Whoa – big subject, thanks Leadie. I was tempted to duck this and pass it off with a flippant remark or two. However, with the CASA gargoyles breathing down your neck and the internal malarkey – off the top of my old wooden head,
as a discussion start point only:-
Crock 'o ****e; or, a bloody good idea ? My battered two bob's worth weighs in on taking a measured, responsible, outcome based approach. Accepting prescriptive, complex regulation will not get you there; you will however cover the well padded CASA arse by accepting it.
Take 'volunteers' for example. Father and son team, Dads going flying, Junior is going to do the hand start, or plug in and remove the ground power. I doubt anyone 'off the street' could amble airside and do it without an unacceptable risk level; so it becomes reasonable that a degree of training is required. Here is where the problem begins; in the "operations manual" AOC type of system, there needs to be a presciptive system for qualifying and certifying the trainer, that requires oversight to ensure the trainer is doing the right thing, then you need a system for recording and monitoring that. Then come the 'training' course syllabus, training, qualification and recording; all available for audit. Now if there is a problem, (real or imagined) at audit, is the whole AWAL outfit at risk? The short answer is Yes, under the proposed rule set.
Leadie – It's a big subject - I am not sure what procedures are currently in place for AWAL, but I think we can acknowledge that there needs to some form of control document; lets call it a procedures and policy manual (PM). The manual could be exactly that; to be a member of AWAL the procedures and policy must be complied with. Then, the PM could carry an outcome based policy section related to "Volunteers". The section could identify high risk volunteer tasks like hand starting and low risk tasks like removing the Minty's wrappers from the cabin.
The AWAL policy makes the 'operator' responsible for providing a training section for the 'aircraft' i.e. – Hand swinging for DH 82 – then for ensuring the 'aircraft' listed volunteers were, indeed trained and qualified. I don't believe they need to be 'employees'; but they do need to properly trained to avoid the dangers. This probably 'informally' occurs every time two people decide to go airside, like taking the kids into the hangar – my boys knew the rules by the age of seven. Formalise this and you have the basis for a safety training case.
I'll bet my hat that AWAL could run a hand swinging course, combined with hand signals and ramp safety course; take a day with a BBQ afterwards. Pretty certificate for the dunny wall, valid for 5 years.
In short, the Organisation needs a general policy and procedures manual which provides and expects a safety 'outcome', the aircraft operator provides type specific procedures. It may seem like a lot of work – but it beats, hands down adopting an AOC type of control.
Invoice for four pints following – two for the words – 'tuthers for sticking out neck.
