Mandatory Lifejackets & Liferafts?
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Mandatory Lifejackets & Liferafts?
Dear All
In relation to the recent announcement reproduced below, can anyone let me know whether or not it is now mandatory to carry a liferaft for a private flight over water (eg cross channel) in circumstances where it is impractical or impossible to do so (eg single seaters). Many thanks. SC
"The UK Civil Aviation Authority (CAA) has today announced general exemptions from the Air Navigation Order (ANO) for light aircraft engaged on non-public transport flights.
The exemptions cover the requirement in the ANO to carry an approved Emergency Locator Transmitter (ELT) and also the requirement for approved lifejackets, life rafts and supplementary oxygen equipment.
The original change was the result of consultations conducted between April 2004 and March 2005 and a Letter of Intent issued on 29 March 2005; this letter resulted in the change to the ANO this March. Details of the consultation were posted on the CAA website, where the relevant documents are still available for viewing.
The original intention of the ANO change for lifejackets, life raft and supplementary oxygen equipment had been to require suitable equipment rather than approved equipment. Whilst the carriage of lifejackets, life-rafts and supplemental oxygen will still be required, the CAA intends to issue a general exemption stating that this equipment need not be approved. Similarly a general exemption will be issued permitting a Personal Locator Beacon to be carried, in lieu of an Emergency Locator Transmitter, whilst a further review is undertaken.
For media enquiries please contact the CAA press office on 020 7453 6030. "
In relation to the recent announcement reproduced below, can anyone let me know whether or not it is now mandatory to carry a liferaft for a private flight over water (eg cross channel) in circumstances where it is impractical or impossible to do so (eg single seaters). Many thanks. SC
"The UK Civil Aviation Authority (CAA) has today announced general exemptions from the Air Navigation Order (ANO) for light aircraft engaged on non-public transport flights.
The exemptions cover the requirement in the ANO to carry an approved Emergency Locator Transmitter (ELT) and also the requirement for approved lifejackets, life rafts and supplementary oxygen equipment.
The original change was the result of consultations conducted between April 2004 and March 2005 and a Letter of Intent issued on 29 March 2005; this letter resulted in the change to the ANO this March. Details of the consultation were posted on the CAA website, where the relevant documents are still available for viewing.
The original intention of the ANO change for lifejackets, life raft and supplementary oxygen equipment had been to require suitable equipment rather than approved equipment. Whilst the carriage of lifejackets, life-rafts and supplemental oxygen will still be required, the CAA intends to issue a general exemption stating that this equipment need not be approved. Similarly a general exemption will be issued permitting a Personal Locator Beacon to be carried, in lieu of an Emergency Locator Transmitter, whilst a further review is undertaken.
For media enquiries please contact the CAA press office on 020 7453 6030. "
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You still need to carry a life raft if travelling over large areas of water. from my interpretation it does not need to be an approved device. WHich is a bonus because you can go and buy a marine life raft instead of an "Aviation" lift raft for a hell of a lot less. The same goes for life jackets.
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Good question, and one which typifies the total confusion the CAA has managed to create with these ANO changes.
SI 2007 No 274 specifically amends the ANO to mandate the carriage in specified circumstances of fire extinguishers, first aid kits, landing lights, torches, life jackets, elt's, oxygen, etc but does not specifically mandate the carriage of life rafts.
However, the SI also amends the ANO to require that the commander of a UK-registered aircraft not flying for public transport "shall reasonably satisfy himself before take-off that the aircraft carries such additional equipment as the commander reasonably considers necessary for the purpose of facilitating the survival of the persons carried in the aircraft."
The exemption permitting the use of equipment not approved by the CAA or EASA subsequently announced by the CAA (and referred to by you) does, though, specifically refer to liferafts. You could, then, reasonably infer that the CAA believes liferafts to be mandated by that new 'commander's responsibilities' clause for flight overwater. But it's your call, since the legislation leaves it to "what the commander reasonably considers necessary."
SI 2007 No 274 specifically amends the ANO to mandate the carriage in specified circumstances of fire extinguishers, first aid kits, landing lights, torches, life jackets, elt's, oxygen, etc but does not specifically mandate the carriage of life rafts.
