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Old 4th Mar 2016, 06:44
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Emergency Checklists

In the course of discussions with colleagues on the subject of ECL's we constantly come up against the requirements of the RFM.

Now, of course the RFM is a certification document and so reflects the philosophies embraced by the certification criteria. So, for example the engine bay must be capable of containing a fire for a prescribed period of time. This apparently negates the need for any 'immediate action' should a fire warning appear.

My problem is that where the RFM philosophy is technically correct I am not sure it reflects what we would consider to be 'industry best practice'.

It seems that the RFM limits it's scope to the needs of the certification process without recognising that fire warnings, when they are genuine, may well be caused by something more complex than a simple, contained, engine fire. An uncontained turbine burst for example.

Another example is a BATT HOT warning. It may be technically correct to 'continue flight (which is advised by my RFM) but would you, really. I've had three HOT BATTs in other types and landed asap each time. As for a double BATT HOT (AW139) I most certainly wouldn't think twice about continuing flight (advised by RFM) but would find some terra firma as soon as poss.

So my question is 'Do we slavishly follow the RFM or use our experience and airmanship where appropriate when designing our company ECL?'

G.

Last edited by Geoffersincornwall; 4th Mar 2016 at 07:11.
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Old 4th Mar 2016, 07:52
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Geoffers;

Nothing should ever preclude airmanship, and most of us will at some time have stepped outside the ECL, RFM and Ops Manual to solve a situation. Where problems arise in our horrendously litigeous age is when we act outside those guidelines and get it wrong.

With the threat of the lawyers it is a brave Chief Pilot who puts an SOP in his manual that lawyers could get their teeth into in the event of an incident. Coupled with EASA "dumbing down" manuals we now have a situation where lots of good ideas aren't covered by AMC's and while the manual is "compliant" with the AMC's you can't get into trouble.

I have a current question about the fire drills on one type on our fleet. the RFM says that after firing the first bottle during engine fire drills you should wait 10 seconds and fire the second. EVERY other type I have ever flown goes for 30 seconds between bottles to give them time to work and to see if they have worked. I would dearly like to re-write that part of the check-list, but daren't and the OEM can't give me a reason why the RFM was written the way it is.

The same aircraft requires AL48, despite the fact that the engines/filters/fuel lines don't. The AL48 requirement was for an earlier mark but was left in the RFM during a number of up-grades. We now have to use AL48 when the RFM says so, with all the attendant hassle, because not using it could raise questions about our operational standards in the event of an incident.

The AMC's state that the aircraft should be flown with the auto-pilot (if fitted) coupled at all times. I have noticed a degradation of manual flying skills as a result and advocate hand flying as often as possible when there are no pax on board, because we still have to hand fly an approach for LPC/OPC/IRR.

Sadly I think our current system was written with little practical understanding of rotary ops, and despite the best efforts of some very good people at Gatwick in fighting our corner, very little care on the behalf of the faceless EASA mandarins.

Just my rather frustrated 3d worth.

SND
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Old 4th Mar 2016, 08:07
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Spot on SND. Often wondered why we don’t emphasise the first line of any ECL/EOP come FRC drill with “I SURVIVE” (Airmanship) My outstanding BRW instructor (John Yates RN/Bristows) taught me that many years ago.
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Old 4th Mar 2016, 08:35
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Originally Posted by MOSTAFA
Spot on SND. Often wondered why we don’t emphasise the first line of any ECL/EOP come FRC drill with “I SURVIVE” (Airmanship) My outstanding BRW instructor (John Yates RN/Bristows) taught me that many years ago.
Just on SND's point about fire drill, one needs to contemplate the "why?"s. You have 2 extinguishers and 1 fire. If you use one extinguisher it may put the fire out. In which case you have another extinguisher available for another fire. But just how likely is that?

If you use one extinguisher that knocks the fire back but doesn't quite put it out, and then wait, the fire re-establishes itself. You then use the second extinguisher which not surprisingly has the same effect as the first and you are still on fire.

On the other hand if you hit the second bottle pretty quickly before the fire has a chance to re-establish you are maximising the chances of putting the fire out. Ok you then have no more bottles but surely dealing with the fire you have is more important than trying to keep a spare bottle for the fire you don't yet have?

So this is the sort of area where one has to be careful if going against the RFM. You are just guessing that 30 secs is optimal for that engine installation. Whereas the manufacturer has probably done some much more robust study to come up with the 10 secs.


