*click image to enlarge
For the past several months, we have heard from Minister Garneau and Transport Canada that their new proposed fatigue rules for Canada’s pilots will be based on science.
As it turns out, that’s not quite right.
Canada’s proposed rules may be inspired by science and international best practice, but as you can plainly see from the chart above, there’s a significant gap between what Minister Garneau proposes for Canadian pilots and what science and best practice recommend when pilots' duty periods begin in the evening hours.
Why are these evening duty periods so problematic? When a pilot starts his or her duty in the evening, those working hours will likely extend into the window of circadian low. And science has established that during this period between 0200 and 0600 hours, a person's physiology creates a tremendous drive for sleep.
In fact, when evaluating routes currently in operation with such evening duty periods that would be permissible under Minister Garneau’s proposed rules, we uncovered alarming results. Through biomathematical modelling that takes into account rest periods, duty periods and time of day, this analysis provides a blood alcohol equivalent (BAE) of the fatigue impairment that would afflict pilots.
Our analysis showed that many flights, especially those departing in the evening and operating into this window of circadian low, generated fatigue impairment with a BAE is 0.08% or higher. In fact, some routes were associated with a BAE as high as 0.117%.
Contrast this to laws regarding impaired driving, where the legal limit in Canada is 0.08%. In every province but Quebec, the police can seize your car keys if you have a BAE of above 0.05%1. So why are new rules not taking impairment from fatigue seriously enough to base them on science – especially for more fatiguing evening duty periods.
A stark example of the difference between Canada and the U.S. is that a Canadian pilot could do a flight of up to 11 hours starting at 9pm where a U.S. pilot would only fly up to 8 hours starting at 9pm.
Impairment from fatigue is a serious issue that pilots grapple with every day. So serious in fact, that Canada’s Transportation Safety Board (TSB) investigates for fatigue in every occurrence2. There’s no simple test for fatigue impairment -- which slows down reaction time, impairs vigilance, and can lead to risky decisions3-- and that impairment makes individuals ill-equipped to accurately self-diagnose. That is why the TSB calls regulation "the first line of defense to protect crews, passengers and operators from the risk of fatigue impairment.4
It’s time to provide Canadian passengers and aircraft crew with fatigue protections that work. The government needs to #CloseTheTwoHourGap.
The Safer Skies Coalition has pointed out several issues with the proposed regulations in our submissions to government. Today we are focusing on one of our issues in particular to help move Minister Garneau in a safer direction.