Has ATSB gone totally mad?

[Tee Emm]

From a recent ATSB report about an aircraft that did not take off using the centre line of the runway: .

Bombardier DHC-8-315 commenced the take-off roll on runway 01 at Townsville Aerodrome for Cairns, Queensland. During the takeoff, the pilot in command realised that the aircraft was aligned with the left runway edge. The aircraft was manoeuvred to the centre of the runway and the takeoff rejected. It was later determined that the aircraft’s left main wheel had damaged a runway edge light. There were no injuries to the 34 passengers or five crew members and no damage to the aircraft.

The operator did not have procedures to assist the crew to ensure that the aircraft was lined up on the runway centreline in preparation for takeoff.

Does that mean that legally all aircraft from Cessna 150 to Airbus A380 are required to have a "procedure" to assist a pilot to ensure they are properly lined up? Don't pilots have eyes to assist them to line up? Isn't this just normal pilot competency from the very first solo? Does ATSB now require this "procedure" to be published in the company Ops manual.

How much wet nursing are ATSB writers attempting to foist on pilots? Or are the legal eagles in ATSB trying to stamp their authority on Operations Manuals and how bloody ridiculous this all is...:mad:

[1a sound asleep]

OR

The operator did not have procedures to assist the crew to ensure that the aircraft was lined up on the runway centreline in preparation for landing.

OR

The operator did not have procedures to assist the crew to ensure that the aircraft was taxing on the taxiway centreline.

OR

The operator did not have procedures to assist the crew to ensure that the microphone switch was off when not transmitting

OR

The operator did not have procedures to assist the crew to ensure that the gear lever was adequately lubricated before flight.


:ugh:

[theheadmaster]

"Does that mean that legally all aircraft from Cessna 150 to Airbus A380 are required to have a "procedure" to assist a pilot to ensure they are properly lined up?"

No. The report stated this was a 'minor safety issue'. The statement was an observation, not a direction.

I just read the report, not too much I can pick to criticise it.

[ShyTorque]

Procedure for ensuring pilots line up with the centre of the runway:

Having received and acknowledged ATC clearance to enter the runway in use, crews must ensure that the runway cleared for use is the same runway as the one to be entered. Visually aquire runway centre line. This can be determined by a centre line marking, or by finding a position equidistant from each edge of the runway. Line up with the centreline, making sure that the aircraft is aimed along the correct runway heading.

Pilots must ensure that the aircraft is not allowed to line up on the runway edge, which may cause damage to runway edge lighting.


There, backsides covered; is that better? The usual consultancy fee is required.

[Sunfish]

Not withstanding any other regulation, a Pilot in command must not allow an aircraft to commence a take off from a designated runway, unless:

a) The aircraft has a valid take off clearance for that runway, and,

b) the centreline of the aircraft is positioned over the centreline of the runway, and,

c) the heading of the aircraft is within one degree of the designated runway heading.


This is an offence of strict liability. Penalty sixty penalty units or Five years in jail.

[regitaekilthgiwt]

the heading of the aircraft is within one degree of the designated runway heading. :confused::confused:

Guess I need a few hundred years in jail. Where did u get that tripe from Smellslikefish?

[Dragun]

After this incident, the operator issued a change in procedure for the FO to call 'on centre line' prior to commencing the take off roll. What I find amusing is that I'm pretty sure the crew thought they were on centre line before they commenced the take off roll so even if that procedure had've been in place at the time of this incident, wouldn't they have called 'on centre line' anyway?

These reactive procedures really aren't thought out prior to issue. All is does is add another thing for crews to get wrong in cyclics. Any competent pilot with good situational awareness is going to line up properly on the centre line and check it prior to opening up the levers.

[bankrunner]

Isn't this just normal pilot competency from the very first solo?

From the TIF, more like it. During mine the instructor said "line it up with the nosewheel on the centerline", and I did. If a 14 year old in his first flight in a Cherokee can do it, a professional DHC8 crew should be able to achieve the same between the two of them.

Just wait, CASA will be onto this quick as a flash. Hope all your ops manuals have a section dedicated to lining your acft up on the centreline! :E

[TSIO540]

was it an overly enthusiastic rolling takeoff? Perhaps they just got a bit wide from opening the taps a bit early..

[beaver_rotate]

A pilot at my old operator did the same thing around the same time on the exact runway in a 404. Happens I guess.