All that said in some cases the RFM procedure can be badly written, not written well for the aircraft's role etc, or plain wrong, and personally I think there can be times when one should deviate from the RFM when writing the EOPs. You have to be pretty sure of your ground though! More recently, and depending on the individual FOI, you may struggle to be allowed to have EOPs that deviate from the RFM. Years ago RFMs used to say that only the limitations section was mandatory but recently, certainly in the case of AH, there are statements in the RFM mandating the Emergency Procedures section too. Which is a shame!
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Old 4th Mar 2016, 09:01
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I can't imagine that any regulator would have a problem with a company tightening up any guidance/direction contained within the RFM.

In the case of the quoted battery over-temperature, for instance, if a company wish the pilot response to be 'land as soon as possible' rather than 'continue flight' then that's fine, but if they changed a 'land as soon as possible' from the RFM into a 'continue flight' in their company drills then that's a entirely different matter which I suggest would not stand up to external scrutiny in the same way.
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Old 4th Mar 2016, 09:07
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Do most FLMs not say something along the lines of;

Basic rules
These procedures deal with common emergencies. However, they do not prevent the
pilot from taking additional action necessary to recover the emergency situation.
Although the procedures contained in this Section are considered the best available, the
pilot’s sound judgement is of paramount importance when confronted with an emergency.

To assist the pilot during an inflight emergency, three basic rules have been established:
1. Maintain aircraft control
2. Analyse the situation
3. Take proper action

NOTE It is impossible to establish a predetermined set of instructions which would provide
a ready-made decision applicable to all situations.


FLIGHT MANUAL EC 135 P2+
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Old 4th Mar 2016, 09:20
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Imagine you've been asked to contribute to a draft FCOM...

.... so do you slavishly follow the RFM or use the 49 years of aviation experience to influence a more cautious approach? There does appear to be an assumption on the part of manufacturers that their carefully designed and lovingly built machines arrive in perfect shape on day one and stay that way. It's been my experience that every helicopter ever built assumes a different persona the day a maintenance worker lays his hand on it.

We have seen many times that assertions that certain failure modes are protected against because they comply with the necessary certification requirements. These assertions are occasionally blown apart by actual events - good old Murphy's Law, aggravated by Sod's Law and compounded by 'The Jammy Side Down Syndrome' (if you trust to luck don't be surprised if you are disappointed!).

So, go with and by 'The Book' - or use actual real world experience to influence your contribution to this vital FCOM document. It will invariably be more cautious than the RFM but under the heading of 'guidance' there may be scope for some words of wisdom.

G.
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Old 4th Mar 2016, 10:00
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The Super Puma fire drill is the obvious example. According to RFM when the fire warning comes on you pull the big red handle, the engine stops.

That would be fine if the ratio of spurious fire warnings to real ones wasn't over 1000:1. If we followed the RFM we would spend most of our lives on 1 engine.

Of course the solution is to improve the fire detection reliability but whilst EC/AH have been tinkering with it ever since it came out in 1982(?) and it has improved, it is still very unreliable.

So we had a completely different EOP for fire for many years, that was more cautious about shutting down the engine and taking a few moments to try to verify that it was actually on fire (which it virtually never was).

Of course EC/AH didn't want to change the RFM since that would be an admission of the lack of "fit for purpose" of the warning system, and anyway the heat was off them as our procedures worked well. Before I retired in 2013 I was aware that another operator had been forced by CAA to implement the RFM procedure which was a shame. Whether that has now been imposed on us I don't know, but it would be a shame to throw away decades of experience in favour of a manufacturer's procedure coloured by vested interest.
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Old 4th Mar 2016, 10:01
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Originally Posted by SilsoeSid
Do most FLMs not say something along the lines of;

Basic rules
These procedures deal with common emergencies. However, they do not prevent the
pilot from taking additional action necessary to recover the emergency situation.
Although the procedures contained in this Section are considered the best available, the
pilot’s sound judgement is of paramount importance when confronted with an emergency.

To assist the pilot during an inflight emergency, three basic rules have been established:
1. Maintain aircraft control
2. Analyse the situation
3. Take proper action

NOTE It is impossible to establish a predetermined set of instructions which would provide
a ready-made decision applicable to all situations.


FLIGHT MANUAL EC 135 P2+

Sadly, no, not on the types I've flown.
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Old 9th Mar 2016, 23:31
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Inserting amendments to FLM; interesting to read the addition to the 'Basic Rules'...

The pilot may deviate from these procedures if judged necessary under the given circumstances (specific failure condition, outside factors and type of terrain overflown).
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Old 10th Mar 2016, 13:59
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and as always: Aviate, Navigate, Communicate
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