Regulatory Reform -See and Avoid

[Greedy]

I recently had cause to complain to CASA concerning the conduct of a Line Check. During the Check the Check Captain placed an opaque card above the glareshield to block the sun. The card was bigger than A4 but less than A3 size. The aircraft, a SAAB 340, is fitted with tinted sunshades.
The reply I received from Mr Roger Chambers at CASA stated that there was no CASA regulation to prevent a pilot doing this nor was visibility from the flight deck impeded to a hazardous degree following a CASA experiment. I note there was no scientific method outlined with this statement!
I have just whiled away a little time looking at FAR 91.113b ,EASA material and CAR 163.
Is CASA and Mr Chambers seriously saying that a card about a half meter in front of a pilot obscuring a cone like area of vision that A3 to A4 would is consistent with these regulations or the guidance on scan provided by the FAA ,EASA or the ATSB ?
Or is it more about covering up and supporting the Check Captain regardless in a company that appears to have a CASA green light?

What are your thoughts?

[27/09]

Hmmmmmmmmmmmm here we go..........

I take it the line check didn't go to well?

I would have thought discussing your concern with the said Captain might have been a better course of action, rather than running off to CASA.

My thoughts on the use of the opaque card? If the sun was creating a problem and the use of the card removed that problem then it was likely the lesser of two evils.

[sms777]

I tend to agree with 27/09. It seems you may have a personal issue with said Check Captain and too afraid to discuss with him so you run off to Big Brother instead. Aviation community is rather small in Aus and most of us are members of Pprune so it does not take long to find out who you are especially the amount of clues you have provided in your post. There is a good chance said Check Captain already read your post and planning revenge......Don't get me wrong but in Aus no one likes a dobber.
As for the card.....have you thought about the fact that he may have been trying to aid the sunglare rather than testing your IFR skills see how good your scan is?

[megle2]

Bit difficult to comment with the lack of background detail
Did the Chief Pilot concur with the Checkie
Does the OM not address this at all
Check status Pass/Fail
Was it a one off or is it done regularly
I take it all correspondence was in writing

Personally not taking sides but any window blocks do make me nervous
Lost a associate to a mid air long ago ex Bankstown on IFR training

[ad-astra]

You might like to ask around the wider aviation community to find out how many pilots have used a map/sick bag/newspaper/notam/crew briefing report/etc to block out the effects of a blinding sunset/sunrise.

You may very well find the result surprising.

Whatever your agenda was you have quite successfully shot yourself in the foot.

Not taking the issue up with the Check Captain at the time, not taking it up with his Department head, running off to the regulator to achieve nought, and then seeking comfort and solace at PPRuNe will worry a lot of people (myself included) who may very well have to share a cockpit with you.

Please tell me you have no applications with Virgin.

[Hempy]

Either the checky uses this method a lot (i.e it's company approved) or he's only used it recently on you (i.e now you are screwed). Not sure what the 'see and avoid' has to do with it assuming you were in receipt of a clearance?

[Greedy]

Just to clarify , all of you have assumed I did not raise it with the Check Captain immediately.I did. He knew he had done something that if not a breach of regulations ,was extremely poor practice. You are right in that the check did not go well. I however I did not breach regulations and flew in tolerance and well. I disputed the result. I think I have a right to do so.You seem to imply I do not.Why?

I have seen quite a few people obscure the windscreen during flight including a couple of pilots who did it on descent into CTAF's. If you both condone or do this I dont want to be on any aeroplane you are flying !

I am interested in why ,despite all this educational material, some like you posters above seem to think it is acceptable practice.

Have you you seen the posts concerning the pilots of a passenger jet seeing a powered chute at F130 near WAREN recently ?

Greedy

[Duck Pilot]

I have flown around for years with maps and anything I can get my hands on placed around cockpit windows to prevent sun glare, no problem in my opinion - no rules broken and common sense used when doing this, ie normally in the cruise and less densely populated airspace.

I'm somewhat confused as to what this has got in relation to regulatory reform and CASA? What do you expect CASA to do? A public forum isn't the place to discuss a failed check ride. I have had the displeasure of failing a check ride a few years ago, turned my life upside down for a short period, however the long term results of the negative assesment has done wonders for my career progression, to the point where I have felt like sending the checkie who failed me a letter thanking him for failing me on the day! And I still hate the checkie for what he did to me that day, as I still believe that me and the other pilot (who also failed) didn't deserve to fail, however I do respect the checkie - no hard feelings against him as he was only doing his job, he just made the wrong decision at the time in my opinion.

[ad-astra]

Greedy,

You asked for our thoughts! You got them!

I am not sure what the issue is now but if the problem is the disputed check flight then yes you have a right to speak up - via the appropriate channels.

If the problem is the Check Captains attempt to stop the glare and you have received no support from the Check Captain himself, the Regulator, and what seems at least a couple of pilots on PPRuNe then I am not sure what you want to happen.

Having ASKED for our collective opinions and very obviously not getting the support you expected (and now changing the story further) you are now defensive and dismissive of our responses and make assumptions and critique my operation.

Having trained a lot I empower my students with the confidence to speak up but specifically through the appropriate chain of command and NEVER to go over anyone's head without warning them that a report will be submitted.

From the story so far it seems the Check Captain was reported to CASA and now MR R**** C******* from CASA is being reported to the wider community via your PPRuNe campaign for not agreeing with YOUR opinion.

