COVID-19 safety risk mitigation plan

To exercise the privileges of the COVID-19 alleviation exemption, CASA EX 92/21, you will have a safety risk mitigation plan (SRMP) approved by CASA

A safety risk mitigation plan details how you will manage your operations.

If practical to do so, we expect you to comply with the regulations. The relief provisions of the exemption are a last resort.

What you should consider

When creating a plan, you should consider:

  • completing training and checking in accordance with prescribed regulations and approved tests and checks described in your training and checking manual wherever possible and practicable to do so
  • ensuring that each crew member remains adequately trained and proficient for each aircraft, duty position, and type of operation in which they have assigned duties
  • to the maximum extent possible, not pairing flight crew who are operating under the exemption, together in multi-crew operations
  • the justification for the continuation of alternate methods of proficiency testing and checking
  • recording and tracking crew members who completed proficiency testing and checking using alternative methods
  • a process for proficiency testing and checking recovery e.g. managing a backlog of crew currency requirements and demonstration of practical proficiency in the use of emergency equipment and emergency procedures.

What your plan should include

Your plan needs to detail the WHAT, WHY, WHO and HOW.

It will include:

  • a list of the exempted legislative provisions you would like relief from
  • the type of operations you will be conducting under the exemption
  • the number of operating crew that will continue operation under the exemption
  • the proposed length of time that you intend to operate under the exemption
  • the alternative training, tests and checks that the operating crew will need to complete to ensure competency, and and how they will conduct the training, tests and checks
  • a risk assessment that addresses each provision of the exempted operations to show that you are mitigating identified risks to as low as reasonably practical
  • a return to normal operations plan that demonstrates how you will return to full compliance with the regulations prior to the expiry of the exemption, or sooner if possible.

Examples for your SRMP

These examples provided brief guides as to the sort of content required. You must provide detail in the ‘how’ area. You must review your operations and develop proficiency checks as required.

Example 1

What

Regulations require that we use a synthetic training device and use an overseas flight simulator to conduct our annual IPC.

Why

Due to COVID-19 travel restrictions we are unable to get access to the flight simulators.

Who

Flight crew whose IPC was valid on DATE but has subsequently expired.

How

We propose the following proficiency check to allow flight crew to continue operations through to DATE in accordance with the regulations.

This will be an on-ground assessment including:

  • non-normal touch drills conducted in the aircraft including checklist use and flight management considerations
  • systems refresher training and knowledge test.

There will also be an inflight assessment - normal operations including:

  • a 2D and 3D holding and approach operation
  • a missed approach
  • normal approach and landing.

Example 2

What

We require 0perating crew to complete an emergency procedures proficiency check annually.

Why

Due to the actions of various of government to stop the spread of COVID-19, we require relief from conducting an annual proficiency check up until DATE.

Who

Operating crew whose emergency procedures proficiency check expires after DATE up until DATE.

How

Prior to 31 March 2021 operating crew will complete an emergency procedures proficiency check in accordance with the regulations in the following way.

Operating crew will view an online course demonstrating the operation of all the emergency equipment and complete an online exam.

We will assess flight crew in emergency equipment and procedures during their simulator sessions, however they will not need to physically don equipment.

We will assess cabin crew in emergency equipment and procedures during the pre-flight briefing by the cabin manager.

We have included a list of questions that you will need to assess.

Example 3

What

CAO 82.5 paragraph 2E requires CASA to approve amendments to our HF/NTS training program. The training and checking manual requires our operating crew to complete a joint HF/NTS training program each 12 months. Relief is requested from conducting classroom activities.

Why

Due to the government mandated social distancing rules to prevent the spread of COVID-19, we are unable to conduct the classroom activities in accordance with our training and checking manual.

How

All our operating crew will complete the current approved online training program.

We are assessing flight crew during their simulator sessions in NTS1 and NTS2 competencies.

For cabin crew, the captain will discuss HF/NTS issues during their pre-flight briefing.

For cabin crew we would like relief from the following provisions of their approved training and checking system until DATE:

We propose the following:

  • request relief from the annual emergency procedures proficiency check
  • cabin crew will review computer-based training on emergency equipment and complete an examination. Cabin managers will include in their pre-flight briefing questions on the operation of various pieces of emergency equipment to confirm competency
  • relief from the requirement to conduct joint HF/NTS training
  • mitigation: we require cabin crew to view our HF/NTS training program on our website. We require Captains to address HF/NTS issues during their pre-flight cabin crew briefing
  • relief from the annual line check requirement
  • mitigation: we provide cabin managers with an assessment sheet and will observe cabin crew conduct during line operations.

Prior to DATE we roster operating crew to attend the standard joint classroom training course when it’s safe to do so, as part of plans to return to normal.

Impact on safety management systems

If you have a safety management system (SMS) you we expect you to follow your risk management plan.

If you do not have an established SMS you will need to identify how you can conduct your proposed activities safely, by detailing your alternative training and proficiency checks.

Submission of safety risk mitigation plans

There are no fees to submit a safety risk mitigation plan. Complete and submit the form in accordance with the instructions in the form:

Last updated:
5 Dec 2021
Online version available at: https://www.casa.gov.au//operations-safety-and-travel/safety-advice/covid-19-advice-industry/covid-19-safety-risk-mitigation-plan
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