minister of Transport to protect the safety of passengers, flight crews and the public by amending the proposed flight crew fatigue management regulations to:
1. Afford pilots and passengers of all sizes of aircraft – whether they carry passengers or cargo – the same protective fatigue limits, coming into force 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 FRMS relies on science-based prescriptive limits as a foundation, requiring independently verifiable data and stringent Transport Canada approval and oversight.
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