Commercial and Business Aviation Advisory Circulars

Monitoring of Flight Time and Flight Duty Time

PURPOSE

This Commercial and Business Aviation Advisory Circular (CBAAC) is intended to bring to the attention of operators and flight crewmembers the requirement to ensure that all flight time and flight duty time is considered when determining compliance with the flight time and flight duty time limitations of the Canadian Aviation Regulations (CARs).

REFERENCE

CAR sections 700.14 and 700.15.

BACKGROUND

All flight time and flight duty time is inherently fatiguing. A flight crew member working for operator A may choose, in their free time, to work for operator B. Flight times and flight duty times accumulated with the other operator need to be considered when determining whether or not a flight time or flight duty time limitation has been reached.

CARs subsection 700.14(1) requires that air operators establish a system for monitoring the flight time, flight duty time and rest periods of each of its flight crew members and that details of the system be included in the Company Operations Manual (COM). CARs subsection 700.14(2) places responsibility on any person (an employee of the air operator or the flight crew member for example) to notify the air operator if a flight assignment will result in either the flight time or flight duty time limitations being exceeded.

It has come to Transport Canada's attention recently that not all perators are monitoring all the flight time and flight duty time of their flight crew members and that affected flight crew members are not always reporting non-company flight time and flight duty time to the air operator.

ACTION REQUIRED

Operators shall ensure that:

1. All flight time accumulated with an operator is counted when determining compliance with CARs subsection 700.15, Flight Time Limitations. [CARs subsection 700.15(1) is clear in this regard by referring to "the flight crew member's total flight time in all flights conducted by the flight crew member"];
2. Flight duty time and any associated rest period accumulated with operator A are considered in operator B's flight duty time calculations (and vice versa); and

A system for monitoring the flight times and flight duty times for those flight crew members engaged in flights other than those related to company operations is established and detailed in the COM in accordance with CARs subsection 700.14(1). As it is not reasonable to expect the operator to be fully aware of all of a flight crew member's activities outside of the company, the COM shall also include instructions to flight crew members requiring them to report to the air operator in a timely fashion (daily if necessary) all flight time and all flight duty time accumulated with another operator. Notice of Proposed Amendments (NPA) for amendments to Commercial Air Service Standards (CASS) 722.82, 723.105, 724.121 and 725.135 that elaborate on the COM requirement will be introduced at the December 2002 Commercial Air Service Operations Technical Committee (CASO).

CONCLUSION

Operators and flight crew members shall ensure that all flight time and flight duty time is considered when determining compliance with the flight time and flight duty time limitations.

Michel Gaudreau
Acting Director
Commercial & Business Aviation