Growth of the Australian helicopter sector, safety concerns and CASA's strategy to improve safety
Thank you, Mr Richard Tudge for inviting me to address this gathering on behalf of CASA and thanks to all of you for giving up valuable time to consider safety matters in a forum such as this.
As I see it, this is a great opportunity to share information and knowledge with some of the Australia’s leading helicopter engineering and airworthiness personnel at a time when the helicopter sector has and continues to, exceed the growth rate of all other sectors of Australian aviation.
Helicopters are a key element in the development of Australia and have served our community well. If you think in broad scope, there is not a sphere of life that is not touched by this sector—i.e. general transport, agricultural operations, fire fighting and flood relief, medical transport and mineral resource development including off-shore petro-chemical operations, which have all the indications of becoming the next 'big thing' in Australia as gas and oil fields will need increasingly to be supported off the coast of Australia.
At present helicopters make up 13 per cent of the approximately 14,800 aircraft on the CASA Aircraft Register. Helicopter numbers have almost doubled in 10 years in Australia – from 1,034 in 2002 to 1,975 in mid-August 2012 – and they will double again, in perhaps as early as seven years as a result of the accelerating rate of growth generated by the demands from Asia for Australia’s energy and mineral resources.
Further, there is 21 per cent annual growth of the twin-engine fleet, which is nearly three times more than the annual growth rate of the single-engine fleet, which is 8 per cent. This means that while the current rapid increase in the number of helicopters in Australia – outstripping all predictions—will now not only continue, but will come increasingly to involve heavier and more complex machines.
On the world stage, Australia is rated 6th and New Zealand 10th for helicopter totals. Looking comparatively at Asia, there are very few helicopters—China, whilst showing signs of rapid growth, currently has only 150, Thailand and Malaysia total less than 100, and PNG about 200. India (again another area of high potential growth) has less than 300. So, when it comes to helicopter numbers, Australia is clearly a leading aviation nation in this part of the world.
Safety issues and concerns
Helicopter safety is at once similar, and yet uniquely different, to fixed-wing safety. It has its own distinct characteristics, but there are many similar underlying trends.
Due to the technical complexity of helicopters and the rapid growth rates mentioned above, particularly in the off shore passenger and emergency medical transport fields, it is widely recognised that significant improvements in the safety of certain kinds of operations are needed.
In this regard there have been notable improvements over the past decade. However, the latest ATSB report on Aviation Occurrence Statistics between 2002 and 2011 still reveals that the accident rate in helicopters engaged in any type of operation is higher than that for aeroplanes performing the same type of operation. This ranges from 1.2 times more accidents in aerial work, up to 2.5 times more in flying training.
When general aviation aeroplanes and helicopters were compared, using pooled data, between 2002 and 2010, general aviation helicopters had an accident rate of about 122 per million hours flown (293 accidents for about 2.4 million hours flown) and general aviation aeroplanes had about 92 accidents per million hours flown (820 accidents for about 8.9 million hours flown). This represents an accident rate in general aviation helicopters that is about 1.3 times higher than general aviation aeroplanes.
Overall, even though they account for only 13 per cent of the Australian civil fleet, helicopters were involved in about 36 per cent of all accidents in general aviation in the last 10 years—and 47 per cent of all fatal accidents.
As with aeroplanes, despite helicopters’ unique operational characteristics, they share the same hierarchy of risk. The evidence shows that private flying is the most risky, for both aeroplanes and helicopters, followed by flying training, aerial work and charter. It’s a fact, unfortunately, that helicopters have distinctly higher fatal accident rates in most categories.
These statistics are ringing alarm bells in the industry with the formation of such bodies as the International Helicopter Safety Team (IHST). Well, for the same reasons, aviation safety regulators cannot accept that existing safety standards are sufficient, without making improvements.
Service Difficulty Reporting
Further to the above, the growth of the helicopter sector in Australia leads to the perception in some quarters that most of them are new, or low-time aircraft. In fact, about 39 per cent of the Australian helicopter fleet is more than 20 years old (the oldest are three Bell 47s manufactured in 1962).
While the fixed-wing world is struggling with ageing aircraft problems, and playing catch-up to regain lost ground, this is not quite the case in the helicopter industry, primarily because operators in this sector have been obliged to follow manufacturers’ maintenance requirements.
All machines are ageing, however, and there are a number of factors that contribute particularly to rotorcraft - vibration-related fatigue issues can be especially problematic.
