Australian Warbirds
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Leadsled ! - censored version.
Whoa – big subject, thanks Leadie. I was tempted to duck this and pass it off with a flippant remark or two. However, with the CASA gargoyles breathing down your neck and the internal malarkey – off the top of my old wooden head, as a discussion start point only:-
Crock 'o ****e; or, a bloody good idea ? My battered two bob's worth weighs in on taking a measured, responsible, outcome based approach. Accepting prescriptive, complex regulation will not get you there; you will however cover the well padded CASA arse by accepting it.
Take 'volunteers' for example. Father and son team, Dads going flying, Junior is going to do the hand start, or plug in and remove the ground power. I doubt anyone 'off the street' could amble airside and do it without an unacceptable risk level; so it becomes reasonable that a degree of training is required. Here is where the problem begins; in the "operations manual" AOC type of system, there needs to be a presciptive system for qualifying and certifying the trainer, that requires oversight to ensure the trainer is doing the right thing, then you need a system for recording and monitoring that. Then come the 'training' course syllabus, training, qualification and recording; all available for audit. Now if there is a problem, (real or imagined) at audit, is the whole AWAL outfit at risk? The short answer is Yes, under the proposed rule set.
Leadie – It's a big subject - I am not sure what procedures are currently in place for AWAL, but I think we can acknowledge that there needs to some form of control document; lets call it a procedures and policy manual (PM). The manual could be exactly that; to be a member of AWAL the procedures and policy must be complied with. Then, the PM could carry an outcome based policy section related to "Volunteers". The section could identify high risk volunteer tasks like hand starting and low risk tasks like removing the Minty's wrappers from the cabin.
The AWAL policy makes the 'operator' responsible for providing a training section for the 'aircraft' i.e. – Hand swinging for DH 82 – then for ensuring the 'aircraft' listed volunteers were, indeed trained and qualified. I don't believe they need to be 'employees'; but they do need to properly trained to avoid the dangers. This probably 'informally' occurs every time two people decide to go airside, like taking the kids into the hangar – my boys knew the rules by the age of seven. Formalise this and you have the basis for a safety training case.
I'll bet my hat that AWAL could run a hand swinging course, combined with hand signals and ramp safety course; take a day with a BBQ afterwards. Pretty certificate for the dunny wall, valid for 5 years.
In short, the Organisation needs a general policy and procedures manual which provides and expects a safety 'outcome', the aircraft operator provides type specific procedures. It may seem like a lot of work – but it beats, hands down adopting an AOC type of control.
Invoice for four pints following – two for the words – 'tuthers for sticking out neck.
Crock 'o ****e; or, a bloody good idea ? My battered two bob's worth weighs in on taking a measured, responsible, outcome based approach. Accepting prescriptive, complex regulation will not get you there; you will however cover the well padded CASA arse by accepting it.
Take 'volunteers' for example. Father and son team, Dads going flying, Junior is going to do the hand start, or plug in and remove the ground power. I doubt anyone 'off the street' could amble airside and do it without an unacceptable risk level; so it becomes reasonable that a degree of training is required. Here is where the problem begins; in the "operations manual" AOC type of system, there needs to be a presciptive system for qualifying and certifying the trainer, that requires oversight to ensure the trainer is doing the right thing, then you need a system for recording and monitoring that. Then come the 'training' course syllabus, training, qualification and recording; all available for audit. Now if there is a problem, (real or imagined) at audit, is the whole AWAL outfit at risk? The short answer is Yes, under the proposed rule set.
Leadie – It's a big subject - I am not sure what procedures are currently in place for AWAL, but I think we can acknowledge that there needs to some form of control document; lets call it a procedures and policy manual (PM). The manual could be exactly that; to be a member of AWAL the procedures and policy must be complied with. Then, the PM could carry an outcome based policy section related to "Volunteers". The section could identify high risk volunteer tasks like hand starting and low risk tasks like removing the Minty's wrappers from the cabin.
The AWAL policy makes the 'operator' responsible for providing a training section for the 'aircraft' i.e. – Hand swinging for DH 82 – then for ensuring the 'aircraft' listed volunteers were, indeed trained and qualified. I don't believe they need to be 'employees'; but they do need to properly trained to avoid the dangers. This probably 'informally' occurs every time two people decide to go airside, like taking the kids into the hangar – my boys knew the rules by the age of seven. Formalise this and you have the basis for a safety training case.
I'll bet my hat that AWAL could run a hand swinging course, combined with hand signals and ramp safety course; take a day with a BBQ afterwards. Pretty certificate for the dunny wall, valid for 5 years.
In short, the Organisation needs a general policy and procedures manual which provides and expects a safety 'outcome', the aircraft operator provides type specific procedures. It may seem like a lot of work – but it beats, hands down adopting an AOC type of control.
Invoice for four pints following – two for the words – 'tuthers for sticking out neck.
Last edited by Kharon; 11th Feb 2013 at 19:18. Reason: Adroitly avoiding the engineering questions -
Kharon,
Very interesting answer ---- because the AWAL does have a document called the ESAM, their self-administration manual.
