Originally Posted by
TWOTBAGS
CC, you are very much correct and this is in fact the problem with the way our regulations are written...... everything is open to interpretation and zero guidance fro the powers that be.... because they don't know themselves, or if there is guidance material its not readily available....
Hence the way every one get screwed over here, someone comes along and presents an acceptable means of compliance that one FOI says yep good to go. The next audit that happens the next FOI says.... but that's not the way we did it in Big Airship Co Ltd... you don't comply.... do not pass go, collect and NCN for your trouble......
This of course side-steps the stupidity of some organisations who continue to employ people with no experience whatsoever. One company I heard of was NCNd by CASA because they had apparently written in their Ops Manual that a safety cone "...SHALL be placed 1m from the wingtip and engine intakes..."
A CASA person took out a tape measure and found the cones on just about every aircraft they checked were more or less than 1m, sometimes by mm but they raised an NCN because of the way the Ops Manual was written.
Now, people might say that's petty on the part of CASA if it's true, but it's not really. It is not a regulatory requirement to put cones in front of engines and wingtips, it is just good safety practice. Presumably CASA was highlighting the fact that what you say you must do... using the word 'shall' gives zero room for movement... "... should be placed approximately 1m or three steps from..." might have been a better wording. Thing is, if the company concerned didn't employ people just out of high school virtually and got some people experienced in regulatory requirements and authoring manuals, they wouldn't have had to go through that experience.
There is a tendency for CASA people to say "that's the way we did it at..." but in my experience, those people are retiring mostly now and I have found many CASA people good to deal with in the last few years, very practical in many respects.