Clarification needed RFM or Ops manual
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Clarification needed RFM or Ops manual
What is the absolute when operating helicopters? Is it the RFM provided by the manufacturer, or the operations manual provided by some nitwits. A trusted source was told that the RFM shall be neglected, and the aircraft shall only be operated according to the operations manual. Does that also mean that the red placard "this aircraft shall be operated according to the RFM" can be removed from the aircraft?
Employees, after they scrutinized JAR Ops 3, were told if they do not like to operate according to the ops manual they can pack up and leave.
Now what?
Employees, after they scrutinized JAR Ops 3, were told if they do not like to operate according to the ops manual they can pack up and leave.
Now what?
use the most restrictive. Just cos your ops manual says you can fly IFR, doesnt mean the heli you're in is able to. Maybe the company who said that ain't worth sh*t??
However, after re-reading the post above, maybe if the OPS manual says one thing but legally you are unable to go, then use it to your advantage. Surely there will be very few occasions when this happens anyway.
However, after re-reading the post above, maybe if the OPS manual says one thing but legally you are unable to go, then use it to your advantage. Surely there will be very few occasions when this happens anyway.
Tightgit
If limitations in the Ops manual are more restrictive than those in the RFM (minimum landing fuel for example) then the Ops Manual would take priority. However the Ops manual may not make limitations less restrictive than the RFM.
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You must fly in accordance with the RFM. The RFM is linked to the aircraft's C of A. The C of A is only valid if the aircraft is flown iaw the RFM.
However, as Handysnaks says, the Ops manual can impose limitations additional to the RFM. The Ops Manual cannot raise or remove a limit imposed by the RFM
However, as Handysnaks says, the Ops manual can impose limitations additional to the RFM. The Ops Manual cannot raise or remove a limit imposed by the RFM
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The Operations Manual of any reputable company will, anyway, be based on (amongst other things) the RFM and should have been approved by the regulatory authority under which the aircraft is operating. Remember that the only part of the RFM which is mandatory is actually the limitations section.
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The Ops manual is the Bible. Approved by your aviation authority for your companies specific operations. The only time it isn't gospel is if it countermands or conflicts with something in the Limitations section of the RFM or dash 10.(rare these days)..Although this requirement can be overruled by a specific 'operations specification' ...Command seat position, or crew requirements in external load ops as an example...This may well be in the Limitations section but can be countermanded by Ops Specs in approved circumstances.
It used to be only in the US that the 'prudent man' rule applied, and if you were in Europe and following the written rules you were safe...But I was talking with a JAA ops inspector in Marseilles last week, and he said there are moves afoot in Europe that if you conduct an 'imprudent' operation they can still nail you even if it's in compliance with a written regulation, but that the written regulation would be considered imprudent by a jury of your peers (or words to that effect)
So it seems that prudence is the catchword! (wonder what it means?
170'
It used to be only in the US that the 'prudent man' rule applied, and if you were in Europe and following the written rules you were safe...But I was talking with a JAA ops inspector in Marseilles last week, and he said there are moves afoot in Europe that if you conduct an 'imprudent' operation they can still nail you even if it's in compliance with a written regulation, but that the written regulation would be considered imprudent by a jury of your peers (or words to that effect)
So it seems that prudence is the catchword! (wonder what it means?
170'
or the operations manual provided by some nitwits
As has been said, you cannot readily deviate from the Part 1 Section 1 RFM Limitations section, without a statement of 'non objection' or similar from the manufacturer and open discussion with the regulator.
Bear in mind too, that JAR OPS-3 is not law in itself, and it will depend on which national regulator's jurisdiction you are under and what rules they have adopted.
In reality, the RFM content does not tend to figure very highly in the OPS-3 requirements, other than performance, so it may help if you posted some more specific concerns for debate.
JAA ops inspector
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Bear in mind too, that JAR OPS-3 is not law in itself, and it will depend on which national regulator's jurisdiction you are under and what rules they have adopted.
