Review into North Sea offshore helicopter operations announced by CAA

[Savoia]

Review into North Sea Helicopter Operations announced by UK CAA

The operations of helicopters in the North Sea are to be reviewed in the wake of recent accidents, the Civil Aviation Authority has announced.

The regulator said it would work with its Norwegian counterpart and the European Aviation Safety Agency to draw up a report, which it expects to publish early next year.

It will examine areas including helicopter airworthiness and training.

BBC News - Review into North Sea offshore helicopter operations announced by CAA (http://www.bbc.co.uk/news/uk-scotland-north-east-orkney-shetland-24227805)

[FrustratedFormerFlie]

From BBC web site on 24/9
BBC News - Review into North Sea offshore helicopter operations announced by CAA (http://www.bbc.co.uk/news/uk-scotland-north-east-orkney-shetland-24227805)

[SASless]

I would suggest to the BALPA Leadership they get their proverbial head out of their Butts and engage the CAA and offer all assistance possible in the Review.

Yes the CAA may be late to the Party....but at least they are to attend....perhaps it took some public embarrassment to get them to do so...but they are going to do a review.

BALPA and its members can play a huge role in ensuring the CAA has to address every concern made known to the CAA by BALPA members.

The CAA has a vested interest in making sure they come out of this smelling like Lilacs and Rosewater.....and you can bet the Rent money they shall make every effort to do so.

Bureaucrats do not like to take responsibility or admit any shortcoming however minor.

I am sure the CAA can find ways to improve their part in the situation....if they care to do so. BALPA should help them by pointing out some of those issues that the CAA could address that fall within their authority to control and administer.

[Rigga]

So where's the "Like" Button for SASless's first line?

[OffshoreSLF]

Just listened to the Grampian TV news where a BALPA spokesman said that they wanted the CAA role to be PART of any review into helicopter operations.

Sounds like a good idea to me.

[wiggy]

From BALPA.org:

"REGULATOR NOT RIGHT BODY TO REVIEW NORTH SEA SAFETY
24/09/2013


Please see below a comment from the British Airline Pilots’ Association (BALPA) on today’s announcement that the Civil Aviation Authority (CAA) will be conducting a review into North Sea aviation safety.

‘We will consult with those members currently operating in the North Sea as to their views on the effectiveness of a CAA-led review, but our immediate reaction is this is too little , too late.

‘Firstly, the CAA has not shown itself adept at getting below the surface of industry, the real life experience of pilots and understanding the human factors that drive safety. Nothing in today's announcement gives us confidence that this has changed.

‘Secondly, we believe a review needs to look at the totality of the commercial cut throat business that is the North Sea, and not just the helicopter operation. In short, just how high in the pecking order does safety really sit for an incentivised contract manager?

‘Finally, we believe any review must look at the role of the regulator in this lengthening trend of accidents. We are, for instance, concerned that there does not appear to have been any pre-existing comparison of accident rates being maintained despite a series of accidents. In the light of this we just do not think it credible to expect the Regulator to review itself.

‘BALPA has called on the government to set up a judicial-led independent review along the lines of the post-Piper Alpha inquiry led by Lord Cullen. Today's announcement by the CAA does not do it for us.’

See https://www.balpa.org/News-and-campaigns/News/REGULATOR-NOT-RIGHT-BODY-TO-REVIEW-NORTH-SEA-SAFET.aspx

[8021123]

If we accept the caa review at face value, it will be limited by their legal remit to questions of aviation safety (though they will look at ditching and survival - see terms of ref). Other, wider, issues are raised about the offshore working environment and unions are rightly emphasising these in the Piper Alpha memory year - the emotional level is understandably high.
We can't ignore the uk accident history, but with 3 recent gearbox failures which arguably might have occurred anywhere in the world, that seems to leave blun, etap & the latest (plus poss cormorant alpha?). Is there a common theme different to anywhere else?

[bondu]

As the CAA (and EASA) are actually part of the problem, how can anyone have any sort of confidence in a CAA-led review? A review/inquiry is most certainly required if confidence in North Sea operations is to be restored. But only a fully independent, judicial-led, wide reaching inquiry will suffice.

The CAA, EASA and HSE must contribute, BUT must NOT lead the inquiry! The helicopter operators must be there. BALPA must also be part, as should RMT and Unite. So should Oil&GasUK, Eurocopter (Airbus Helicopters!), Sikorsky, Augusta Westland etc. The oil companies must also be called to explain their part, from the top down, especially 'middle management'! The media must also be taken to task, especially after the extremely poor standard of reporting during the last few years. BUT all of the above should be attendees, to give evidence etc, not to lead the review! ALL of the above have involved in allowing North Sea operations to the current position. And by that, I also mean US, the pilots! We are not blameless in this!

To date, it seems we will have two separate review/inquires already: the CAA one and the previously announced House of Commons one. Why do I feel that neither will produce results that will improve the situation? Why do I feel that the CAA one will exonerate the CAA? And the Commons one will say it is looking to the 'regulator' to 'regulate' and therefore not their problem?

You may want to say that I'm being somewhat cynical! 26 years on the North Sea does that to anyone!

bondu :ugh::ugh:

[Grenville Fortescue]

As the CAA (and EASA) are actually part of the problem, how can anyone have any sort of confidence in a CAA-led review? A review/inquiry is most certainly required if confidence in North Sea operations is to be restored. But only a fully independent, judicial-led, wide reaching inquiry will suffice. The CAA, EASA and HSE must contribute, BUT must NOT lead the inquiry!


Simply to state the obvious.

That bondu is absolutely correct.

[jimf671]

So should we expect Issue 2 of CAP 641?
CAP 641: Review of Helicopter Offshore Safety & Survival | Publications | About the CAA (http://www.caa.co.uk/application.aspx?appid=11&mode=detail&id=138)

Or does this,
Review of North Sea Helicopter Operations Home Page | Safety & Risk Management | Operations and Safety (http://www.caa.co.uk/default.aspx?catid=2657&pagetype=90)
http://www.caa.co.uk/docs/2657/20130923%20ReviewOfOffshoreHelicopterOperationsTermsOfRefere nce.pdf
particularly considering the international dimension, constitute something greater?


I note that an FAI features strongly in 641, that a another FAI is expected to commence in the next few weeks, and yet another relevant FAI can be expected, months or a year or two away.

[HeliComparator]

Seconded. (Or is that thirded). The CAA are complicit in the whole process and therefore totally unsuitable to be independant reviewers.

[SASless]

Should we begin an inventory list of CAA issues that should be assessed by the Independent Review?

What has the CAA done or not done....decisions they have made or not made....actions they have taken or not taken that adversely affect the North Sea Offshore Helicopter Operations?

We all have our pet peeves....but what really serious issues should the bright fresh sunlight shine upon?

[Special 25]

Night Approaches offshore - Still the biggest cause of accidents in the North Sea

Gearbox Monitoring and Maintenance

Getting some 'Controlled' Airspace at long last

[dakarman]

-- Survivability for those jammed in a full 332/225 with comfort linked to this

[jemax]

Can we change that to uncouple night approaches offshore, I don't believe there has been a problem when fully coupled machines have done night approaches done with appropriate use of automatics.

Perhaps ignoring SOP's at night would be more appropriate!

[JimL]

CAP 1145 - "Safety review of offshore public transport helicopter operations in support of the exploitation of oil and gas" will be published at noon today.

Jim

[212man]

http://www.caa.co.uk/docs/33/CAP%201145%20Offshore%20helicopter%20review%20and%20annexes% 20final.pdf

[satsuma]

'With effect from 01 April 2015, helicopter operators are to ensure that only passengers with a body size (including all required safety and survival equipment) commensurate with push-out window exit size are carried on offshore helicopter flights.'


Should be interesting trying to enforce that.

[Bravo73]

'With effect from 01 April 2015, helicopter operators are to ensure that only passengers with a body size (including all required safety and survival equipment) commensurate with push-out window exit size are carried on offshore helicopter flights.'


Should be interesting trying to enforce that.

Why not? If the offshore employers make it a contractual requirement, then all of the fatties have got just over a year to lose the weight. (The same rule should obviously also apply to the pilots up the front).

It will, however, probably have a knock on effect on the sort of food that is provided in offshore galleys.

[212man]

(The same rule should obviously also apply to the pilots up the front).



Well, most types jettison the doors the crew used to enter the cockpit in the first place, so that shouldn't be an issue. The S92 has huge cockpit windows and if you couldn't get out of those you a) wouldn't be able to get into the cockpit in the first place and, b) if hypothetically you could enter, you would be incapable of moving the cyclic freely when seated :}

[terminus mos]

Some oil and gas companies already do enforce such a "fit through the window"policy.

Overall.....


The operators will be pleased with this report, = more helicopters
Could lead to an increased pilot shortage and lower experience levels?
It will place some increased cost burden on oil and gas companies.
The oil and gas companies do appear to get some blame for the existing state of affairs, this report will not improve the adversarial attitudes that exist
There will be lots of no fly days due sea state >6
It may increase the perception of safety but I am not sure how much it will improve safety in reality, it has more effect on survivability after a crash than preventing a crash.
Perhaps less diversity will create less competition and more stable long term pricing among providers.

A lack of leadership within the helicopter industry has meant that big brother CAA will now enforce what the industry should have innovated. Perhaps this is what it needs, a regulatory approach to re level the playing field?


Luckily, it won't affect my company much, we were already ahead with many of these "initiatives"through self regulation and rigid risk reduction criteria.

[SASless]

How many Years have some of these issues been known of and ignored?

Finally....kicking and screaming....the CAA comes to the Table!

But.....it is an improvement no matter how reluctantly they come.


What stands out to me in the Stats, looking at the accident data and the Trend line on the Chart is despite the introduction of the latest generation of aircraft....there appears to have been an uptick in the numbers of accidents.

There was a period of time where the chart line goes flat....along the bottom....and I assume that to be the time period after the Tigers and 332 series matured.

In time I wonder if the Chart will again show such success.

[212man]

Another official report where Pprune gets a mention (by name this time)!

1.2.3.1.1 This safety concern does not come as an entirely new revelation in that it supports the findings of an informal PPrune ‘markings quiz’ conducted several years previously for the pilot workforce.

(Annex E)

[mtoroshanga]

Further to the above may I ask a few pertinent questions_


Why was the sliding door opened and not jettisoned. This resulted in the exit windows being blocked.


Why did the co-pilot open his door and not jettison.


Why was the left (port) sliding door not jettisoned.


Why were none of the exit windows on the port side jettisoned


I suspect that there is one common denominator--lack of proper training of the passengers and crew.


These are my problems with the most recent accident which I suspect was the result of the pilot entering a vortex ring situation on the approach.


Regarding the Bond gearbox problem the object of collecting the debris in the gearbox is to establish the amount of damage that has occurred.
When the CAA was still a knowledgeable organisation and not a group of people with micky mouse qualifications we had a manual called airworthiness notices. In this manual was a reference to unusual or unfamiliar measurements and one of those was the amount of debris permitted in an Aerospatial 330J gearbox. This stated that the amount of bearing debris was 2 cm2. This entry was there because of an avoidable accident in Sarawak
Because of the lack of practical knowledge we now have a bunch of incompetent jobs-worth's rushing around blaming competent people in an effort to hide their own short-comings. One can only suspect that this whole sorry episode would be better served by the old school of CAA or ARB type people who knew what they are talking about.

[HeliComparator]

I think reducing the max number of passengers so that everyone is next to a window is likely to reduce overall safety in the short term at least, due to the need for more flights, ie more pilots, more training and the consequential likelihood of levels of competence and experience being reduced, at a time when there is already a big expansion in pilot numbers going on.


Fortunately, the report doesn't actually say that, even though the media is promoting this line. It says that passengers have to be next to an exit / window UNLESS they have Category A emergency breathing systems (or side floats, which if they ever come about are some way off).


However I couldn't be bothered to wade through 169 pages of CAP 1034 so I don't really know what a Category A device is. Can anyone sum up?


Otherwise I find the report a little disappointing. Nothing concrete about VHM / HUMS except "we will form another committee, and its going to take until the end of the year just to do that, never mind the committee actually doing anything useful" which is surprising since 3 of the recent accidents have a direct link to sub-optimal use of VHM/HUMS.


Simulators don't get much of a mention either. Nothing about the quality of devices, the need accurately to replicate the complexities of display and autopilot systems (which are glossed over in the regulations for simulator approval).


I suppose the acid question is whether, had the actions and recommendations already been implemented, the recent spate of accidents would have been avoided. It's hard to answer "yes".

