CAA GM General Aviation Address to AAAC 12 October 2007 Agricultural Aircraft Safety Review Introduction Greeting pleasantries. Apologies from Director. Time passes quickly (quicker each year I find) and with so much happening in agricultural operations I thought it would be useful give a summary of work in the last two years, a sort of ‘state of the nation,’ in terms of that work, the reviews we have underway and where we have got to. Following my presentation I will ask Jack Stanton, one of our Airworthiness engineers from Aircraft Certification Unit, to brief us on information gained to date from our Agricultural Aircraft Safety Review. In 2005 CAA identified two important issues as safety projects: Agricultural aircraft loading; and The need for either an Advisory Circular to Part 137 OR A requirement for Part 137 operators to have an operations manual or Exposition. The Exposition would address outstanding issues in agricultural operations, including: • Agricultural aircraft loading, • Flight Crew Fatigue management, • Chief pilot supervision, and • Senior Persons responsibilities. Action taken on these two issues and others identified as a consequence I will cover over the next few minutes. First, Agricultural Aircraft Loading Note: Comprehensive briefing from Mike Keen this morning The loading of agricultural aircraft has been an issue since aerial topdressing began, some 60 years ago. In the early days the only available aircraft were ex-military types pressed into service in the new industry. In order to facilitate such operations the FAA Civil Aeronautics Manual 8 (CAM 8) was introduced. This permitted aircraft loads above the manufacturers’ Maximum Certificated Take Off Weights provided certain compensatory provisions were also observed. CAM 8 was written against the typical US agricultural operating environment: flat terrain, sealed strip aerodromes and a crop spraying type of operation. New Zealand’s operating environment has proved to be considerably more demanding, with
mountainous terrain, high winds, turbulence and very much less sophisticated airstrips. (As Mike Keen noted this morning). The original CAM 8 recognised the need for “compensating factors” when agricultural aeroplanes were loaded above MCTOW which specified what flight operational parameters should be adjusted. Those compensating factors were not carried over into New Zealand’s Rule Part 137 Agricultural Aircraft Operations. The issue has been difficult to monitor because of the nature of agricultural operations in isolated areas. In recent years the NZAAA and CAA have combined very well in an effort to reduce accidents but the problem remains. You yourselves have done much to review and improve safety margins. However, with the advent of higher powered aircraft, with the ability to carry significantly increased loads, there has been some confusion and misunderstanding to do with the interpretation of the various requirements laid down in the Civil Aviation Rules and aircraft Flight Manuals. In mid-2005 Bernie Lewis was contracted to scope a project. Bernie reported the results of his study in August 2005. In response to that report the Director agreed to: • Accept the contents of the report; • Appoint an internal CAA Working Group led by John Fogden to consider the P137 Appendix B provisions; and • To progress the project in consultation with representatives of the agricultural aviation industry. The internal CAA Working Group has since joined with industry to form a larger joint CAA/Industry Working Group on the issue. In order to bring to industry notice the importance of the issues, immediate action was also taken. A major advisory letter was sent to all operators in December 2005 by CAA Manager Agricultural Operations, John Fogden. The letter had three purposes: • To advise operators of the formation of the CAA/Industry Working Group • To provide operators immediately with urgent recommendations regarding flight operational parameters which should be adjusted when operating an agricultural aeroplane in the overload regime. • To issue, as an Appendix to the letter, a two-page set of Recommended Best Practices regarding flight operational matters that should be adjusted when operating an agricultural aeroplane under the CAM8 provisions. With all the distractions of normal regulatory and business life the joint CAA/Industry Working Group, mentioned above, has made slower progress than we would like. However, in January this year an Issues Assessment Group (IAG) was formed under the provisions of ACAG to consider Part 137. I’ll return to that a little bit later.
Second, Part 137 Agricultural Aircraft Exposition. As noted above, the second issue identified in 2005 was the need for production of either: • An Advisory Circular (AC) in support of CAR Part 137; OR • An Agricultural Aircraft Operator Generic Operations Manual or Exposition It is very pleasing that the concept of an Exposition has enjoyed the full support of NZAAA. In consultation with AAA, CAA has compiled relevant information from various sources, such as earlier operators agricultural operations manuals required under the Act 1953 and Regulations, the CASA approved Australian Generic Agricultural Operations Manual, previous Civil Aviation Safety Order (CASO) material and, more recently, the content of two current Operations Manuals written and adopted on a voluntary basis by two of the largest New Zealand agricultural aircraft operations. It is likely that the best of this collective information will be incorporated into a Generic Operations Manual or Exposition. As I noted earlier, the IAG formed in January this year considered the Exposition in detail. Foggy will talk more about that this afternoon but, I’m pleased to say that the IAG was very well attended and I hope that we can give it some fresh impetus to keep up the good work. I would like to divert briefly now and mention two specific issues. First, the Industry Guidelines on Farm Airstrips and associated Fertiliser Cartage, Storage and Application Bernie Lewis recommended the introduction of best practise industry guidelines and this particular initiative deserves special mention. As you know, the Department of Labour, in association with CAA, recently published the Safety Guideline for Farm Airstrips and Associated Fertiliser Cartage, Storage and Application. ( and I understand that this was the subject of a very good presentation yesterday by Garth Galloway). Before determining distribution John Fogden requested about 60 of your fixed wing agricultural operators to provide lists of their farming, carrier, quarry and associated clients. Accordingly, a print run of 5000 copies was completed. Some 3000 copies have now been posted to those addressees by CAA staff. A further 1000 copies and 500 copies have also been provided to Department of Labour and Federated Farmers, respectively, for further distribution. Field Safety Advisers are also actively distributing the document, all in all a great result!
The second issue I will mention briefly is Fatigue Management Systems A major CAA Fatigue Management Workshop was conducted June 2006. The aim of the workshop was to identify issues using fatigue management professional and technical experts to review fatigue management in the various aviation sectors, to identify where regulatory or educational gaps exist and to workshop appropriate methods of solution. The Workshop was made up of flight operations specialists from all CAA units and from industry, including leading experts in the field: The Workshop made several recommendations regarding P 137 agricultural operations, including that: • CAA review its database to ascertain the reliability or otherwise of identification of fatigue as a casual factor • That; more emphasis be placed on investigating fatigue as a possible casual factor in accidents/serious incidents • That; training in identification of fatigue casual factors be provided to CAA and TAIC investigators • That; as a minimum, guidance and educational material (including OSH obligations) should be provided for operators • And finally, that Fatigue Management Systems (FMS) be a requirements for Part 137 agricultural operations I appreciate that the subject is controversial and so would hasten to add that we do not envisage the imposition of rigid flight and duty time for Ag Ops. Rather, we see something along the lines that ‘operators are to have Fatigue Management Systems that recognise the specialist nature of Ag Ops and the particular requirements of individual operator businesses’. By that I mean that it might be quite satisfactory for a pilot to work a given number of days in a row, provided that the pilot finishes each day at an appropriate time and is then free of all duties, such as organising work for next day, after a given time. In other words, you manage flight and duty time and fatigue as an active process and not just by the ‘get hard, shape up or ship out’ method. ( I was very pleased to note that Graeme Martin spoke yesterday about the work his company is doing on FMS with University of Melbourne material. Great to see and we encourage Graeme and his team to keep up the good work!). Finally, that brings me to the Agricultural Aircraft Safety Review There is clearly an issue regarding the rebuilding of aging aircraft and, in particular, the use of old airframes with new components and significantly more powerful engines. Associated with that issue are reports (many of them anecdotal) of the rate of defects or failures occurring in areas such as the undercarriage, tail fin and rudder structure, wing spar and engine mounts.
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