Ermm...Believe I'll leave it at that! Not too many in your neck of the woods I imagine?
170'
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Swamp Dwarf,
A classic example of Companies (including CHC, Bristow, PHI, OLOG, ADA, GHC etc. etc.) choosing to modify RFM procedures in favour of their own has existed for many many years on the 212/412 type.
The RFM Fire Drill in the respective 212/412 RFM's requires the immediate actions: -
"T" Handle - PULL
Fire Bottle - Fire Main
Throttle - CLOSE
As every schoolboy (suitably type rated!) knows - to follow this procedure would have no effect at putting out an engine bay fire since immediately after pulling the "T" handle, the respective particle separator door would have only just begun to close therefore the extinguishing agent would be immediately blown away having little or no chance to do its' job
The modified procedure is: -
"T" Handle - PULL
Throttle - RETARD TO IDLE
Confirm Correct Selection
Idle Stop - RELEASE
Throttle - CLOSE FULLY
Fire Bottle - FIRE MAIN
This stands a much better chance of success
RFM's are written by Test Pilots who by definition do not have 20 years plus experience on type - pretty obvious.
They do an excellent job but can only test a limited number of scenarios and profiles in the Certification Programme time allocated.
Years of commercial use will often highlight oversights or shortfalls which if not in contravention of the RFM Limitations Section will be addressed by individual Operators in either Company Operations Manuals or Emergency Check List Procedures.
A classic example of Companies (including CHC, Bristow, PHI, OLOG, ADA, GHC etc. etc.) choosing to modify RFM procedures in favour of their own has existed for many many years on the 212/412 type.
The RFM Fire Drill in the respective 212/412 RFM's requires the immediate actions: -
"T" Handle - PULL
Fire Bottle - Fire Main
Throttle - CLOSE
As every schoolboy (suitably type rated!) knows - to follow this procedure would have no effect at putting out an engine bay fire since immediately after pulling the "T" handle, the respective particle separator door would have only just begun to close therefore the extinguishing agent would be immediately blown away having little or no chance to do its' job
The modified procedure is: -
"T" Handle - PULL
Throttle - RETARD TO IDLE
Confirm Correct Selection
Idle Stop - RELEASE
Throttle - CLOSE FULLY
Fire Bottle - FIRE MAIN
This stands a much better chance of success
RFM's are written by Test Pilots who by definition do not have 20 years plus experience on type - pretty obvious.
They do an excellent job but can only test a limited number of scenarios and profiles in the Certification Programme time allocated.
Years of commercial use will often highlight oversights or shortfalls which if not in contravention of the RFM Limitations Section will be addressed by individual Operators in either Company Operations Manuals or Emergency Check List Procedures.
Last edited by Troglodita; 20th Apr 2008 at 16:31. Reason: typo
The person (steady now!) That enforces the above mentioned regulators jurisdictional differences among other things.
212man is spot on (he usually is 
)
As a pilot you should follow your Ops Manual, published checklists, etc but you always have to follow what is printed in the Limitations section of the RFM.
The Company you work for has the option to deviate from the rest of the RFM if it chooses to do so, but unless any deviance is agreed by the manufacturer then there is always the risk that it can be challenged by the lawyers should something go wrong!
A pilot will expose himself to challenge by the lawyers if he doesn't follow Part 1 Section 1 of the RFM or your Company published procedures.
Simple really
It has to be otherwise line pilots wouldn't know what to do
(just redressing the usual management/FOI bashing that goes on!!)
)
As has been said, you cannot readily deviate from the Part 1 Section 1 RFM Limitations section, without a statement of 'non objection' or similar from the manufacturer and open discussion with the regulator.
The Company you work for has the option to deviate from the rest of the RFM if it chooses to do so, but unless any deviance is agreed by the manufacturer then there is always the risk that it can be challenged by the lawyers should something go wrong!
