A Confidential Aviation Incident Report (CAIR) was received by the
Bureau in which the reporter raised concerns that helicopter
crewmen, who are essential members of the crew for winching and
rappelling operations, are not governed by the requirements of
flight and duty time limitations as described in Civil Aviation
Order (CAO) 48.
The Civil Aviation Regulations (CARs) define a flight crew member
as a licensed crew member charged with the duties essential to the
operation of an aircraft during flight time. Other crew members
such as helicopter winch operators and load masters/despatchers,
are not required to be licensed and are therefore not covered by
the definition. Consequently, they are not governed by the flight
and duty time limitations of CAO 48. In addition, crew members
engaged in aerial work operations are not required to demonstrate
competence in emergency procedures as defined by CAO 20.11.
It has been traditionally understood that flight crew members
included only those crew from the flight deck of an aircraft,
namely pilots, flight engineers and flight navigators. This
traditional definition was the basis for the original development
and application of the CAO 48 requirements. The role and importance
of various helicopter operations both within Australia and
overseas, including Search-and-Rescue (SAR) and medical evacuation,
had not been fully developed at that stage. Today, however, it is
evident that helicopters play a crucial and often high-risk role in
a variety of commercial operations.
When required, crewmen such as winch operators are directly
involved in the operation and safety of the aircraft. The flight
crew are, at times, totally reliant on the guidance and expertise
of the winch operator in order to safely complete a winching
exercise. The role of such crew is now highly complex and requires
specific training to achieve a high level of skill so that the
risks associated with the exercise can be minimised. It is
therefore considered important that these crew members are not
suffering the effects of fatigue as a result of extended duty times
and inadequate rest periods. Many studies show that judgement and
decision making are eroded to various degrees in such cases,
particularly in an unanticipated or stressful situation.
Discussions with a number of operators indicate that some are
already taking a proactive approach to this issue. Such companies
are directly applying the CAO 48 limitations, or similar, to
helicopter crewmen such as winch operators and loadmasters. Some
companies are also extending these limitations to their medical
attendants, who often carry out a multi-purpose role during both
flight and winching phases.
Although there are currently no licensing or medical requirements
for such crew members, some operators are also imposing their own
set of standards to comply with their duty of care commitments.
Additionally, some of these operators require their crew members to
complete CAO 20.11 emergency procedures tests to ensure a high
level of proficiency in the handling of emergencies such as fire,
ditching and evacuation.
Whilst this evidence of a proactive approach to safety in the
helicopter industry is encouraging, there are still many operators
who have not considered these issues. It is the Bureau's opinion
that an industry wide-regulation is required to ensure a consistent
level of safety.