Interesting that he reported the flap overspeed but not the RTO (well that's how I read it).

I also know he got the chop by Sunnies over the incident. Fair?

[Ultralights]

so what will the procedure be for unsurfaced runways?

[Capn Bloggs]

"Does that mean that legally all aircraft from Cessna 150 to Airbus A380 are required to have a "procedure" to assist a pilot to ensure they are properly lined up?"

No. The report stated this was a 'minor safety issue'. The statement was an observation, not a direction.

I just read the report, not too much I can pick to criticise it.

I don't agree. This is nanny-state stuff. Either the investigator has no real-world experience putting in that statement/observation OR he did it deliberately to "force" some sort of policy change by the operator.

Either way, this is totally over the top. A written policy to stop this sort of thing? How are we now to do a rolling takeoff without compromising the RTOW?

How about the training departments/Regulators ensure that pilots are trained properly so that this sort of thing doesn't happen instead of making yet another rule?

[Horatio Leafblower]

I presume the taps weren't opened unless the crew thought they were on the CL.

The "procedure" for lining up had been followed, but the crew member made an error, probably a perceptual error.

WHY did the crew member make that error? THAT is the question.

The ATSB acknowledges some criticism that their investigation model focusses on "organisational" factors, to the detriment of the acts and omissions of the individual. If the addition of another f:mad:ing procedure is the best recommendation/observation that comes out of this report then I suggest the criticism is valid. :suspect:

[theheadmaster]

The question was "legally" does every operator have to have a procedure based on the findings of this investigation. My opinion was no. The reason: the ATSB is an independent investigative agency. Industry and government are responsible for policy change, not the ATSB. The ATSB makes findings. My take on the findings in this case were that crew distraction, weather, night, and the unusual arrangement of the runway having Ordinance Loading Areas and associated lighting at the threshold, were the major causal factors, and that not having a procedure was listed as a 'Minor safety issue'. The aircraft operator made a decision implement changes to procedures based on the incident, but that does not mean that all operators are legally required to do so.

[4Greens]

In what publication does ATSB admit this? Have harped on this for some time. Would be interested to read it.

[TBM-Legend]

how do we do a formation takeoff then????

[nitpicker330]

CX has a requirement to verbalise the RWY and intersection just before you cross the holding point and we are not allowed to cross the red lights until they are switched off even if cleared to line up.

In LWMO we will also tune the ILS and check centered when lined up.

Maybe a thread drift here but It's the lights on taxiways you have to watch out for, wrongly identifying sideline blue with centerline GREEN is a biggy!!

EDITED BY ME. Oops lah

Apron B and C heading east in Bali at night is an example to watch, it has sideline blue BUT only on the south side!!! In the rain at night you have to be very careful not to track the lights under the nose!!

[training wheels]

So was this at night in low visibility? If at night, does the runway have centreline lights? I can't imagine any pilot lining up on the runway edge line during the day.

[Red Jet]

Maybe a thread drift here but It's the lights on taxiways you have to watch out for, wrongly identifying sideline blue with centerline white is a biggy!! Ehhemm Nitpicker 330 - wrongly identifying taxiway centerline as WHITE, when it is in fact GREEN, could be even bigger, wouldn't you say??!!

Apron B and C heading east in Bali at night is an example to watch, it has sideline blue BUT only on the south side!!! In the rain at night you have to be very careful not to track the lights under the nose!!

Being an APRON, having the edgelines marked with the EDGE LINE color, seems quite appropriate to me and certainly in accordance with Op Specs in ICAO Annex 14. Seeing that the northern side of Apron B & C are the actual buildings, where you would normally nose in, I don't quite get how you perceive this as confusing?

[rmcdonal]

Townsville has ORP's either side of the runway threshold, I doubt these are lit. They effectively double the width of the runway at the threshold. It would be easy to mistake them for being on the runway, particularly as the whole aircraft would be on a sealed surface for the first 100 or so meters.

[Centaurus]

I must say that one of my beefs with a typical ATSB statement is the over-use of the term "is consistent with".

Ex: A smoking hole was discovered in the ground which was consistent with witness reports of an aircraft in a vertical dive.

CAVOK was forecast which is consistent with a witness report there was no cloud in the area.

Shortly after take off the captain threw up all over his first officer which is consistent with witness reports that he had been pissed as a newt that night.

[Horatio Leafblower]

In what publication does ATSB admit this?

