Thomas Coupling,
You have to be careful when mixing and matching terminology; my comments were with regard to CAT operations, which ICAO establishes is:
Commercial air transport operation. An aircraft operation involving the transport of passengers, cargo or mail for remuneration or hire.
To my knowledge (and it has been some time since I was involved) the ANO does not use the term CAT - preferring instead Public Transport. As you also know, there is a lack of a definition of
Crew Member; the reason why some activities - considered by ICAO and Europe to be Aerial Work - are regulated as Public Transport in the UK.
The last complication is that there is no legal basis for JAR-OPS 3 in the UK; it is permitted to be used as the basis for regulation of operations as an alternative to the ANO. The CAA is the arbiter of exactly what might be applied (or not applied) based upon its perception of what is safe - in accordance with safety targets and policy in the UK.
It is an entirely justifiable stance to insist that hoist training is performed with engine failure accountability - the whole crew is exposed to an engine failure in training on far more occasions than when operating for real; thus the risk is higher. This is not an issue of regulation but one of Risk Assessment and Risk Reduction.
Cyclic,
SAR is specifically included in the ICAO definition of Aerial Work
Aerial work. An aircraft operation in which an aircraft is used for specialized services such as agriculture, construction, photography, surveying, observation and patrol, search and rescue, aerial advertisement, etc.
however ICAO does not provide SARPs for Aerial Work and the State must decide under what regulations it permits the operation. It is not regulated under JAR-OPS 3 and, in view of the diverse nature of SAR in European States, when we produced draft regulations for Aerial Work, we specifically recommended that SAR be excluded from JAR-OPS 4 and left to the individual States.
Jim