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HSST D-NPAs Presentation for 1st RST review

HSST D-NPAs Presentation for 1st RST review. Content D-NPA-OPS 67 - JAR-OPS 3 Type IVA FDR’s D-NPA-OPS 68 - JAR-OPS 3 Use of headsets D-NPA-OPS 69 - JAR-OPS 3 Helicopter Hoist Operations D-NPA-OPS 70 - JAR-OPS 3 Dangerous Goods How to proceed. D-NPA-OPS 67 - JAR-OPS 3 Type IVA FDR’s.

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HSST D-NPAs Presentation for 1st RST review

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  1. HSST D-NPAs Presentation for 1st RST review RST 07-2 26th June 2007

  2. Content D-NPA-OPS 67 - JAR-OPS 3 Type IVA FDR’s D-NPA-OPS 68 - JAR-OPS 3 Use of headsets D-NPA-OPS 69 - JAR-OPS 3 Helicopter Hoist Operations D-NPA-OPS 70 - JAR-OPS 3 Dangerous Goods How to proceed RST 07-2 26th June 2007

  3. D-NPA-OPS 67 - JAR-OPS 3 Type IVA FDR’s RST 07-2 26th June 2007

  4. Requirement The Type IVA FDR is mandated by ICAO Annex 6 Part III Section II Helicopters with a maximum certificated take-off weight in excess of 3180 (3175) kg With the first individual certificate of airworthiness issued after 1st January 2005 The Type IVA FDR can capture an increased range of data derived from the most recent developments in helicopter technology and avionics with up to 47 parameters being recorded JAR-OPS 3 does not yet cover this requirement RST 07-2 26th June 2007

  5. Background • After the completion of the approval process of NPA OPS-25, the OST tasked the Flight Recorder Study Group (FRSG) to introduce the new ICAO flight recorders standards for helicopters into JAR-OPS 3 • This was conducted and WP FRSG 03-04 was produced • WP not progressed • OST Action 06-2/23 tasked HSST with EQSG • Significant updating completed by HSST with agreement of EQSG to produce WP-06/03.7 • Considerable liaison with ICAO FLIRECP conducted RST 07-2 26th June 2007

  6. Draft NPA • Amend JAR-OPS 3 by introducing a new requirement (3.712) and associated Appendix and ACJ, to align with ICAO Annex 6 Part III Section II and FAR Part 135 • Requiring an enhanced level of parameters to be recorded by FDR’s. This will require the fitment of a FDR with at least Type IVA capabilities. • Introduction of a significant number of consequential changes to both Section 1 and 2 and corrections following previous amendments RST 07-2 26th June 2007

  7. Consultation • Considerable consultation was conducted by the FRSG/ HSST / EQSG in drafting this NPA including liaison with representatives of the FLIRECP RST 07-2 26th June 2007

  8. Summary and Final Assessment • The proposed changes to JAR-OPS 3 will ensure alignment with the ICAO Annex 6 • The retro-fitting of helicopters first issued with Cs of A after 1st January 2005 (Annex 6) would be largely impracticable and would involve unreasonable expense • The preferred option is to mandate the fitting of Type IVA FDRs in helicopters first issued with an individual Certificate of Airworthiness on or after 1st January 2010 RST 07-2 26th June 2007

  9. D-NPA-OPS 67 – Type IVA FDR’s • Included in the JAA Rulemaking Plan 2007/2008 (RMP) as CAT 2 • To progress work under the JAA system (without finalising it) for tasks that can deliver an input to the draft Implementing Rules before the related EASA NPA are published; as said above this means that a deliverable blessed at least by the OST or LST, with sufficient technical consensus, shall be available by October 2007. These tasks are called hereunder “Cat 2 tasks”. RST 07-2 26th June 2007

  10. D-NPA-OPS 68 - JAR-OPS 3 Use of Headsets RST 07-2 26th June 2007

  11. Background • A recent review of the requirements for the use of headsets within aeroplanes resulted in a change to JAR-OPS 1 as proposed by NPA-OPS 49 • Action OST 05-2/37 tasked HSST to consider similar review for helicopters? • Initial view was no as headsets generally worn due to noise and environment • Fitment is covered, but wearing is not • Sensible to add requirement for clarification and harmonisation RST 07-2 26th June 2007

  12. Draft NPA • Proposal to amend JAR-OPS 3 for the purpose of introducing a new requirement (3.313) for the use of headsets by flight crew when required to be at their station • Amend IEM OPS 3.647 to ACJ OPS 3.647 • Equipment for operations requiring a radio communication and/or radio navigation system • Add new text into the ACJ and cross reference to 3.313 RST 07-2 26th June 2007

  13. Harmonisation • The proposal will bring JAR-OPS 3 closer to both JAR-OPS 1 and ICAO Annex 6 • There are no issues on alignment with FAA • Introduces guidance on the use of aviation helmets RST 07-2 26th June 2007