[farsouth]

However I couldn't be bothered to wade through 169 pages of CAP 1034 so I don't really know what a Category A device is. Can anyone sum up?


I'm in the process of "wading through" - this seems to explain Cat A and Cat B breathing devices.

ƒAn EBS mitigates the consequences of capsize by extending the underwater
survival time of occupants and is issued to passengers by the oil and gas
companies. Independent research commissioned by the CAA that has
culminated in the production of a draft performance specification
(CAP 1034) implies, however, that the form of EBS presently deployed is likely
to be effective only in the case of ditching where it can be deployed in good
time and prior to submersion, i.e. the EBS currently deployed is likely to only
meet the CAP 1034 Category ‘B’ standard. It is unlikely to be adequate in the
event of a water impact where deployment at very short or no notice and/or
underwater is likely to be required, i.e. the CAP 1034 Category ‘A’ standard. (Page 32 9.9)

[SASless]

HC,

As the CAA does not ascribe to the Bristow Safety Goal of Zero Accidents.....the CAA judges success by the Rate of Accidents/Fatalities per 100,000 Flying Hours.

So if the current Rate is held or hopefully decreased by these changes then they shall consider that to be "success".

You should be glad all this results in more flying....more helicopters...more Pilots and Engineers....and greater revenue for the Operators and hopefully Dividends to Share Holders as a result.

As there are fewer passengers per flight then the actual exposure will be less as when an aircraft is lost there are fewer folks aboard.

Remember the Stats on that comparing the GOM to the UKCS Operations discussed in the past here?

Rough numbers....half the passenger load per fatal accident....and you can have twice as many accidents to arrive at the same number of lives lost.

It all depends upon how you want to measure success I guess.

[JimL]

HC, in simple terms a STASS type devices which can be used with little preparation and be deployed even under the water - i.e. not just in a ditching but also after a water impact. These devices can be quickly introduced without affecting the seating configuration. If the oil companies then wish to improve the comfort levels by reducing capacity, it is up to them.

Haven't seen any comment yet on the limitation of operations to the Ditching Approval. How many of the North Sea fleet are not certificated to SS 6?

There is also a subtle little clause in the report about the introduction of fire-fighting equipment to normally unmanned platforms. When the CAA takes over the licencing of the offshore landing sites, it can address this and also ensure that the additional visual cues (leg lighting) that are necessary on well-head platforms (as recommended in CAP 647) are fitted.

Jim

[HeliComparator]

Farsouth - thanks. So I wonder if there are any category A devices out there, and what form they might take. Of course, if you make the passengers wear their re breathers throughout the flight, so just needing to pop the valve, that would probably make them Cat A!

SAS, I have no interest in increased revenues since I had to sell all my shares when I retired. I only have an altruistic interest.

You're right about the stats, but in this neck of the woods the emphasis seems to be on how often they fall into the water, rather than the body count (in other words, the Sumburgh L2 carried the same "weight" as the gearbox failure L2, at least as far as public opinion goes)

[HeliComparator]

Jim, yes I presumed the use of Cat A a devices was a feasible short term goal, since the report goes on to require their use later anyway.

I'm sure pilots and passengers alike will be glad of the SS6 limit. Of course further reducing the limit for helicopters with a lower float SS certification is a little further down the line. Personally I don't see a need to limit SS at the destination to that of the float certification but plenty of my ex colleagues do. In any case, what about SS en route?

On the NUI thing, I see this as a minor tidy-up. On the one hand, the logic of so doing is obvious, but on the other hand when was the last time firefighting kit was required on a helideck?

[farsouth]

Page 37 9.18.d

d) Only passenger seats adjacent to push-out window emergency exits are
to be occupied on all offshore helicopter operations (paragraph 9.17 (d)) –
this restriction can be implemented with a very short lead time; a modest
period of notice is considered appropriate, however, in order to allow for
schedules to be adjusted and any other provision/planning required to be
instigated in order to mitigate the consequences. Since the side-floating
helicopter scheme represents a medium to long lead time measure, this
restriction can most expeditiously be removed by the deployment of
CAP 1034 Category ‘A’ EBS. It is expected that Category ‘A’ EBS could be
introduced within a period of one to two years.

So, from 1st June 2014, until Cat "A" EBS is developed - maybe one to two years - it seems we will be down to max of 13 passengers in the S92. At least we'll be able to carry lots of fuel...........:)

[Langball]

Had a quick look at the CAA document. One glaring anomaly, to me anyway, is the statement that sea state 6 is a sig. wave height of between 4 and 6 metres. Where we operate there is a huge difference between the occurrence of 4m and 6m waves.

[JimL]

Langball,

Standard designation used in Part 29.

Jim

[heli1]

So are there any helicopters currently in North Sea service where seating will be adversely affected by the new rules ,for instance the S-92 with internal long range tanks, early Super Pumas with smaller windows?

[HeliComparator]

So are there any helicopters currently in North Sea service where seating will be adversely affected by the new rules ,for instance the S-92 with internal long range tanks, early Super Pumas with smaller windows?

Yes, pretty much all of them. The S92 has similar or smaller windows to the old Super Pumas, so it's not about window size, it's about being next to a window. Only helicopters with 2 seats total in a row would be unaffected, and there aren't many (any?) of them. Hardest hit would be those with 4 seats in a row. AW139?

But anyway, if the pax have the Cat A emergency breathers there is no impact.

[jimf671]

... it seems we will be down to max of 13 passengers in the S92 :eek: At least we'll be able to carry lots of fuel...........:)

The aircraft of choice becomes the one with the worst windows.

12 in an EC225?

8 in an AW189, or do the rear windows count?

6 in an EC175?

This getting silly.


Just get the £#<&ing doors off!

[Sir Niall Dementia]

JimL;

There will be all sorts of hormonal fits at the Belgrano if you keep posting on here! What I really struggle to understand these days is that when you and I flew together we were in a S61 with basic sas, Decca roll maps and crap radar and we seemed to manage a higher level of safety than today.

My copy of the ops manual from back then covered so many situations and procedures better than the modern manuals. Has JAR opened up more holes in the Swiss cheese? Is training not as thorough? Are the procedures JAR compliant, but in fact not fit for purpose?

How many of us on here remember the rule of no deck landings in 50 + kt winds after the Cormorant crash in 1992? That lasted until the oil companies couldn't get urgent supplies offshore. Oddly the first oil company to whine owned the Cormorant.

I'm glad I no longer work offshore, but I believe that this safety review should have started at Gatwick, then Brussels, and then the oil companies who have slashed costs and compromised safety by their cheap attitude for so long.

I expect Shell Management will be along shortly to justify the behaviour of the oil companies, but I personally will take a lot of persuading that current practise as defined in legislation is best practise.

SND

[BARKINGMAD]

Congratulations to the UK Regulator and the principal Union for reacting to the issue of North Sea Helo Ops so long after the events!!!

Now we await the next fixed-wing disaster to stir a similar reaction, too late.

Eurocopter fuel guaging, turbofan engine cowlings, fatigued aircrew to name but a few of the much-flagged issues which are waiting to produce the next fixed-wing airline disaster, but so far the warnings from the coalface are ignored.

SASless, I totally agree with your postings and others in the same vein, but until we see the suits at the top of the aviation food chain carted off in 'cuffs etc......you know the rest? :ugh:

[terminus mos]

Jim

I said it at the top of the page

There will be lots of no fly days due sea state >6


SND

I'm glad I no longer work offshore, but I believe that this safety review should have started at Gatwick, then Brussels, and then the oil companies who have slashed costs and compromised safety by their cheap attitude for so long.

I expect Shell Management will be along shortly to justify the behaviour of the oil companies, but I personally will take a lot of persuading that current practise as defined in legislation is best practise.

I am not SM but I do work on the customer side. As I have said before, I think that much of the responsibility lies with the helicopter companies who have had to be dragged kicking and screaming into buying new aircraft. Thank goodness that industry has demanded newer aircraft, otherwise 30+ year old 332Ls would still be on offer........oh, wait a minute......

[Langball]

Standard designation used in Part 29.

JimL, forgive me ignorance (non-pilot here), but what is 'Part 29'

[JimL]

Yes TM but the limitation is associated with the ditching approval:


Action A6: With effect from 01 September 2014, the CAA will prohibit helicopter operators from conducting offshore flights, except in response to an offshore emergency, if the sea state at the offshore location that the helicopter is operating to/from exceeds the certificated ditching performance of the helicopter.

Sea State 4 (which is the base line approval for most medium offshore helicopters - and some of the larger) is a significant wave height of 1.25m - 2.5m (4ft - 8ft).

It was this that was being referred to.

Jim

[HeliComparator]

So does the sea state limitation apply to a land based destination where the approach is made over water, such as Sumburgh? If so, how is the sea state measured there considering it varies so much with depth of water and exact position. If not, surely it is not addressing the Sumburgh L2 accident?

If you look at the 5 accidents, only one (the ETAP) could possibly be impacted by this new rule. So it's hardly going to create a step change in safety! It seems to me to be mostly a PR excercise.

[212man]

forgive me ignorance (non-pilot here), but what is 'Part 29'

It's the design certification standard for large rotorcraft. Detailed guidance can be found here, including a lot of information about floatation gear certification:

http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_29-2C_CHG3_Incorporated_%28with_updates%29.pdf

What I really struggle to understand these days is that when you and I flew together we were in a S61 with basic sas, Decca roll maps and crap radar and we seemed to manage a higher level of safety than today.

I think that quote wins the "rose tinted spectacles of the week" award!

[212man]

So does the sea state limitation apply to a land based destination where the approach is made over water, such as Sumburgh?

That's how I interpreted the intent (and the reference to arming floats).

[HeliComparator]

That's how I interpreted the intent (and the reference to arming floats).

Certainly the arming floats bit. But I'm not so sure about the onshore destination sea state limit. After all, there is no sea state at a land destination. And which airports and runways are you going to include and exclude? For example, Aberdeen presumably not, Scatsta maybe, Sumburgh yes on the instrument runways. Wick probably not etc. No, I don't think they mean to include onshore destinations in the sea state rule, but it needs to be clarified!

[212man]

but it needs to be clarified!

I fear not every recommendation is as well thought through as they might be....

[212man]

Is Sikorsky going to do anything about their ridiculous floats "arming" limitation speed of 80kts?



Yes, AMS 8.0 (I think) will introduce auto-arming. The FSI simulators already have the 3 position switch installed.

[HeliComparator]

What are the criteria for auto-arming?

[212man]

It will use an IAS sensing switch to physically arm the floats (at 80 kts) but I don't know much more than that. I think the SOP will be 'select auto' when coasting out, and leave it there until coasting in. The EICAS will show the actual status. A 'manual arm' position is still retained.

[Heathrow Harry]

back in the bad old days people would fly out in overalls and (maybe) a life jacket

Now, especially in winter, they have so much survival gear on that even the slimmest person looks like a Michelin Man

I'm sure it is good to have if you can get out of the helicopter but you have to get out first

[SASless]

I am not believing what I am seeing here!

Sea State applies to the body of water you are flying OVER....where or why you are flying over it has naught to do with business....just the mere fact you are exposed to a qualifying Sea State at any point in your flight should be the Criteria.

If this is the level of understanding as an indicator of how some folks think....Lord Help Us!

As to having a very slow Ground Speed on Approach....in the old days we saw that as not being a bad thing especially in really bad weather. You are flying a Helicopter.....Remember?

If you feel the need to whistle down the glide path at near Warp speed....perhaps you might rethink the capabilities and advantages of flying a Helicopter.

[JimL]

SASless,

Sea State applies to the body of water you are flying OVER....where or why you are flying over it has naught to do with business....just the mere fact you are exposed to a qualifying Sea State at any point in your flight should be the Criteria.

Could be a matter of accountability.

Jim

[BlackIsle]

I am not believing what I'm seeing here!

.... well I'm glad it's not just me, I managed Sumburgh Airport a good few years ago and am dumbstruck by suggestions of sea state criteria perhaps not applying to flights to land-based destinations?

[SASless]

Could be a matter of accountability.

Care to expound upon that a bit, Jim.....as that short statement leaves us unsure of what you are actually saying? Do you mean some form of "counting" or as a device for "eluding responsibility"?

[cyclic]

Auto-arming floats, Cat A rebreathers, slimmer passengers, smooth seas - NS problems solved - phew, there was me thinking this could take a while, thank goodness we have the CAA and NDB holds.

