Originally Posted by
KiwiNedNZ
Okay after speaking to one of the senior FAA Safety Inspectors we discussed what I and other professional photographers do. I explained to him about the two harnesses that I have and the tethers. He told me (after discussions with people back east) that as long as I am using a harness with either a quick release system such as the CASA approved one I mentioned previously that I can manually action myself without the involvement of anyone else and it must be within reach of myself, OR I have on a harness with a quick release device on the tether system that is also within reach of myself and not operated by anyone else, then as far as FAA is concerned I am ok to fly.
He explained that some within FAA were surprised at that notice coming out as a lot of the key FAA people had not been consulted about who would be caught up in this ruling and who wouldn't be. I asked him did each operator we flew with have to get specific approval by the FAA/FSDO and he said no, as long as the operator is comfortable with the quick release mechanisim I am using they are ok with it. He told me he looks at it as long as the "system" has a quick release option not just a harness.
While I don't doubt the information you have received is probably valid and reliable, it does not meet the requirements of the prohibition and wouldn't stand up in court. What your 'mate said on the phone' vs having a FAA issued approval are two very different things. As a sensible solution, I would be inclined to make an application to the following:
Applications for a determination as to whether a supplemental passenger restraint system can be quickly released by a passenger with minimal difficulty may be submitted to the FAA Aircraft Certification Service, Policy and Innovation Division, Rotorcraft Standards Branch, 10101 Hillwood Parkway, Ft. Worth, Texas 76177, Attention: Jorge Castillo, Manager (email:
[email protected]; tel: 817-222-5110).
In the application, I would state what you have stated that you have multiple jobs in different types arranged but will use the same harness type in each case that ensures consistency and should enable a blanket approval for that harness type.
At least then you cover your own arse and have a piece of paper to prove it.
That's just my $0.02 but given the nature of your business Ned, I would be very cautious about falling foul of the FAA, they'll be scrutinising the **** out of this over the coming months no doubt.