  14. Consultation • The consultation process has been conducted within the Helicopter Sub-Sectorial Team and reflects the consultation already conducted under NPA-OPS 49 RST 07-2 26th June 2007

  15. Summary and Final Assessment • The proposed new JAR-OPS 3.313 will introduce a regulation that will help to ensure good communications and therefore enhance safety. The proposal will have no significant cost implications and will harmonise JAR-OPS 3 with ICAO Annex 6 Part III and FAA requirements • Note: Para 1.2.4 (c) should be (b) RST 07-2 26th June 2007

  16. D-NPA-OPS 68 – Use of Headsets • Transferred into JAA Rulemaking Plan 2007/2008 (RMP) as CAT 2 after comment to the draft RMP by UK CAA • To progress work under the JAA system (without finalising it) for tasks that can deliver an input to the draft Implementing Rules before the related EASA NPA are published; as said above this means that a deliverable blessed at least by the OST or LST, with sufficient technical consensus, shall be available by October 2007. These tasks are called hereunder “Cat 2 tasks”. RST 07-2 26th June 2007

  17. D-NPA-OPS 69 - JAR-OPS 3 Helicopter Hoist Operations RST 07-2 26th June 2007

  18. Background • Some of the requirements relating to Helicopter Hoist Operations detailed in Appendix 1 to JAR-OPS 3.005(h) have been found to be difficult to interpret and implement • This is particularly relevant to text which relates to the helicopter hoist equipment and its standard of airworthiness approval appropriate to the intended use or function • The aim of this paper is to introduce a new ACJ to provide explanatory material to clarify and explain the requirements RST 07-2 26th June 2007

  19. Background • FAA included the airworthiness standard for Human External Cargo (HEC) application into Part 27.865 Amendment 36 and Part 29.865 Amendment 43 • JAA endorsed these as JAR 27.865 Amend 2 (with some modifications - including JAR 27.865(c)(6), the requirement for one-engine-inoperative hover performance data - not present in FAR 27.865) and JAR 29.865 Amendment 2, which were released in May 2001 • EASA adopted as CS 27/29.865 with some modifications in November 2003 RST 07-2 26th June 2007

  20. Background • FAA advisory circular (AC), AC29-2C Change 1, remains the current guidance for compliance as indicated in the Acceptable Means of Compliance Book 2 of CS-27/29 • AC has been updated to Change 2 status which amongst other subjects included merging MG 12 into AC27.865B and AC29.865B • Change 2 to AMC to CS-27/29 under review by EASA • AC likely to be incorporated in due course • outstanding issues to be dealt with RST 07-2 26th June 2007

  21. Background • The majority of hoist installations currently in existence were certificated in accordance with previous amendment standards where the airworthiness requirements did not distinguish between the kinds of external cargo that were intended to be carried • In interpreting the phrase “appropriate to the intended function” of para (e)(1) of the Appendix, and due to past experience following several accidents, some Authorities decided to require the higher standards necessary for HEC applications to be applied to existing installations • It was clearly explained in AC29-2C MG12 that the described methods of compliance were intended to apply only to either new designs or major modifications to existing designs from the effective date of the specs RST 07-2 26th June 2007

  22. Background • Such Authorities require that retrofit actions or further investigations are mandatory for the granting or maintaining of the operational approval for existing hoist systems • The new ACJ describes alternative approaches to the minimum level of retrofit effort necessary to achieve a satisfactory standard of equipment installation. • These approaches could include a comprehensive review to confirm safe design of the existing hoist installation to demonstrate an acceptable level of compliance against the actual specifications of HEC as required by CS 27/29.865 or JAR 27/29 Amendment 2 (27/29.865) RST 07-2 26th June 2007

  23. Draft NPA • Proposal to amend JAR-OPS 3 in order to achieve a European wide solution to the interpretation of the requirements relating to Helicopter Hoist Operations detailed in Appendix 1 to JAR-OPS 3.005(h), by the introduction of a new ACJ to Appendix 1 to JAR-OPS 3.005(h) sub-paragraph (e)(1). • Additionally, it is proposed to insert references to the relevant ACJ’s into the heading of Appendix 1 to JAR-OPS 3.005(h) which are currently missing RST 07-2 26th June 2007

  24. Harmonisation • There are some harmonisation issues with regards to the current standards of FARs and CSs in dealing with Human External Cargo requirements • These are outlined in the NPA but are subject to review by EASA RST 07-2 26th June 2007

  25. Consultation • This proposal has received wide input from operators, National Authorities and manufacturers during its development within the HSST and has been reviewed and amended by EASA RST 07-2 26th June 2007

  26. Summary and Final Assessment • The introduction of this advisory material will help to alleviate different interpretations of text within Appendix 1 to JAR-OPS 3.005(h) sub-paragraph (e)(1) and a more harmonious approach to its application. • Those affected would be operators of older helicopter / hoist equipment combinations which had certification completed before more stringent standards were applied for the external carriage of human cargo. RST 07-2 26th June 2007