It's on my desk at work so can't give you exact title (too lazy to look it up online) but it is their report describing their accident investigation procedure.

They note the criticism (and specifically that it has been made by CASA) and then reject it :}

[nitpicker330]

Red Jet, good pickup!! I've edited the reply.:{

With regards to Apron B maybe a bit more explanation might help.
We pushed back at night in heavy rain from Apron B and were left by the tug at about 70 deg to the taxiway. The FO looking through his wet side window mis identified the blue sideline lights for green centerline and began to turn directly toward the nice row of lights!! I corrected him in plenty of time before we got bogged.

So, what I'm trying to say is this, if there is only 1 row of lights be sure you carefully observe which colour they are.

Anyway I guess it was a bit of thread drift as the Dash in TSV was on the runway.
:ok:

[Red Jet]

if there is only 1 row of lights be sure you carefully observe which colour they are.
Now THAT, is GOOD advise! :D
Sorry if I came across as a smartarse. The small inconvenience and slight embarrassment that may arise from "loosing the plot" temporarily, bringing the aircraft to a complete stop and ask someone for help - absolutely PALES INTO INSIGNIFICANCE to the potential consequences of taxiing on with an uneasy feeling in your tummy, while hoping that you pick up something you should recognize soon.Someone just buried a 732 on its arse in a ditch over in Africa while trying to reverse taxi out of a blind spot after a wrong turn.
Anyways - back to the thread.

[Philthy]

Safety Bulletin - Managing Misaligned Takeoff at Melbourne (http://www.airservicesaustralia.com/flying/safety/bulletins/docs/20101014_Managing_misaligned_take-off_at_Melbourne.pdf)

[Capn Bloggs]

Good stuff! Somebody finally taking the bull by the horns with some good education material. Well done, that man. :D

[4Greens]

Horatio, would really like to check out the report. Pse to give a link.

[Hempy]

Factors influencing misaligned take-off occurrences at night (http://www.atsb.gov.au/publications/2009/ar2009033.aspx)

Full report http://www.atsb.gov.au/media/1543486/ar2009033.pdf

[601]

"line it up with the nosewheel on the centerline"

THUMP THUMP THUMP - Get off the bl***y centerline

[Horatio Leafblower]

Title: Analysis, Causality and Proof in Safety Investgations

Report #:AR 2007-053

[Mach E Avelli]

IMHO, limiting line-up checklists (or 'checks below the line') to calling a maximum of two essential items would go a long way to reducing the recurring problem of crews rushing or otherwise becoming distracted at such a critical time, when attention should be outside the cockpit. Lights, strobes and transponders are hardly items requiring checklists or responses. If CASA got out of the business of approving checklists maybe the local industry could follow world's best practice and move in this direction.

[LeadSled]

If CASA got out of the business of approving checklists maybe the local industry could follow world's best practice and move in this direction.Particularly when the "CASA approved" check list is contrary to the aircraft's AFM.

Remember the Jetstar A320 missed approach in Melbourne.

The AFM, with which compliance is legally required. See CASR Part 21 and CAR 138, where "flight manual" means the AFM, part of the aircraft certification package.

I constantly marvel at the CASA ability to not understand the ramifications of their own legislation.

CASA have no power to direct amendment to an AFM, unless it is an Australian type certified aircraft ---- which excludes all but a handful of the aircraft on the Australian Civil Register.

Tootle pip!!

[Capn Bloggs]

Sled del,
CASA have no power to direct amendment to an AFM
Typical theoretical bureaucratic mumbo jumbo. Do you honestly think that CASA would allow changes to checklists if their own regulation prevented it?

Operators make changes to checklists for good reasons. Normally, it's because the procedures created in an office somewhere in the US or Toulouse can't and don't work in every possible operating scenario of the aircraft in the world. Besides, the AFM procedures are just that: procedures. They are not multi-crew checklists. Get into the real world, Sledled.

In fact, my Boeing's AFM says:"these procedures are for guidance only in identifying acceptable operating procedures and are not to be considered mandatory or in any way construed as prohibiting an operator from developing their own equivalent procedures".

To say that one must follow the AFM verbatim regardless is ridiculous. Have your ever heard of the term "No Technical Objection"?

It is an entirely different issue that the JQ changes were not appropriate. That should have been picked up internally.

