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Safety risk mitigation plan for COVID-19 exemptions
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Operators will need to develop a safety risk mitigation plan and have it approved by CASA to exercise the privileges of the COVID-19 alleviation exemption, CASA EX 57/20, from 1 July 2020. Although approved plans can commence sooner.
The exemption provides an initial period (up to 30 June 2020) for operating crew to continue operations with an expired proficiency check or flight review or other training requirement. This period gives operators time to develop their safety risk mitigation plan. When satisfied CASA will approve the plan.
It’s important to note that, if practical to do so, operators are expected to comply with the regulations. The relief provisions of the exemption are a last resort. For example, if your operating crew complete their dangerous goods training online, we expect that you be able to continue to do so.
A safety risk mitigation plan details how an operator will manage their operations under the CASA EX57/20 exemption.
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 are 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.
Your plan needs to detail the WHAT, WHY, WHO and HOW.
It will include:
- a list of the exempted legislative provisions the operator would like relief from
- the type of operations the operator will be conducting under the exemption
- the number of operating crew that will continue operation under the exemption
- the proposed length of time that the operator intends to operate under the exemption
- the alternative training, tests and checks that the operating crew will need to complete to ensure competency, and how the training and those tests and checks will be conducted
- a risk assessment that addresses each provision of the exempted operations to show how risks have been identified and mitigated to as low as reasonably practical
- a return to normal operations plan that demonstrates how the operator will return to full compliance with the regulations prior to the expiry of the exemption on 31 March 2021, or sooner if possible.
These examples provided are by no means comprehensive, but rather, brief guides as to sort of content that will be required. Operators are expected to provide more detail particularly in the HOW area. Each operator will need to review their operations and develop proficiency checks as required.
We are required by regulations to use a synthetic training device and use an overseas flight simulator to conduct our annual IPC.
Due to COVID-19 travel restrictions we are unable to get access to the flight simulators.
Flight crew whose IPC was valid on the 31 March 2020 but has subsequently expired.
We propose the following proficiency check to allow flight crew to continue operations through to 31 March 2021 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.
Operating crew are required to complete an emergency procedures proficiency check annually.
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 the 31 March 2021. WHO Operating crew whose emergency procedures proficiency check expires after 30 June 2020 up until 31 March 2021.
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.
Flight crew will be assessed in emergency equipment and procedures during their simulator sessions however will not be required to physically don equipment.
Cabin crew will be assessed in emergency equipment and procedures during the pre-flight briefing by the cabin manager.
We have included a list of questions to be assessed.
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.
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.
All our operating crew will complete the current approved online training program.
Flight crew are already being assessed 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 31 March 2021:
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: cabin crew will be required to view our HF/NTS training program on our website. Captains will be required to address HF/NTS issues during their pre-flight cabin crew briefing
- relief from the annual line check requirement
- mitigation: cabin managers have been provided with an assessment sheet and will observe cabin crew conduct during line operations.
Prior to 31 March 2021 operating crew will also be rostered to attend the standard joint classroom training course when it’s safe to do so, as part of plans to return to normal.
Operators who have a safety management system (SMS) are expected to follow their risk management plan. Operators who do not have an established SMS will need to identify how their proposed activities can be conducted safely, by detailing their alternative training and proficiency checks.
Operators will need to submit their safety risk mitigation plans to email@example.com.
All fees related to SRMP applications are being waived. If you have not yet made payment, please disregard any estimate sent to you, no payment is required.
If payment has been made to CASA, a full refund will be processed. CASA will continue to progress the SRMP application submitted and will be in contact should we require further information or documents.