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Interim Recommendation issued to: Civil Aviation Safety Authority

Recommendation details
Output No: IR19980232
Date issued: 02 March 1999
Safety action status:
Background:

See report `Regional airlines safety Study'

Output text

The Bureau of Air Safety Investigation recommends that the Civil Aviation Safety Authority require Certificate of Approval holders maintaining Class A aircraft greater than 5,700 kg to introduce an effective system to monitor functionally related staffing versus anticipated workload, and that these records be available for CASA surveillance.

Additionally, as a result of the investigation of the safety deficiency, the Bureau simultaneously issues IR980233 which states:

"The Bureau of Air Safety Investigation recommends that Certificate of Approval holders maintaining Class A aircraft greater than 5,700 kg, introduce an effective system to monitor functionally related staffing versus anticipated workload".

Initial response
Date issued: 16 April 1999
Response from: Civil Aviation Safety Authority
Action status: Monitor
Response text:

The regulatory requirements regarding the provision of trained staff by operators engaged in commercial operations is contained in regulation 213 of CAR 1988. For maintenance organisations, the requirement for the number of qualified and experienced persons in the employ of the organisation at the time of application for a certificate is contained in regulation 30 (2) of CAR 1988.

While CASA monitors maintenance organisation compliance under a periodic system of surveillance, it is accepted that maintenance organisations have a superior advantage in monitoring their own performance for planned and unplanned maintenance, etc. This day to day monitoring includes not only compliance with maintenance requirements contained in legislation and maintenance control manuals but also for the provision of adequately trained personnel for given workload situations. Such workloads can vary considerably between scheduled, unscheduled and contract maintenance inputs.

Future regulation will require maintenance organisations and operators to implement an internal evaluation system (IES) designed to ensure continued compliance with regulatory requirements. There will also be advisory material provided on the subject of human factors in maintenance as a means of bringing to the attention of all persons engaged in maintenance of their limitations and the impact this can have on their performance due to fatigue, sickness etc. To this end, legislation is being proposed that requires maintenance personnel not to engage in any activity that they are permitted to carry out if suffering from fatigue, illness, injury or are under the influence of alcohol or drug or any other substance to the extent that their ability to carry out the activity is impaired.

Although there will remain a requirement for organisations and operators to provided adequate numbers of trained staff, there is little scope available to CASA to ensure, in real time, that adequate numbers are available at any one time. This is clearly the responsibility of the operator or organisation who will need to consider their responsibilities with regard to their quality control, assurance and internal evaluation systems, maintenance control and procedures manual practices and procedures, together with their obligations under State law as it applies to employee work cover arrangements.

Irrespective of the above, it is recognised that oversight arrangements by CASA should adequately address the matters raised by BASI. In this regard it is recommended that further comment be made by the Aviation Safety Compliance Division.

Further correspondence
Date issued: 01 June 1999
Response from: Civil Aviation Safety Authority
Response status: Closed - Accepted
Response text:

Thank you for the interim recommendation on airline maintenance personnel staff numbers and workload which resulted from a study into the safety of Australian regional airlines conducted by BASI between October 1995 and July 1997.

This recommendation is fully supported by CASA, indeed, we are currently developing future regulations which will require maintenance organisations and operators to implement an internal evaluation system designed to ensure continued compliance with regulatory requirements, including the effective monitoring of maintenance staff numbers versus workload.

Given the results of your study, however, which indicate that maintenance shifts are moving to minimum staffing levels now, it is our intention to commence immediate discussions with the major airlines to encourage and assist them to develop a monitoring system pursuant to your recommendation.

Administrative action will be taken in due course to ensure that all operators and maintenance organisations implement a similar monitoring program.

 
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Last update 01 April 2011