Helicopter Offshore Operations (HOFO) - CRD 2013-10

[Tomcat01]

You are totally correct! And it worries me that there is so few comments posted to the NPA, regarding this regulation. I hope the relevant stakeholders have been informed and are able to post comments to the CRD by now.
As we have seen from the Norwegian Helicopter Safety Study-3 and the Safety report (HC 289) in UK, they both recommend national oversight from the NAA where the operation actually commences.
In HSS-3, currents threats to safety, for the current period is identified.

“According to the report, the most important potential threats for helicopter safety in the period 2010–2019 are considered to be:

— lack of the possibility to maintain established Norwegian additional requirements
for offshore flights, or that it will not be possible to introduce new requirements adapted to the conditions on NCS;

— exemption from offshore special requirements and deviation from recommended guidelines;

— unwanted consequences from changes implemented by helicopter operators and other players in this area;

— reduced competence among technicians and pilots in helicopter companies due to retirement of existing personnel;

— lack of competence and resources regarding offshore helicopters in CAA-N; and

— too much focus on cost and revenues by the different players on NCS.”


These threats are directly transferred to the NPA text, but there are very few preventive measures in the new regulation text, to mitigate those threats. In fact, by adopting the new regulation (for countries with well established national regulation, like UK and Norway), almost all these threats may become reality.

As well, EASA seems to disregard most of the important comments from the national regulatory bodies, in favour of level-playing field, free movement of services and mutual exeptance of NAA's, in relation to performance of oversight and in the approval process to obtain an AOC or SPA.
By only asking one single question;

Question 2.12.1
Operator XYZ holds an offshore approval from MS A. Operator XYZ has one of its main activities in MS B.
Do stakeholders and NAAs see it as beneficial to introduce a regulatory requirement for operator XYZ to inform MS B before engaging into offshore operations from that MS?
Please justify your answer.


If the scenario will end up in a requirement of just giving information about the operations, unlike a full approval process, we should be deeply worried about how the NAA can be able to perform proper oversight of operations.