The safety of our passengers and employees is always Air Canada's top priority and for this reason we view this incident very seriously. We sincerely regret that some of our customers were injured and we have taken measures to prevent a re-occurrence of this type of event and improve safety overall. Air Canada, including the flight crew, fully cooperated with the TSB throughout this investigation. Based on preliminary findings, we have taken appropriate actions and we will now study the final report to determine if there are additional measures we can implement to enhance safety.

As cited in the TSB's report, Air Canada has already taken the following measures to improve safety:

• Reinforced through formal channels the proper procedures to follow in cases where controlled rest is used by pilots.

• Increased efforts outside regular training, including through articles in in-house publications, to heighten awareness of fatigue issues, particularly with respect to the effects of sleep on the human body;
  

• Undertook a Pairing Evaluation and Assessment Committee (PEAC) data collection on the Toronto-Zurich route to better understand the alertness levels of crews on these flights. This committee has company and Air Canada Pilots Association representatives.

• Air Canada has developed a special fatigue report form for use in its safety reporting system to ensure all fatigue reports are integrated in a common database to track fatigue issues. This enhanced system should be in place in summer of 2012.

• Issued a directive for pilots requiring them to fly one or two nautical miles laterally off the centre line of internationally designated flight tracks in order to increase separation from other aircraft. 
  

I know you are looking at fatigue, among other things Air Canada:

• Requires pilots who feel they are too tired to fly or otherwise not capable of flying safely to report this, in compliance with Transport Canada regulations. A non-punitive system is in place that allows pilots to withdraw from assignments;

• Operates with rules respecting duty days and rest periods that are more conservative than what Transport Canada requires. For example, the Canadian Aviation Regulations allow two pilots to operate for a 14-hour duty day at any time of day or night, but under its collective agreement with its pilots, Air Canada schedules a duty day for two pilots of 10 hours - four hours less than legally permitted - for duty commencing between 22:00 hours and 04:59 hours;

• Maintains a Pairing Evaluation and Assessment Committee that also involves both managers and pilots who look at specific routes to determine if there are concerns. There is no statutory requirement for such a committee.

• Is in the process of acquiring new software that will use algorithms to analyze flight pairings and rosters to identify flight combinations that could induce fatigue. Once a vendor is selected, Air Canada will use this technology to analyze flight sequences and take appropriate measures to increase crew alertness.

• Is developing a Fatigue Risk Management System (FRMS) that will draw upon the most current knowledge and incorporate global best practices with respect to fatigue-related issues. It is envisioned that FRMS will be implemented in cooperation with members of flight operations management, the Air Canada Pilots Association, Corporate Safety and Occupational Health. There is currently no statutory requirement for an FRMS in Canada;

• Air Canada also participates in the Canadian Aviation Regulation Advisory Council (CARAC). This is a joint industry-government body that regularly reviews policies and regulations, including those related to flight and duty time limitations.