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June Missive by Skidmore places onus away from CASA

June 2015 Missive by Skidmore

A short read of this shows CASA is still going the way of “…we know best, if you think differently, you must prove it to us…”.

This means there is the opportunity for people in the aviation community to show CASA how the right safety outcomes under the regulations can be achieved at a lower cost or administrative burden. 

Skidmore then tries to have it that the industry could not be correct in saying:

In other words, CASA is not saying “it is our way or the highway” when it comes to the exercise of our discretionary compliance powers.

As the press recently has been saying, this does not auger well for the industry.

We must have Jeff Boyd and the Board correcting this situation so that another Part 61 [some concessions to the helicopter industry] does not occur, where it near to impossible to comply without huge across all the aviation industry.

The ASRR [Aviation Safety Regulatory Review] must be implemented in full.

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CASA Briefing
June 2015

From the Director of Aviation Safety, Mark Skidmore

I recently released an important new policy directive about the development and application of the aviation safety regulations. While the directive reaffirms CASA’s position on the development of regulations, it takes the principles a step further by clearly setting out how they relate to the application and administration of the regulations. CASA must still apply the regulations in accordance with their intent and safety must be regarded as the most important consideration. But we must also consider all other relevant issues, including costs and administrative burden.

This means there is the opportunity for people in the aviation community to show CASA how the right safety outcomes under the regulations can be achieved at a lower cost or administrative burden. In other words, CASA is not saying “it is our way or the highway” when it comes to the exercise of our discretionary compliance powers.

Of course, anyone who wishes to put forward an alternative approach to the application and administration of the regulations will have to be able to convincingly demonstrate they can achieve the same safety outcome intended by the regulations. The alternative approach they propose must not be inconsistent with an express regulatory requirement. They will also have to show how they will fully and effectively implement the alternative approach to compliance in a timely fashion. Alternative approaches must not require unreasonable additional oversight or administration by CASA and no other persons should be adversely or unfairly affected. The directive I issued concludes by saying: “CASA will entertain a reasonable proposal for the adoption of another approach and, in the absence of good reason not to do so, CASA will adopt such an alternative approach.”

When developing regulations the directive makes it clear CASA must address known or likely safety risks that cannot be addressed effectively by a non-regulatory means alone. Every proposed regulation must be assessed against the contribution it will make to aviation safety, having particular regard to the safety of passengers and others who may be affected Regulations must not impose unnecessary costs or unnecessarily hinder levels of participation in aviation or the capacity for growth. Regulations should be aligned with the standards and practices of the International Civil Aviation Organization and leading aviation countries, unless differences are necessary due to unique Australian factors and can be justified on the basis of safety. Where it is appropriate, regulations are to be drafted to specify intended safety outcomes. In developing regulations, CASA must consult appropriately with the aviation community in an open and transparent manner ensuring that all communication is clear, timely and effective. Subject to the applicable drafting requirements, CASA will strive to ensure regulations are drafted as clearly and concisely as possible within a three-tier framework.

Please read the new directive and if you have any comments send them to me.

This is the directive about the development and application of regulations.

Send your feedback to me.

Safe flying

Mark Skidmore AM


On-line services unavailable during IT upgrade

A number of CASA’s on-line services will be temporarily unavailable in early July 2015. The services will be off-line from the close of business on Tuesday 30 June 2015 for up to five working days. At the latest CASA’s on-line services will restart from the opening of business on Wednesday 8 July 2015. They may be available earlier and CASA will advertise this on its website. The services will be unavailable due to work being undertaken to introduce a new IT system to support CASA’s day-to-day regulatory activities. The new system – known as the Aviation Information Management System – is needed because CASA’s existing IT platform is simply out of date. On-line services affected by the upgrade work include the old self-service portal, the new on-line self-service facility, the medical records system, service difficulty reports, the delegate management system, examination bookings or changes and new applications for ASICs. Anyone who urgently needs any of these services during the time the on-line systems are unavailable should contact the relevant area within CASA by telephoneor email.

