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Cockpit Voice Recorders (CVR) JAR-OPS 3

Cockpit Voice Recorders (CVR) JAR-OPS 3. OST WP-10-06 HSST WP-05/15.4. Interduction. JAR-OPS 3.700 and 3.705 are sections dealing with the requirements to fit Cockpit Voice Recorders (CVR) into helicopters.

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Cockpit Voice Recorders (CVR) JAR-OPS 3

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  1. Cockpit Voice Recorders (CVR)JAR-OPS 3 OST WP-10-06 HSST WP-05/15.4

  2. Interduction JAR-OPS 3.700 and 3.705 are sections dealing with the requirements to fit Cockpit Voice Recorders (CVR) into helicopters. Whilst 3.700(a) is written in a clear and unambiguous way, 3.705(a) is open to interpretation and has caused confusion amongst some readers.

  3. Interduction In order to remove this problem, it is proposed to amend the text to state the requirement more clearly. Additionally, the date of applicability in paragraph 3.705(f) regarding HEMS operations requires aligning with the requirements of 3.700(a) and 3.705(a).

  4. Proposal • The text at 3.705(a) refers to two categories of helicopter mass and two dates for applicability. It is the way the two dates are written that has caused the confusion as the text can be interpreted in several ways. • The paragraph has been incrementally amended over time and the sense of applicability has been lost. • It could be read that the date of 01 January 1987 refers to both categories or that the date of 31 July 1999 only refers to the greater than 7000 kg helicopters.

  5. Proposal • To make the text clear and to reinsert the intent to align the applicability with that of ICAO, it is proposed to introduce an editorial change and re-word the paragraph so that there can be no ambiguity. • The current text has been compared with ICAO Annex 6, Part 3, Section II, paragraphs 4.3.5 and 4.3.6 for the correct interpretation. The amended text is detailed below.

  6. Proposal • Paragraph 3.705(f) allows helicopters operated for the purposes of HEMS on or before 01 August 1999 with a MCTOM of over 3175 kg but not more than 7000 kg to continue to operate to 31 Dec 2010 without a CVR if acceptable to the Authority. • It is considered that the applicability date should reflect that at paragraph 3.705(a) and should be changed to on or before 31 July 1999.

  7. Regulatory Impact Assessment • The effect of the changed text at 3.705(a) will be to make the interpretation of the requirement to fit CVRs to commercial transport helicopters unambiguous and to ensure that the intent of the code is harmonious with ICAO Annex 6.

  8. Regulatory Impact Assessment • The date of 01 August 1999 at 3.705(f) has been changed to 31 July 1999 to make it consistent with other paragraphs and should have limited, if any, consequential effect.

  9. Regulatory Impact Assessment • There are not expected to be any additional economic, safety or other effects following these amendments.

  10. Amendment to JAR-OPS 3.705(a)(Text today) • (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 7 000 kg or a maximum [ certificated take-off mass (MCTOM) over 3 175 kg but not more than 7 000 kg and first issued with an individual Certificate of Airworthiness on or after 1 January 1987; ] unless it is equipped with a cockpit voice recorder which records with reference to a timescale: ]

  11. Amendment to JAR-OPS 3.705(a)(new Text) • (a) An operator shall not operate a helicopter which has either a maximum certificated take-off mass (MCTOM) of over 3175 kg but not more than 7000 kg and first issued with an individual Certificate of Airworthiness between 1 January 1987 and up to and including 31 July 1999, or a MCTOM of over 7000 kg and first issued with an individual Certificate of Airworthiness up to and including 31 July 1999, unless it is equipped with a cockpit voice recorder which records with reference to a timescale:

  12. Amendment to JAR-OPS 3.705(f)(new Text) • (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 August 199931 July 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.]

  13. Questions ??

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