In the original policy agreements with CASA, going back to about 2007, control of the operations of aircraft administered by AWAL was to flow from the SAM (now ESAM) , and enforcement would have been by withdrawing approval to operate.
Generally, an outcome based approach, and it complied with Bruce Byron's Directive 16, a document less than popular with a certain section of middle CASA.
Now we are to have an expensive and cumbersome Approved Operations Manual specific to each aircraft, mandated approved inclusions will undoubtedly grow like Topsy, as they have with current operations manuals. What is already required by Part 132 is bad enough. Elements in CASA seem unable to get their minds around the idea that repeating regulatory requirements in manuals will somehow improve compliance. I have never seen any believable evidence to support this approach.
That AWAL manuals will be "approved" and not "accepted" has some interesting ramifications for AWAL, particularly when it come to negotiating their next PLI insurance premiums.
Indeed, the proposed Part 132 very unwisely re-introduces liability issues for CASA that are explicitly excluded by present legislation --- why would anyone in aviation, including CASA, knowingly take on additional liability ---- I would think it is "unknowingly".
"Tweaking" Part 132 will not fit the bill, the policy behind the proposals is the core problem. The original policy agreements with CASA achieved the same objectives, without any of the presently proposed legislation, undermining the intent of a large slab of Part 21.
Tootle pip!!
PS: You have very thoroughly outlined the potential nightmare of accountability for training "employees", and Part 132 explicitly excludes volunteers, but the old adage:"If it ain't broke, don't fix it" is a concept unknown to the "born regulator".
Very interesting answer ---- because the AWAL does have a document called the ESAM, their self-administration manual.
In the original policy agreements with CASA, going back to about 2007, control of the operations of aircraft administered by AWAL was to flow from the SAM (now ESAM) , and enforcement would have been by withdrawing approval to operate.
Generally, an outcome based approach, and it complied with Bruce Byron's Directive 16, a document less than popular with a certain section of middle CASA.
Now we are to have an expensive and cumbersome Approved Operations Manual specific to each aircraft, mandated approved inclusions will undoubtedly grow like Topsy, as they have with current operations manuals. What is already required by Part 132 is bad enough. Elements in CASA seem unable to get their minds around the idea that repeating regulatory requirements in manuals will somehow improve compliance. I have never seen any believable evidence to support this approach.
That AWAL manuals will be "approved" and not "accepted" has some interesting ramifications for AWAL, particularly when it come to negotiating their next PLI insurance premiums.
Indeed, the proposed Part 132 very unwisely re-introduces liability issues for CASA that are explicitly excluded by present legislation --- why would anyone in aviation, including CASA, knowingly take on additional liability ---- I would think it is "unknowingly".
"Tweaking" Part 132 will not fit the bill, the policy behind the proposals is the core problem. The original policy agreements with CASA achieved the same objectives, without any of the presently proposed legislation, undermining the intent of a large slab of Part 21.
Tootle pip!!
PS: You have very thoroughly outlined the potential nightmare of accountability for training "employees", and Part 132 explicitly excludes volunteers, but the old adage:"If it ain't broke, don't fix it" is a concept unknown to the "born regulator".
Last edited by LeadSled; 11th Feb 2013 at 23:54.
OZ,
Good idea, and we should include the very adverse changes to Experimental as well, which, once again, sees Australia departing from long standing international practice, particularly US, where our present rules came from, more or less.
At lest the fracas has had at least a temporary result, CASA are now publicly saying the published draft regulations are just a consultation draft, which is not what the CASA representative at the AWAL AGM Part 1 said.
Not to be ignored is cost shifting, given the taxes we pay, directly (fuel levy) and general taxation, to fund CASA.
Some years back, Bruce Byron thought the Ag. operators were good candidates for self administration, and he was right.
The Ag, Association was not adverse to the idea but they, not surprisingly, had no interest in paying twice. At that stage, their combined fuel taxes were something like $900,000 a year, so their answer was, refund out fuel taxes, and we will consider self administration.
That is where the idea came to an abrupt halt.
Tootle pip!!
Good idea, and we should include the very adverse changes to Experimental as well, which, once again, sees Australia departing from long standing international practice, particularly US, where our present rules came from, more or less.
At lest the fracas has had at least a temporary result, CASA are now publicly saying the published draft regulations are just a consultation draft, which is not what the CASA representative at the AWAL AGM Part 1 said.
Not to be ignored is cost shifting, given the taxes we pay, directly (fuel levy) and general taxation, to fund CASA.
Some years back, Bruce Byron thought the Ag. operators were good candidates for self administration, and he was right.
The Ag, Association was not adverse to the idea but they, not surprisingly, had no interest in paying twice. At that stage, their combined fuel taxes were something like $900,000 a year, so their answer was, refund out fuel taxes, and we will consider self administration.
That is where the idea came to an abrupt halt.
Tootle pip!!