CASA apologises for the inconvenience caused by the unavailability of the systems but once the work is completed it should enhance CASA’s service delivery. The new IT platform will host all personnel licences, all certificates and approvals, aircraft registration and a range of other permissions. After the new platform is operational there will be a few changes, including an extra space on forms where an aviation reference number needs to be entered. The additional space is for the issue of new aviation reference numbers in the future and does not affect existing numbers. People who have an existing six digit aviation reference number should just leave the space blank.

Find out more about the unavailable on-line services and where to contact for assistance.

Register soon for new on-line self service

CASA’s old online self-service portal will close on 30 June 2015. The old portal has been replaced by a new online self-service facility which is progressively offering a wider range of services to users. The new facility can be used by pilots, licensed engineers, air traffic controllers and ground handling personnel. From 8 July users will be able to view and update their personal details including residential address, contact phone number and email address. Maintenance personnel and air navigation services licence holders can already view their licence details. The new facility provides a range of benefits to users, including the ability to download, submit and track the status of forms submitted online. There are online forms available for flight crew licensing covering aeroplanes, helicopters and unmanned aerial vehicles, as well as those relating to maintenance personnel. To use the new facility people will have to register, with registration on the old self -service portal not transferred to the new facility. When registering, people will need to use their aviation reference number and make sure CASA has their current email address as this is used as part of the self-service activation process.

Register and use the new CASA online self-service now.

Anyone who has difficulties setting up an account should telephone 1300 737 032 or emailclarc@casa.gov.au.

Feedback informs licensing regs fine tuning

A rolling update on the post implementation review of the new licensing suite of regulations is now available. The online update shows the activities underway to adjust the new regulations, as well as those already completed. It is standard practice for CASA to commence a post implementation review of a comprehensive set of regulations such as the licensing suite shortly after they have commenced. Many of the actions taken to date have involved preparing additional explanatory material in the form of information sheets on specific topics identified through feedback from the aviation community. There have also been changes to a number of new requirements introduced in the regulations. The most recent of these changes relates to the low-level rating. As a result of feedback the 12 month flight review requirement for the low-level rating has now been extended to 24 months. In addition, feedback indicated concerns with the new requirement to maintain a minimum of two hours of low-level flying over six months. This requirement has been removed.

Most of the feedback on the low-level rating came from the helicopter industry, which put forward a case to show there were minimal safety benefits from the new requirements while they created administrative difficulties for pilots and air operators. However, as CASA and the aviation community have identified aerial mustering as a higher risk activity there are recent experience requirements for these operations. Aerial mustering pilots will be required to have flown a minimum of 20 hours of aerial mustering operations in the preceding 12 months. If mustering pilots cannot meet this requirement they can complete a flight review, proficiency check or flight test that includes aerial mustering. The changes to the low-level rating have been made by an exemption to the Civil Aviation Safety Regulations Part 61. In due course the regulations will be amended to include the changes. As a result of feedback CASA also recently made a change to the requirements in Part 61 relating to student pilots. The new 14 day dual check requirement has been extended to 30 days.

Keep up-to-date with the review of the licensing suite.

Take care and think before washing

Every aircraft owner wants their pride and joy to look great and sparkle. But there are risks in keeping your aircraft shiny and clean that need to be considered before every wash. Defect reports submitted to CASA over many years have identified damage to undercarriage bearings and control surface hinge points because bearings were not re-lubricated after washing. Through a combination of the resulting corrosion and excessive wear, this has led to failures of undercarriage torque links and various other movable pivot points. In some instances rod end bearings were found to have failed prematurely due to continual washing of the aircraft with heavy duty, solvent cleaning agents. Additionally, there have been reports of the use of unapproved cleaning agents, such as truck wash, which have a high sodium chloride content and are not intended for cleaning aluminium aircraft structures. In an airworthiness bulletin CASA says although it is good to keep aircraft thoroughly clean of contaminating substances such as oil, grease, dirt and other organic or foreign materials, it is even more important that the cleaning agents used should not add to aircraft corrosion problems. A number of recommendations are made including using only cleaning products specifically approved for aircraft, being aware automotive and household products can cause damage to the airframe and components and can be corrosive to aluminium, and ensuring all applicable fittings are relubricated after washing. Chlorinated solvents or detergents are not to be used to wash aircraft as they can cause stress corrosion cracking in stainless steel and in some aluminium alloys.

