As PJ2 rightly suggests, Transport Canada has not addressed the issue of fatigue in any serious way. I would add that this is just one manifestation of a much larger -- and very serious -- issue of civil aviation oversight in Canada. Put succinctly, Transport Canada is no longer funded, or even structured, in a way that ensures adequate safety levels and regulatory oversight in Canada. I`ll go even further and assert that Transport Canada is no longer meeting its mandate and obligations, under Canadian statutes and under its ICAO obligations.
There are many reasons but the two primary underlying causes are:
1. Resources. TC has been in a `death spiral` for many years. Example: Serious underfunding has led to too few inspectors to meet TC`s own schedule of surveillance. The added workload on those on that front line has led in turn to morale being lower than the Mariana Trench, which has led to further resignations and early retirements, which has led to even higher workload, which has led to TC reducing and even eliminating its mandated surveillance activities. And on and on and on.
So, given that TC does not have the resources to meet its primary role and first responsibility, what do you think it`s doing about addressing issues like fatigue – and the multitude of other serious safety issues and concerns raised by CTSB, users, service providers, unions, ICAO, the public, etc.? Nada…
2. Structure. Transport Canada is NOT an independent, autonomous Civil Aviation Authority, as recommended (strongly) by ICAO, and as most countries have. TC is simply another department of the (Canadian) federal government. A few of TC’s areas of responsibility include: civil aviation, motor vehicles, railways, shipping and marine transportation, etc. As ICAO rightly asserts – and the experience of many countries attests – without an independent autonomous CAA, aviation safety issues are just another budget item for another branch of another department of a huge federal bureaucracy.
Canada’s international reputation as a model of civil aviation safety is based on a philosophy, a structure, a commitment and an entity that existed in Canada in the late 20th century. That is all gone. Transport Canada’s logo should be the setting sun (an Avro Arrow disappearing into the sunset would be a nice touch…)