Our staff, along with sector participants, joined a sector safety risk profile (SSRP) workshop in June 2023. During the workshop, we identified inherent risks within the sector.
Operators should be aware of these risks. If these risks are relevant to your operation, make sure you have appropriate mitigation strategies in place. These strategies should be in line with your existing risk management practices.
The significant issues facing the sector included:
- pilot experience requirements – determining if pilots can achieve current standards for entry and recency
- standard operating procedures
- communication equipment and procedures
- fatigue
- lack of sharing of sector occurrence data and safety promotion initiatives within the sector.
How we support aerial fire fighting operators
CASRs Part 138 largely adopts the new legislative framework of safety outcome-based legislation rather than prescriptive.
Due to the diverse nature of this sector and the complexity of the operation, outcome-based legislation provides flexibility to an organisation. This means operators can use the systems and procedures most appropriate to them to achieve the required safety outcomes.
To support operators in meeting their CASR Part 138 requirements we published:
- Part 138 Aerial Work Operations Acceptable Means of Compliance and Guidance Material
- AC 138-01 – Part 138 Core Concepts
- CASA’s Aerial Work Operations (OPS.138) – protocol suite.
We introduced requirements to have safety management systems and a safety risk management process within Part 138.
To support the implementation of these requirements, we developed online and hard copy resources, including for safety risk management. Other resources include:
- Safety Management System Resource kits. Structed on ICAO’s safety management principles of safety policy and objectives, safety risk management, safety assurance and safety promotion. They also include human factors integration and have a booklet that assists operators scale their SMS for the size and complexity of their activities
- Aviation Safety Advisors. They are here to help you meet your safety requirements. The team offers safety education and advice through on-site visits and seminars and have and will continue to support this sector.
Not all aerial firefighter operators will operate under CASR Part 138. Some operators may elect to operate under CASR Part 137 (where permitted).
Those operating under CASR Part 137 are not required to meet CASR 138 requirements. Although, operators may find resources and guidance to support CASR 138 useful for CASR 137 operators in managing specific aspects of their operational risks.
The SSRP forum identified that the way forward to address these issues is not with additional regulations rather working with the Regional Fire Services and the National Aerial Firefighting Centre (NAFC) to harmonise procedures, adopt best practice standards and foster an increased focus on safety management systems and practices. CASA continues to play an active role in supporting operators, Regional Fire Service and NAFC to collaborate effectively to manage their risks.
Through CASA’s National Oversight Plan – Campaign Surveillance and Monitoring of this sector was conducted in 2022. This surveillance activity extended to approximately 15 operators and agencies across Australia to gain a better understanding of the issues facing this sector. CASA continues to support the ongoing industry forums that are addressing these issues and are supporting the adoption of systems to focus on aviation safety within this sector.