Calculations of flight and duty time limitations made under the provisions of section 48.1 shall take into account any flight and duty time performed in the course of private operations.
The definition of "duty time" per the CARs and CAOs is very clear. "tour of duty means the period between the time a flight crew member commences any duties associated with his or her employment ....". In my personal situation, virtually all of my private flying has nought to do with my employment so the appropriate duty time is NIL. i.e. I comply with the law to record that duty time however it is zero per the law.
As for RAA, I don't see where they are exempt from flight and duty time limitations - can anyone point me to that please?