Part IIFinal RegulationPublished: September 16, 2020

Seaplane PFD Requirement Delayed

Regulations Amending the Regulations Amending the Canadian Aviation Regulations (Parts I, VI and VII — Seaplane Operations): SOR/2020-190

The requirement that pilots and passengers on Subpart 703 commercial seaplanes wear inflatable personal flotation devices (PFDs) while operating on or over water has been delayed from September 6, 2020 to June 6, 2021. Pilot underwater egress training for Subpart 703 and 704 operators remains scheduled for March 6, 2022.

Published
September 16, 2020
Department
Unavailable
Section
Regulations Amending the Regulations Amending the Canadian Aviation Regulations (Parts I, VI and VII — Seaplane Operations)
Comment deadline
Unavailable
Effective date
June 6, 2021
Publication part
Part II

Summary

Summary#

The federal government amended the Regulations Amending the Regulations Amending the Canadian Aviation Regulations (Parts I, VI and VII — Seaplane Operations) to delay one safety rule for small commercial seaplanes. Instead of starting on September 6, 2020, the rule that passengers and pilots must wear inflatable personal flotation devices (PFDs) when flying on or over water will take effect on June 6, 2021. The separate pilot underwater egress training remains scheduled for March 6, 2022.

What it does#

  • Changes the coming-into-force date for the PFD-wearing requirement for Subpart 703 seaplane operations from September 6, 2020 to June 6, 2021.
  • Keeps the pilot underwater egress training date for Subpart 703 and 704 operators at March 6, 2022 (no delay).
  • The amendment itself was registered and published so the change is now official. The government says this gives operators more time to acquire PFDs and for manufacturers to supply them.

Who's affected#

  • Small commercial seaplane operators and their crews and passengers. The government estimated about 187 operators and a fleet of about 630 seaplanes. About 4,524 passengers and crew were counted as needing PFDs.
  • Many operators are small businesses (about 80% to 90% of them).
  • PFD manufacturers and suppliers, who need time to meet increased demand.
  • The delay was requested by industry groups and companies, including the Northern Air Transport Association (NATA), Harbour Air, and Wilderness Seaplanes Ltd., and the change was made by Transport Canada.

Why it matters#

  • It gives operators more time to buy required inflatable PFDs during a period when many lost revenue because of COVID‑19. The government estimates this delay shifts about $1.63 million in costs out of 2020 and reduces the total present-value industry cost by $0.26 million over 10 years (from $5.16 million to $4.90 million).
  • It helps avoid forcing some seasonal operators to stop serving customers in late summer 2020 because they could not afford or find enough PFDs.
  • There is a safety trade-off: delaying mandatory wear slightly reduces the intended safety benefit (fewer people wearing PFDs while flying), but regulators note most seaplanes already carry PFDs for emergencies and that flying time fell during the pandemic.
  • Once the rule is in force, non‑compliance can lead to penalties (up to $1,000 for individuals and $3,000 for corporations) or other enforcement actions.

Key topics

Canadian Aviation RegulationsAeronautics ActTransport Canadainflatable personal flotation devicePFDSubpart 703Subpart 704pilot underwater egress trainingNorthern Air Transport AssociationHarbour AirWilderness Seaplanes Ltd.seaplane operationscommercial air taxiseaplane safetyTransportation Safety Board (TSB)

Source: Canada Gazette

Official source