Originally Posted by
robsrich
Update: Helicopter industry concerned about new Part 138 MOS and CASA's new CATS requirements
Since March 2020, the Australian helicopter industry has been generally locked down with the COVID disaster; and CASA, in good faith, have asked for a review of two substantial legislative packages; firstly, the CASR Part 138 MOS - aerial work operations which closed for comment early in June. Secondly, another layer of even more complex legislation has been offered for review. The proposed rules are known as the “CATS regulations,” issued for comment on 2 June with replies due by 30 June 2020.
CASA has provided guidance material for the CATS review which runs to 28 pages; however, the time allowed for completion is effectively four weeks. Please see guidance material at:
https://consultation.casa.gov.au/reg...P%201918OS.PDF
Industry’s complaints are two-fold; the CASR Part 138 MOS runs to 130+ pages and the CATS documentation requiring cross referencing would be, at a guess, several hundred pages depending on the nature of a company’s AOC. The immediate problem is industry is generally locked down with enormous COVID restrictions, and many companies are probably in hibernation with staff stood down. In particular, the largest group of operators are in the rural mustering industry and they are presently approaching the peak of the mustering season. This means their staff are deployed in extremely remote areas away from base and of course unable to respond to the request for comments in a matter of weeks.
So, what is the answer? Many helicopter pilots and companies got together online to work out what can be done with the two projects which they are duty-bound to complete by the due dates. Mary Brown representing several hundred industry key players, contacted Shane Carmody, CEO and Director of Aviation Safety to discuss the Part 138 MOS review. It was agreed the due date would not be changed; however, industry was encouraged to submit some form of reply so the future handling of this project could be evaluated after all the feedback had been studied. In hindsight, all parties agreed this was a sensible solution; although, there is insufficient time to provide a detailed analysis.
However, during the review process of the MOS, the CATS legislation was launched and has proved to be an even more complex project than the MOSS, which had not been approved by the regulators technical working group as it was too complex and difficult to understand. (Despite the fact CASA had offered to produce plain English explanations of what the new rules meant).
More soon ......
About bloody time that CASA was disbanded and replaced with a reulgator that understands that it works for the industry and NOT the other way around. CASA regs are overly complex at best and bewildering at worst. There are far more simple regulations in other agencies worldwide that are no less safe. I deliberately exclude anything in Europe or the UK in that statement!