Cabin Safety Bulletin No. 2 - Emergency and Life Saving Equipment - CAR 253 and CAO 20.11
Date of Publication: Issued 8 December 2017
Who does this bulletin apply to?
This bulletin applies to all Charter and Regular Public Transport (RPT) operators of Australian registered aircraft.
What is the purpose of this bulletin?
The purpose of this bulletin is to explain how regulation 253 of the Civil Aviation Regulations 1988 and Civil Aviation Order (CAO) 20.11. apply to RPT and charter aircraft operators.
This bulletin has been written to address misunderstandings about the application of CAR 253 and CAO 20.11 as they relate to the training and testing of crew members operating on RPT and charter.
Understanding CAR 253 and CAO 20.11 Appendix IV
Summary of main matters explained in this bulletin
- In CAR 253 (2), testing of competency is required in relation to all emergency and life-saving equipment carried in the aircraft to which the crew are assigned, not just those things listed in Appendix IV of CAO 20.11.
- In CAR 253(2), testing for competency in the use of the equipment will generally involve the actual use of the emergency equipment.
- The procedures listed in the proficiency test syllabus in Appendix IV of CAO 20.11 are not an exhaustive list of the procedures which may need to be tested. It details the minimum of what needs to be tested.
What does CAR 253 mean in relation to crew proficiency in emergency procedures?
CAR 253 states:
An operator shall not assign a person to act as a crew member of an aircraft, and a person shall not act as a crew member of an aircraft, unless the person is competent in the use of the emergency and life-saving equipment carried in the aircraft.
An operator shall ensure that crew members are periodically tested as to competency in the use of the emergency and life-saving equipment carried in the aircraft to which they are assigned.
CARs 253(1) and (2) refer to 'the use of emergency and life-saving equipment carried in the aircraft'. This is a reference to every item of safety or life-saving equipment carried on the aircraft to which the crew member is assigned. The term 'every' in this context means items of equipment documented within the operator's emergency procedures manual.
In CAR 253(2), testing as to 'competency' in the 'use' of the equipment will generally involve the actual use of the emergency equipment. However, that competency may be established and/or tested through means other than actual use subject to the requirements for proficiency testing in Appendix IV of CAO 20.11. As an operator of an RPT or charter flight you must be able to provide evidence that your crew are competent to carry out their functions as documented in your procedures.
Appendix IV of CAO 20.11 practical assessment requirements
Part 1 of Appendix IV of CAO 20.11 lists various types of emergency equipment under the heading 'Practical Operation'. Under that heading, the words 'method of operation' and 'methods of use' are used. CASA considers all items in Part 1, as set out below, requires that crew members physically use the safety equipment to demonstrate their competency:
- Emergency evacuation procedures — operation and use of each type of normal and emergency exit, evacuation slide and escape rope and procedures for evacuation
- Fire extinguishing — method of operation of each type of portable fire extinguisher
- Oxygen — methods of use of fixed and portable oxygen equipment
- Portable megaphones — Method of operation of each type of portable megaphone
- Ditching procedures — where applicable:
- fitting and inflation of life jackets and location and use of equipment stowed as part of the life jacket. For initial qualification, each crew member shall demonstrate competency in the use of the life jacket in the water
- removal from stowage, launching and inflation of life rafts. For initial qualification each crew member shall demonstrate proficiency in his or her assigned duties. Thereafter all crew members shall be given an annual demonstration of launching and inflation and shall demonstrate competency in boarding procedures and the use of the life raft and its equipment
- use of signalling equipment
- use of first aid kits.
Use of mock-ups in practical assessment
However, paragraphs 1.5 and 1.6 of Appendix IV of CAO 20.11 provide relief from the requirements for practical operation in situations when the actual use of aircraft safety or emergency equipment is not practical or possible. CASA can approve the use of realistic mock-ups of emergency equipment as an alternative.
