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Cockpit Voice Recorder JAR-OPS 3.700/3.705 D. Suriaganda. Problem Description. Clarification. Proposed Changes. The working paper for this subject should have been distributed to you last week. Problem Description.
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Cockpit Voice Recorder JAR-OPS 3.700/3.705 D. Suriaganda
Problem Description • Clarification • Proposed Changes The working paper for this subject should have been distributed to you last week
Problem Description Date of Issue of the first individual C. of A defines the features of CVR to be met. MTOM > 3175 kg These are reflected in two requirements: 3.700(a) ~ ED56A 01.08.1999 3.705(a) ~ ED56 01.01.1987 31.07.1999 • MTOM ≤ 7000 kg • 3175 kg < MTOM ≤ 7000 kg 1. It is found difficult in subpart (a) of JAR-OPS 3.705 to understand the references of logical relationships “or” and “and”. 2. Overlapping area 3.705 preferred!! Which one is the correct one?
01.01.1987 31.07.1999 1. NPA-OPS 27 2. • Clarification Which one is the correct one? Interpretation 1. or 2.? • To solve this, we need to go through changes made for these requirements • Last changes were made in the Amendment 2 arising from NPA-OPS 27. The aim of these changes : To bring the rule into compliance with ICAO Standard (4.3.5.2) • The ICAO Standard mandates the carriage of a CVR on helicopters under following two conditions: • Having C of A first issued individually on or after 1 January 1987. • Having MCTOM between 3175 and 7000 kg. • So it looks to mean: • BUT as the JAR-OPS 3 sets a different design standards after 01.08.1999:
Clarification (cont.) The correct understanding, as to which design standard is to be met, is shown below: MTOM > 3175 kg 3.700(a) ~ ED56A 01.08.1999 3.705(a) ~ ED56 01.01.1987 31.07.1999 No Overlapping Area Clarification needs to be amended • MTOM > 7000 kg • 3175 kg < MTOM ≤ 7000 kg
Proposed Changes • JAR-OPS 3.705 Cockpit voice recorders-2 • (See ACJ-OPS 3.705) • An operator shall not operate a helicopter first issued with an individual Certificate of Airworthiness, up to and including 31 July 1999, which has: • A maximum certificated take-off mass (MCTOM) over 7000 kg , or • A maximum certificated take-off mass (MCTOM) over 3175 kg but not more than 7000 kg and an individual Certificate of Airworthiness first issued on or after 1 January 1987 • unless it is equipped with a cockpit voice recorder. • (a) An operator shall not operate a helicopter first issued with an individual certificate of Airworthiness, up to and including 31 July 1999 which has a maximum certificated take-off mass (MCTOM) over 7000 kg, or a maximum take-off mass (MCTOM) over 3175 kg but not more than 7000 kg and an individual certificate of Airworthiness first issued on or after 1 January 1987, unless it is equipped with aThe cockpit voice recorder shall, with reference to a timescale, record:] • (f) [Helicopters with a maximum certificated take-off mass (MCTOM) over 3 175 kg but not more than 7 000 kg operated for the purpose of HEMS on or before 1 August31July 1999, may continue to be operated for the purpose of HEMS without being equipped with a cockpit voice recorder until 31 December 2010, if acceptable to the Authority.]
Proposed Changes (cont.) -------------In order to have the same structure as proposed for the JAR-OPS 3.705(a), the leading text of subparagraph (a) of JAR-OPS 3.700 shall also be moved and put as a leading text for the whole requirement JAR-OPS 3.700---------------------- • JAR-OPS 3.700 Cockpit voice recorders-1 • (See ACJ-OPS 3.700) • An operator shall not operate a helicopter first issued with an individual Certificate of Airworthiness, on or after 1 August 1999, which has a maximum certificated take-off mass (MCTOM) over 3 175 kg unless it is equipped with a cockpit voice recorder. • An operator shall not operate a helicopter first issued with an individual Certificate of Airworthiness, on or after 1 August 1999, which has a minimum certificated take-off mass (MCTOM) over 3175 kg unless it is equipped with aThe cockpit voice recorder which shall, with reference to a time scale, records: -----------------end of clarification--------------------