[contrails8]

i read somewhere that just before taxying to the runway the PIC commented to the FO that " i have reached my limits"

[Brian Abraham]

To say that one must follow the AFM verbatim regardless is ridiculous. Have your ever heard of the term "No Technical Objection"?Capn Bloggs, fully understand what you say re what your Boeing manual says, but what about CAR 138.
CAR 138 Pilot to comply with requirements, etc of aircraft’s flight manual, etc
(1) If a flight manual has been issued for an Australian aircraft, the pilot
in command of the aircraft must comply with a requirement, instruction, procedure or limitation concerning the operation of the aircraft that is set out in the manual.
Penalty: 50 penalty units.
With regards to compliance my ops manual, for example, says,
This Manual shall not supersede or countermand any Regulations, Orders or Instructions issued by the Civil Aviation Safety Authority. Compliance only with the terms of this Manual shall not absolve any personnel from the responsibility of abiding by such Regulations, Orders and Instructions.
By what instrument is one allowed to deviate from CAR 138.

You really need to carry a silk around in the flight bag these days to attempt to make sense of anything.

[SIUYA]

Brian...

CAR 138 Pilot to comply with requirements, etc of aircraft’s flight manual, etc
(1) If a flight manual has been issued for an Australian aircraft, the pilot
in command of the aircraft must comply with a requirement, instruction, procedure or limitation concerning the operation of the aircraft that is set out in the manual...

...which would seem to clearly if an NTO to amend the OEM checklist had been issued.

Unless the original certification basis is Australian, then CASA does not have the power to approve the checklist, because it forms part of the aircraft certification documentation. So CASA can only 'accept' the checklist, OR an amendment to it if an OEM letter of NTO has been issued.

Perhaps you need to sort out/discriminate between CAR 138 and CAR 215(b)?

I think you'll find that if the NTO to amend a checklist is necessary to comply with CAR 215(b), then CAR 138 would be satisfied. :ok:

I'm not a lawyer, so maybe the legally qualified might like to add their 2-bob's worth here.

Good suggestion re the flight bag 'silk'...maybe an APP for iPad perhaps, now it's apparently been accepted by the FAA as an EFB? :D

Maybe CASA-acceptance of the iPad as an EFB will follow in about 50 or 60 years?? :8

On second thoughts though, and from its past track record, perhaps that's going to be a bit too tight as a timeframe? :zzz:

[pig dog]

Correct rmcdonal, additionally it was dark, pissing rain and inexperienced f/o. Very easy to make the same mistake.

[LeadSled]

Brian A & Siuya,

You have indeed got it right.

Along with a good slice of CASA FOIs, the full ramifications of the legislative changes in mid-1998 still have not filtered through our old mate Bloggs cranium, and he is far from alone. In his defense, individual pilots should not need to know about this sort of stuff, you "should" be able to depend on CASA to get it right ---- and company manuals being "legal".

As is traditional, when CASRs 21 to 35 were put in place, the necessary transitional amendments to existing CARs were either incomplete, incorrect or non-existent.

Large slabs of the CASA AOCM make interesting reading, the many inconsistencies (not limited to CAR 138 v 215 v 232) are clear, if, and only if, you understand the significance of the 1998 changes.

The Australian arrogance shines through in the said AOCM. Of course we know better than the manufacturers. I love the bit that says words to the effect that changes should not be made to CASA approved flight check systems ( the manufacturers --- [they really mean TC holder] ) on a new type until "---- adequate experience has been gained - for example, the aircraft has been in service for 300-400 hours".

So, we are so smart that after 3-400 hours, we know better than a TC holder, whose accumulated fleet experience is in the thousands, or tens of thousands of hours, not forgetting all the development, experience and test work that formed the basis of the aircraft certification, including the AFM, in the first place.

Bloggs, my dear fellow, I know the legal requirements for processing a change to an AFM all too well.

Boeing's "no technical objection" is but a small part of the story ----- and if you understand the implication of the Australian aviation law framework, as it is, and not how you (and many others) think it is, you would understand the "nto" is not sufficient, any longer.

This is not necessarily so in other countries --- it all depends on the legal framework under which the NAA works.

In my personal opinion, as a pilot, the A320 matter was not caused by the procedural change, but non-the-less a change was made to the G/A procedure without the approval of the TC holder -- not legally possible under current Australian law.

And not very smart.

Tootle pip!!

[4dogs]

Folks,

You seem to searching for roadblocks, consistent with the behaviour you so readily accuse your regulator of demonstrating.