The Check Captain, the Company, Mr R***** C******* all read and will be most interested in you next career move.

One point that WE are both in TOTAL agreement on is that if there is a choice we won't be flying together.

I'm out!

[Duck Pilot]

Never mention individuals names on a public forum - especially from the regulator!!!! Naughty...

[Old Akro]

If this is a guy who had a bad checkride complaining about a matter of style of his examiner, then its not a very good look.

However, there are some real issues behind it - some of which go to CASA's biggest weaknesses.

1. The PIC should have the ability to ask for something distracting that obscures view to be removed. If the PIC did and was failed vindictively, then there is a real issue.
2. Isn't the check captain acting as a safety pilot? I presume the flight was conducting instrument procedures in VFR. In which case the check captain has a duty to look for traffic, etc. This is inconsistent with obscuring the screen.
3. The check captain should be displaying best practice - which is probably not consistent with sticking up pieces of paper and finally, the major point
4. It highlights that CASA do not have a consistent standard across its staff - FOI's, ATO's, check Captains, etc. Acceptable practice by one can be condemned by another and any or all of them may choose to disregard regulations that they disagree with or believe (probably correctly) are unworkable.

[Greedy]

Thanks for your replies. Yes I did seek opinions including yours ad astra. I sincerely thank you for expressing it. The reason I have done so on pprune is that being a forum ,I knew that people would not hold back and express it without any bias toward the speaker as one would have in a conversation or meeting. A robust exchange if you like.

I have now read multiple advice and Regulator websites now that have sections on see and avoid. Lots of advice is given. Clean windscreens, remove curtains and opaque sunshades, scan in certain patterns both vertically and horizontally etc etc. Not one advocates blocking the sun with a large object which prevents any vertical scanning and obscures an angle of about 30 degrees subtended at the eye position.

My opinion is that this obscuring is not safe and that it would be impossible to defend this action in the event of an incident. You would be mincemeat, perhaps literally.
And for those concerned: No check captains were harmed by my actions. He and the company were aware I was reporting the matter both internally and externally.

Greedy

[Seagull V]

Partially obscuring the pilot's view as described could be contrary to the aircraft's certification standard. See FAR 25.773 Pilot compartment view.

[morno]

On the other hand, what if the sun shining in the pilot's eyes were obscuring their vision more than something blocking it out?

[Paragraph377]

Interesting post Greedy. I am divided in my thoughts, but to be blunt I would have probably worded your post a little differently to de-identify the key players involved. Last thing you need mate is to end up on a 'black list' that is used against you in the future. Chatham house rules should apply to a degree. However with that said, I still understand your point of view and understand your frustration.
Also this post below is certainly of merit;
However, there are some real issues behind it - some of which go to CASA's biggest weaknesses.

1. The PIC should have the ability to ask for something distracting that obscures view to be removed. If the PIC did and was failed vindictively, then there is a real issue.
2. Isn't the check captain acting as a safety pilot? I presume the flight was conducting instrument procedures in VFR. In which case the check captain has a duty to look for traffic, etc. This is inconsistent with obscuring the screen.
3. The check captain should be displaying best practice - which is probably not consistent with sticking up pieces of paper and finally, the major point
4. It highlights that CASA do not have a consistent standard across its staff - FOI's, ATO's, check Captains, etc. Acceptable practice by one can be condemned by another and any or all of them may choose to disregard regulations that they disagree with or believe (probably correctly) are unworkable.

I have to agree entirely with this statement. You as the pilot were in charge of the aircraft. If you didn't want anything placed on the glare shield then so be it. Who gives a **** whether 'CASA have experimented or not', anything they attempt is usually not best practise and did they conduct an official experiment? Wouldn't that be the role of the aircraft manufacturer or even the ATSB to a degree?
I bet if you were being ramped and you had put that opaque card up there of your own volition and they noticed it they would have charged you with every offence known to aviation. Hypocrites.

[maverick22]

I don't see what your issue is. Bit different if said captain covered the entire windshield, but if he was just blocking the sun in a particular area, than this has got to be better than damaging his eyesight and not being able to see anything anyway? Those Transparent visors are fine, but still not much chop if you are flying directly into the sun. And also a bit of context to this situation might be required. The above practice might be fine sitting in the flight levels, in CTA, but probably not on descent in the vicinity of an uncontrolled aerodrome. Common sense issue:ok:

[Prince Niccolo M]

Seagull V,


Reading 14CFR25.773 will tell you what a bunch of other paperwork will explain in fine detail as to what the manufacturer needs to convince the FAA they have done to comply so that they will gain a type certificate. Temporarily obscuring the view in these sort of circumstances has never been considered to have any relevance to the type certificate and was controlled via CAR 153. :ugh:


If the sun was in my eyes so that I couldn't see anything, then there are plenty of occasions when placing a judiciously sized object in the sun path to allow me to see everywhere else except directly into the sun would be a safety enhancement... :E

[Duck Pilot]

Not being rude Seagull, who cares what FAR ******* says! We operate on the CASA rules in Australia not the FAAs. This issue is a storm in a tea cup, what ever happened to common sense?

Lock the thread mods.

[tail wheel]

This issue is a storm in a tea cup, what ever happened to common sense?

I'm inclined to agree.

Greedy, go talk to your Chief Pilot and if you don't like the scene, move along.