However, the SI also amends the ANO to require that the commander of a UK-registered aircraft not flying for public transport "shall reasonably satisfy himself before take-off that the aircraft carries such additional equipment as the commander reasonably considers necessary for the purpose of facilitating the survival of the persons carried in the aircraft."
The exemption permitting the use of equipment not approved by the CAA or EASA subsequently announced by the CAA (and referred to by you) does, though, specifically refer to liferafts. You could, then, reasonably infer that the CAA believes liferafts to be mandated by that new 'commander's responsibilities' clause for flight overwater. But it's your call, since the legislation leaves it to "what the commander reasonably considers necessary."
There are differences, I understand, between 'marine' and 'aviation' liferafts - and it's not just price. Aviation liferafts are required to vent to atmosphere in the event of a fault. Marine not so. Therefore to carry a marine raft in the confined space of a light aircraft might just provide the excitement of a lifetime if things go horribly wrong and spontaneous self-inflation occurs. I use an aviation liferaft but I also carry an open pocket-knife ready to hand at all times over the water. Just in case.
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Islander 2: Many thanks for your reply. At the end of the day, since I cannot carry a liferaft I have to assume that the CAA did not mean to restrict private flights over water in certain types of aeroplane without specifically saying so. So I'll continue to make do with the lifejacket, parachute and EPIRB... Plus I will go with the actual letter of the law rather than the aids to interpretation (which as you say do refer to liferafts):
The Air Navigation (Amendment) Order 2007 - 2007/274 - states:
(5) After article 52 add —
" Non-public transport aircraft - survival equipment
52A —(1) This article shall apply to any aircraft registered in the United Kingdom which is not a public transport aircraft.
(2) The commander of an aircraft to which this article applies shall reasonably satisfy himself before take-off that the aircraft carries such additional equipment as the commander reasonably considers necessary for the purpose of facilitating the survival of the persons carried in the aircraft.
(3) In satisfying himself as required by paragraph (2) the commander shall have regard to the circumstances of the intended flight, including in particular the likelihood of ditching and the availability of search and rescue facilities.".
The Air Navigation (Amendment) Order 2007 - 2007/274 - states:
(5) After article 52 add —
" Non-public transport aircraft - survival equipment
52A —(1) This article shall apply to any aircraft registered in the United Kingdom which is not a public transport aircraft.
(2) The commander of an aircraft to which this article applies shall reasonably satisfy himself before take-off that the aircraft carries such additional equipment as the commander reasonably considers necessary for the purpose of facilitating the survival of the persons carried in the aircraft.
(3) In satisfying himself as required by paragraph (2) the commander shall have regard to the circumstances of the intended flight, including in particular the likelihood of ditching and the availability of search and rescue facilities.".
Hmm. Don't think I can elaborate except to say that I read it somewhere a couple of years ago when I was in the market for a liferaft myself, have spent the last 30 mins on the internet trying to find it again and given it up as a bad job ! Sorry.
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One can argue about ELTs etc and anybody not carrying a raft when away from gliding range of land is a fool.
Wearing just life jackets, unless they are gliding in from FL200 in a motor glider (and thus give the rescue services a good head start), or they ditch close to some boat, they will likely be dead by the time the official helicopter reaches the scene.
It's a £1000 or so, but arguably this is the cost of expanding one's ability to go places in a plane.
Wearing just life jackets, unless they are gliding in from FL200 in a motor glider (and thus give the rescue services a good head start), or they ditch close to some boat, they will likely be dead by the time the official helicopter reaches the scene.
It's a £1000 or so, but arguably this is the cost of expanding one's ability to go places in a plane.
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Wearing just life jackets, unless they are gliding in from FL200 in a motor glider (and thus give the rescue services a good head start), or they ditch close to some boat, they will likely be dead by the time the official helicopter reaches the scene.
Why are these lifesavers so rarely mentioned?
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Probably because most British people can't get inside one if you paid them 
And if you make them wear them, they will never fly with you again.
Technically, a drysuit is a very good solution but it's strictly for the most dedicated anoraks.
Even lifejackets are a pain. I have the best GA ones, with the reasonably breathable fabric (the £100 ones from SEMS rather than the £50 ones) yet I still find nobody will wear them except for the actual water crossing. And I don't blame them.
Also I am not sure about how visible you are bobbing up and down in one of them - unless you have a 121.50 beacon tied to yourself with a piece of string, or some other means of detection.