Why is the majority of this report actions regarding survivability of a crash? Are the CAA saying that a crash is inevitable? Are the real safety issues being addressed or is this the CAA (government) looking for a good way to pacify our passengers? Limits on sea state were introduced after two of the recent incidents by all three companies I think, but the first week it impacted on commercial ops, the restrictions were deemed unnecessary. Who were the pilot group that were consulted? Does anyone know of someone that was consulted outside of management? Is the CAA as the regulator really in touch with what actually happens and if so, why have all their actions been after the event? They can't claim to be short of cash judging by how much they charge for an outdated licence document, just as an example.

We had spoken up about sea state, night bow decks, Dacon scoops (good prospect of recovery...WTF) and the like but nobody wanted to listen after each incident/accident. Even now, decisions we make are still being questioned and that is something that would surprise our passengers. Do I think we have moved on? Yes, a little, but the regulator's intervention is aimed incorrectly and is too little too late. The current mini-boom creates a whole new raft of problems which they had better get a grip of quickly. As someone who has contributed significantly to the coffers of the regulator I am a little disappointed. Our fixed wing brethren must be having a good giggle. As for BALPA...:eek:

[mtoroshanga]

I thought that the object of using helicopters was to access the installation under all sea conditions. When I started we did crew changes in Bell 47s
with two to four passengers.
If the authorities knew what they were talking about we would not be running into this ludicrous situation.
I sure SAS will agree that real pilots should cope and that passengers who don't think that they are Nurth Sea Tigers and just people going to work in often pretty basic jobs and just do what they are told. The Leggoland helicopter dunker trainers don't help!

[HeliComparator]

I am not believing what I am seeing here!

Sea State applies to the body of water you are flying OVER....where or why you are flying over it has naught to do with business....just the mere fact you are exposed to a qualifying Sea State at any point in your flight should be the Criteria.



It could be. In your opinion. However there area couple of problems with using sea state anywhere en route.

Firstly, who is going to measure it?

And secondly, we all know that helicopters only crash near the offshore installations whilst taking off and landing, that's why we have the safety vessels lurking there...... Er, well, that used to be the perceived wisdom anyway! How many out of the 5? Oh yes, just one, the ETAP!

[HeliComparator]

.... well I'm glad it's not just me, I managed Sumburgh Airport a good few years ago and am dumbstruck by suggestions of sea state criteria perhaps not applying to flights to land-based destinations?

Well the point is that helicopters aren't supposed to fall into the sea during an onshore instrument approach. They have sufficient speed to fly happily on one engine until over the runway. Whereas offshore, they have to slow down to below OEI flight speed before landing, whilst at the same time crossing over all sorts of nasty jagged metal bits.

OEI flight is, as we know, the only malfunction the CAA concern themselves with.

Which is just as well because if they contemplated the need to ditch immediately (not that this ever happens ... Ahem!) they would stop us from flying over land in weather where the cloud / fog was on the surface and especially over mountains when the cloudbase was below mountain top height.



Doh, I think I've blown it now...

[Pittsextra]

Here is the thing I don't understand. Criticism of this initiative makes some feel smug but industry isn't doing any better, read for example the HSSG newsletters and - for example - the last time HUMS got a mention was 2012 to report nothing needs doing..... Super.

[AnFI]

Well the point is that helicopters aren't supposed to fall into the sea during an onshore instrument approach. They have sufficient speed to fly happily on one engine until over the runway. Whereas offshore, they have to slow down to below OEI flight speed before landing, whilst at the same time crossing over all sorts of nasty jagged metal bits.

OEI flight is, as we know, the only malfunction the CAA concern themselves with.

Which is just as well because if they contemplated the need to ditch immediately (not that this ever happens ... Ahem!) they would stop us from flying over land in weather where the cloud / fog was on the surface and especially over mountains when the cloudbase was below mountain top height.



Doh, I think I've blown it now...

Yup, cat, pigeons etc

Do I hear that EASA apparently want to exclude Single Engined Helicopters to fly over Hostile Environments?
Doh They want unreliable, underpowered, weak tail rotor aircraft instead in the mountains? A twin Exposed is more than twice as dangerous as a single.

Over obsession with Engine Failure distorts methodologies.

Duplicating Engines might just be a good idea under some extreme circumstances but it is not the magic answer that people want it to be, evidently.

Set realistic and proportionate goals and let designers deliver using their initiative and skill.

[AnFI]

http://www.ihst.org/Portals/54/Partners/India/5_McColl.pdf

[SASless]

Some interesting questions raised.

I always wondered about flying over mountains with the maybe just the very tippy tops showing....not rounded grassy tops but real sharp, jagged, granite like things....that even Mountain Goats avoid due to poor footing.

One beautiful Moon Lit night....VFR on Top in a Cessna Caravan....routing across an area in Washington State known locally as "The Alps"....a few craggy tops poking up out of the murk that ran right down to about a 1000 feet MSL....with elevations ranging from 4,000 to 9,000 or so. The destination was clear beneath an overcast so had no expectations of problems getting home.

Smack dab in the middle of the "The Alps", while star gazing and admiring a big bright Moon....and how it caused the granite rock below us to twinkle....the sudden realization that I was bore sighting a single PT-6 engine ruined a very pretty night.

Had that engine failed....it would have been fatal....and the quality of life from the instant it quit till we quit Earth would not have been very pleasant.

Helicopters are very much like that Caravan....One Main Gearbox.....and if it decides to experience a serious problem that requires an immediate landing....Things like Sea State, undercasts that go to the surface, and some other interesting situations should give us pause for thought.

We can always warmly note the Authority's definition of "Very Remote" or "Extremely Remote" however they label the concept that such things only rarely happen thus our risk of a sudden demise is not something to get concerned about.

So why should we get fussed about such issues.

The Cougar thing off Newfoundland was just a statistical fluke....as have been all the North Sea 225 Swim Calls.

What we do see....is the difference in the outcomes when Sea State is within the aircraft's certification level.

If a Rig Crew has to work over now and then....is it really that big a deal?

[Tango123]

Spot on SAS

I find it really ridiculus to do crew change with gigantic waves beneath thinking:"is it really that important for the oil companies, to get Mr. B out so Mr. A can get in? Survival if we have to ditch now is impossible."

But that thought also go with: "this is what they are paying me to do, not only to fly Cavok, sea state zero, in day light...."

[JimL]

SASless,

The text was underlined to emphasize that the limit was on the certification status of the aircraft and not just SS6 (as HC has concluded).

As I tried to indicate (probably too succinctly), it is likely that for the whole of offshore operations, sea state will only be consistently reported for the offshore locations. Yes, there might be occasions when it could be worse at the onshore site (Sumburgh for example) but that would be an exception that would not justify the complexity that would be added to the regulatory regime by including it.

Cyclic,

It is not clear that you have read the whole report; the questions you have about getting to the heart of the problems are discussed and have resulted in Actions/Recommendations. You do need to read more than the press review and comments on PPRune.

The HF issues of automation will also be dealt with in an RAeS Conference on the 3rd and 4th July. This conference is intended to have all parties discuss:

"Technology Friend or Foe - the introduction of automation to offshore operations"

By having presentations and discussions from the majority of the interested parties.

Jim

[Sir George Cayley]

Did I read that only pax sat next to an emergency exit can be carried?

And if so is there a Body Mass Index associated with this?

SGC

[Bravo73]

Did I read that only pax sat next to an emergency exit can be carried?

Only if you stopped reading at that point.

The rest of the sentence says "...unless they are wearing a Category A rebreather" (or words to that effect).

[unstable load]

What exactly is a Category A Rebreather, please? The only
ones I know of are SCUBA type which clearly aren't what is
mentioned.

[Bravo73]

What exactly is a Category A Rebreather, please? The only
ones I know of are SCUBA type which clearly aren't what is
mentioned.

Read this thread from post 26 onwards.

[somesuch]

So JimL, a couple of questions..... Will this appy to the likes of NHV and DanCopter, who don't have UK AOCs but operate from the UK? And does any other jurisdiction (ie Norway) intend to adopt equally draconian rules in such a short time scale?

Don't get me wrong, I believe that each step provides safety benefit, but 7 weeks notice to reduce the capacity of every helicopter operating by between 30-50% is going to be problematic (understatement of the month) for oilcos and heliops. There is no Cat A EBS in use on the North Sea, at least not that I can find, and the training for whatever new device is selected with take a lot longer than the 7 weeks provided. Not even sure it can be done by the 2016 cut for for all occupants!

I assume the chaps in LGW Ivory Tower have considered all of this though, so I am sure they have a solution in mind.

[EESDL]

Why a Class A 're-breather' when CAP1034 clearly states that they add to the buoyancy of the wearer when you need it least - ie, inside the cabin/cockpit.
Now a Class A Compressed Air device would be solution - and does not require 'special' training as how deep do you think you are going to use it?

Personally, not considering the pax (in this respect) as they have been equipped with a far greater level of safety equipment than my industry has afforded me.................

[SASless]

I assume the chaps in LGW Ivory Tower have considered all of this though, so I am sure they have a solution in mind.

They write Rules....solutions are the Industry's Problem.:E

[bondu]

JimL,

I spoke to a very nice Met man at the Aberdeen Met Office about 15 months ago, who showed me the data that is now available on sea states/sig wave heights in UK waters. It is possible now, with satellite measured data, to show the sea states along a route from Aberdeen to, for example, the North Alwyn. When I asked why this wasn't available to me every day as a line pilot, he told me that was because "no-one had asked for it"!
It will probably cost the helicopter companies a little more, but on those days when sea states are an issue, it should be available.
And, as some have already pointed out on this thread, both the EC225 ditchings took place en-route, nowhere near an offshore installation.
No-one wants to see airframes in the water, but it will occur again despite all the training and improvements we are likely to see in the future. Surely, we owe it to our passengers (and ourselves!), that we cover all the bases and do all we can to ensure a safe outcome.

bondu

[unstable load]

Bravo73,
Read this thread from post 26 onwards.
Link not working.

[SASless]

Bondu.....ever the trouble maker!:D

Why is it I get the direct impression that the CAA and the Met Service eat at different subsidized Messes?:ouch:

[Bravo73]

Bravo73,

Link not working.

What link?

I'm talking about this thread. The one that you're in. Try reading it from the beginning.

[Sir George Cayley]

The Messes are different - one at Gatwick and one at Exeter.

Oh and the CAA subsidy has been removed.:ok:

SGC

[Slfsfu]

Ok, for you professional types - I'm ready to be shot down:( and this may have been addressed already) BUT..

Reduced number of pax (30%) will require an increased number of flights (30%?). What does this do for the frequency of potential ditching. It occurs to me that, statistically, they should increase.

I don't know all of the details but, again, it occurs to me that we are dealing with survivability (and I'm all for that) , after ditching, without actually improving the fundamental issue of NOT ditching in the first place.

All with good intent, to learn

[JimL]

Hi Somesuch,

It would appear that the only means of achieving a level playing field (if you can have this in SS 4) would be with an airspace requirement - whether that would be the method of application is not known to me.

As the Report applied only to UK offshore operations, it is also not clear (to me) whether other fringe States would follow suit.

Bondu,

I'm sure all are aware of Sea State forecasts (it appears in Annex E page 25 of the report) along with this text:

2.10 Sea State Information

2.10.1 ICAO Annex 3 has a recommended practice in relation to the provision of information for helicopter operations. It is stated in Appendix 3.

4.8.1.5 Recommendation.— In METAR and SPECI, the following information should be included in the supplementary information, in accordance with regional air navigation agreement:

a) information on sea-surface temperature, and the state of the sea or the significant wave height from aeronautical meteorological stations established on offshore structures in support of helicopter operations;

2.10.2 The UK has arranged that state of the sea information is provided from a number of offshore installations and is included in the AUTO METARs. Arrangements are being made to change the reporting from state of the sea to significant wave height which has been made possible following an amendment to ICAO Annex 3.

2.10.3 In addition forecast significant wave height information is provided on OHWeb.

I have to remind you that I do not speak (or think) for the CAA but am merely reporting what is contained in CAP 1145.

I find it somewhat bizarre that canteen practices always seems to be in the minds of some of the members. I wonder what Freud would make of that?

Jim

[cyclic]

Hi Jim

I have read the report, end to end. I wasn't referring to the use of automation which I don't think is a huge problem or at least one that can be remedied very easily. You only have to look at some of the knee jerk reactions that have already taken place to see that a few topics have peen picked which aren't at the core of the problem/s. I really worry about the emphasis on post crash survival, the horse has already bolted. It needs to be reviewed and changed but isn't the answer to all the problems, nor is the use of automation. My reference is really to one of ethos, how we actually operate day to day and how we need to look with an open mind, a genuine will to thoroughly review gloves off. This forum shows how quickly "we eat our own babies" when it comes to a slightly varying point of view.