A pilot will expose himself to challenge by the lawyers if he doesn't follow Part 1 Section 1 of the RFM or your Company published procedures.
Simple really
It has to be otherwise line pilots wouldn't know what to do
(just redressing the usual management/FOI bashing that goes on!!)
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In Oz. Our Ops Manual (the worlds largest company) opening statement was "These instructions and procedures are mandantory for all aircrew." Two paragraphs on it says "This manual shall not supercede or countermand any Regulation, Orders or Instructions issued by the Civil Aviation Authority. Compliance only with the terms of this Manual shall not absolve any personnel from the responsibility of abiding by such Regulations, Orders and Instructions."
Civil Aviation Regulation 138
Pilot to comply with requirements, etc of aircraft’s flight manual, etc
The Ops Manual did contain erroneous advice. When we changed from the 76A to 76C it retained the A model collective bias failure procedure for some 18 months before ammendment. The Cat A chart produced in the Ops Manual only took into account the reject mode and not the continued take off (failure after CDP). Despite the discrepancy being pointed out, over a period of some eight years or so it never was changed, and possibly remains so to this day. My advice is know your RFM and read the Ops Manual with a jaundiced eye (212man excepted).
Civil Aviation Regulation 138
Pilot to comply with requirements, etc of aircraft’s flight manual, etc
(1) If a flight manual has been issued for an Australian aircraft, the pilot in command of the aircraft must comply with a requirement, instruction, procedure or limitation concerning the operation of the aircraft that is set out in the manual.
Penalty: 50 penalty units.
(2) If a flight manual has not been issued for an Australian aircraft and, under the relevant airworthiness standards for the aircraft, the information and instructions that would otherwise be contained in an aircraft’s flight manual are to be displayed either wholly on a placard, or partly on a placard and partly in another document, the pilot in command of the aircraft must comply with a requirement, instruction, procedure or limitation concerning the operation of the aircraft that is set out:
(a) on the placard; or
(b) on the placard or in the other document.
Penalty: 50 penalty units.
(3) An offence against subregulation (1) or (2) is an offence of strict liability.
Note For strict liability, see section 6.1 of the Criminal Code.
Penalty: 50 penalty units.
(2) If a flight manual has not been issued for an Australian aircraft and, under the relevant airworthiness standards for the aircraft, the information and instructions that would otherwise be contained in an aircraft’s flight manual are to be displayed either wholly on a placard, or partly on a placard and partly in another document, the pilot in command of the aircraft must comply with a requirement, instruction, procedure or limitation concerning the operation of the aircraft that is set out:
(a) on the placard; or
(b) on the placard or in the other document.
Penalty: 50 penalty units.
(3) An offence against subregulation (1) or (2) is an offence of strict liability.
Note For strict liability, see section 6.1 of the Criminal Code.
Nom d'un chien - Rover! C'est pas tout EASA maintenant?
Last edited by 212man; 21st Apr 2008 at 02:31.
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IGW
Yes, they are but the jobs usually gets dumped on some poor sod.
The real problem, for JAA manuals at least, is that whoever wrote the spec in JAR OPS didn't have the faintest clue about technical writing (it was probably dumped on another poor sod). Trying to use their numbering system is a real pain. It's not so bad when you are dealing with inspectors in the UK, for example, but with those from countries whose native language is not English, and where everything has to follow the numbering exactly, it can be impossible (especially with Part B).
I hope that whoever takes over the specs in EARSA has the sense to ask!
Phil
Yes, they are but the jobs usually gets dumped on some poor sod.
The real problem, for JAA manuals at least, is that whoever wrote the spec in JAR OPS didn't have the faintest clue about technical writing (it was probably dumped on another poor sod). Trying to use their numbering system is a real pain. It's not so bad when you are dealing with inspectors in the UK, for example, but with those from countries whose native language is not English, and where everything has to follow the numbering exactly, it can be impossible (especially with Part B).
I hope that whoever takes over the specs in EARSA has the sense to ask!
Phil