And if you make them wear them, they will never fly with you again.Technically, a drysuit is a very good solution but it's strictly for the most dedicated anoraks.
Even lifejackets are a pain. I have the best GA ones, with the reasonably breathable fabric (the £100 ones from SEMS rather than the £50 ones) yet I still find nobody will wear them except for the actual water crossing. And I don't blame them.
Also I am not sure about how visible you are bobbing up and down in one of them - unless you have a 121.50 beacon tied to yourself with a piece of string, or some other means of detection.
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To consider the likelihood of ditching, the commander would need to know how many of the thousands of channel crossings by SE aircraft have ditched (with the exception of the ones that ran out of fuel).
Having made numerous long channel crossings, I must admit feeling the odds of an in flight emergency must be getting shorter and the CAA requirement has caused me to consider the issue more seriously.
In my case I consider a survival suit preferable to a life raft. I don't fancy my chances of successfully getting a life raft out of a high winger and clambering aboard, whether the aircraft remains upright or flips inverted on contact with the water.
Having made numerous long channel crossings, I must admit feeling the odds of an in flight emergency must be getting shorter and the CAA requirement has caused me to consider the issue more seriously.
In my case I consider a survival suit preferable to a life raft. I don't fancy my chances of successfully getting a life raft out of a high winger and clambering aboard, whether the aircraft remains upright or flips inverted on contact with the water.
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My views on the (non)value of a liferaft were confirmed recently by an ex SAR pilot.
He told me that of the 4 successful light aircraft ditchings he had attended where a liferaft had been carried, only two were able to get the raft out of the plane. Of the two that succeeded in extracting and inflating the raft, nobody was able to get aboard. Nobody. Apparently it is almost impossible in even the slightest sea.
His advice was:
1. Your best chance from a light a/c is in an immersion suit with a life jacket.
2. Dye or a streamer makes a big difference to visibility from above.
3. Never tow an aircraft behind a boat through the water backwards - it'll destroy it in minutes, even if travelling slowly.
To insist on the carriage of a liferaft is daft. The weight penalty reduces other options more likely to save your life.
He told me that of the 4 successful light aircraft ditchings he had attended where a liferaft had been carried, only two were able to get the raft out of the plane. Of the two that succeeded in extracting and inflating the raft, nobody was able to get aboard. Nobody. Apparently it is almost impossible in even the slightest sea.
His advice was:
1. Your best chance from a light a/c is in an immersion suit with a life jacket.
2. Dye or a streamer makes a big difference to visibility from above.
3. Never tow an aircraft behind a boat through the water backwards - it'll destroy it in minutes, even if travelling slowly.
To insist on the carriage of a liferaft is daft. The weight penalty reduces other options more likely to save your life.
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As a matter of fact I did! - and an engineering degree. Boring, I know, but these days carrying out a risk assessment is considered de rigeur for even the simplest task.
but these days carrying out a risk assessment is considered de rigeur for even the simplest task.
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Therefore it seems I am a fool for flying an aeroplane outside of gliding distance to land without a liferaft, even though the machines I fly have no capability of carrying a liferaft.... hey ho. There I was relying upon lifejacket and ELT (the latter being the single most important factor in shortening the SAR time significantly according to a former Bristows SAR pilot friend of mine)....
Cheap (and multi-use) immersion suit? = wetsuit under one's flightsuit...
Cheap (and multi-use) immersion suit? = wetsuit under one's flightsuit...
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Originally Posted by SLFguy
I've got a red 4 man one for sale if you are anywhere near Bristol....
Originally Posted by rjakw
Apparently it is almost impossible in even the slightest sea.
It is definatley worth while trying to get on some sort of course, or swim a dingy out in the sea and try to get in to it fully clothed. Even better, if you are a club member and the club has a liferaft. When it is time for the raft to have it's inspection book a swimming pool for half a day and inflate the raft. That way you can make use of the inflated life raft. It annoys me to have to inflate a raft for inspectiona and not get any use out of it.
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Don't inflate a raft for fun - the inflation process involves a lot of cooling of the gas coming out of the bottle and this makes the rubber brittle, which is not a good thing in the long run. When the overhaul company (e.g. SEMS) tests a raft they inflate it using normal air, not by emptying the gas bottle into it.
