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Old 9th Jan 2010, 13:57
  #44 (permalink)  
JimL
 
Join Date: May 2003
Location: Europe
Posts: 900
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The responsibility for operational supervision does not rest with the regulator but with the operator.

The regulator, before issuing an AOC, makes an assessment on whether qualified staff (post-holders etc) and appropriate systems (procedures) are in place so that operational control can be maintained. In the system of continuing oversight, the regulator periodically samples the product to establish whether adequate control is being exercised within the system.

If Helicomparator's contention is correct, then all operations manuals will be generic and have identical text. Yes JARs do have an OM template for the operators to use but you should not infer from that the text of the template is that which should appear in the OM.

For example the paragraph 'Operational Control and Supervision' merely says "A description of the system for the supervision of the operation by the operator..."; it is expected that the operator's system will be described here.

When it says in a later paragraph ..."Operational control. A description of the procedures and responsibilities necessary to exercise operational control with respect to flight safety"; I would expect to see a description of the system (and the person responsible for that system) of providing a serviceable aircraft on the ramp; the system for ensuring that the aircraft are dispatched within precise criteria (and the person responsible for that system).

Later in the template where it requires "Flight Preparation Instructions. As applicable to the operations."; I would expect to see precisely the information that is being discussed in this thread.

Sox6, yes I have understood the banter and appreciate the situation in Aberdeen. Clearly, the understanding of the limitation on the DA was part of the culture of one of the companies but not of the others. It would also appear that this is not part of the written procedures in that company but one of adherence to the limitations of the RFM.

My view is that a company culture that relies upon the memory of pilots is not an adequate safety culture - these high pressure and low temperature regimes occur very infrequently in the North Sea, and that should be recognised by the operators. Why is it do you think that before every winter, most fixed wing companies issue a reminder about cold weather operations?

I also take issue with your contention that the CAA should (in your words) 'regulate current rules and requirements' (in fact I am not sure what that statement means). As part of its SMS, each company should have quality assurance procedures that ensure that its product is (re)produced as described. It is for the CAA to ensure that the product described is, in their opinion, adequate for purpose.

I have to say that I see similarities in this thread to discussions that we had following the EC225 ditching. It is not good enough to rely upon the judgement (memory) of the crew members; there have to be adequate SOPs in place to ensure that the frailty of the human is not exposed.

Jim
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