Briefing Note – Transport Canada Fit to Fly Workshop June 6-7, 2017

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On June 6 and 7, 2017, Transport Canada hosted its first Fit to Fly Workshop in Gatineau, Quebec.

The two-day workshop, attended by some 200 members of the aviation industry focused on measures aimed at supporting aviation staff in the interest of the health, safety, and well-being of crew members and passengers. Among the topics discussed were employee assistance programs, healthy workplace promotion, peer to peer support systems, and understanding the mental and physical risks to safety, particular to the aviation industry.

Minister of Transport, Marc Garneau, kicked off the Workshop with an introduction to the events leading up to the Workshop, namely, the German Wings incident and two recent incidents of pilot impairment. Minister Garneau emphasized that the purpose of the Workshop was to initiate an open, honest discussion of the range of mental health issues that may lead to personal and occupational hazards in the aviation industry. He noted that Transport Canada will be moving forward with amendments to flight and duty time regulations, set to align with those in the United States and the European Union, as well as amendments to extend the 8-hour “bottle to throttle” rule, to prevent flight crew members from operating within 12 hours of consuming alcohol. He urged operators to explore preventative measures such as employee assistance plans and peer to peer support programs, and raised the question of random drug and alcohol testing of pilots.

The Workshop then began with a panel discussion aimed at providing participants with an understanding of mental, physical, and substance abuse disorders, and the potential effects of such disorders on safety and fitness for flight. One major theme was the notion of treating mental health and substance abuse as illnesses requiring compassion, empathy, and treatment, just like any other illness, and fostering an overall culture of openness, support, and safety. Rather than punishing individuals dealing with substance abuse issues, participants were encouraged to think about ways to support such individuals in their recovery, with the goal of returning them to health and to their careers. In light of the shortage of experienced pilots, it was suggested that the industry should aim to support pilots to keep them in the air, barring a minority of conditions that make it impossible to fly. An aviation physician specializing in addiction emphasized the distinction between intoxication, meaning current influence of drugs or alcohol, and impairment, which is much broader, and may include symptoms of withdrawal, chronic alcohol or substance use, as well as fatigue, distraction, and other mental states. A recurring message was that impairment bends more planes than intoxication, and distraction, in all its forms, bends more planes than impairment. A distracted pilot, be it by substance abuse, mental illness, fatigue, personal issues, financial stress, performance anxiety, or otherwise, is a dangerous pilot. For that reason, operators were urged to implement measures to identify issues and concerns before an incident occurs, and to raise these concerns in an open, encouraging manner. The key should be to keep the approach supportive, not disciplinary, and provide resources for assistance.

In discussions regarding random testing, it was noted that while such testing does serve a specific and general deterrent effect, it is a costly way to manage a problem that should instead be addressed earlier, at the stage of prevention, identification, and treatment. Further, testing will catch only intoxication, and not the other types of impairment identified.

A recurring issue raised by participants was the upcoming legalization of marijuana. The panelists were clear that there should be zero tolerance for marijuana, given its varying effects on individuals, and the lengthy time for which it remains in the system. It was noted that since THC, the psychoactive substance in marijuana, is fat-soluble, it can be released when adrenalin kicks in, in situations where a clear mind is most needed. For that reason, it was clear that, regardless of legality, marijuana use within a lengthy period of time prior to flight will not be tolerated.

Panelists then focused on tools and programs for encouraging workplace well-being, including Employee Assistance Plans, peer to peer support programs, and substance abuse recovery programs, all aimed at promoting safety, health, and well-being.

While many of the suggestions raised had been implemented at larger organizations, there was a recognition that the thinner margins and resources of smaller operators may prove prohibitive. It was suggested that smaller operators train individuals to provide on-site first instance support, and consider the possibility of third-party employee assistance programs. Peer to peer support programs, and mentorship programs may also be effective in such operations, provided peers are properly trained. Managers and supervisors should be trained on early detection of concerns, to be able to identify signs and symptoms that may point to an issue needing to be addressed. While it is not the duty of employers to diagnose their employees, employers are obliged to inquire where they suspect an issue, and provide reasonable accommodation to the point of undue hardship.

Apart from practical and operational considerations, employers must recall their obligations pursuant to the Canadian Human Rights Act, the Canada Labour Code, and privacy legislation when addressing concerns of fitness to fly.

The Canadian Human Rights Commission has recently published a guide for accommodation of substance dependence in the workplace, entitled “Impaired at Work.” It can be found as a PDF on the Commission’s website: http://www.chrc-ccdp.gc.ca/sites/default/files/impaired_at_work.pdf

Slides from the Workshop will be made available on our website, once published by Transport Canada.

For further information, please contact Steven Williams at 613-9400-2737 or Larissa Volinets Schieven at 613-940-5660 #230.