Over water flights - life jackets/floats

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Meatloaf
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Over water flights - life jackets/floats

Postby Meatloaf » Sat Apr 19 2014, 04:31

Is this a correct summary of over water flights and life jackets with a single engine helicopter:

- Life jackets to be worn by all POB and an approved flotation system fitted when operating CHTR or RPT behond autorotative distance from land

- Life jackets to be worn by all POB but no flotation system required when operating AWK behond autorotative distance from land

- TKOF/APCH path over water, life jackets required to be carried (not worn) and no requirement for floats
and now for something completely different
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Twistgrip
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Re: Over water flights - life jackets/floats

Postby Twistgrip » Sat Apr 19 2014, 07:59

Correct, however floats not reqd when following an "Access lane" and also don't forget about CAO 20.11 Sect 5.2.1.1 (b) Re carriage of Rafts :D

http://www.comlaw.gov.au/Details/F2007C00541
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CYHeli
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Re: Over water flights - life jackets/floats

Postby CYHeli » Sat Apr 19 2014, 22:57

In your second example, PVT same as AWK.
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Re: Over water flights - life jackets/floats

Postby hoverthrust » Sun Apr 20 2014, 18:06

That's correct. In a single engine helicopter without floats you need to be autorotative distance from land for charter or RPT . There is a misconception that you have to wear life jackets in a helicopter without floats, sure it's a good safety practice and get you some ticks in your SMS system but not legally required. It's only when you have the floats because you wouldn't be out of range in a helicopter that doesn't have them.
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Re: Over water flights - life jackets/floats

Postby Meatloaf » Sun Apr 20 2014, 22:44

Brilliant, thanks all.
and now for something completely different
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Re: Over water flights - life jackets/floats

Postby Rattlegun » Thu Oct 20 2016, 12:12

G'day,

Sorry to revive and old thread, but I'm a bit confuzzled on this one. Could someone with a better understanding point me in the right direction regarding floats for PVT/AWK ops over water?

Meatloaf wrote:- Life jackets to be worn by all POB but no flotation system required when operating AWK behond autorotative distance from land

CYHeli wrote:In your second example, PVT same as AWK.


CAR258 says we must not fly over water....unless in accordance with directions issued by CASA.

AIP ENR (a CASA direction) then goes on to say:

63.1 Aircraft engaged in PVT, AWK or CHTR operations, and which are normally prohibited by CAR258 from over-water flights.....may fly over water subject to compliance with the conditions in this section;

and

63.7 Helicopters must be fitted with an approved flotation system unless exempted under the terms of CAO 20.11.

While CAO 20.11 (5.1 - 5.3) only talks about CHTR and RPT, I can't find an exemption from the AIP ENR 63.7 for PVT or AWK ops. I feel like I have overlooked something?

Thanks,

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Capt Hollywood
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Re: Over water flights - life jackets/floats

Postby Capt Hollywood » Sat Oct 22 2016, 18:12

Nope, you haven't overlooked anything. It only talks about Charter and RPT because "under the terms of 20.11" those are the operations where floats are required. It doesn't mention Private and Airwork because they're not required for those ops.
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Re: Over water flights - life jackets/floats

Postby Rattlegun » Sat Oct 22 2016, 23:12

Thanks heaps Capt Hollywood.

Just to be sure I've got my head around this correctly:

AIP ENR 63.7 requires all PVT, AWK & CHTR Helicopters operating over water to be fitted with floats "unless exempted under the terms of CAO 20.11"

but,

because PVT & AWK are not mentioned in CAO 20.11, they are not "under the terms", and that omission qualifies as an exemption?
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Re: Over water flights - life jackets/floats

Postby Capt Hollywood » Sat Oct 22 2016, 23:51

My little bit of wisdom for a Sunday morning - The rules are there to tell you what you MUST do and what you MUST NOT do, they're not going to address every conceivable situation. If it doesn't say you MUST NOT do it then you should be able to do it and if it doesn't say you MUST do it then you shouldn't have to do it.

As a simplified example think of an intersection with a stop sign, you must stop at the stop sign. But if there's no stop sign there isn't a sign that says "You don't have to stop here". You're 'exempt' from the requirement to stop due to the absence of an indication to stop.

Well that's my simplistic interpretation anyway and it's worked for me so far.
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Re: Over water flights - life jackets/floats

Postby Rattlegun » Sun Oct 23 2016, 02:05

Thanks again Capt Hollywood.

