Flight manual integrity

[Phoinix]

I'm scratching my head over our training officers idea about implementing supplement manual procedures into normal and emergency procedures.

I'm talking about actually rewriting the manual, not the quick reference check list. For example: Agusta Power has an appendix about fire extinguishing system and its procedure. This procedure would than be entered into emergency section of the "flight manual". That changes everything, from FLM's contents to LEP and so on.

When I pointed out that Flight manual should keep it's integrity as it's the manufacturers document and an obligation to procedures plus the FLM should be kept in the helicopter at all times, he just said "it's not a sacred document and the new rules require that implementation".

What new rules? Did I miss anything JAR-wise? We removed all the non-applicable appendixes years ago, and we have covered the supplement equipment in the normal and emergency QR checklist.

I checked ICAO Annex 6 and 8 which are very basic when it comes to manuals. What other documents are there that make the Flight manual a serious manufacturers document that shouldn't be tempered with?

[Geoffersincornwall]

The RFM is indeed a legal document and by law must be carried in the aircraft unless you have a derogation issued by the appropriate NAA. The appropriate supplements should be carried if equipment not included in the 'basic' helicopter is installed.

Problem is that as a practical working document it's about as much use as chocolate tea-pot unless of course you have the 'basic' helicopter. That's why the JAA required a PT operator to create a Part B (for each type) to the Ops Man which if put together correctly will act as a more practical substitute to the RFM insofar as it will be a document that more correctly reflects the configuration of your fleet. Included in that would be the Normal and Emergency Checklists (RFMs only contain 'procedures' which may be technically correct but are insufficient for a working pilot's needs. For example the AW139 Emergency Procedure for a Main and Aux Batt Hot is to 'continue flight'. Any operator that writes that in his version of the ECL wants (IMHO) his head testing). The Part B, if properly put together will be more focussed than the RFM (irrelevant material can be omitted) and easier to interpret (graphs can be turned into tables that contain data relevant to the environment in which you operate). All in all it can be a godsend to the CP in his quest for pilots that know all they should know and can find the stuff in a book that has the identical structure in every other Part B.

Sounds like your CP may be trying to do the right thing but going about it in a way not to be recommended by those who get a bit picky about the legal niceties.

G. :ok:

[paco]

Phoinix - the flight manual forms part of the Certificate Of Airworthiness. Anything you create (and use in its stead, unless you go through certain onerous steps) will not be legal* and you will not have insurance as the C of A would be invalid.

phil

*edited in the light of comments below

[Phoinix]

Thank you for replying. Where can I find some black-on-white about its status.

[212man]

Some googling with appropriate terms (such as RFM, AOC, EASA etc) brings up lots of useful stuff for you. This Australian CAA (CASA) link states fairly conclusively how supplements should be approved (by them) and is a common standard with all NAAs: Civil Aviation Safety Authority - What is an Aircraft Flight Manual supplement? (http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_90268)

You will also see the AFM/RFM specified in the TCDS as the basis for operating, and - as has been stated - they form part of the AOC.

[JimL]

The basic requirements for a Flight Manual can be found in CS 29.1581; section (b) specifies the status of the associated information.

CS 29.1581
General

(a) Furnishing information. A Rotorcraft Flight Manual must be furnished with each rotorcraft, and it must contain the following:

(1) Information required by CS 29.1583 to 29.1589.

(2) Other information that is necessary for safe operation because of design, operating, or handling characteristics.

(b) Approved information. Each part of the manual listed in CS 29.1583 to 29.1589 that is appropriate to the rotorcraft, must be furnished, verified, and approved, and must be segregated, identified, and clearly distinguished from each unapproved part of that manual.

(c) Reserved.

(d) Table of contents. Each Rotorcraft Flight Manual must include a table of contents if the complexity of the manual indicates a need for it.

As others have stated, appropriate information from the flight manual can be included in Part B of the Operations Manual (which will also have to be approved under the new regulations). Unapproved elements of the Flight Manual can be issue by the manufacturer without reference to the Certificating Authority.

As far as JAR-OPS 3 is concerned:
JAR-OPS 3.005 General

(c) Each helicopter shall be operated in compliance with the terms of its Certificate of Airworthiness and within the approved limitations contained in its Helicopter Flight Manual. (See Appendix 1 to JAR-OPS 3.005(c).)

JAR-OPS 3.130 Manuals to be carried

(3) The current Helicopter Flight Manual is carried in the helicopter unless the Authority has accepted that the Operations Manual prescribed in JAR-OPS 3.1045, Appendix 1, Part B, contains relevant information for that helicopter.

JAR-OPS 3.1050 Helicopter Flight Manual

An operator shall keep a current approved Helicopter Flight Manual or equivalent document for each helicopter that it operates.

Jim

[RVDT]

For example read -

Part 27 - Requirement for Flight Manual and Approved Manual Material

CFR FAA FAR Part 27 Airworthiness Standards: Normal Category Aircraft

Section 1581 - General

and

EASA Certification Specifications for*Small*Rotorcraft CS 27

Section 1581

And therefore is part of the Type Certificate requirements.

Be aware of what is "Approved" and what is "Not Approved" i.e. Manufacturers data.

