Review into North Sea offshore helicopter operations announced by CAA
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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.
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.
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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.
'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.
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
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
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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.
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.
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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.
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.
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
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
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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?
http://www.caa.co.uk/docs/33/SafetyNotice2011017.pdf
Somewhat prophetic, don't you think?
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.
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?
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
Jim
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
Jim
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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.
Somesuch,
I keep on saying it you keep on missing it (I'm sure it is bad form quoting oneself):
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).
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?
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).
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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......
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......
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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?
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?
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!
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!
Last edited by EESDL; 27th Feb 2014 at 14:56. Reason: placate deadline phobia
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...... 
I for one will carry my own..
I for one will carry my own..