July 25, 2002

Regulatory Affairs, Civil Aviation (AARBH)
Transport Canada Safety and Security
Ottawa ON K1A 0N8

This submission constitutes the comment of the International Association of Fire Fighters (IAFF) on proposed amendments to the Canadian Aviation Regulations, Part III – Aerodromes and Airports, as published in the Canada Gazette, Part 1 on June 29, 2002. There is no objection to the disclosure of this document in its entirety under the provisions of the Access to Information Act.

Specifically, this comment will address the proposed amendment to add the word “Rescue” to the heading of Subpart 3.

The IAFF represents 252,000 professional fire fighters and emergency medical personnel in North America, 17,500 of them in Canada. The IAFF’s Canadian membership includes fire fighters who work full-time at a number of designated airports in Canada, as well as fire fighters who are otherwise called to respond to emergency situations at designated airports in Canada. The status of airport regulations in Canada have significant consequence on the ability of these fire fighters, whether primary or secondary responders at a designated airport, to carry out their duties safely and effectively in response to an airport emergency.

The IAFF has long advocated the introduction of responsible airport rescue and fire fighting standards in Canada, through direct contact and correspondence with the Minister of Transport and as a member of the Canadian Aviation Regulation Advisory Council (CARAC) Technical Committee III.

At first glance, the addition of the word “rescue” to the title of CAR 303 would appear to be a positive step toward the introduction of airport rescue and fire fighting standards that reasonably protect the flying public in the event of an aircraft accident, or at least an acknowledgement that the specific function of rescue is an element of aircraft accident survivability.

However, analysis of the definition provided under Section 303.01 (Interpretation) illustrates that this proposed amendment is completely without consequence, since the proposed definition contains the phrase “if circumstances permit.” This ambiguous language makes the amendment completely meaningless and without impact.

The Regulatory Impact Analysis Statement (RIAS) for this amendment in fact admits that the definition was drafted “in support of the regulatory authority’s undertaking that no additional resource requirements will be imposed on operators as an unintended consequence of this proposed title change.”

Adding the word “Rescue” to the title of CAR 303 for the purpose of optics, or in an attempt to retroactively and inaccurately describe the existing situation at designated airports in Canada, will serve only to exacerbate the flying public’s false sense of security about airport emergency response at Canada’s designated airports. The argument that the amendment is proposed for the sake of uniformity with other jurisdictions is not convincing.

This proposed amendment would simply not change the fact that there is no regulatory requirement for airport operators to provide the on-site resources necessary to perform the task of rescuing trapped passengers in the event of an aircraft accident or fire at a designated airport in Canada.

As an example, airport fire fighters at the Macdonald-Cartier Airport in Ottawa confirm that if an aircraft accident or fire was to occur, they would not be able to attempt interior fire suppression or the rescue of trapped passengers because they are not provided with the staffing and other resources that are necessary to do so. Any form of rescue at this major airport could be considered only upon the arrival of secondary response from off-site providers – which could be 10 minutes away. This is despite the fact that conditions inside the cabin of a downed aircraft become lethal – reaching temperatures of 1,800 F – in three to four minutes. It is therefore widely held any rescue mission that has a chance of saving lives must have a response of three minutes or less. Expecting there will still be surviving passengers to be rescued by secondary responders arriving 10 minutes after the accident is not realistic.

These critical considerations are reflected in the standards set by such bodies as the International Civil Aviation Organization (ICAO) and the National Fire Protection Association (NFPA), which both specify a response time of under three minutes to all points on all operational runways, and importantly, both specify rescue as a function of airport fire fighters.

While one or two designated airports in Canada voluntarily provide the resources necessary to effect the rescue of trapped passengers in a timely fashion, this major public safety issue is deserving of a national standard that is applied evenly at all designated airports in Canada.

The IAFF submits that while the acknowledgment that the function of rescue is a critical element of aircraft survivability may appear to be a positive step, it is ultimately meaningless without any companion amendment that would specifically require airport operators to allocate the on-site resources necessary for any practical form of rescue that would indeed increase the chances of survivability in the event of an aircraft accident or incident.

All of which is respectfully submitted.

Jim Lee
Assistant to the General President, Canadian Operations
International Association of Fire Fighters