CASA's tendency to 'rule by exemption' can be hard to understand.

Certainly agree with your stop sign analogy, but where I come unstuck is that the AIP says "all vehicles driving for purpose P,A and C must stop at particular (flight over water) intersections - unless there's a clause in the CAO that says certain vehicles don't have to stop at those intersections."

To me, that reads that in order to avoid stopping, there would have to be a specific clause in the CAO that states "Vehicles driving for purpose P & A are except from stopping".

Capt Hollywood wrote:The rules are there to tell you what you MUST do and what you MUST NOT do


AIP ENR 63.7: Helicopters MUST be fitted with an approved flotation system...

I wonder if the exemption was included in previous CAO's but was dropped for what ever reason? Or perhaps AIP ENR 63.7 was added without updating the CAO?

It's certainly accepted across the industry (and probably the regulator) that floats are not required for PVT or AWK - I just don't understand how that's reflected in the law. Perhaps it's one of those things I should just accept and move on?
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Capt Hollywood
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Re: Over water flights - life jackets/floats

Postby Capt Hollywood » Sun Oct 23 2016, 03:18

Perhaps it's one of those things I should just accept and move on?


There's nothing wrong with trying to understand the law a little better but it might be better for your own sanity to follow your suggestion! :D
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Re: Over water flights - life jackets/floats

Postby CYHeli » Sun Oct 23 2016, 04:09

because PVT & AWK are not mentioned in CAO 20.11, they are not "under the terms", and that omission qualifies as an exemption?
Yes, The law (CAO 20:11) is 'silent' on this so that you can choose what you think is the best option.
Stay tuned for the new part 91 General Rules. There might be changes...
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Re: Over water flights - life jackets/floats

Postby hand in pants » Mon Oct 24 2016, 01:57

Lets just hope that the new part 91 stuff has been written properly and that it will actually work right out of the gate, unlike the garbage that is part 61, 141,142.

Again, I know I'm being negative all the time, but I'm not against change, I'm against change that doesn't work or hasn't been tested properly first.
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Re: Over water flights - life jackets/floats

Postby Rattlegun » Mon Oct 24 2016, 10:22

Quick update for any spectators:

I emailed CASA's Northern Region Safety Assurance Branch (FOI) and got a response very consistent with Capt Hollywood and CYHeli's interpretation:

“Does the omission of PVT and AWK ops in CAO 20.11 qualify as an exemption to AIP ENR 63.7, thereby allowing PVT and AWK helicopter ops over water without an approved flotation system installed?”

Simple answer – Yes


If it's not already obvious, this one had me stumped - particularly the clause AIP ENR 63.7 - "unless exempted under the terms of CAO 20.11". I thought an exemption would have to be expressly stated - something like: "PVT and AWK ops are exempt from the requirements of AIP ENR 63.7"

I now realise that "under the terms" must mean that if the particular operations are not mentioned, then the rule (63.7) does not apply - ie. "under the terms of CAO 20.11, PVT & AWK ops are not required to have floats, and are therefore exempt from AIP ENR 63.7, even though such an exemption is not expressly stated."

In my view, it might be easier to understand if AIP ENR 63.7 instead read " Helicopters must be fitted with an approved flotation system as per the terms of CAO 20.11".

Enough semantics. At least I've learned something. My thanks to all.

Rattlegun.
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Re: Over water flights - life jackets/floats

Postby oldrotorhead » Mon Oct 24 2016, 23:34

Hi Rattlegun. First of all a disclaimer that I am neither a lawyer nor an expert and I agree with the explanations you have been given above. For what it's worth here is some additional verbage which represents my view only. First of all, I don't believe that the AIP constitutes "directions given by CASA". The AIP is not published by CASA but by Air Services under the auspices of Air Services Regulation 4.12. It is published to satisfy obligations we have to ICAO and is structured and laid out generally in accordance with ICAO requirements. (See AIP GEN 0.1). The AIP, again only in my opinion, is not designed to give "exemptions" against any regulation or CAO. (other than, of course, any exemption or "direction from CASA" already published in a CAO such as CAO 20.11) I doubt that there is any head of power any where which would authorise that. If you were to regard everything in the AIP as strictly "regulatory" in its own right, you would or could have your name taken and get fined every time you stuffed up a radio call....just sayin.
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