Additionally, in situations where the replacing of a particular item of equipment would involve an excessive amount of maintenance (paragraph 1.5) CASA may provide approval for the operator to provide a group demonstration of the emergency equipment. If a demonstration is used, it must be supported by a pictorial presentation which is also subject to the approval of CASA. As part of the approval process, CASA will review the proficiency test to ensure it includes a mechanism enabling each crew member to demonstrate adequate knowledge of the emergency operation of equipment, and that crew have physically assessed the difficulty involved in operating it where necessary.
When the operation or use of the emergency mechanism may cause damage to the aircraft or equipment or be a hazard to personnel (paragraph 1.6), CASA may approve the use of a pictorial or simulated presentation. Once again the proficiency test must include provision for each crew member to demonstrate an adequate knowledge of the emergency operation of equipment.
To comply with CAO 20.11, a proficiency test must cover all emergency procedures that crew members may be called upon to perform and includes the criteria outlined in Appendix IV of CAO 20.11 as a minimum. Appendix IV outlines the theoretical components that must be assessed. It would be beneficial to have a matrix or checklist to ensure that all of the required components are covered for compliance purposes when conducting a written examination. The checklist CASA uses to assess the suitability of a proficiency test is available on the CASA website.
What else needs to be included in the proficiency test?
Parts 1 and 2 of Appendix IV to CAO 20.11 refers to the specific manner of testing competency in the use of specific pieces of emergency and life-saving equipment. As stated previously, these parts do not represent an exhaustive list of the procedures that may need to be tested. This is suported by the opening paragraph to Appendix IV of CAO 20.11 which states: 'The proficiency test shall cover all of those emergency procedures that the crew member may be called upon to perform. It shall include at least the following.'
The proficiency test is required to cover procedures relevant to the use of all emergency or life-saving equipment that the crew member may be called upon to utilise, even where that equipment (or the procedures relevant to its use) is not specified in Appendix IV of CAO 20.11. For example, if an aircraft is fitted with emergency equipment additional to that specified in Appendix IV (such as a defibrillator) and procedures for the equipment are contained within the operator's manual, the equipment should then be included in the proficiency test.
In circumstances where the equipment and the relevant procedures are not expressly specified in Appendix IV, the manner in which the operator tests the competency of its crew members in relation to that equipment is at the operator's discretion. However, it will be subject to the requirement that the method of testing used involves a reasonable, objective test of the crew members competency. For example, a scenario based assessment could be used.
Consideration should also be given to any mock-up approval requirements as described in paragraphs 1.5 and 1.6 of Appendix IV, and how these approvals may be managed in future within an 'exposition' format. This is discussed in further detail in the following sections.
What else should be considered in relation to the training and checking of crew in emergency proecdures?
Monitoring and Improvement
It is recommended that operators periodically review the emergency procedures that are documented in their operations manual to ensure that they meet the requirements of CAO 20.11 Appendix IV, noting the requirement that 'The proficiency test shall cover all of those emergency procedures that the crew member may be called upon to perform'. The word competency in CASA's CAAP SMS -3(1) and from the ICAO Cabin Crew Safety Training Manual Doc 10002, is defined to mean: A combination of skills, knowledge and attitudes required to perform a task to the prescribed standard.
Data is an important aspect to the ongoing effectiveness of the training and assessment of crew. It allows the operator to assess which areas require increased focus to proactively manage risks. In addition to the mandatory criteria outlined in Appendix IV of CAO 20.11, the integration of data and associated analysis into the training and checking system will significantly enhance the training system's effectiveness. In order to maintain SMS and embrace evidence-based training (EBT), an organisation should ensure their data and records management processes are adequate. Organisations utilising an SMS should ensure that the CAR 217 organisation is driven by information collected from other parts of the organisation as well as training records.
Training and Competency
In addition to reviewing the minimum requirements in Appendix IV of CAO 20.11, operators should consider whether their crew require additional training, and whether the training provided is evidence based and auditable. It is worthwhile asking:
- What do we need our crew to be able to do?
- Are we able to provide auditable evidence that our crew are competent in this regard i.e. have crew members met a standard against specific performance criteria, which have been appropriately documented and recorded?
