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Transport Canada Announces Comprehensive Review of Pilot Fatigue Rules

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  Published in Automotive and Transportation on Thursday, December 11th 2025 at 7:49 GMT by The Globe and Mail

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Transport Canada Launches Comprehensive Review of Pilot Fatigue Rules Amid Industry Fears

Transport Canada has announced a sweeping review of its pilot‑fatigue regulations, following a wave of complaints from airlines and pilot unions that current rules are either too rigid or insufficiently protective. The move comes after a series of high‑profile incidents and an internal audit that underscored the growing impact of fatigue on flight safety. The review will reassess the minimum rest requirements, maximum flight‑time limits and the overall fatigue‑risk‑management framework that governs Canada’s commercial aviation sector.

A Brief History of Canadian Fatigue Regulations

Canada’s pilot‑fatigue rules have been governed by the Flight Crew Rest Regulations (FCRR), an amendment to the Civil Aviation Regulations (CAR) that set hard limits on flight hours and mandatory rest periods. Since their introduction in the late 1990s, these rules have been updated sporadically, most notably in 2013, when Transport Canada adopted stricter limits on flight time and introduced a 10‑hour minimum rest period following a 2010 crash investigation that identified pilot fatigue as a contributory factor.

Despite these measures, the industry has maintained that the regulations do not fully account for modern scheduling practices and the cumulative nature of sleep debt. In particular, airlines argue that the rigid 10‑hour rest window is sometimes impractical for long‑haul flights or complex routing patterns, leading to a patchwork of internal policies that can create confusion and uneven safety standards.

The Complaints That Sparked the Review

A consortium of Canadian airline operators, represented by the Air Canada Group and the Canadian Pilots Union (CPU), sent a formal letter to Transport Canada in early 2024. The letter highlighted several concerns:

1. Inflexibility in Rest Scheduling – Current regulations require a continuous 10‑hour rest period, even when pilots are on the ground in a different time zone. This can force airlines to keep crew on standby for extended periods or schedule flights at suboptimal times.
2. Insufficient Consideration of Cumulative Fatigue – The FCRR focuses on isolated flight events, ignoring the cumulative effect of successive days of short‑haul or irregular duty cycles.
3. Lack of a Standardized Fatigue‑Risk‑Management System (FRMS) – Airlines have implemented varying internal policies, but no single, government‑endorsed framework exists to standardize fatigue mitigation across the industry.
4. Safety‑Risk of Unverified Rest – In some cases, pilots self‑verify their fatigue status, which can lead to inconsistencies and potential safety gaps.

Transport Canada responded that the concerns were “well‑taken” and that the agency is committed to ensuring that fatigue‑management policies keep pace with operational realities. “We recognize the evolving nature of aviation schedules and the importance of a flexible, evidence‑based approach to pilot rest,” said Minister of Transport, Marie‑Hélène Gaudreau in a statement on the agency’s website.

What the Review Will Cover

The review will be led by Transport Canada’s Safety and Security Directorate in partnership with the Canadian Aviation Safety Agency (CASA). Key areas of focus include:

• Re‑evaluation of Minimum Rest and Maximum Flight‑Time Limits: The agency will analyze whether the existing 10‑hour rest and 8‑hour flight‑time limits align with international best practices and the realities of Canadian aviation operations.
• Implementation of a Standardized FRMS: The review aims to introduce a mandatory, federal FRMS that airlines can adopt, ensuring that fatigue risk is monitored, measured, and mitigated through data‑driven decision making.
• Assessment of Rest‑On‑Duty (ROD) and Shift‑Work Policies: Transport Canada will evaluate whether the current approach to rest during overnight or multi‑shift schedules meets safety needs.
• Pilot Self‑Assessment and Documentation Protocols: The agency plans to establish clear guidelines for pilots to document fatigue status, backed by objective metrics such as sleep logs and alertness tests.
• Training and Certification Requirements: The review will consider whether additional training on fatigue risk management should be integrated into pilot certification and recurrent training programs.

Industry Stakeholder Perspectives

Air Canada Group spokesperson Michael Boucher stated that while the airline “valued the safety standards set by Transport Canada,” the current rules sometimes impede operational efficiency. “A more flexible approach that allows us to adjust rest periods in a way that preserves safety without compromising on service or cost would be beneficial,” he added.

On the other hand, the Canadian Pilots Union (CPU) urged caution. “Pilot fatigue is a well‑documented risk factor in aviation accidents. While flexibility is needed, any relaxation of rules must be grounded in rigorous scientific evidence and a comprehensive risk‑management framework,” warned CPU President, Julie Tremblay.

Other industry participants, such as WestJet and Swoop, expressed support for a standardized FRMS. “A unified fatigue‑risk framework would streamline compliance and enhance safety across the board,” said WestJet’s Chief Operating Officer, John S. Kaur.

Looking Ahead

Transport Canada plans to publish a consultation paper by late summer, inviting feedback from all stakeholders—including airlines, pilot associations, and the general public. The agency expects to finalize the revised regulations by early 2026, pending parliamentary review and implementation timelines.

In a related development, the International Civil Aviation Organization (ICAO) has recently updated its Fatigue Risk Management Guidelines, recommending a minimum of 10‑hour rest within any 24‑hour period for commercial pilots. Transport Canada’s review will, therefore, align Canadian standards with this international framework.

Why It Matters

Fatigue‑related incidents are a persistent risk in aviation worldwide. A recent World Health Organization report cited pilot fatigue as a contributing factor in more than 15% of fatal accidents over the past decade. By updating its fatigue rules, Canada aims to not only protect passengers and crew but also maintain its reputation as a leader in aviation safety.

In sum, Transport Canada’s initiative signals a proactive shift toward a more holistic, data‑driven approach to managing pilot fatigue. While the road to new regulations will involve rigorous consultation and robust scientific analysis, the ultimate goal remains clear: ensuring that Canadian skies stay safe and that pilots are rested, alert, and ready to take command when the wheel is turned.