Canada COVID Vaccine Mandate and its impact on business aviation crew

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Transport Canada recently released a new FAQ addressing its Vaccination Mandate Policy that clears up much of the conflicting information we’ve been hearing across the industry – particularly around the crew requirement portion.

Download it here [PDF]


Crew are exempt until at least Nov. 30, 2021

Private operators (CAR 604) are exempt from the requirement to develop a vaccine policy for their employees (i.e., crew) and the paperwork that goes with it until, at least, November 30.

However, private crew will lose their exemption if they need to access a “restricted area” in a Schedule 2 airport.


Schedule 2 Canada airports

On November 15, Schedule 2 airports are required to designate a “restricted area”. The FAQ covers the formal definition of that.

The unknown is the actual area within each airport that will be designated as restricted. It could be the whole airport, the customs area, or somewhere else that crew have to transit…and it could vary widely from airport-to-airport.

Guidance hasn’t yet been published on this, so right now our Global Regulatory Services team is working closely with CBAA and NBAA to report on the latest.

CBAA has built this map showing Schedule 2 airports (blue pins) and other accessible airports that don’t fall under Schedule 2 (yellow).

Canada vaccine mandate impact on Charter operators (opinion)

We’re still seeking clarity on how this applies to charter operators – specifically CFAOC holders vs. non-holders.

For example: If a U.S. Part 135 operator holds a Canadian AOC, would they in fact be considered  701 operator for these purposes or would they still be considered more like a 604?

We’re still working on attaining official confirmation on the answer, but our current opinion based on conversations with our colleagues at CBAA is as follows:

If a US operator does in fact hold a 701 then they would be required to draft a vaccine policy and follow the air carrier reporting obligations. If they don’t hold a 701, then they won’t have to worry about the policy creation and reporting.

Reminder that regardless 91, 91k, 135 are all required to demonstrate that negative COVID 19 Molecular test coming into Canada. In addition, they’re likely going to be flying vaccinated passengers because the quarantine won’t be something that the average pax is willing to consider upon their arrival. Therefore, the average operator will be transporting vaccinated and COVID test carrying passengers.

If the above is true, then operating within Canada with these new rules is not an issue for those who came in. The only thing to consider potentially is if they happen to pick up a Canadian passenger from a Schedule 2 airport. The upcoming rules around the restricted area access will provide more information about what if any rules are actually to be followed in order to get access to an airports declared restricted area.


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