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Project OS 16/01 - Review of the role of the Weight Control Officer and the Weight Control Authority system of CASA
The role of the Weight Control Officer (WCO) is one of the recognised responsible roles in the operation and airworthiness of aircraft through its two main functions:
- establishing and maintaining the empty weight and empty weight centre of gravity (CG) of aircraft
- designing and maintaining the loading system of aircraft.
WCOs are issued with Weight Control Authorities (WCA) under paragraph 33B(1)(e) of the Civil Aviation Regulations 1988 (CAR), based on provisions included in Civil Aviation Order (CAO) 100.28. The authority is provided ‘to weigh aircraft and determine the CG for each aircraft’. The data from the weighing is subsequently used to control the operation of the aircraft. WCAs are time-limited authorities, valid for a period of 2 years. Renewal of a WCA is available within the validity period, subject to maintained proficiency.
Separation of WCA functions
CASA has recognised that establishing and maintaining the empty weight and empty weight CG of aircraft (function 1) is an airworthiness function associated with the compliance of maintenance requirements, while loading system design (function 2) which uses the weight and CG from the aircraft weighing is a separate operational engineering function. Aircraft weighing is an activity that potentially could be conducted by a holder of a Part 66 B1 licence without a separate approval from CASA.
The specific WCA skills and knowledge requirements are reflected in the syllabus of training for the grant of a WCA, found in Appendix 1 to CAO 100.28, which is essentially designed to cover the requirements of aircraft weighing. The skill and knowledge requirements relevant to aircraft loading systems comprise a very small component of the WCA syllabus. These are skills, knowledge and competencies that are within the capabilities of a professional engineering or equivalent qualified technician. In accordance with section 1.2 of CAO 100.28, the holder of a professional engineering qualification is exempt from the course of training referenced in paragraph 1.1(a) of CAO 100.28.
The considerable differences of the required qualifications to carry out the two different functions indicate that the current qualification process does not prepare the WCO for the wide scope of aircraft covered by the functions other than aircraft weighing. For example, a WCO with weighing experience on both Beechcraft Barons (under 3,000 kg MTOW) and Airbus A380s (575,000 kg MTOW), would have their WCA qualification cover both aircraft, allowing them to carry out every aspect of weight and balance control for both types of aircraft.
However, the two distinctly separate WCO functions require different skills and requirements and could be separated to more closely relate to the scope of the two functions. In addition, it is highly likely that a person who designs loading systems and related documents will not be involved in the airworthiness function of aircraft weighing.
For smaller operators who would operate under the future Part 135 of CASR, a person holding a WCA could potentially cover both aircraft weighing and aircraft loading systems functions, whereas for operators who would operate under the future Part 121 of CASR, the loading system function could be self-managed by the operator’s safety critical personnel under Part 119 of CASR.
Currently, airlines have professional engineers that can carry out both functions independently; however, the airlines also have specialists who are trained and qualified in accordance with OEM training but are currently required to hold a WCA. Removing the requirement for a WCA for the operational function of loading system design would reduce red tape and introduce potential savings on costs related to the maintenance of their authority for some current WCA holders.
Assessment of loading systems proficiency
CASA has also recognised that the current system of issuing initial and renewed WCAs focuses mostly on proficiency in determining and maintaining empty weight and empty weight CG of aircraft. The current system does not provide the option for a WCO to retain their WCA by only maintaining their loading systems privileges. CAO 100.7, 5.2(3) requires loading systems to be approved by a WCO whose appointment covers the activity; however, evidence of proficiency in loading system design is not a requirement for the initial issue or renewal of a WCA. In addition, the WCA syllabus and testing does not cover the knowledge level required for that function unless the relevant person holds professional engineering qualifications or equivalent.
Assessment and authorisation of WCOs
Finally, CASA acknowledges that mature organisations would be capable of training their own responsible personnel (WCOs or equivalent) to cover for both weighing and loading system functions as listed above, without the need for CASA to be directly involved in the assessment and authorisation of such personnel.
The objectives of this project are to:
- determine if aircraft weighing and loading systems functions should be separated, and if so to assess how the two functions of a WCO could be separated
- determine how training and authorisation of WCOs (or equivalent) could be accommodated outside CASA
- specify criteria to determine which organisations would be eligible to appoint such personnel to cover the required responsibilities
- review the associated regulations, documents and policy material that may be affected (or would need to be created) if the proposed changes were introduced.
This assessment will be completed through issue of a Discussion Paper for internal and industry consultation.
The aim of the project is to determine how the project issues are to be solved and what regulations, other documents or policy material would be affected. There are no rules directly affected at this stage; however, the current WCA is not captured as a requirement in the future CASR operational Parts. As such, CASR 135 and CASR 121 operators would potentially be affected if the current WCA is carried across as a requirement. Applicable CAR 1988 regulations may also be affected if benefits identified by the project are transferred to that regulation.
|Consultation updates in 2018|
|Summary of consultation on CD 1603OS - Changes to aircraft weight and balance requirements - CAO 100.7||Summary of consultation on CD 1603OS has been published.||6 March 2019|
|Consultation updates in 2018|
|CD 1603OS - Changes to aircraft weight and balance requirements - Consultation draft CAO 100.7||Comments close 19 April 2018.||6 April 2018|
|Consultation updates in 2016|
|Project OS 16/01 - Review of the role of the Weight Control Officer and the Weight Control Authority system of CASA||Project approved.||9 Mar 2016|
Technical lead: Marta Benedek, Aircraft Performance Engineer
Policy manager: Manager, Flight Standards Branch