Project OS 13/26 - Amendment to CAO 29.11 Helicopter Winching and Rappelling...

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Project OS 13/26 - Amendment to CAO 29.11

Helicopter Winching and Rappelling operations
and CAO 29.6 Helicopter External Load
operations
Closure notes
Project closed 22 April 2016.

Project OS 13/26 - Amendment to CAO 29.11, Helicopter Winching and Rappelling operations and CAO
29.6, Helicopter External Load operations, commenced October 2013. The proposed amendments
included the incorporation and introduction of risk management and mitigation concepts into the planning
and performance of helicopter external load operations (winching, rappelling and sling load operations),
both human and non-human. This process included the introduction of a national standard for the carriage
of persons as a sling load where none had existed previously.

The proposed Part 138 of the Civil Aviation Safety Regulations 1998 (CASR) includes external load
operations and winching operations, and introduces concepts of risk management and mitigation to these
operations. At the time project OS 13/26 commenced it was considered that there was a considerable
safety benefit in bringing certain policies forward from Part 138 via a CAO amendment until such time as
the Operational CASRs were in place. The amendments to the CAOs were consulted via NPRM 1321OS
with comments closing on 25 July 2014. CASA received 33 responses in reply to the NPRM.

Noting that the CAO amendments and Part 138 contained the same safety policies, the publication of the
NFRM for the CAO amendments was placed on hold when Part 138 was released for public consultation
via NPRM on 15 September 2015.

The consultation received on Part 138 has resulted in the policies being updated. This has effectively
overtaken and now superseded the policy amendments proposed in the CAOs. Consequently this project
has been closed and the proposed policy amendment will be achieved via the proposed Part 138 of CASR.

Issue
CAO 29.11
Section 29.11 of the Civil Aviation Orders (CAO) contains the requirements for the conduct of helicopter
winching and rappelling operations. The requirements do not reflect the latest concepts in the use of risk
assessment and management in regard to these operations.

Winching and rappelling from a helicopter have a higher level of inherent risk associated with them than
other helicopter operations. Further, these operations are generally associated with emergency situations
which present several unique operating characteristics which make them distinct from other helicopter

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operations. Emergency operations are often time-sensitive and crucial to getting a critically ill or injured
patient to a medical facility as efficiently as possible, which may influence flight crews to fly under
circumstances that they otherwise would not. In addition, these operations often are conducted under
challenging environmental conditions.

In a medical emergency, patients may not be able to participate in the decision to use helicopter transport
or winch recovery. CASA believes that these individuals should therefore be afforded the protection of a
pre-flight risk assessment which considers; the operational environment, human factors, suitability of the
equipment for the performance of the particular task, patient's level of injury and the availability and
suitability of other means of recovery with less associated risk.

Pre-flight risk assessment is considered to be industry best practice in helicopter emergency operations. It
is proposed to require operators to implement pre-flight risk-analysis procedures and to document them in
their operations manuals. CASA considers that pre-flight risk analysis will assist towards preventing
accidents by enabling risk mitigation strategies to be employed prior to the commencement of the flight.

The introduction of CASR Part 138 will require a more detailed approach to an operator's policies and
procedures for risk mitigation and a risk assessment based process for approval of certain helicopter
operations. Bringing these policies forward earlier via a CAO will provide for additional safety advantages
earlier, prior to and until the operational CASRs are in place.

This will ensure that regulatory standards for helicopter operations keep pace in the interim with
recognised best practice concepts and risk management based processes.

CAO 29.6
Subregulation 207 (1) of the Civil Aviation Regulations 1988 (CAR 1988) states that a person must not use
an Australian aircraft in a class of operation if the Civil Aviation Safety Authority (CASA) has not authorised
and approved the particular type of aircraft for that use.

Regulation 303A of CAR 1988 provides that CASA may issue an approval or authority subject to any
condition that CASA thinks necessary for the safety of air navigation.

Section 29.6 of the Civil Aviation Orders contains the requirements for the conduct of helicopter sling load
operations.

The CAO is out of date and does not reflect the latest concepts in the use of risk assessment and
management in regard to these operations. It also does not contain a general low flying permission for
helicopter external load operations, which requires these operations to be controlled by the issue of
numerous CAR 157(3) permissions to avoid breaches of low flying regulations.

Helicopter operations are becoming more complex and diverse, a situation which is particularly true for
sling load operations, which is a growing and highly specialised area of helicopter operations. The generic
nature of the provisions in the current Order are now in a situation where they do not adequately address
the many and varied situations which can arise in the operations, particularly when they occur in or near
populous areas where the overall risk of the operation is potentially very high.