Most of the items in the review are blindingly obvious and ones that could have been implemented with a little vision long before the last accident. Why didn't we do it? Because, in my humble opinion, the ethos is not right in many respects.

[bigglesbutler]

Reduced number of pax (30%) will require an increased number of flights (30%?). What does this do for the frequency of potential ditching. It occurs to me that, statistically, they should increase.

Can't argue with you Slfsfu, it has also been mentioned on this thread earlier so you're not the only one. I don't have an answer though and neither does anyone here yet.

Si

[somesuch]

Thanks for that Jim. It would be rather concerning if non-UK operators can continue to fill up their helicopters on flights out out the UK while the rest of us are limited by up to 50%. Hardly a level playingh field - is this another one for Mr Farage? ;)

I am surprised how little discussion this issue has triggered here. I am sure management (helicos and oilcos) are getting a bit sweaty over this!

As far as risk goes, I guess it makes no difference to a particular passenger (who won't be doing any more flying than he does now, but those of us upfront will be doing even more than we do now. This doesn't seem to be considered in the pages and pages of CAP1145.

[satsuma]

cyclic


'I wasn't referring to the use of automation which I don't think is a huge problem'


You may not, but others do across the aviation world. Here's what the CAA had to say in 2011:


http://www.caa.co.uk/docs/33/SafetyNotice2011017.pdf


Somewhat prophetic, don't you think?


Then from this latest CAA release:


'It is felt that the underlying instrument flying skill set of some of these candidates may be introducing latent problems when managing and using these more complex systems.


There is a well recognised dichotomy affecting both aeroplane and helicopter operators known as 'automation dependency' which affects those who operate these highly complex types. This has been reinforced by BALPA who expressed concerns about new helicopter pilots joining the industry who rely too much on automated systems, and tend to focus on managing the systems rather than flying the aircraft.


Whilst operators may implement SOPs that require optimum use of autopilot functionality there still remains a need to ensure flight crews can manage a manual flight situation. This may not be manifested until manual flight control is suddenly needed as is the case of an autopilot failure or recovery from an undemanded aircraft attitude.


There are of course those on this thread who will bang the drum for increased automation and have done already, at length, on other threads. However it doesn't take a genius to spot the patterns in recent years in both the fixed and rotary wing worlds and to recognise that not every pilot on the line is going to be as skilled, diligent or mentally capacious as those for whom automation is a gift from God. Until they are, which may take some time, then it looks like the measures imposed by the CAA to make unintentional 'landings' on the sea more survivable are wholly appropriate.

[Grumpyasever]

GFT3 was scrapped many years ago. Is this chickens coming home to roost?

[JimL]

With respect to seating limitations; there needs to be more concentration on the solution. If adequate mitigation is provided, there will be no reduction in seating capacity. The Canadians have already moved to the solution that is required by the CAP - that solution is therefore available now.

To my knowledge, there is no immediate action to mandate breathing devices it is, at this time, the means of mitigation for the projected seating reduction (for the purpose of increasing breath-hold for escape for those who are not seated immediately adjacent to an escape means). The standard is contained in a CAP - i.e. guidance material.

For operational limitations associated with certification for ditching; we in the helicopter offshore safety and survivability committee (HOSS) made it quite clear more than a decade ago that certification at SS 6 should be the standard for offshore operations in a hostile environment. That this was resisted by a number of parties (including one major regulator) was a thorn in the side of proactive policy. The chickens have now come home to roost.

When it comes to automation issues; it is not a case of too much or too little but one of an appropriate level to ensure maximum efficiency/safety. However, as was pointed out in the reference shown earlier, there is an issue of automation dependency - this is not a new phenomenon, it was extensively researched and written about by Billings and others in the early 1990s. It was also pointed out in that and subsequent reports (including the recent report on "Operational Use of Flight Path Management Systems").

The introduction of automation brings with it additional (and sometimes unique) challenges. Some of these have recently been observed and promulgated - for example in the Cougar 851 report. However, it is noteworthy that there has been little recognition that the issues identified in fixed wing translate directly across to automation in complex helicopters. Was this subject aired in any of the comprehensive SINTEF reports? It is clear that automation is on a growth path in complex helicopters and we need to acknowledge that. Our culture of operations needs to change (and we are seeing that already in the debate on best practice SOPs); along with that, and as also mentioned in the early reports, the introduction of automation does not come cheap in terms of human factors. There needs to be a comprehensive review of training regulations to ensure that they are based upon competency and not time/tick box lists.

We, as pilots, also have a responsibility to understand automation and its associated advantages/limitations. It is clear from musing on recent threads (not just in offshore operations) that we continue to be baffled by displays and input devices. There are a number of reasons for that some of which are associated with the actual design - it is not exactly human-centric - a subject which is also discussed extensively and not just in aviation.

That is the basis for the conference to which I referred earlier.

Jim

[somesuch]

Hi JimL, while I am generally in whole-hearted agreement with you on this, I don't understand your first point.

Surely there will indeed be an immediate reduction in seating. Side-floating thingies don't exist at the moment, so they are out for the 1 June deadline.

The EBS get-out requires stuff to meet an as yet unfinalised draft technical specification. Now it might well be that the Canadian HUEBA are close enough to this, but it would be nice if the CAA would make it clear. Even if they are, and assuming enough sets can be bought and delivered in 7 weeks, surely we are not just going to give these SCUBA devices to people without theoretical and practical training? I see that there is onfgoing discussions in Canada as to what is and what isn't safe training, and I haven't found consensus on this in my googling.

I hear that management are trying to plan for reduced payloads, and I guess this is being shared with oilcos, so I cannot be the only person who doesn't see how the dots join up here.

Still concerned that the oilcos best way out of this is to stop using UK AOC holders and just contract in the foreigners. That was none of this applies. Not sure how that improves safety for passengers, or job security for pilots. Just makes the UK operators less and less competitive.

[terminus mos]

That the UK CAA would issue such a report with such short time lines; without any substantive research into the availability and training of breathing equipment or side floats is baffling.

OEMs have no current credible solution to side floats. If you are in a side floating helicopter, sitting in the middle and release your seatbelt, isn't the first thing you will do is to fall to the bottom of the side inverted helicopter and crush the people on the "down" side?

What about the consequences of inadvertent inflation? Which side will deploy? Fitted one side or both? Manual or auto? Water or inertia switch activated? Pilot or pax deployed? Armed on each take off and landing or all the time? Winglets?

Industry is already considering reduced payloads, more flights and having to extend temporarily again, the life of the 332L carrying more passengers in a 33 year old airframe with old technology and little automation further delaying standardised automation training and operations.

This academic and today, impractical report appears as a rushed reaction in response to public pressure produced by a regulator trying to catch up with industry.

The UK CAA has done some good work, this is not its best.

[JimL]

Somesuch,

For more that a decade it has been recognised (research in Canada) that the time to escape from an inverted Puma-size helicopter exceeds the breath hold time. For that reason, the HOSS committee provided a two stage policy: the first stage would be a temporary fix to provide passengers with enhanced breath hold with the use of EBS; the second stage (long term) would be to produce a side floating capability which would preserve an air-gap in the cabin permitting evacuation without full submersion. All of this has been contained in research reports for some time but, following the introduction of EASA, was collated into a single document and published by the CAA.

As far as I can see (and anyone who reads the report can as well) the CAA intends to provide operational limitations which recognise these (long-standing) choices: the seating will be restricted unless the breath hold time for the passengers matches the escape time (the objective standard). In practical terms this translates to: side floating without the aid of EBS as a final solution; and, EBS (as a temporary solution) until side floating has been achieved (or remains impractical). The Standards for EBS (Category A and Category B) in contained within CAP 1034. If there has been an advance it is that deployment has been seen as problematical and complex and unlikely to work in other than a ditching case (i.e. water impact in a survivable accident). In the absence of a requirement for certification, this CAP serves as guidance for those parties who wish to purchase and take advantage of EBS to mitigate the operational limitation on seating capacity. As I said previously, the oil companies in Canada are already employing devices which (I am told) meet the Category A standard.

With respect to EBS, for the time being compulsion does not exist neither is there a process of Approval. Make of that what you will!

As I said previously, there is likely to be an airspace requirement (similar to that for the EC225 operational restriction) that will mandate the operational limitation on the UK continental shelf. What more is there to say?

Terminus mos,

Your statements, as always, are provocative in the face of the evidence. With respect to side-floating; passenger testing was carried out in the early 2000s and the evacuation drills were found to be practical - read the original report; it also answers your questions on the principles of side-floating.

The working groups who have been involved in this work have been in existence for almost two decades but their will has been thwarted by various parties, and events such as the advent of EASA and the transfer of responsibility (which itself resulted in five lost years); there is little here that is new except a willingness by the CAA to make this happen and take the appropriate actions.

If the oil companies have alternative to these measures, the question should be asked, why did they not put them in place?

Jim

[cyclic]

You may not, but others do across the aviation world. Here's what the CAA had to say in 2011:

http://www.caa.co.uk/docs/33/SafetyNotice2011017.pdf

Somewhat prophetic, don't you think?

Yes, there are certainly improvements to be made with handling automation but in both non-mechanical accidents the SOPs were not complied with. How much training do you need to stop someone going against the grain? The first CFIT accident happened because someone thought they could fly the aircraft better manually than using the automatics - a question of ethos whose roots are a lot deeper than just ops manuals and training. I agree with everything you say Jim with regards to automation, crash survivability etc. but I think it is just scratching the surface, a sticky plaster over what is sometimes a broken industry. I will say no more on the subject so you can all get on and argue over chuffin rebreathers (which up front we have never had...).

[JimL]

Cyclic,

Go to PMs.

Jim

[SASless]

For more that a decade it has been recognised (research in Canada) that the time to escape from an inverted Puma-size helicopter exceeds the breath hold time.

That is one hell of an indictment you just made of the CAA and other Authorities!

The Passengers going offshore without the proper equipment to at least give them a chance at surviving must feel really good about that kind of thinking by the various Authorities and the Offshore Oil Industry.

That being said....the Operators and Oil Companies were not barred from supplying the necessary gear themselves.

Any wonder why I advocated a "Shields Down" Review?

[Outwest]

can someone explain what "side floating" means and how this would look?

Does it mean there would be floatation bags installed above the cabin doors for instance?

[Harry the Hun]

Side floats? Easy, just glue 500 rubber-duckies to either side of the fuselage :-)

[JimL]

SASless,

I'm sure the same holds true for a fixed wing!

What's the point in calling for a shields-down review when your main interest is using it to sneak punches.

Passengers have been equipped with re-breathers since the results of this research was published and specifications produced. Re-breathers were seen only as providing breath hold in the ditching case; what has changed in the meantime is the realisation that, whilst we have never lost a passenger in a ditching incident, we continue be susceptible to water impact accidents (such as Sumburgh).

Outwest,

Look in here:

CAA Paper 2005/06: Summary Report on Helicopter Ditching and Crashworthiness Research | Publications | About the CAA (http://www.caa.co.uk/application.aspx?atid=33&pagetype=65&appid=11&mode=detail&id=2084)


Jim

[somesuch]

Many thanks JimL. It all makes perfect sense to me, and if we worked in an industry run by rational people, rather than lawyers, I would be less concerned. The problem is that, at the moment, only a CAP has been published. This isn't legislation and has no legal authority for non-UK operators. One would hope that the CAA is lobbying its colleagues around the North Sea to see similar limitations applied, but nothing is currently evident to us outside those meetings. I have no argument with the fact that other jurisdictions are using EBS, including Canada, and have been for several years. However, we (the UK) weren't willing to learn from other peoples mistakes in the past, and now seem to be trying to frantically catch up in a rather uncoordinated way. How will UK AOC holders be able to compete with their European competitors if we have to apply some pretty significant limitations. I do hope that your view is the one that prevails, ie that EBS can be acquired, trained for and put in place in the next 7 weeks. I am just not so convinced that it is achievable in reality. I guess only time will tell. In the meantime, I'm off to the pub. Thanks for you perspective though.

[JimL]

Somesuch,

I keep on saying it you keep on missing it (I'm sure it is bad form quoting oneself):

As I said previously, there is likely to be an airspace requirement (similar to that for the EC225 operational restriction) that will mandate the operational limitation on the UK continental shelf. What more is there to say?

That is, it will apply to any helicopter flying to a UK offshore installation (from wherever they originate).

Jim

I have to add that if you think that the UK has been behind the rest of the world, you have not been following the debate (over two decades).

[Outwest]

Thanks Jim,

large document, but I think it appears that they are suggesting the use of passive floatation (buoyant engine cowlings,etc) rather than active (bags).

I would be interested to see the size of an engine cowl that would contain enough buoyant material to keep the a/c from going inverted......

[terminus mos]

Jim L

Please point me to the study on side floats. Are they available today?

If OEMs or operators have a side float system available now which is tested and certified and can be incorporated into current helicopters, we will specify fitment to our contract fleet and raise a contract amendment to do so forthwith.

You can criticise my provocative comments, but implementation of the measures contained in this report will decrease passenger capacity, increase flights and crew exposure and prolong the life of technologically obsolete aircraft. A slightly longer adoption period would have been helpful.

Looking at the aircraft configurations, it seems that based on the report criteria, the 33 year old 332L may be able to carry 1 more passenger than the 225, the law of unintended consequences perhaps?

[JimL]

...or, you can provide a Category A breathing apparatus (for those passengers who are not adjacent to the exit) - as have the Canadians.

Jim

[EESDL]

At last - our CAA have grown some!!!
How many decades has the industry been faffing about?
Consultants procrastinating and ensuring nothing gets resolved so they can continue to invoice for some more 'expertise'........
It's about time that deadlines are set otherwise we will simply continue to blunder on regardless.
Congratulations to passenger groups for mandating re-breathers for themselves.
Pilot groups/representatives/operators should hold their heads in shame for the lack of EBS in the cockpit. Regardless of implementation, it is simply a money issue and 'they' have 'got away' with it for far too long.
The trouble is - the industry has managed to disguise who 'they' are.
Numerous Aberdeen-centric meetings and soirees, full of men and women practicing the art of 'face-time'. Agenda items simply regurgitating the last meeting's minutes and lost amongst another sub-committee.
If you don't supply EBS for the crew then remove the meaningless/ridiculous Ops Manual phrase where it dictates that the crew should assist the 're-breathing' passengers upon 'ditching' and enter the life-raft last, after collecting numerous items scattered around the cockpit/cabin.

Perhaps we could actually learn from 'Johnny Foreigner' - at least they do not appear to treat crews as 2nd-class citizens - I understand one Northern European outfit is on the verge of implementing crew EBS - and this decision was made before recent review.

PS. It's only a National Document so get your Waiver Applications in the post!

[griffothefog]

STASS is the only way forward, let the twats that say it's a flight safety hazard follow that up with a practical environmental 5degs pool practice in which they partake...... :eek:
I for one will carry my own.. :E

[Vie sans frontieres]

Who on earth considers STASS a flight safety hazard? Why?

[SASless]

Griffo ever the Rebel....always causing trouble.

Laddy...you must cease and desist....this injecting logic and commonsense into such an argument is patently unfair, uncalled for, and absolutely insulting to those who craft Rules, Regulations, and Policies for a living rather than Walking the Walk instead of merely Talking the Talk.:ok:

[Variable Load]

Did anyone say that STASS is a flight safety hazard?

I know that some pilots do not wish to do STASS training - in fact some do not wish to do basic HUET!

There is a training risk with STASS that should not be dismissed.

On a personal level, give me STASS tomorrow and I'll be a much happier pilot!

[nowherespecial]

Shell think Pilot STASS is a snag hazard. I've had it in audit findings. It's not against SGRAO but it is always a sticking point.

[SASless]

Paragraph 2.2 begins the UK Civilian Experience.....and cites the 1995 CAA Study. What is quoted there is not very flattering. Look where we find ourselves today....18 Years later.


http://traktoria.org/files/helicopter_ditching/AG-341-02.pdf

Comments that support Griffo's fondness for such kinds of Breathing Systems....



They concluded that HEED had facilitated underwater escape. They reported that there were 25 individuals who reported that they would not have survived without an emergency breathing system. EBS users consistently reported a calming effect replacing the post-impact panic frequently experienced with the initial in-rush of water.

So much so, that the Marine Corps were seriously considering training their ground troops and supplying units to those proceeding on over-water missions.

Like the soon to come into service Canadian design, the US Navy was modifying the system so that the compressed air bottle was an integral part of the vest. An air hose was added so that only the regulator / mouthpiece need be located, retrieved and placed in the mouth.

[meanttobe]

Section 5 of this document covers training with STASS. Interesting feedback from participants.

http://uk.opito.com/uk/library/documentlibrary/huet_exit_repot.pdf

[jimf671]

It occurs to me that many UKCS offshore workers will have been around long enough to have used short-term air supply devices in the fire part of their survival course. These were cylinders with nominally 4min30s of air for use in smoke-filled areas. Clearly, these are different from the rebreathers with air supply but possibly similar to other devices that are potential solutions.

[Vie sans frontieres]

'Shell think Pilot STASS is a snag hazard.'


Well that tops the irony league table for this year. The item of equipment designed to help you free yourself from snags is considered a snagging hazard. Let's hope they've got big lungs and warm water in which to ditch.

[somesuch]

Haha, as usual, not everything on here is awfully well researched. Was just chatting with an old navy bud if mine, who flies for Shell in Brunei, where the pilots carry them!

That having been said, not sure how the pax will squeeze a STAS onto that fat thing they wear now and still get out of a window. I guess they will need new LSJs to go with the new EBS.

And all this will be done in 7 weeks? Hmmmmm

[Tango123]

jimf, you could be right there, every little helps. One of the best things for those afraid of water could even be a scuba diving course but it is unrealistic (not sarcastic ment). On the Nutec courses I have been on, the platform workers are not trained in short-term air supply devices (only the firefighters).

The problem with the HEED (where you get around 3-4 minuts of oxygen) is that it is a plus and a minus. A plus for the guys who can handle a chaotic situation, but not for those who have a tendency of panic in that situation. Many of the guys I fly out, don't like to fly in the first place, don't like to get their head under water (and turned around) and I really don't expect them to be able to handle the ditching properly. I see every time I am in the dunker.

HEED is not going to help these guys, it can have an adverse affect, where they try to remember what to do, in the right order; not being able to, and trying to use the HEED and relying on it, they are not holding their breath, and then it's over.....

I would certainly say that all pilots should have it, not only to get out (that's easy with our emergency exits), but that extra oxygen could give us an opportunity to dive and look for passengers, if the helicopter stays at the surface (which most do for while).

I have tried HEED, not sure if I can recommend it for ALL the passengers.

[Vie sans frontieres]

That would be very decent of you, but I believe the teaching has always been GET OUT AND STAY OUT! As bad as you may feel you will be neither trained, equipped or mentally attuned enough to safely become a diver and go looking for trapped passengers.

[obnoxio f*ckwit]

Tango123,

I'm with VSF. I may hang around a bit to try and make sure all the pax are out, but once I am out I am never ever going to go back in.

Search for the loss of Lynx XZ668 in the Adriatic in 1995 as an idea of why.

OF

[Tango123]

Everytime during the briefing before going to the dunker training, if the instructor doesn't say it, I say to the offshore workers on the course:" don't expect that the pilots will help you out, if the cabin is full of water. You have to know the procedure and get out by yourself."

But if I end up in a situation like the pume still floating but upside down BBC NEWS | UK | Scotland | North East/N Isles | Helicopter survivor offers thanks (http://news.bbc.co.uk/2/hi/uk_news/scotland/north_east/7901124.stm)
I hope that I would anything to try to open the doors, and getting acess that way to the cabin to check for pax.

Not trying to be a hero, but like anyone else in the cockpit, I do feel a big responsebility for the pax onboard.

[EESDL]

Don't pax already use rebreathers - Hybrid versions already exist that contain compressed air and curry gas? - ie no holding of breath required, no additional devices blah blah
Recent Safety Notice highlighted that some pax didn't know how it worked......they've all been trained and information on system is plentiful.
If they choose to treat their PPE with such regard that is their lookout - I just hope they don't block any exits whilst they suddenly realise that all those repetitive safety videos were for reason.......

Passengers already appear to be well cared for, can we just concentrate on us chaps and chappettes up the front who have been ignored since Pontius Pilate flew?

[diginagain]

I thought pax use the LAPP jacket? - ie no holding of breath required, no additional devices blah blah
Recent Safety Notice highlighted that some pax didn't know how it worked......they've all been trained and information on system is plentiful.
If they choose to treat their PPE with such regard that is their lookout - I just hope they don't block any exits whilst they suddenly realise that all those repetitive safety videos were for reason.......

Passengers already appear to be well cared for, can we just concentrate on us chaps and chappettes up the front who have been ignored since Pontius Pilate flew?
"Good morning, ladies and gentlemen, and thanks for flying with Whiteknuckle Airways. Just a reminder that if, as a result of the ineptitude of either the regulator or our training department you find yourselves up to your oxters in salt-water, you're on your own."

[EESDL]

Diginagain - you might very well have neatly summed up the current situation?
In the chopper I fly we cannot get into the back to assist our pax (who have EBS) - so yes, they are completely on their own.:ugh:

You must fly one of the larger types where you can pop down the back to ensure the pax are using their EBS correctly and guide them to their 'nearest available exit' - whilst holding your breath.
I envy your capacity and wish you luck !
Lip service has been paid to realistic HUET training since day one.
Can I suggest that it is not the pax who, when they

"find yourselves up to your oxters in salt-water, you're on your own"

but the ill-equipped, minimally-trained pilots?

As you might have noticed -vast majority of Safety Review is not about preventing the crash/ditch but about survivability.
Anything in there about increased 'mandatory' flying training, improving monitoring skills.
Always laugh when I read that the ADF is preferred to my gps tablet and that crew EBS could be a 'snag hazard'

Heaven help us - or perhaps the CAA?

[jimf671]

... ...they've all been trained and information on system is plentiful. ...

I think you need to check your facts.

[Democritus]

Lip service has been paid to realistic HUET training since day one.
Can I suggest that it is not the pax who, when they

"find yourselves up to your oxters in salt-water, you're on your own"

but the ill-equipped, minimally-trained pilots?

Agree with that first sentence EESDL. I flew as a pilot on the North Sea for 27 years from 1973 until 2000 and on only one occasion did my various employers require me to take part in HUET training. It was entirely voluntary otherwise.

[diginagain]

@EESDL - I'm a passenger, albeit one with a thousand hours or so twin turbine helicopter.

I have some sympathy for the plight of the pilots who seem so ill-equipped, but it must be down to you as a collective to address those shortcomings. I have to wear PPE - and any safety professional will tell you that PPE should always be the last resort - as a result of events where the aircraft has ended-up in the oggin. I cannot speak for my colleagues, but I travel with careful consideration of where I am, and what I might need to do if it becomes necessary to escape.

[EESDL]

unbelievable - been flying for over 30-years but relatively 'new' to NS flying - find it absolutely incredulous that not all passengers have access to any form of EBS. Packed in with interlocking knees etc etc anyone in the back without EBS or direct access to escape has my sympathy.
Well done CAA for realistically taking control back from numerous committees.

I took the advice offered here and asked around - beggars belief that, as a passenger, it is left to your employers' Risk Assessment whether or not you have a re-breather!! Did that assumption thing as our pax are so equipped.
Looks like 'we' have been very lucky not to have lost a greater number of pax. Money talks I guess -p even though we are talking miniscule fractions of overall costs :-(

Would have thought that prospect of 'negligence' cases would have encouraged better care for their employees....

This is a rumour network afterall

[nowherespecial]

Somesuch,

Not bad research. I have my last Shell Aircraft audit report in front of me. I don't agree with it and think it might change but until I get audited again (end of the month), STASS is an open finding against us.

[212man]

NWS
Shell think Pilot STASS is a snag hazard.

I don't have your report to see what they say, but I suspect - because it's true, and I used that combination for 7 years - that they refer to the poorly incorporated pocket on the MK44 crew life jacket, which lets the bottle dangle very loosely. That nice Capt AB who runs his own company has designed a 'fix' for it: http://www.pose-online.com/index.php/online-catalogue?page=shop.product_details&flypage=flypage.tpl&product_id=3&category_id=3 with supporting comments from that website:

This meant that the top of the STASS unit fell away from the life jacket whilst the pilot was seated and hampered operations in the cockpit, at the same time it pulled the two stoles of the life jacket apart resulting in it being ill fitting

But, let's not let facts get in the way of a good slagging off.......

[JulieAndrews]

Wading through the review for a morning read during this remarkable extended period of UK sunshine (roll on Global Warming)


Lack of crew EBS make me smile - you need to use your powerful lobbying union to just mandate the provision of readily-available solutions for all crews .........oh yeah - that's right!

Can anybody direct me to the section which covers commercial pressure/working practices re maintenance & manufacture of these machines we take over large expanses of cold water?
Pilot Error has been the handy catch-all for majority of incidents/accidents as the poor old pilot 'touched it last' - but the fact that HUMS-equipped aircraft MGBs have 'failed' with catastrophic results and only very fortunate ditching environments has kept the toll lower.

No excuse for poorly-written SOPs and not using 'all available' aids but can't see how inadequate training and inappropriate use of autopilot can be used as a 'reason' for some of the decision-making processes witnessed in NS. Pilots have been trained to use the ap. Is the competition so fierce that one feels must push-on or is it over confidence in ones own ability after amassing thousands of hours in the rotary equivalent of 'Long Haul'. Going to be interesting to see the line of IF approaches at Aberdoom!


More IF training will only have an effect if already known procedures are followed/used.


Latest accident happened due to lack of 'monitoring' - it hit the sea due to timeframe of acting upon situation etc - is this a company problem with cockpit sops or just complacency? I understand their sops have changed but many people report not for the better - not sure what could be worse than what has already happened?


No doubt the law suits will roll and rightly so - the industry needs a kick as too many wake-up calls have seen the 'snooze' button hit by the industry!


Probably why one of the NS companies (with a seemingly disproportionate number of accidents) appears to be moving their assets into their Norwegian arm?

[John R81]

BBC News - Super Puma fatal accident inquiry: Findings due on Thursday (http://www.bbc.co.uk/news/uk-scotland-north-east-orkney-shetland-26522011)

Fatal accident inquiry to report Thursday 13 March

[helitech]

I would like to inform all of you about the Norwegian reaction to the review. Several organizations have posted their opinion online, and one of them is NHF.

Norsk Helikopteransattes Forbund (http://www.nhaf.no/index.php/component/content/article/32-lover-og-bestemmelser/lob-generell-info/71-cap-1145-wiping-the-problem-under-the-carpet)

The Norwegian magazine Teknisk Ukeblad, has also written several articles regarding the actions and recommendations in the report.

The last one contains comments from the Norwegian Civil Aviation Authorities.

(Translated with Google translate, for english readers)

http://translate.google.com/translate?hl=no&sl=no&tl=en&u=http%3A%2F%2Fwww.tu.no%2Findustri%2F2014%2F03%2F17%2Fvi-har-bare-en-dodsulykke-hvert-tredje-ar

and;

http://translate.google.com/translate?hl=no&sl=no&tl=en&u=http%3A%2F%2Fwww.tu.no%2Findustri%2Fmotor%2F2012%2F10%2F26 %2F11-av-12-helikopterulykker-i-nordsjoen-skjedde-i-britisk-sektor&sandbox=1

Do you accept that there are no real conclusions why helicopters end up in the North Sea, and are you really satisfied with actions only safeguarding people after they are swimming for their life in the ice cold waters?”

[HeliComparator]

Do you accept that there are no real conclusions why helicopters end up in the North Sea, and are you really satisfied with actions only safeguarding people after they are swimming for their life in the ice cold waters?”

Yes. No.

I think we (I) have said before that the concept of reducing pax numbers hasn't taken into account the effect on overall safety of stretching resources to accommodate the increased number of flights at short notice. However the intention, as JimL has indicated, is for this to be a short term effect pending the Cat A devices. So I guess we have to keep fingers crossed that we get through that period without a consequential accident. I know from practical experience that the first thing that suffers at such times is training. Of course it will continue to meet the legal requirements but it will be cut to the minimum and messed around (eg cancelled at the last minute, rescheduled repeatedly until checks actually run out etc, and generally devalued) in order to meet the line flying requirements.

I agree that the reasons behind the repeated crashery have not really been addressed. As you link suggest, maybe it is a cultural issue. I suppose from the UK CAA's point of view, addressing touchy feely cultural issues is really difficult, whereas slapping in some new rules is easy, and as usual they have to be "seen to be doing something". Of course as you suggest, most people would rather not end up swimming around in icy waters and it will not be too much consolation that they are always next to a window or have a breathing device.

This process just goes to reinforce why an independent enquiry is needed since only that has the chance of addressing cultural issues endemic in the industry, as was the case with Cullen.

[Boudreaux Bob]

Pilots and Mechanics can always find a way to put a Chopper into the drink. Nothing really changes over the years as the same old causes for crashes keep happening over and over. Pilots aren't very innovative in that they cling to the same old proven ways of tearing up helicopters.

Here in the GOM we don't change the way we do things much even though we are going much further out. The FAA doesn't care. The Oil Company doesn't care.

We did make a lot of changes a while back that has cut down our accident rate.

It sounds like you guys on the North Sea are where we were several years ago.

Our accident rate had gotten bad and our safety standards had slipped.

We changed then and maybe you need to change now.

The it will be our turn again but I bet we have to lose a few Choppers first.

[tottigol]

Whadd'ya change Boudreaux?

Do you guys wear exposure suites in Winter? Even GoM water temps drop in the 40s.

Do you fly only in twin engine helicopters? Ask RLC, PHI and ERA pilots.

Do you limit the size and weight of your duffel bags so that the helicopter companies do not need to use passenger seats for your VCRs, work boots, helmets and stuff even though you always go to the same place week on and week off?

Any of you guys drop his weight below 300 lbs?

Are you organized in Labor Unions that force the OGP employers to act on safety standards like in the North Sea?

What did you change in the last 30 years?

[Boudreaux Bob]

Check the accident Stats....and there's your answer.

You don't need a bunch of feather bedding Union members or fancy uniforms to get the job done.

Compare the accident Stats to the British North Sea over the past few years.

We may be more casual and far less burdened by Rules and SOP's....but the Oil flows.

[tottigol]

Oh yes? It doesn't seem so.

HSAC > Statistics (http://www5.verticalgateway.com/hsac/Statistics.aspx)

[AnFI]

wow - all those things they didn't do and it still doesn't make any difference, maybe the UK is 'barking' up the wrong tree?

[Tomcat01]

Sure, they are barking up the wrong tree! Why does not the Civil aviation authorities in UK want to check the cultural differences between UK and Norway?
If the helicopter companies, rules and regulations, operation procedures and the equipment are the same, why do the major part of the accidents and incidents happen on the UK side?
There must be some diffenences in operation?
From a flight safety perspective, I mean the review and it's recommendations and actions are far to focused on the reactive side. What about trying to prevent crashes to happen!

[Kawijet]

Hello Guys,

My 2 cents for what its worth...
I am not a pilot (but have 20hrs on my PPL) but I have worked offshore for 7 years.
These CAA "new" regulations are pretty amusing as most of them are already in force. I think they are trying to make it look like they are doing something about safety when really doing nothing.

First off the sea state of 6m is already in force for a majority of platforms/rigs. It is monitored by the standby vessels. The ONLY reason its a 6m stipulation is so that they can safely launch their Fast response crafts should a chopper ditch. It has nothing to do with the helicopter directly.... (So the CAA have jumped on that one to make it look like change)

Secondly the EBS systems we use are "Hybrid" systems which consists of a bag on your chest that you have to inflate with a single breath of air before the chopper turns turtle. However, they also have a small cylinder of oxygen that will also fire into the bag once submerged - there is also a safety back up pull chord to manually fire the oxygen if necessary. Because of this they ARE class A equipment! (Class A meaning they CAN be deployed under water if you fail to get a breath before the chopper turns over.) Yet another CAA "improvement" that already exists... spot any patterns?

The size restriction is a tricky thing to enforce - I struggle to see how they could effectively police that one without strolling into discrimination teritory. After all we are not just talking fatties here - Well built guys will struggle to comply also (Luckily I am neither).

So as for the 2 points raised above its nothing new.

[Tomcat01]

Agree with you Kawijet!
But why does not the CAA try to identify the cause of all the accidents?
Are they afraid what they will find, or do they just don't want to know?
As a general view, I see this review just as a action, to calm down the masses. We all know that people was protesting heavily, after the last ditching. So the easy thing to do, is to try to come up with a review with actions who seems trustworthy to the normal passenger (and his relatives).
And I think that this is the result of this review, more or less.

[Kawijet]

The CAA do know the causes of all of these accidents as they are looked into in quite some depth by the AAIB. The accident reports are available for anyone to read online.

The CAA is being forced to make a change by the Unions (who really have no clue about the aviation industry) and realistically there is no changes to be made that will really make any significant difference as far as safety is concerned. So they took the step of looking at a variable that does affect the likelyhood of escape - the size of the workforce! (And quite right too).
Its now quite amusing that the Unions, who are set up to protect the interests of the workforce, are now potentially putting their workforce directly in the firing line should a size restriction be enforced.

So you are correct Tomcat - I think this is a shrewd move by the CAA, just an action to calm them down a bit.

Maybe in future the Unions should keep their heads down and mouths shut instead of trying to judge the aviation industry by its own standards.

[Offshorebear]

As of 1st June we go from 6 flights a week with max 19 pax each way to 8 flights a week with max 13 pax each way so still move 10 pax less despite the increased flying hours.

No idea what the numbers crunch to from an overall risk perspective but if you are flying more flights I suspect it must go up ?

I think we all fully appreciate that they had to be seen to be making an intervention to improve but even with all the changes being implemented there is still no guarantee everyone will survive in the event of a crash / heavy ditching anyway.

I await with interest how they will manage the pax size issue when that one comes into force ..............

[DOUBLE BOGEY]

Offshore bear - if money was no restriction PAX would be issued with a one piece streamlined suit integrated with life jacket, beacon and SCUBA kit including a full face mask tucked into a chest pocket.

such equipment provide ensures the PAX has vision, air and no snags. He is able to select a suitable exit and wait for it to clear of other PAX before he uses it. His size is now no longer a primary factor in his survivability.

I am talking about a properly pressure balance demand valve that will work at depth. A face mask with integrated self purging valve. This is simple and easy to provide but costs a bit more than the current re-breather bag that is not pressure balanced.

The CAA are using the seating restriction to force Oil Companies and operators to properly address the safety provisions for PAX. They are firmly on your side.

[ericferret]

http://www.oilandgasuk.co.uk/cmsfiles/modules/publications/pdfs/HS027.pdf

This report has some interesting comments on the safety of offshore helicopter operations.
It also looks at UK operations and North Sea ops as a whole.
During the period covered 1981/2010 the UK fatal rate is comparable with other North Sea operations and the non fatal rate is about half.


"There is a long held perception by the workforce that UKCS offshore helicopter operations are a “high risk
mode of transport”; this is not matched by the statistical evidence. This led to HSE commissioning and
publishing the initial “Safety Record Report” in 2003 to gain a better insight into offshore helicopter risk,
including available safety performance data and the criteria used to measure it. This current report published
by Oil & Gas UK simply updates the original “Safety Records” to the end of 2010.
The purpose of this study is to provide an accurate historical safety record for (the) UK."

[gasax]

The report does indeed give details of the safety data from 1981 to a date before the recent spate of accidents.

UK Oil and Gas have been keen to publicise the 'improving helicopter accident rate', until the data showed that was not the case. As with all statistics the detail is the critical aspect. Choose your data set and many things can be proven. Data back to 1977 has frequently been used to demonstrate the trend mentioned above.

A couple of points worth noting. All North Sea data would not unnaturally include the UK. Thus any differences would be partially masked by that inclusion - any differences would be partially from the UK plus the rest rather than directly against the 'rest'. So the data being presented is not a true comparison. For that you need the direct Norway - UK comparison.

Even here you need care as the EC225 shaft failure might have occurred in Norway or the UK as it is notionally a parts related failure - although again there were a lot of human factor elements in failure to deal with the defect.

But if the accident rate from one side of the North Sea to the other is so different luck or mis-fortune over more than 15 years seems a poor explanation.

[Boudreaux Bob]

If a Statistical analysis is going to have any reliability at all, it must include data current right up till yesterday evening. Cutting off a few Years at this end fails the "Smell Test". Including Data from Day One of North Sea Operations is valid so long as comparisons use similar Data derived from similar periods of time.

I can see where omitting the Loss of a Rotor Head and a CFIT crash that killed four people might skew the Safety Stats in a more favorable direction than if they were included (and I am just a Dumb Ass Helicopter Pilot).:=

[jimf671]

... so still move 10 pax less despite the increased flying hours. ....



It is going to be interesting observing how a second summer of reduced maintenance levels, unaddressed mooring issues, increased overstays and so on will influence safety overall. Maybe there will be a thread about this in 2024.

[Variable Load]

second summer of reduced maintenance levels, unaddressed mooring issues, increased overstays

Err, what? You are talking a language I don't understand - mooring issues, overstays......!

More flying hours = more maintenance, not reduced maintenance levels.

[212man]

VL,
I assume he is referring to the platforms, in which case he has a very valid point.

[Tomcat01]

Someone hit the sweet spot right now. Reduction in pax in the cabin will for sure result in more flights. More flighthours is equal to more accidents and incidents if you look at the statisics worldwide (helis, fixed wings etc).
But...
There are no really good replacement for helicopter offshore transportation, in regards to getting people offshore and onshore again, if you don't want to use weeks transporting people. So it will be a bad alternative to just let them sit on the ground to prevent accidents and incidents.

Also, when did a helicopter in north sea operation last ditch because it was fully loaded with pax? The actions and recommendations in the CAP 1145 safety review, does concentrate on preventing people from dying after the ditching, but I think the primary focus should be preventing ditching at all!
The review also state that the statistics available is not significant. Okey, but it is all we have. Should we just sit down and wait for more statistics, before we act?
And in regards to unions and relatives speaking up after horrible accidents, the stakeholders of professional aviation industry, should not accept the CAA's attempt to silence the masses, by producing a review with such shallow content.
But if you look between the lines, it's really easy to explain. There have been to many accidents and incidents for british operations the last years, and people have been feeling bad after the loss of their loved ones, so a action needed to be performed. And performed really fast.
Because of this, it's easy to make a review close to what people want to hear, but not to dig to deep into the real problem.

If the CAA really would find the cause, the question should be really simple:

There have been more accidents in British operations than in Norwegian operations for the last years. Of course some of them could have happened in Norwegian operations, but they did not. WHY?
If they could find the answer to that question, and implement actions and recoomendations mitigating the reason I think this would impact the flight safety in a more serious way than recommendations and actions from CAP 1145 does!

[Noiseboy]

According to the document passengers will need to be sat next to "emergency exit push out windows" to be carried. The small windows in the L2 and all the windows in the S92 are not big enough to be classified as emergency exits, just escape windows. The plug doors on the L2 are emergency exits, as are the 4 emergency exits on the S92. The document uses the phrase above only mentioning push out window emergency exits.

Does the document intend to mean pax sat next to any push out window, or any emergency exit or any of the above? It will make a dramatic difference to the numbers carried.

[DOUBLE BOGEY]

Tomcat - the CAA requirement to be either, sat next to a push out window OR be equipped with proper breathing equipment is designed to force stakeholders to address the safety equipment for offshore PAX.

If the Oil Companies and Operators decide simply to mount more flights, and therefore increase a perceived risk in doing so, it is juxtaposition to the overall goal. The seating restriction is, in effect, an alleviation to reduce risk to passengers in the short term allowing the Operators the time to research, source and procure better breathing equipment.

The UK CAA investigated the differential between both NS sectors. They could not identify any real differences in the Operations. Bear in mind the Helicopter Companies operate on both sides of the divide. However, this assessment continues by many stakeholders in an attempt to find something tangible that might make a difference.

I agree though with you that all of this, although essential, is secondary to the requirement to do everything possible to stay out of the sea.

Hope this helps.

[Tomcat01]

Let there be no doubt that the actions and recommendations concerning safety after ditching may be good in some situations.

I'm trying to highlight why the review does not look for a root cause for accidents and incidents.

Regarding the differences between UK and Norway, the CAA was not able to identify any differences. Yes, the review states that the operators, equipment, regulations and procedures are the same.
But as I have said earlier, the major part of the fatal accidents have taken place on the UK sector. Why? If everything is the same, why does it happen to UK operations? Culture diffenences?
And just for info; here in Norway the stakeholders of the industry are not satisfied with CAP1145.
Operators, pilots, technicians, pax (offshore workers), safety advisors and so on. The are skeptical to the result of this review. Basically because the review is written and investigated by a subjective part, and because it contains no "vision zero". As said earlier, the major actions and recommendations are reactive after an accident, but there are very few actions to prevent the accident to happen.

[Kawijet]

Double Bogey - Category A breathing aperatus is defined as a system that can be deployed under water. The Hybrid system we use in the North Sea CAN be deplyed under the water if necessary - so the new regs dont actually mean anything in my opinion. It depends on how they actually decide to class the Hybrid system because at the moment (according to their own literature) it is Class A - but they dont say that.... Probably to make it look like they are making steps to change when they are really not.

[jimf671]

VL,
I assume he is referring to the platforms, in which case he has a very valid point.

Correct. Nobody flies out there without a good purpose. When places are tight, and this has often been the case since, ooh, around 22 Oct 2012, somebody is going to get bumped.

It is not normally going to be owner/operator crew/drilling/production guys. And it's not going to be the cook. :ok: Much more likely that it is going to be the folks who are involved in periodic maintenance and inspection.

"We need this inspected, but it doesn't have to be THIS week." That's fine this week but what if this stumbles on in one form or another for a year and a half and then gets worse?


Declaration of vested interest.
Getting bumped a lot. :(

[Tomcat01]

New post from the Rigzone magazine: RIGZONE - CAA Helicopter Safety Timeline Criticized (http://www.rigzone.com/news/oil_gas/a/132484/CAA_Helicopter_Safety_Timeline_Criticized)

[HeliComparator]

I see the CAA have changed the dates for implementation of the class A rebreathers so that non-window seats can be occupied until Sept. Very sensible, to avoid reduced safety from trying to stretch resources to out on more flights.

A bit of brinksmanship going on perhaps?

[jimf671]

CAA announces changes to timescales for Offshore helicopter safety measures | CAA Newsroom | About the CAA (http://www.caa.co.uk/application.aspx?catid=14&pagetype=65&appid=7&mode=detail&nid=2358)

[EESDL]

I guess the good news is that EBS for all on board has been brought forward to next year rather than 2016......

[cyclic]

You think the crews will have a useable EBS in place, be trained etc by January 2016?

[EESDL]

I will be;-) Indeed I might just pop off to the local scuba shop and buy myself a HEED3, pof to train with and use - no great mystery to it - just money.
Have to use that FRE on something.

don't tell me CAA are going to have to draw another line in the sand........

[cyclic]

Yep, and carrying it in your company's aircraft will be illegal. We all know that this was possible years ago but it costs money and no crew have drowned...yet.

[EESDL]

Ha! Classic! I'll take my chances thanks ;-)
My own risk assessment overrides that of an accountant - especially as their office is on dry land and mine is shuttling around at night (do I put a LOL in here as well?)
Strikes me that people try to make this job too complicated !
All this re-drawing of lines in the sand reminds me of Gadaffi with his various ultimatums - we laughed at him then and I imagine some are smirking at the CAA now with their attitude - same attitude which has got us in this situation in the first place.
Great news that all to get a viable ebs in near future.......

[212man]

I guess the good news is that EBS for all on board has been brought forward to next year rather than 2016......

Not quite as per their latest SD:

....the all occupants requirement remains as 1 April 2016 which in effect means that the crew will also require EBS by then
http://www.caa.co.uk/docs/33/SafetyDirective2014001.pdf

[cyclic]

So we are still nearly 2 years off getting EBS. We are next to an exit which you can only hope has not become bent or buckled and will still open/jettison. STASS is available now, the courses are available now, the jacket stowage is available now, why can't the companies start putting the crews through on renewal of their 3 yearly survival qualification?

[HeliComparator]

So we are still nearly 2 years off getting EBS. We are next to an exit which you can only hope has not become bent or buckled and will still open/jettison. STASS is available now, the courses are available now, the jacket stowage is available now, why can't the companies start putting the crews through on renewal of their 3 yearly survival qualification?

Could you remind us how many N Sea accidents there have been where having STASS for pilots would have made any difference? Once you have done that, you will probably have answered your own question.

[Boudreaux Bob]

HC,

Many Years ago the US FAA was convinced by an Airline that having to meet Over Water Survival Equipment Requirements on New York to San Juan, Puerto Rico passenger runs was un-needed as there had never been a ditching or any emergency that could have caused a ditching and the routing took the aircraft only about an hour offshore.

The FAA agreed, the Airlines removed all the Life Rafts and Jackets. That allowed them to top off with added passengers.

Two weeks later, a FE managed to shut down all three engines on a Boeing 727 by mis-managing the Fuel System. Fortunately, the Crew managed to figure out what had happened and were able to get the Engines re-started before hitting the Water.

Your kind of Logic, similar to the concept of "Very Remote Probability" can have some serious repercussions when the Holes line up on the proverbial Cheese.

[cyclic]

HC

We've been here before. My view of safety is proactive not reactive. Just because it hasn't happened doesn't mean it won't. STASS has been used by the military on a few occasions and it has saved lives. The maritime military world isn't a great deal different to the North Sea. A ditched aircraft with a twisted frame, your door won't jettison, the aircraft rolls over, you have to get out of the cabin. Try doing that on one breath. I have used STASS and know that I would rather have it with the option to plan my escape. In the big scheme of things it doesn't cost a lot. For those who don't want to do the training or can't do it then they can carry on without it. Most objections to STASS centre around the training, but as it used to say on the poolside wall at Yeovilton, "self determination now!" One life saved is worth the investment.

[Boudreaux Bob]

If this can be done for a Pressurized Jet Aircraft....why not for a helicopter and make it a jettison able escape window as well. Time to think outside the box maybe?

EBACE: Fokker proposes giant window to Boeing Business Jets - 5/21/2014 - Flight Global (http://www.flightglobal.com/news/articles/ebace-fokker-proposes-giant-window-to-boeing-business-399588/)

[HeliComparator]

BB and cyclic. Of course one should address known possible survival issues following ditching, however one should also keep in mind a sense of priority. Surely it is far better to concentrate on issues that are known to have caused fatalities and likely to do so in the future, rather than put efforts into the "remotely possible". But instead of concentrating on pilot competence issues, which seem to be a recurring theme in many loss of life accidents and "near misses", you are banging on about STASS. Is it just a smokescreen?

[212man]

But instead of concentrating on pilot competence issues, which seem to be a recurring theme in many loss of life accidents and "near misses", you are banging on about STASS. Is it just a smokescreen?

At least they are not banging on about side mounted floats.....:ugh:

[Boudreaux Bob]

Seems you are banging on about something that has never been fixed in the history of Aviation. Pilot's are not very clever people as they continue to kill themselves and other people while destroying aircraft in the same old tried and true methods.

Since we have had questionable success in avoiding the need for Life Saving equipment like Rafts, Jackets, Exposure Suits, Sarbe's, Epirbs, Jettisonable Windows and Doors, safety harnesses, In Floor and Exit Lighting, and all sorts of other useful gear......why not simply accept that Breathing Gear will also save Lives when that fateful day or night happens and add that bit of kit to the long list of improvements made so far?

[Treg]

Question for all

If it was your child/partner sitting in a non-window seat of a full machine would you prefer them to have a compressed air escape set including a demand valve, or a rebreather?

[obnoxio f*ckwit]

I would prefer them to have whatever gives them the best chance of escape. If that bit of kit happens to be a re-breather, then great. If it's compressed air, then that's great too.

[Boudreaux Bob]

Norway differs with UK CAA answers.

Norway shuns UK offshore helicopter safety rule changes - Oil and Gas News (http://www.oilandgaspeople.com/news/928/norway-shuns-uk-offshore-helicopter-safety-rule-changes/)

[GenuineHoverBug]

I do not think this article gives a good representation of the official Norwegian view. What has been said earlier is just that CAA-Norway does not agree 100% with everything in the report. And that the actions and recommendations need to be reviewed before a decision is made on what to do.

The apparent lack of full support and enthusiasm for the actions may be because:


some have already been implemented or tried before
some are not relevant
some are probably too complicated/huge for a small authority like the Norwegian to take on
slightly different views with respect to where the highest risks are and how to treat them
last but not least, there is no feeling of urgency on the Norwegian side. Could it be that the lack of accidents has given us a (false) sense of safety - and that a touch of complacency has set in?

[Brian Abraham]

Transport Committee - Second Report - Offshore helicopter safety

House of Commons - Offshore helicopter safety - Transport Committee (http://www.publications.parliament.uk/pa/cm201415/cmselect/cmtran/289/28902.htm)

[satsuma]

A full independent public inquiry into offshore helicopter safety, prompted amongst other things by a failure to acknowledge the role commercial pressure plays in impacting safety related decisions.

How long have they got?

[Self loading bear]

Contrary to what Kawijet posed on 5 april on this thread the current re-breathers are NOT Cat. A.

I personnally already questioned very much if one would be able to apply the current re-breathers under water and clear the water out of the submerged mouthpiece/valve while pushing the valve to transfer to re-breathing. This would spill quite an amount of air from your lungs which would therefore not be available for re-breathing. (I know the unit itself also "adds" 4 liters air from a presurized bottle but overall i think you would lose too much air by clearing).
At least this has never been teached to me this way during training. During my last refresher, I did got some water in my re-breather and I can tell you that is quite frightening if you gulp water instead of air!
Not to mention that during my first training I did not gently squeezed the red knob but pulled the complete valve from the mouth piece.
Leaving me with an forced open mouth (by the mouth piece) in an ditching helitrainer!
That was due to a non secured hose connection on the trainer re-breather but I imagine one could pull it off under real stress as well.

Anyway the solution has been approved, announced and is now being rolled-out:
From Helihub 15th July:
EASA and UK CAA approve world?s first Category A Emergency Breathing System | Helihub - the Helicopter Industry Data Source (http://helihub.com/2014/07/15/easa-and-uk-caa-approve-worlds-first-category-a-emergency-breathing-system/)

Note worthy is the sequence of roll out for the UK as announced by Survitec: Sumburgh, Norwich, Aberdeen.:confused:

Today the company I work for (we are 3rd party contractors) got an announcement from Dutch Shell (NAM):
New Cat A Emergency Breather System will be implented for flights from Den Helder 1st September 2014! So even earlier as in the UK!!

1,5 hour dry training sessions will be made available at Den Helder Airport from 28th of July only for the month August.
These training sessions are Free (course paid by Shell)
Hours presumably to be paid by contractors as it is outside check-in hours.
2 to 4 training sessions a day to match departing or arriving rotating crews.
Non rotational crew to be planned-in where possible.:confused::confused::confused:
From 1st September only training in the certified training centra,
From another source I already heared that they will NOT be able to meet the start of training for next Monday July 28th.

Questions on which I hope to get answers soon:
- Only Shell on Dutch side? (I haven't heared from my other clients/
O&G companies yet and the training session roster which I have seen
seems to match only Shell/NAM flights from Den Helder)
- When will training be available at training centres and what will be training costs?

Cleverly arranged during Dutch holiday month August.
How should I get al my guys through training?
We have little offshore work coming month, but the more for september!

In the announcement was a link to a very clear video from Survitec.:D
http://www.stepchangeinsafety.net/newsevents/news/news.cfm/newsid/162 (http://www.stepchangeinsafety.net/newsevents/news/news.cfm/newsid/162)

I wonder how they will fill in the remaining 70 minutes of the training session.:confused:

SLB

[diginagain]

SLB - have you tried contacting NOGEPA for advice? NOGEPA (http://www.nogepa.nl/en-us/)

I suspect that the UK training-providers will be maxed-out at the moment as they try to process those of us bound for the UKCS.

I wonder how they will fill in the remaining 70 minutes of the training session?

I'll let you know on Monday. If the fog lifts.

[Self loading bear]

Diginagain,

Still a lot of fog since one month ago?
I did my training last week at Den Helder airport.
Actually quite a good training.


Verbal instruction in Dutch supported by power point presentation.
Video (Same as linked on this thread before) (in English)
Dry training



With 11 participants we were ready in 1 hour. We all think we are generally better off with this new CA-EBS.

One disadvantage not mentioned in the video but believed to be a point by all the participants:


The possibility of un-observed loss of air when the purge button is slightly pushed. This might happen in a cramped heli when you fall asleep.

It was hilarious that most were not afraid that it would happen to them if there would be a ditch. They were more worried that their relief colleague coming on board with the helicopter would fall asleep and empty the bottle and that they would be forced to stay on board the platform with no spare life-jackets or spare bottle available!!:O

I already had put the question out to NOGEPA before you suggested.
They have responded:
For the moment it is only NAM/SHELL (with DanCopter) who have chosen to make the change for all Dutch NAM platforms.
They expected that Wintershall and Centrica might be the first ones to follow as they too have some operations which are flown from both sides. But they use CHC and NHV. I believe the operators who use CHC have some kind of helicopter sharing agreement which makes it more difficult to change over?
Nothing formal and no signs that Dutch government will take over this to be enforced on Dutch side as well.

The courses are now also given by Falck and STC-KNRM in Netherlands for € 75.

Hats-off for such a quick implementation.
When I wrote my previous post on this thread I did not know that training in the UK was already in full swing. I thought they only just had the new approved device. In mean time about the number of the core crews of UK personnel has had the course.

http://www.offshoreenergytoday.com/26100-offshore-workers-trained-with-emergency-breathing-system/ (http://www.offshoreenergytoday.com/26100-offshore-workers-trained-with-emergency-breathing-system/)

How much contractors/non-core-crew would there be in UK? 50.000-75.000??
Should be do-able with on-going training rate.

SLB

[diginagain]

Still a lot of fog since one month ago?
Apologies, got fogged-in and only got the course done last Sunday evening. Scheduled for two hours, the 18 of us were done and dusted in 50 minutes, including admin and wash-up. No dramas; a short video presentation, intro to the kit, a bit of famil with pre-use checks, and finished with donning and using the second-stage.

Loss of capability due to inadvertant purging was covered - "Don't do it!" was the response. We'll see. Given where the second-stage sits it shouldn't be an issue. More worrying would be pax pressing the purge just to check that it works!

How much contractors/non-core-crew would there be in UK? 50.000-75.000??
OGUK figures show around 32,000 offshore in the UK. http://www.oilandgasuk.co.uk/employment.cfm

[malabo]

So in the Netherlands and UK your EBS training can be completed in a classroom without in-water pool training?

As an experienced diver, the upside down experience in cold water without a mask or nose clips was a surprise that I'm thankful I got to try in a controlled environment.

Doesn't Cougar provide all passengers with diving masks? Are the NS pilots going to stash one in their flight bags?

[diginagain]

So in the Netherlands and UK your EBS training can be completed in a classroom without in-water pool training?
We'll be given wet-training with the new EBS and lifejacket when we next do our survival refresher course. There simply isn't the capacity to get everyone dunked with the new kit within the timescale we've been given.

[terminus mos]

We'll be given wet-training with the new EBS and lifejacket when we next do our survival refresher course. There simply isn't the capacity to get everyone dunked with the new kit within the timescale we've been given.

Which really shows that it's a knee jerk reaction which has been ill thought out and poorly planned.

[212man]

As a non-diver who trained to use the HEED/STASS and found it a very uncomfortable learning process, I cannot for one moment imagine anyone using a SCUBA-type appartus for the first time, in anger, following a classroom briefing!

[Boudreaux Bob]

Despite being a very experienced Diver but not current at the time of the training in the pool....it was not exactly a piece of cake. No big deal just dropping down and breathing while up right but upside down with legs hung over the side of the pool edge was a bit of a trick to cope with.

Now as to trying that without being an experienced Diver, for real in cold water, following a hard impact....well at least your odds are improved but how much really?

In Pool training is a must!

[diginagain]

In Pool training is a must! I doubt that anyone would disagree. However, we've become so risk-averse that the in-pool training environment has become rather benign.

[Self loading bear]

Pool training

Nobody is allowed offshore without proper pool training.
At least in the Netherlands. We have done away with 72 hour excemptions.
The dry trainer CA-EBS is an add-on onto the rebreather training covered in Bosiet training.

SLB

[coatimundi]

But the EBS "training" is not very realistic, all it really shows you is how to put the thing on, and deploy it.

I did my last survival refresher in September 2013, therefore it will be Sep 2017 before I get a chance to try the EBS in an underwater environment (although I don't intend to still be offshore by that time!). That is a long time, and there are many of my offshore colleagues in a similar situation.

[diginagain]

Memo out today advising that a number of jackets have been returned post-flight with depleted bottles. Contents will be checked at offshore departure-point and if there are empty cylinders and no spares employees will be delayed offshore until they can be provided with a full cylinder.

[Langball]

Folks, may I ask how is the new EBS system working out. Apparently the 'mouth piece and nose clip' needs a bit of a re-design. I was speaking to someone who did the training and he said that the oval mouth piece is hard to grip and the nose clip gave him a piercing pain if he moved his head.

I just saw this on the internet https://falckebs.wordpress.com/ and the mouth piece looks a much better design. I thought that there was only one unit type available, but maybe I was wrong.

[EESDL]

Lines have to be purged before going into the boot so bottles will deplete - also, purging makes a great noise so helps to pass the time.......
Different degree of servicing and those whom have it in SNS seem happy enough. I suggest any niggles with nose clip being designed to suit maximum shapes will soon be forgotten when under water!
Atleast they have EBS - unlike the crew who will still suffer from 'cold shock' regardless of how big their escape door is ;-)

[Pi1ot]

The latest safety directive from the UK CAA is published here: http://www.caa.co.uk/docs/33/SafetyDirective2014002.pdf

According to the SD it is applicable to "All AOC Helicopter Operators Conducting Offshore Operations".
Does any of you know how the UK CAA plan to enforce this applicability after EASA HOFO regulation is implemented next year? According to CRD 2013-10, the new rule will replace all national regulation, and from my understanding it will also invalid this SD.

After the new regulation is implemented, operators from all EU states will be welcome to engage in UK offshore heli ops, and these will be under the oversight from the authority in their respective home states. I do not see how UK CAA can add any additional requirements like this in the future.

[squib66]

however one should also keep in mind a sense of priority

There were nearly 120 fatalities in the UK sector in 40 years. In justifying their directives on EBS and window size the CAA seem to have implied around 30% were people trapped in capsized helicopters.

The real percentage turns out to have been just 9%, 11 people, with just 4 in the last 20 years.

CAP1145 Helicopter Water Impact Survivability Statistics - A Critique (http://aerossurance.com/helicopters/cap1145-survivability-stats/)

The difference? The CAA included pax incapacitated on impact who were unable to escape and 20 tourists on the way to the Sillies.

Good to see the operators doing some operationally directed research: Helicopter industry collaborates on eyetracking research to enhance flight safety (Helicopterindustrycollaboratesoneyetrackingresearchtoenhanc eflightsafety)

[Bravo73]

Good to see the operators doing some operationally directed research: Helicopter industry collaborates on eyetracking research to enhance flight safety (Helicopterindustrycollaboratesoneyetrackingresearchtoenhanc eflightsafety)

Is this link that you meant? Helicopter industry collaborates on eye-tracking research to enhance flight safety | Vertical Magazine - The Pulse of the Helicopter Industry (http://www.verticalmag.com/news/article/Helicopterindustrycollaboratesoneyetrackingresearchtoenhance flightsafety)

[squib66]

Is this link that you meant?
Yes. Thanks.

[212man]

There were nearly 120 fatalities in the UK sector in 40 years. In justifying their directives on EBS and window size the CAA seem to have implied around 30% were people trapped in capsized helicopters.

The real percentage turns out to have been just 9%, 11 people, with just 4 in the last 20 years.

CAP1145 Helicopter Water Impact Survivability Statistics - A Critique

The difference? The CAA included pax incapacitated on impact who were unable to escape and 20 tourists on the way to the Sillies.


Quite. My personal view is that (sadly) the CAA may rue the day they enforced these devices :(

[zalt]

A derivative of the widely used military STASS system called HEUBA was introduced on the Canadian East Coast were it is being / has been used by passengers from Conoco-Phillips, Hibernian (an ExxonMobil JV), Husky, Suncor, Shell and Statoil for over 5 years.

[CG4A]

Correct, Zalt. This was in response to the Cougar accident and in my opinion, a good one. More expensive training, but vastly superior to those horrific re-breathers used elsewhere. I've used EBS in the military and commercially since 1989 and feel quite uncomfortable over cold water (or warm, for that matter) without it. The pax seem to appreciate it as well.

[squib66]

My personal view is that (sadly) the CAA may rue the day they enforced these devices

Why? If Canada and the Military are using them would it not reflect badly on CAA (and the oil companies) 'next time'.

[212man]

Why? If Canada and the Military are using them.....

Firstly, they are not 'using' them, they are 'wearing' them, which is an entirely different thing. Secondly, the training is superior and not classroom based.

The idea that somebody who is not a sports diver, will take a mouthpiece and purge it and then start breathing underwater for the first time, ever, in a real emergency, seems very far fetched. I say that as someone that has never used SCUBA gear and has done HEED/STASS training.

[[email protected]]

Having consulted with a world-leading expert on water survival at a SAR symposium a few years ago - the mouthpiece needs to be in place before you enter the water since the human 'gasp-reflex' will likely render you unable to purge the mouthpiece if you wait until after water entry and the colder the water, the worse it gets.

Purging upside down is an art and needs to be practised in a pool not a classroom.

[squib66]

I was under the impression in Canada a SWET chair is used to practice HEUBA deployment underwater at a 'safe', shallow depth but in the UK the oil industry training body has removed all EBS HUET runs from their CA-EBS standard harving the total HUET runs too. Considering the AAIB have already queried the training for the earlier rebreathers in an interim Sumburgh report one can only hope they opine on EBS training in their final report.