Eight Hours

Doing company annual paperwork sends me back to reading the CARs and the ops manual to answer all those questions again. I have read the below rules dozens of times, can pretty much recite them by heart, but today I suddenly saw a possible new interpretation of paragraph (f).

700.15 (1) Subject to subsection (2), no air operator shall assign a flight crew member for flight time, and no flight crew member shall accept such an assignment, if the flight crew member's total flight time in all flights conducted by the flight crew member will, as a result, exceed



(a) 1,200 hours in any 365 consecutive days;



(b) 300 hours in any 90 consecutive days;



(c) 120 hours in any 30 consecutive days or, in the case of a flight crew member on call, 100 hours in any 30 consecutive days;



(d) where the flight is conducted under Subpart 4 or 5 using an aircraft other than a helicopter, 40 hours in any 7 consecutive days;



(e) where the flight is conducted under Subpart 2 or 3, or is conducted using a helicopter, 60 hours in any 7 consecutive days; or



(f) where the flight crew member conducts single-pilot IFR flights, 8 hours in any 24 consecutive hours.

Now Canadian pilots all know this, and generally know their company exceptions well, too, so I'm not even sure why I re-read it. I could have told you that I wasn't allowed to fly more than eight hours in a day if I was doing single-pilot IFR. I'd usually say it, "I'm not allowed to fly single pilot IFR if I fly more than eight hours in a day." I've actually flown eight hours of SPIFR, cancelled IFR, and flown out the balance of my 14 hour duty day VFR. I thought of it as the same kind of thing as doing part 702 work at the end of the week when you already have forty hours of 704 work done: dutied out for one kind of flying but okay for the other. And then when you're dutied out for 702 you can go do flight instruction, because there is no limit on flight instructors. Been there, done that.

Yet suddenly I re-read this and think, "doesn't this make it look as if we are never allowed to log more than eight hours in a day if we ever conduct single-pilot IFR?" This would appear to forbid departing IFR through an area of poor weather, cancelling IFR, and flying VFR for the balance of the flight, then refuelling and doing another five hours VFR. It even appears to forbid flying twelve hour VFR days for a week, taking a week off and then doing a one-hour single-pilot IFR flight.

Surely that can't be what they meant. Surely I've just been reading too many air regs lately. What do you think?