A critical review of procedural practice options should be undertaken to identify opportunities to conduct drills in a simulated environment eg fire fighting, cabin preparation for an emergency, evacuation on land and water. The focus of procedural practice should be determined through evidence based analysis:
- What are the most prevalent events in industry
- What are the most prevalent events in our operation eg Portable Electronic Devices (PEDs)
- Is our training and assessment addressing those events sufficiently
- What areas of proficiency are crew struggling with in assessments
- Where are the gaps in crew knowledge
The effectiveness of training programs can be improved through a risk management assessment that identifies the likelihood and consequence of certain events. Training and assessment processes can then be focused to optimise mitigation of those events.
Competency based assessment
An example of competency based assessment criteria which could be adapted to suit an operator's procedures are set out below. They are found in ICAOs Cabin Crew Safety Training Manual Doc 10002:
Competency element 1.6: Evacuate aircraft
- 1.6.1 Obtain evacuation order or initiate evacuation, as applicable
- 1.6.2 Shout evacuation commands
- 1.6.3 Operate emergency lighting systems, if applicable
- 1.6.4 Don life jacket, in case of unanticipated ditching
- 1.6.5 Assess inside and outside conditions prior to opening exit
- 1.6.6 Open exit
- 1.6.7 Hold on to fixed part of the aircraft to prevent fall
- 1.6.8 Control crowd/manage cabin
- 1.6.9 Conduct cabin search
- 1.6.10 Take survival equipment prior to exiting the aircraft, if applicable
- 1.6.11 Evacuate the aircraft
- 1.6.12 Operate life raft or slide-raft, in case of ditching
- 1.6.13 Gather passengers away from the aircraft
- 1.6.14 Perform post-evacuation duties
- 1.6.15 Apply survival procedures
- 1.6.16 Complete the applicable documentation
- Classroom and/or computer-based training;
- hands-on exercise on survival equipment;
- hands-on exercise on assisting evacuation means (eg slide, slide-raft, life raft, etc), if applicable;
- simulated exercise of an aircraft evacuation in a representative training device capable of reproducing the appropriate environment/equipment, or on an actual aircraft, where cabin crew apply the operator's procedures and associated crew responsibilities for dealing with the situation; and
- descend a slide, if the cabin crew member will operate on aircraft equipped with slides.
It is especially important to ensure that crew are properly trained to evacuate an aircraft successfully. This emphasises the importance of competency in escape procedures, including the operation of exits.
CAO 82.0 states that each operator must provide facilities, equipment and training aids to meet the requirements of each training program. This includes a facility suitably equipped for the periodic demonstration of proficiency in emergency procedures required by CAO 20.11, and must make available such items of emergency equipment as may be necessary, subject to paragraphs 1.5 and 1.6 of Appendix IV to CAO 20.11. In meeting this requirement, operators can apply to CASA for an approval to use mock-ups.
Every effort must be made to ensure the mock-up reflects the operating environment as much as possible. Variances in items or equipment need to be managed within the training and assessment process, and activities in the mock-up restricted if significant differences exist. Supplemental training may be provided to address identified differences. In assessing the suitability of the mock-ups, the following factors will be considered:
- aircraft types are accurately represented
- operation and appearance reflects actual equipment/device
- capable of normal and emergency operation
- capable of withstanding a higher frequency of use associated with training
- supplemental training utilised to address variances
Where an operator uses mock-ups owned by another organisation, the training must comply with the approved training program and operating procedures of the operator whose crews are being trained.
Third Party Providers
Where contractual arrangements with third party providers exist, the operators training and checking process should reflect the third party's status under CAR 217. This is particularly relevant if any components of CAO 20.11 (such as practical operation of doors/exits, use of flexi-cuffs) are being covered by third party provided traning.
Changes to Emergency Procedures/Equipment
If changes are made to emergency procedures and/or the equipment carried on board the aircraft, a change management process should be employed to ensure that crew members remain competent in their required functions. This means that the way in which the changes are introduced should be commensurate to the type of skill/knowledge that the crew member requires. For example when a procedural or policy change requires crew members to perform a new or amended task, it is necessary to establish competency of both the new skill and and related emergency procedure.
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