Recommendation R19970143

Recommendation issued to: Civil Aviation Safety Authority

Recommendation details
Output No: R19970143
Date issued: 13 October 1997
Safety action status:


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.

Output text

The Bureau of Air Safety Investigation recommends that the Civil Aviation Safety Authority:

(i) broaden the definition of flight crew to include any crew member charged with duties essential to the operation and safety of an aircraft during flight time;

(ii) develop and implement medical and licensing requirements for all helicopter crewmen who are covered under the broader definition of flight crew as described in part (i);

(iii) develop and implement CAO 48 requirements to include all helicopter crewmen who are covered under the broader definition of flight crew as described in part (i); and

(iv) extend CAO 20.11 requirements beyond Charter and Regular Public Transport operations to crew members of all commercial operations.

Initial response
Date issued: 20 January 1998
Response from: Civil Aviation Safety Authority
Action status: Closed - Accepted
Response text: CASA agrees with your recommendations. All the points (i) to (iv) have been raised during the course of the TC5 (Flight Crew Licensing) and TC2 (Air Transport Operations) committees. However, those outcomes are yet to be finalised.
Last update 01 April 2011