The introduction of CASR 138 will require a more detailed approach to an operator's policies and
procedures for risk mitigation and a more risk assessment based process for approval of helicopter
external load operations, and it is felt there is great advantage in moving towards these general policies in
the current provisions, prior to and until the operational CASRs are in place.

The scope of the project has been expanded to consider the carriage of external human sling loads. Civil
Aviation Regulations 1988 - Regulation 250 provides that an operator or pilot in command must not permit
a person to be carried on anything attached to the aircraft without the written permission of CASA. The
current CAO provides no guidance in this regard. Incorporation of such operations into the current

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amendment to CAO 29.6 will ensure a consistent risk management based approach is applied to the
consideration of such operations.

The scope of the project has been expanded to include drafting of a CAAP to provide advice as to what
should be included and considered in a formal risk assessment and potential ways to mitigate residual risk
to as low as reasonably practicable or to a higher level as required by and in support of the CAO. The
CAAP will also assist in identifying potential risk along with providing advice on various aspects of external
load operations for the benefit of operators, pilots and persons supervising the securing and detaching of
loads.

Considerations during the development of the CAAP will review and adapt current best practice concepts
and utilise contemporary overseas processes where this is considered to add value.

Project objective
CAO 29.11
The project will amend CAO 29.11 to bring it in line with the policy for helicopter emergency medical
transport operations outlined in the drafting instructions for CASR Part 138. This will align its operational
requirements to industry best practice for controlling the safety of these operations.

CASR Part 138 polices have been extensively discussed at industry working groups and have been
designed using a principle adopting modern international practices for these operations.

CAO 29.6
Phase 1: The project will amend CAO 29.6 to bring it in line with the policy for helicopter external load
operations outlined in the drafting instructions for CASR Part 138. This will align its operational
requirements to more contemporary strategies for controlling the safety of these operations.

CASR Part 138 polices have been extensively discussed at industry working groups and have been
designed using a principle adopting modern international practices for these operations.

Phase 2: Development of a CAAP

Status
This project was approved by: Rick Leeds, A/g Executive Manager Standards Division on 10 October
2013.

Project OS 12/38 (Amendment to CAO 29.6) was combined with project OS 13/26 on 22 January 2014.

Both projects are substantially similar and involve the incorporation and introduction of risk management
and mitigation concepts into the planning and performance of helicopter external load operations, both
human and non-human. It is considered that there is considerable advantage and efficiency in combining
both projects and consulting the amended Civil Aviation Orders via one Notice of Proposed Rule Making.

Accordingly, project OS 12/38 has been closed and its content transferred to this project.

Rules affected
CAO 29.11 and CAO 29.6

Project management
Project Leader/s: Damien Fing, Standards Officer - Rotorcraft
Project Sponsor/s: Gerard Campbell, Executive Manager, Operations Division
Standards Officer/s: Dale South, Section Head Rotorcraft Standards

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Project Priority
High

Standards Consultative Committee (SCC)

Operational Standards Sub-committee [/standard-page/operational-standards-sub-committee]

History

Title Details Date

Consultation updates in 2014

Project OS 13/26 - Amendment to CAO 29.11 Project closed. 22

Helicopter Winching and Rappelling operations and April
CAO 29.6 Helicopter External Load operations 2016

NPRM 1321OS - Amendments to CAO 29.6 - Helicopter Comments to 28 Jul

External Sling Loads and CAO 29.11 - Helicopter this NPRM 2014
Winching and Rappelling Operations [/standard- closed 25 July
page/nprm-1321os?WCMS%3ASTANDARD%3A% 2014.
3Apc=PC_102014]

NPRM 1321OS - Amendments to CAO 29.6 - Helicopter Comment period 30

External Sling Loads and CAO 29.11 - Helicopter extended until: Jun
Winching and Rappelling Operations [/standard- 25 July 2014. 2014
page/nprm-1321os?WCMS%3ASTANDARD%3A%
3Apc=PC_102014]

NPRM 1321OS - Amendments to CAO 29.6 - Helicopter Comments close 5 May

External Sling Loads and CAO 29.11 - Helicopter 27 June 2014 2014
Winching and Rappelling Operations [/standard-
page/nprm-1321os?WCMS%3ASTANDARD%3A%
3Apc=PC_102014]

Consultation updates in 2013

Project OS 13/26 - Amendment to CAO 29.11 Project 10

Helicopter Winching and Rappelling operations approved. Oct
2013

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