Anything that you write may not be any less restrictive than the Flight Manual.

If it is it will require the issue of a Supplementary Type Certificate and the issue of a Flight Manual Supplement.

Supplements that are not applicable to the aircraft should NOT be included.

If your aircraft is in the Transport Category refer to Part 29 as applicable.

The quoted JAR Ops 3.130 in my mind would not pass test in a court as being legal. An "OPS" interpretation over an "AIRWORTHINESS" requirement? How does that work?

Don't get me started on the interpretation of MMEL's!

[Geoffersincornwall]

There are historical precedents for the non carriage of the RFM insofar as British Airways Helicopters received approval from the UK CAA not to carry the 4 kg of (useless) Sikorsky S61 RFM and it was replace by a (coherent) document that contained all the relevant data but in a format that was easy to find, unambiguous and free from errors.

I think from a legal standpoint if you can demonstrate that the required airworthiness data was included in the OPS MAN Part B then you may get away with it.

The problem with the RFM is that we expect it to be a Pilot's Handbook but actually we find it is a technical manual designed to meet certification from a legal obligation point of view.

The information contained does not necessarily relate to the exact version of the airframe you fly unless the Part 5 Supplements are taken into account and these may actually contradict the instructions in the basic RFM thus making the reading of it rather difficult not to say impracticable. Hence the JAA approach - write a version of the RFM that incorporates:

a. Basic RFM procedure modified where appropriate by the relevant Supp.
b. Additional requirements specified by the operator (these may be more restrictive than the RFM but not less so).
c. Advice relating to the specifics of the operating location and task.

I have said it before but I don't believe the Emergency Procedures in the RFM are a substitute for a good Emergency Check List. This will feature 'Immediate Actions', 'Subsequent Actions', and 'Considerations' and have the objective of giving the pilot the best advice consistent with the technical and operational issues as well as Company Policy.

G.

[Phoinix]

Thank you guys, now I've got something to chew on for a few days.

[Shawn Coyle]

Unless you have an over-riding regulation (Part 135 in the USA, for example), there is no requirement that the normal and emergency procedures sections of the flight manual be considered sacrosanct and incapable of being modified.
Most airliners don't carry the original flight manual on-board. They have the Flight Crew Operating Manual (FCOM) that references the flight manual sitting somewhere on a shelf. The flight manual has been modified for their operation.

Notice what it says at the top of the limitations section - these limits must be obeyed, or words to that effect. It does not say that at the top of the normal and emergency procedures section.
I used to work for Transport Canada doing engineering certification, including approving flight manuals, and it was never the intention to not allow people to change the flow of procedures in the flight manual.
Be prepared to justify your actions if the new changed procedures result in an accident or incident, but that's the way of all things.

[rick1128]

Here in the USA, there are provisions to allow an operator to produce their own flight manuals. The requirements are stiff and require the operator to show that there is no degradation of safety. Having the ability to manufacture your own flight manuals can come in handy, particularly if you operate a type of aircraft that has various different limitations. You can standardize the limitations to the lowest common denominator. You can make your procedures fit what you are currently doing within the rest of the fleet. I have worked for several operators that used their own flight manuals. In some cases they were actually better than what the manufacturer produced.

[[email protected]]

I have said it before but I don't believe the Emergency Procedures in the RFM are a substitute for a good Emergency Check List. This will feature 'Immediate Actions', 'Subsequent Actions', and 'Considerations' and have the objective of giving the pilot the best advice consistent with the technical and operational issues as well as Company Policy.
sounds like military FRCs - how is it that such a clearly sensible move has not become the industry standard? Let me guess - fear of being sued or invalidating insurance is more important than giving the pilot the best chance of dealing with a failed system. The Nova Scotia S-92 accident report was somewhat critical of the time taken to peruse the RFM due to its poor layout.

[JimL]

I'm sure it is the industry standard!

It would appear that the point is being missed; it is direct amendment of the Flight Manual that is not permitted not the incorporation of suitably amended check-lists into the Operations Manual.

Jim

[RVDT]

Section 3

Emergency and Malfunction Procedures

3.1 General

This section contains the recommended procedures for managing various types of emergencies,
malfunctions and critical situations.

3.1.1 Basic Rules

These procedures deal with common emergencies. However, they do not prevent the pilot
from taking additional action necessary to recover the emergency situation.

Although the procedures contained in this Section are considered the best available,
the pilot's sound judgement is of paramount importance when confronted with an emergency.

To assist the pilot during an inflight emergency three basic rules have been established.

1. Maintain aircraft control

2. Analyse the situation

3. Take proper action

NOTE It is impossible to establish a predetermined set of instructions for which would provide a ready made decision applicable to all situations.

I think the last note sums it up - how you "operate" and advise your crews to "operate" the aircraft is up to you.

Please note that even though the procedures are "recommended" they are "approved".

There is nothing to stop anyone "expanding" them via Ops Manual or Check List you just cannot "contract" them.

A lot of manufacturers provide "check lists" but I think if you look closely they are not approved at the outset but can be.

Modifying the "approved Flight Manual" is not the way to go. It is the lowest common denominator and is part of the Type Certificate from which to expand that pertains to your specific operation via your "Operations manual".

Rant over :ugh: