Has ATSB gone totally mad?
Join Date: Feb 2001
Location: They seek him here, they seek him there
Posts: 141
Received 0 Likes
on
0 Posts
Easa Cs-25
Further to the above post and in the spirit of 4 dogs I went and found the applicable quotes from EASA CS-25 (current). The bolding is my own.
EASA CS-25 AMC 25.1581 - 6 (c)
And EASA AMC 25.1581 - 6 (c) (4) (ii)
EASA CS-25 AMC 25.1581 - 6 (c)
c. Operating Procedures Section. The Operating Procedures Section of the AFM should contain, as a minimum, the essential information, peculiar to the particular aeroplane type design , that is needed for safe operation under normal and other-than-normal conditions. Procedures not directly
related to airworthiness, or not under control of the flight crew, should not be included in the AFM. A notation similar to the following should be placed at the beginning of the Operating Procedures Section.
The operating procedures contained in this manual have been developed and recommended by the manufacturer and approved by the EASA for use in operating this aeroplane. These procedures are provided as guidance and should not be construed as prohibiting the operator from developing equivalent procedures in accordance with the applicable operating rules.
related to airworthiness, or not under control of the flight crew, should not be included in the AFM. A notation similar to the following should be placed at the beginning of the Operating Procedures Section.
The operating procedures contained in this manual have been developed and recommended by the manufacturer and approved by the EASA for use in operating this aeroplane. These procedures are provided as guidance and should not be construed as prohibiting the operator from developing equivalent procedures in accordance with the applicable operating rules.
(ii) Other Sources of Procedures Information. The flight crew of large transport category aeroplanes typically use other sources of operating procedures information other than the AFM. Examples of other sources of operating procedures information include manufacturer- or operatorproduced
operating manuals, Quick Reference Handbooks (QRH), System Pilot’s Guides and Emergency or Abnormal Checklists. For these aeroplanes, items such as cockpit checklists, systems descriptions, and the associated normal procedures should not be presented in the AFM if they are provided in other documents acceptable to the Agency. Normal procedures that are necessary for safe operation should be presented in the AFM, but the remaining normal procedures should be placed in the manufacturer produced FCOM (or other acceptable sources of operating procedures information).
The non-normal procedures section of the AFM for these types of aeroplanes should include, as a minimum, procedures dictated by the aeroplane’s system and failure modes, and may also include those emergency procedures listed in paragraph 6.c(5) of this AMC. Whenever procedures are provided in another source rather than the AFM, a statement should be placed in the appropriate
procedures section of the AFM referencing where the detailed procedures information can be found.
operating manuals, Quick Reference Handbooks (QRH), System Pilot’s Guides and Emergency or Abnormal Checklists. For these aeroplanes, items such as cockpit checklists, systems descriptions, and the associated normal procedures should not be presented in the AFM if they are provided in other documents acceptable to the Agency. Normal procedures that are necessary for safe operation should be presented in the AFM, but the remaining normal procedures should be placed in the manufacturer produced FCOM (or other acceptable sources of operating procedures information).
The non-normal procedures section of the AFM for these types of aeroplanes should include, as a minimum, procedures dictated by the aeroplane’s system and failure modes, and may also include those emergency procedures listed in paragraph 6.c(5) of this AMC. Whenever procedures are provided in another source rather than the AFM, a statement should be placed in the appropriate
procedures section of the AFM referencing where the detailed procedures information can be found.
4dogs/GaryGnu 1, Ledsled 0. 
Think outside the square. That is the way the world improves.
Ledsled, your hatred of everything Australian really is becoming tiresome. How dare the nutcase colonials even think of challenging the "authority" of the mighty Boeing and Scarebus.
Originally Posted by Ledsled
The Australian arrogance shines through in the said AOCM. Of course we know better than the manufacturers. I love the bit that says words to the effect that changes should not be made to CASA approved flight check systems ( the manufacturers --- [they really mean TC holder] ) on a new type until "---- adequate experience has been gained - for example, the aircraft has been in service for 300-400 hours".
Ledsled, your hatred of everything Australian really is becoming tiresome. How dare the nutcase colonials even think of challenging the "authority" of the mighty Boeing and Scarebus.
It is not illegal to do what what Jetstar did
Not quite what ATSB and Airbus think, is it, Airbus has been quite specific about the changes implemented by Jetstar not being approved by Airbus, Airbus certainly seem to think the have a say.
And CASA have said they knew nothing about the change.
My dear friend Bloggs,
Nowhere in my posts on this subject have I expressed a view (other than comments about certain statements in the CASA AOC Manual that are quite inappropriate in any regulatory or quasi regulatory document) other than the fact that there is a very serious legal disconnect, as I have already described.
And as has been supported by several poster, who understand the law, and its shortcomings.
As for "hating Australia" or whatever your words were, what a load of rubbish, but I have no time for those, here, who disparage what happens elsewhere, particularly the US, a country that has an air safety record head and shoulders above Australia.
We continually demonstrator that we do not know better than the rest of the known aviation universe ---- the safety outcomes are the best illustration of that demonstrable fact.
If we were halfway smart, we would be looking very closely at how and why the US produces a better air safety outcome, in each ICAO statistical category, than any other country, including Australia.
Even the oft quoted Australian claim that we have "never had a jet fatality" isn't quite true, but it sound good, just not really an ICAO statistical category.
Bloggs, I would doubt that even you would claim that we have the world's best aviation regulatory framework ---- or maybe you do think that??
Tootle pip!!
GaryGnu said:
Incorrect. Airbus FCOMs detail ALL normal and abnormal procedures including the procedures for Go Around.
(In case of doubt, I am quoting from personal experience of factory conversion in Toulouse in the mid-90's and subsequent thousands of Airbus flying hours).
GaryGnu said:
But, it is foolish in the extreme for any airline to vary a recommended procedure that has been detailed by the manufacturer without having said variation reviewed, examined and approved by the manufacturer. In this regard, Jetstar failed miserably and the event reflected upon Jetstar's Flight Operations Dept lack of effective oversight, knowledge and depth of experience at that time.
LeadSled has raised some very important inconsistencies in CASA regulations and management.
Airbus AFMs do not contain Standard Operating (Normal) Procedures for the Go-Around. By varying the Go-Around SOP an operator is NOT rendering invalid the certification basis for the aircraft.
(In case of doubt, I am quoting from personal experience of factory conversion in Toulouse in the mid-90's and subsequent thousands of Airbus flying hours).
GaryGnu said:
It is not illegal to do what what Jetstar did.
LeadSled has raised some very important inconsistencies in CASA regulations and management.
Join Date: Feb 2001
Location: They seek him here, they seek him there
Posts: 141
Received 0 Likes
on
0 Posts
AFM not FCOM
Flexible Response,
You are correct that the Go-Around SOP is in the FCOM. My statement was that it was not in the AFM. This is exactly as EASA, the cerifying authority, wants it. (See the extract from CS-25 above).
I agree with your view about the wisdom of the change as opposed to the legality.
Leadsled,
Where in the ATSB report does it say that the change to the Go-Around SOP is illegal?
Airbus may not endorse a particular change to procedures but as discussed above that does not necessarily mean an operator cannot change as desired. Whether that is wise or not is up for debate. I don't think the legality of it is.
There has been a campaign in certain sections of the media that Jetstar acted illegally on the basis that it changed the AFM. It did not act illegally because the SOP in question is in the FCOM not the AFM. The FCOM is considered part of the Operations Manual an operator is required to provide under CAR 215. Changes of the OM are not required to be approved by CASA and/or the OEM and/or the Certifying Authority.
At the time Jetstar was not regulatorily compelled to have a Safety Managment System in place. It did, but the SMS did not require any appropriate process around an SOP change. Once again, perhaps unwise but not illegal.
I actually agree with your general thrust that the Regulatory structure surrounding this is too complex. The Jetstar A320 case would be the perfect example. CASA should not be regulating the final operating procedures that operators use, rather the process that is followed to derive them.
You are correct that the Go-Around SOP is in the FCOM. My statement was that it was not in the AFM. This is exactly as EASA, the cerifying authority, wants it. (See the extract from CS-25 above).
I agree with your view about the wisdom of the change as opposed to the legality.
Leadsled,
Where in the ATSB report does it say that the change to the Go-Around SOP is illegal?
Airbus may not endorse a particular change to procedures but as discussed above that does not necessarily mean an operator cannot change as desired. Whether that is wise or not is up for debate. I don't think the legality of it is.
There has been a campaign in certain sections of the media that Jetstar acted illegally on the basis that it changed the AFM. It did not act illegally because the SOP in question is in the FCOM not the AFM. The FCOM is considered part of the Operations Manual an operator is required to provide under CAR 215. Changes of the OM are not required to be approved by CASA and/or the OEM and/or the Certifying Authority.
At the time Jetstar was not regulatorily compelled to have a Safety Managment System in place. It did, but the SMS did not require any appropriate process around an SOP change. Once again, perhaps unwise but not illegal.
I actually agree with your general thrust that the Regulatory structure surrounding this is too complex. The Jetstar A320 case would be the perfect example. CASA should not be regulating the final operating procedures that operators use, rather the process that is followed to derive them.
Changes of the OM are not required to be approved by CASA
Can you give me a refernce for the above assertion? The Sydney Air Transport Office certainly need to see it if that's the case!!!
Join Date: Feb 2001
Location: They seek him here, they seek him there
Posts: 141
Received 0 Likes
on
0 Posts
CAR 215
HL,
I cannot comment on your particular situation.
However, have a look at CAR 215. Nowhere does it say that the Operations Manual is subject to approval by CASA (unlike, for example, a Flight Check System as per CAR 232).
All that is required is that the OM be furnished to CASA (CAR 215 (6)), that it be revised from time to time in light of experience (CAR 215 (5)) and that CASA may direct that certian information be included, revised or varied (CAR 215 (3)).
Changes to an OM are not subject to approval by CASA under CAR 215.
CAO 82.0, 82.3 or 82.5, as best as I can tell, also do not require an AOC holder to seek approval for the contents of an OM from CASA.
If you can provide a reference to the contrary I will happily stand corrected, concede my error and be thankful for the anonymity of PPRune.
I cannot comment on your particular situation.
However, have a look at CAR 215. Nowhere does it say that the Operations Manual is subject to approval by CASA (unlike, for example, a Flight Check System as per CAR 232).
All that is required is that the OM be furnished to CASA (CAR 215 (6)), that it be revised from time to time in light of experience (CAR 215 (5)) and that CASA may direct that certian information be included, revised or varied (CAR 215 (3)).
Changes to an OM are not subject to approval by CASA under CAR 215.
CAO 82.0, 82.3 or 82.5, as best as I can tell, also do not require an AOC holder to seek approval for the contents of an OM from CASA.
If you can provide a reference to the contrary I will happily stand corrected, concede my error and be thankful for the anonymity of PPRune.
Last edited by GaryGnu; 13th Mar 2011 at 20:49. Reason: add references