Get all the details on correct aircraft washing.

E-cigs must be carried safely

Clear restrictions have been placed on the carrying of e-cigarettes and other electronic smoking devices on aircraft. A new International Civil Aviation Organization technical instruction means electronic smoking devices can only be taken on board an aircraft in carry-on baggage or on the person of a passenger. Electronic smoking devices must not be placed in luggage which is being checked-in and carried in the baggage compartment of an aircraft. The reason for the restriction is the risk of the devices inadvertently being activated in bags while in the baggage compartment of an aircraft. These electronic devices are powered by small lithium ion batteries which when activated in a confined space can overheat and result in a fire. A fire in the baggage compartment of a passenger jet on the tarmac in the United States last year is believed to have been started by an electronic smoking device being accidently turned on while inside a bag. In this case the fire was extinguished while the aircraft was still on the ground. Passengers carrying spare batteries for their electronic smoking device must protect the terminals of the batteries to prevent a short circuit. This can be done by taping over the terminals or carrying batteries in original packaging or separate plastic bags. Recharging electronic smoking devices or their batteries is not permitted on an aircraft. Passengers must also be aware that airlines do not allow electronic cigarettes to be used on an aircraft.

Have your say on aerial firefighting regulation

The aviation community is being asked to comment on new proposals for regulatory arrangements for aerial firefighting. Currently the regulations covering aerial firefighting are in two different areas – for aeroplanes Part 137 of the Civil Aviation Safety Regulations and for helicopters Civil Aviation Regulations 150 and 157, as well as provisions in the Civil Aviation Orders. With a review of Part 137 underway and the continuing development of Part 138 – which will cover aerial work operations – it is now time to decide where the regulations for aerial firefighting should sit in the future regulations. CASA has issued a discussion paper setting out three options. Option one would have the rules in Part 138 of the Civil Aviation Safety Regulations, including standards for tactical firefighting support tasks. The second option would see the regulations in Part 137, although this may result in this Part becoming much more complex and make Part 138 obsolete. Option three would be a dual pathway under both Parts 137 and 138, which while having advantages may create standardisation issues. The discussion paper says aerial firefighting has evolved from a traditional agricultural/application operation into a highly specialised activity in its own right. This means it is very important to have common procedures in place and to take a holistic view of the issues facing firefighting teams.

Read the firefighting discussion paper and have your say before 30 July 2015.

Updated information on warbird maintenance

Updated advice is now available for people who operate or maintain warbirds, historic and replica aircraft. The advice has been expanded to provide guidance for maintainers and maintenance organisations about excluded type training, training for maintenance and certification of wood aircraft structures and fabric covered surfaces. In order to provide a sustainable means of training and authorising warbird, historic and replica aircraft maintainers, CASA has introduced an in-house training and authorisation program for delivery by certificate of approval holders. The Civil Aviation Advisory Publication on the maintenance of warbird, historic and replica aircraft sets out the types of aircraft covered by the in-house training provisions and the scope and limitations that apply. Training may be delivered on-the-job or combined with training delivered by an approved maintenance training organisation or by a factory trained specialist. Due to the complexity or irregularity of these aircraft all maintenance – except unscheduled field maintenance – must be performed under the control of a maintenance organisation whose certificate of approval covers the work.

Read the warbird maintenance advice.
For a print friendly version of this email visit The CASA Briefing on the CASA website. Alternatively, when printing this email change the paper orientation to landscape.

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