CAR 138 says comply with the AFM. No sweat, my FAR/JAR 25 AFMs contain Operating Procedures included in accordance with Section 25-1581 et seq. I note that AC 25-1581-1 includes generic guidance about Operating Procedures (beginning on page 8):

http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/cb7efbdd420bd265862569b3005479d7/$FILE/AC25-1581-1.pdf

which results in the Disclaimer referred to by my good friend Bloggs. It is an explicit permission to vary the "guidance" when and if appropriate.

If I was to develop my own procedures in the light of operational experience, I would be complying with the AFM and certainly not in any way interfering with the certification basis of the aircraft. The regulations recognise that there is some risk in me doing things on my own, so CAR 232 regulates my activity in that regard (as do FARs 121-141 and 121-315 in the US).

The Australian Regulator regulates the use of Australian aircraft in accordance with Australian law. What it takes to convince the regulator to approve the necessary changes is a function of the extant institutional timidity. There is no regulatory requirement for NTOs - they are merely means of transferring the risk back to the manufacturer.

And the OEM just has deeper pockets - not necessarily more or better knowledge - just ask Bloggs about MDD/Boeing and his beloved B717! :mad:

Stay Alive,

[GaryGnu]

The Airbus AFM and FCOM both contain passages similar to the one Bloggs posted above.

Airbus AFMs do not contain Standard Operating (Normal) Procedures for the Go-Around. By varying the Go-Around SOP an operator is NOT rendering invalid the certification basis for the aircraft.

It is not illegal to do what what Jetstar did. It is done by many other operators around the world frequently. The absence of process surrounding the change is another matter completely.

Mr Sandilands and others take note.

[GaryGnu]

Further to the above post and in the spirit of 4 dogs I went and found the applicable quotes from EASA CS-25 (current). The bolding is my own.

EASA CS-25 AMC 25.1581 - 6 (c)
c. Operating Procedures Section. The Operating Procedures Section of the AFM should contain, as a minimum, the essential information, peculiar to the particular aeroplane type design , that is needed for safe operation under normal and other-than-normal conditions. Procedures not directly
related to airworthiness, or not under control of the flight crew, should not be included in the AFM. A notation similar to the following should be placed at the beginning of the Operating Procedures Section.

The operating procedures contained in this manual have been developed and recommended by the manufacturer and approved by the EASA for use in operating this aeroplane. These procedures are provided as guidance and should not be construed as prohibiting the operator from developing equivalent procedures in accordance with the applicable operating rules.

And EASA AMC 25.1581 - 6 (c) (4) (ii)
(ii) Other Sources of Procedures Information. The flight crew of large transport category aeroplanes typically use other sources of operating procedures information other than the AFM. Examples of other sources of operating procedures information include manufacturer- or operatorproduced
operating manuals, Quick Reference Handbooks (QRH), System Pilot’s Guides and Emergency or Abnormal Checklists. For these aeroplanes, items such as cockpit checklists, systems descriptions, and the associated normal procedures should not be presented in the AFM if they are provided in other documents acceptable to the Agency. Normal procedures that are necessary for safe operation should be presented in the AFM, but the remaining normal procedures should be placed in the manufacturer produced FCOM (or other acceptable sources of operating procedures information).
The non-normal procedures section of the AFM for these types of aeroplanes should include, as a minimum, procedures dictated by the aeroplane’s system and failure modes, and may also include those emergency procedures listed in paragraph 6.c(5) of this AMC. Whenever procedures are provided in another source rather than the AFM, a statement should be placed in the appropriate
procedures section of the AFM referencing where the detailed procedures information can be found.

[Capn Bloggs]

4dogs/GaryGnu 1, Ledsled 0. ;)

The Australian arrogance shines through in the said AOCM. Of course we know better than the manufacturers. I love the bit that says words to the effect that changes should not be made to CASA approved flight check systems ( the manufacturers --- [they really mean TC holder] ) on a new type until "---- adequate experience has been gained - for example, the aircraft has been in service for 300-400 hours".
Think outside the square. That is the way the world improves.

Ledsled, your hatred of everything Australian really is becoming tiresome. How dare the nutcase colonials even think of challenging the "authority" of the mighty Boeing and Scarebus. :=

[LeadSled]

It is not illegal to do what what Jetstar didGG,
Not quite what ATSB and Airbus think, is it, Airbus has been quite specific about the changes implemented by Jetstar not being approved by Airbus, Airbus certainly seem to think the have a say.

