Pilot 13A,
I am not an expert with respect to Part 133 but my understanding of it and Part 29 is the following:
It depends upon the Class of operations being performed - information provided in figure AC 29.865B-1 indicates that:
"1. A person(s), being carried or transported for compensation outside the rotorcraft can only be carried as a Class D RLC.
2. A person who is not being carried or transported for compensation, is knowledgeable of the risks involved, and at some point is required to be outside of the rotorcraft in order to fulfill the mission. These persons are considered as RLC Class A, B, or C HEC as appropriate to the operation."
133.1 appears to provide an exclusion in cases of
other than "A person(s), being carried or transported for compensation outside the rotorcraft" - this clause states:
"(d) For the purpose of this part, a person other than a crewmember or a person who is essential and directly connected with the external-load operation may be carried only in approved Class D rotorcraft-load combinations."
Where the whole area becomes quite complex is in the definitions of RLC A, B and C; if I could summarise these, they are:
RLC A = an attached load held above the landing gear
RLC B = a jettisonable load lifted free of the land or water (not sure what would constitute jettisonable in this context)
RLC C = a jettisonable load that remains in contact with the land or water (towing)
RLC D = a load, other than the above, approved by the Authority
Not exactly a beacon of light is it?
Distinctions are applied by most Authorities that I am aware of (some - like the UK CAA apply HEC Class D to training missions). As far as I am aware, Aerial Work (carrying the accepted persons) and SAR are not required to apply the HEC Class D performance standard.
Unless you know different!!
Jim