  27. D-NPA-OPS 69 – Helicopter Hoist Operations • Included in the JAA Rulemaking Plan 2007/2008 (RMP) as CAT 2 • To progress work under the JAA system (without finalising it) for tasks that can deliver an input to the draft Implementing Rules before the related EASA NPA are published; as said above this means that a deliverable blessed at least by the OST or LST, with sufficient technical consensus, shall be available by October 2007. These tasks are called hereunder “Cat 2 tasks”. RST 07-2 26th June 2007

  28. D-NPA-OPS 70 - JAR-OPS 3 Dangerous Goods RST 07-2 26th June 2007

  29. Requirements • State responsibilities: • Inspections, surveillance and enforcement • Record and investigate incidents/accidents • Compliance with Technical Instructions • (JAR-OPS reflects 1999-2000 Technical Instructions) RST 07-2 26th June 2007

  30. Background • JAR-OPS 1 amended by the DGSG but JAR-OPS 3 not addressed • OST Action 06-3/5 for HSST to progress NPA with DGSG • Lack of harmonisation exists on a subject generic to all aircraft • NPA-OPS 46, the amended JAR-OPS 1 and revisions from DGSG used as the framework for this NPA • Helicopter specific areas and differences highlighted and addressed • Chairman of DGSG involved and cooperated with change RST 07-2 26th June 2007

  31. Draft NPA • Proposal to amend JAR-OPS 3 in the same manner as JAR-OPS 1 regarding the carriage of Dangerous Goods and use NPA-OPS 46 as the basis for the change, as updated by the newer requirements of TI for 2007/8. RST 07-2 26th June 2007

  32. NPA-OPS 46 JAR-OPS 1 • Amendments broadly fell under 4 headings: • Alignment with the Technical Instructions • Review of Part 2 material • Amendments proposed by DGSG • Increased reference to Technical Instructions • Incorporated into JAR-OPS 1 at Amend 12 RST 07-2 26th June 2007

  33. Consultation • Considerable consultation was conducted by the DGSG in drafting NPA-OPS 46 together with the public consultation • Additional consultation has been conducted within the Helicopter Sub-Sectorial Team and the DGSG RST 07-2 26th June 2007

  34. Summary and Final Assessment • The proposed changes to JAR-OPS 3 will ensure alignment with the ICAO Technical Instructions, thus preventing significant issues for states and operators alike. • The changes will also align JAR-OPS 3 with JAR-OPS 1 although where there are differences due to the special requirements of helicopter operations these are detailed • Reduce the need to amend JAR-OPS when a new edition of the Technical Instructions is produced RST 07-2 26th June 2007

  35. D-NPA-OPS 70 – Dangerous Goods • Transferred into JAA Rulemaking Plan 2007/2008 (RMP) as CAT 2 after comment to the draft RMP by UK CAA • To progress work under the JAA system (without finalising it) for tasks that can deliver an input to the draft Implementing Rules before the related EASA NPA are published; as said above this means that a deliverable blessed at least by the OST or LST, with sufficient technical consensus, shall be available by October 2007. These tasks are called hereunder “Cat 2 tasks”. RST 07-2 26th June 2007

  36. How to proceed RST 07-2 26th June 2007

  37. EASA and JAAC have agreed on a JAA Rulemaking Plan 2007/2008 (RMP) for the transfer of task undertaken by the JAA into the EASA framework. • The RMP provides a prioritisation for the handling of JAA NPA’s, including their transfer to EASA inventory where appropriate. • Definition of CAT 2 as agreed by the JAAC and EASA. • To progress work under the JAA system (without finalising it) for tasks that can deliver an input to the draft Implementing Rules before the related EASA NPA are published; as said above this means that a deliverable blessed at least by the OST or LST, with sufficient technical consensus, shall be available by October 2007. These tasks are called hereunder “Cat 2 tasks”. RST 07-2 26th June 2007

  38. D-NPA-OPS 67 – Type IVA FDR’s • D-NPA-OPS 69 – Helicopter Hoist Operations • These were already in the RMP as CAT 2 • D-NPA-OPS 68 – Use of headsets • D-NPA-OPS 70 – Dangerous Goods • These were transferred into RMP as CAT 2 RST 07-2 26th June 2007

  39. D-NPA’s as mentioned now incorporated in the RMP as CAT 2 • If agreed by RST as mature papers in accordance with JAR-11, then no further progress through JAA LO • These papers cannot be finalised through the JAR-11 process before October 2007 as an amendment to JAR-OPS 3 • Handover to EASA for incorporation into the IR’s • Public consultation through the EASA NPA RST 07-2 26th June 2007

  40. Questions?? RST 07-2 26th June 2007

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