And CASA have said they knew nothing about the change.

My dear friend Bloggs,
Nowhere in my posts on this subject have I expressed a view (other than comments about certain statements in the CASA AOC Manual that are quite inappropriate in any regulatory or quasi regulatory document) other than the fact that there is a very serious legal disconnect, as I have already described.

And as has been supported by several poster, who understand the law, and its shortcomings.

As for "hating Australia" or whatever your words were, what a load of rubbish, but I have no time for those, here, who disparage what happens elsewhere, particularly the US, a country that has an air safety record head and shoulders above Australia.

We continually demonstrator that we do not know better than the rest of the known aviation universe ---- the safety outcomes are the best illustration of that demonstrable fact.

If we were halfway smart, we would be looking very closely at how and why the US produces a better air safety outcome, in each ICAO statistical category, than any other country, including Australia.

Even the oft quoted Australian claim that we have "never had a jet fatality" isn't quite true, but it sound good, just not really an ICAO statistical category.

Bloggs, I would doubt that even you would claim that we have the world's best aviation regulatory framework ---- or maybe you do think that??

Tootle pip!!

[FlexibleResponse]

GaryGnu said:

Airbus AFMs do not contain Standard Operating (Normal) Procedures for the Go-Around. By varying the Go-Around SOP an operator is NOT rendering invalid the certification basis for the aircraft.

Incorrect. Airbus FCOMs detail ALL normal and abnormal procedures including the procedures for Go Around.

(In case of doubt, I am quoting from personal experience of factory conversion in Toulouse in the mid-90's and subsequent thousands of Airbus flying hours).

GaryGnu said:

It is not illegal to do what what Jetstar did.

But, it is foolish in the extreme for any airline to vary a recommended procedure that has been detailed by the manufacturer without having said variation reviewed, examined and approved by the manufacturer. In this regard, Jetstar failed miserably and the event reflected upon Jetstar's Flight Operations Dept lack of effective oversight, knowledge and depth of experience at that time.

LeadSled has raised some very important inconsistencies in CASA regulations and management.

[GaryGnu]

Flexible Response,

You are correct that the Go-Around SOP is in the FCOM. My statement was that it was not in the AFM. This is exactly as EASA, the cerifying authority, wants it. (See the extract from CS-25 above).

I agree with your view about the wisdom of the change as opposed to the legality.

Leadsled,

Where in the ATSB report does it say that the change to the Go-Around SOP is illegal?

Airbus may not endorse a particular change to procedures but as discussed above that does not necessarily mean an operator cannot change as desired. Whether that is wise or not is up for debate. I don't think the legality of it is.

There has been a campaign in certain sections of the media that Jetstar acted illegally on the basis that it changed the AFM. It did not act illegally because the SOP in question is in the FCOM not the AFM. The FCOM is considered part of the Operations Manual an operator is required to provide under CAR 215. Changes of the OM are not required to be approved by CASA and/or the OEM and/or the Certifying Authority.

At the time Jetstar was not regulatorily compelled to have a Safety Managment System in place. It did, but the SMS did not require any appropriate process around an SOP change. Once again, perhaps unwise but not illegal.

I actually agree with your general thrust that the Regulatory structure surrounding this is too complex. The Jetstar A320 case would be the perfect example. CASA should not be regulating the final operating procedures that operators use, rather the process that is followed to derive them.

[Horatio Leafblower]

Changes of the OM are not required to be approved by CASA

...er... at my LC RPT operation everything (PPM, FCOM, QRH) is CASA-approved.

Can you give me a refernce for the above assertion? The Sydney Air Transport Office certainly need to see it if that's the case!!! :suspect:

[GaryGnu]

HL,

I cannot comment on your particular situation.

However, have a look at CAR 215. Nowhere does it say that the Operations Manual is subject to approval by CASA (unlike, for example, a Flight Check System as per CAR 232).

All that is required is that the OM be furnished to CASA (CAR 215 (6)), that it be revised from time to time in light of experience (CAR 215 (5)) and that CASA may direct that certian information be included, revised or varied (CAR 215 (3)).

Changes to an OM are not subject to approval by CASA under CAR 215.

CAO 82.0, 82.3 or 82.5, as best as I can tell, also do not require an AOC holder to seek approval for the contents of an OM from CASA.

If you can provide a reference to the contrary I will happily stand corrected, concede my error and be thankful for the anonymity of PPRune.