A19-01 - “…the Department of Transport amend the Canadian Aviation Regulations to remove any ambiguity associated with the definition of “safety belt.”
Transport Canada Response to Recommendation A19-01
Transport Canada (TC) agrees with aviation safety recommendation (A19-01).
In December of 2019 TC began to conduct a preliminary assessment of the regulatory impact of changing the definition of “safety belt”. The assessment is expected to be completed in early spring 2020.
The assessment includes: a review of the definition in the Canadian Aviation Regulations (CARs) and an analysis of the potential consequences of this definition change to other parts of the regulations. Once consultation with stakeholders is conducted and the most appropriate mechanism for undertaking this recommended change is determined, the regulatory work to amend the definition will commence.
TC will be able to provide a more detailed timeline for this change upon completion of the preliminary analysis. If the change to the definition is deemed to have minimal impact, then the change may be pursued using the Miscellaneous Amendments Regulations (MAR) process. However, if potential consequences to other parts of the CARs are identified, the change will need to follow the full federal regulatory development process.
In the meantime, as described in the investigation report, TC has already taken mitigating measures to encourage the proper use of safety belts. TC began informally consulting with stakeholders on the potential impact of the recommended change in the margins of the Helicopter Association of Canada (HAC) annual meeting in November 2019. In addition, TC has published guidance material concerning the use of safety belts in Aviation Safety Letters (ASL) 4/2013Footnote 1 and 1/2018Footnote 2, and Advisory Circular (AC) 605-004Footnote 3. Also, more recently, TC has published Civil Aviation Safety Alert (CASA) 2018-02Footnote 4 reminding operators of the correct use of passenger seatbelts and the importance of securing cargo.