Regards getting into a raft... there is a big spectrum of people out there, so please don't generalise.
To be perfectly honest many people are so unfit (or simply inflexible, through age etc) they can only just get into an aeroplane. I fly a TB20 and very much enjoy flying with some definitely senior citizens, yet some of them can only just get in or out of it, and a TB20 is no challenge at all for somebody able to lift one foot about 2ft above the other one.
Looking at today's ageing GA scene (at 50 I am one of the youngest) it's obvious that many pilots would not get out of their plane in a hurry, and getting into a raft is much less likely. I have no illusions about the survival chances of some of my passengers - if they ditch, they will most likely go down with the plane.
I reckon that if you picked an adult off the street at random, they would find it at least slightly difficult to get into a GA piston plane - well maybe except a C182. Into a raft? Not much of a chance. So many people these days are so overweight they can barely walk up steps.
But this does not in any way negate the value of a raft, for those who are reasonably fit and flexible. There is indeed a knack to getting into one - if you start off in the water; you have to "roll in" more or less with the whole body in one go and not try to climb in in the obvious way (upper body first) because it will just tip over backwards, onto you. Anybody who messes about on the water (dinghies, windsurfing, etc) especially in any reasonable sea state will know what I mean.
Ideally one would try to get it inflated close to the aircraft so one can step into it, but this assumes you can all make a rapid exit. Out of a PA28 (or any other single door plane) carrying 3-4 people, forget this option.
The sea state is a valid flight planning option too. Would you fly over sea when it's blowing F10? Ditching in that would be exciting enough, never mind getting out.
The great thing about a raft is that it can just sit on the back seat, ready for use. The U.S. Survival Products ones weigh under 10kg which in terms of W&B is probably about equal to the size of the lie in your female passenger's declared weight Drysuits will absolutely not be worn by 99% of people especially "normal" passengers, so their benefit is theoretical.
Regards getting into a raft... there is a big spectrum of people out there, so please don't generalise.
To be perfectly honest many people are so unfit (or simply inflexible, through age etc) they can only just get into an aeroplane. I fly a TB20 and very much enjoy flying with some definitely senior citizens, yet some of them can only just get in or out of it, and a TB20 is no challenge at all for somebody able to lift one foot about 2ft above the other one.
Looking at today's ageing GA scene (at 50 I am one of the youngest) it's obvious that many pilots would not get out of their plane in a hurry, and getting into a raft is much less likely. I have no illusions about the survival chances of some of my passengers - if they ditch, they will most likely go down with the plane.
I reckon that if you picked an adult off the street at random, they would find it at least slightly difficult to get into a GA piston plane - well maybe except a C182. Into a raft? Not much of a chance. So many people these days are so overweight they can barely walk up steps.
But this does not in any way negate the value of a raft, for those who are reasonably fit and flexible. There is indeed a knack to getting into one - if you start off in the water; you have to "roll in" more or less with the whole body in one go and not try to climb in in the obvious way (upper body first) because it will just tip over backwards, onto you. Anybody who messes about on the water (dinghies, windsurfing, etc) especially in any reasonable sea state will know what I mean.
Ideally one would try to get it inflated close to the aircraft so one can step into it, but this assumes you can all make a rapid exit. Out of a PA28 (or any other single door plane) carrying 3-4 people, forget this option.
The sea state is a valid flight planning option too. Would you fly over sea when it's blowing F10? Ditching in that would be exciting enough, never mind getting out.
The great thing about a raft is that it can just sit on the back seat, ready for use. The U.S. Survival Products ones weigh under 10kg which in terms of W&B is probably about equal to the size of the lie in your female passenger's declared weight
Drysuits will absolutely not be worn by 99% of people especially "normal" passengers, so their benefit is theoretical.
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Regarding the use of a PLB , in your average GA aircraft , is one required
if crossing the Channel at the shortest route ( Fokestone / Cap Gris Nez)
- mid Channel puts me pretty much 10 minutes from land in either direction.
For someone who makes this trip once or twice a summer a PLB is another hit to the pocket
if crossing the Channel at the shortest route ( Fokestone / Cap Gris Nez)
- mid Channel puts me pretty much 10 minutes from land in either direction.
For someone who makes this trip once or twice a summer a PLB is another hit to the pocket