With these considerations in mind, manufacturers’ maintenance programs are continually being improved, tailored to particular operational circumstances. The diligent management of these programs is critical.
However, despite all this, all aircraft, including helicopters will develop unpredictable defects – even when operated and maintained in accordance with the manufacturer’s manual. Only appropriate responses to such defects can prevent unpredictable failures.
Speaking of defect reporting, later in this forum two CASA Airworthiness Engineers will speak more specifically on service difficulty reporting matters and will stand ready to answer your questions on those issues. For now, let me say that I am concerned with under-reporting, with what I understand to be something close to only a 10 per cent of reportable defects coming to CASA’s attention via the SDR process.
To detect defects, to discern the possible consequences and to act to rectify defects, prevent their recurrence and to share the outcomes of those efforts, is a true sign of a maturing safety culture within an organisation and within the industry.
I understand that this process takes time, it doesn’t happen overnight, but I do hope that one of the results of this Safety Forum will be a renewed commitment and determination to share your 'safety' experiences.
Proposed regulations and safety benefits
New operational regulations
Proposed new regulations promise to broaden the focus of helicopter safety to look at operational and organisational standards.
CASA has released a draft of the proposed regulations for rotorcraft transport operations, which will be in Part 133 of the Civil Aviation Safety Regulations (CASRs). These regulations have been subject to extensive consultation with the aviation industry over several years.
A key aspect of the proposed new rules will be a narrowing of the gap between current standards for Regular Public Transport (RPT) and charter operations in the development of common air transport operation standards. The briefing document that accompanies the proposed regulations explains how the anticipated impact of the new rules on the helicopter industry will vary from ‘significant to minimal’ dependant on the current safety systems an operator has in place.
Recognising that some of the envisaged changes will be significant, CASA will ensure that the transition period to the new rules gives operators adequate time to allocate resources and make changes to their operations. Those most affected will be helicopter charter operators with no pilot training and checking organisation, and without safety management systems or fatigue risk management systems.
The proposed regulations align closely with International Civil Aviation Organization standards and recommended practices and harmonise where possible with rotorcraft rules in other leading aviation nations.
Specific aspects of the regulations are designed to address known and likely safety risks, and aims to further strengthen the current regulatory structure to deliver improved safety outcomes.
There will be additional flight preparation and planning requirements for some night operations and minimum equipment, instrument and systems standards for day and night visual and instrument flight rules operations.
Further, the proposed rules require assessment of the risks associated with helicopter landing sites and to ensure landing sites are safe. A set of performance regulations will be introduced, outlining a performance code of operation based on passenger numbers and type of operation.
The proposed rules identify safety-based outcomes for flights over water, with new equipment requirements. Additionally, Part 133 air transport operators will be required to have Minimum Equipment Lists for their aircraft and to comply with the higher standards outlined in our new maintenance regulations.
The draft air transport rotorcraft regulations have been subject to extensive consultation with the aviation industry over the past several years.
New maintenance regulations
The new suite of maintenance regulations (CASR Parts 42, 66, 145 and 147) that came into effect in late June 2011 only apply to operators and maintainers of RPT aircraft. These rules do not apply to the current charter, aerial work and general aviation sectors.
CASA has been advising the aviation industry for a number of years that revised maintenance regulations for the non-RPT sectors will be developed at a later date, after wide consultation with all affected stakeholders and interested members of the wider aviation community.
On that note, we fully recognise the RPT maintenance regulations cannot simply be applied across the board. Each operational sector of aviation is different and the new regulations will reflect those important differences.
However, if aspects of the RPT maintenance regulations are relevant and appropriate to some sectors of the industry, then, subject to the outcome of the consultation process, those provisions may be incorporated into the proposed new rules.
The primary factors that will influence the level of formalised airworthiness management and maintenance required is the risk associated with the operations in which aircraft are engaged. The risk associated with an operation is primarily affected by the following elements:
- the complexity of the aircraft
- the complexity of the operations
- the number of people potentially affected; both in the air (i.e. occupant capacity) and on the ground (i.e. size of the aircraft and whether operations are conducted over populous or remote areas).
The factors I have mentioned above set the fundamental basis for the proposed operational CASR Parts and apply the same principle for the remaining maintenance regulations.
At this stage, CASA is working on a series of Discussion Papers that will provide options for each of the different operations described above, in the following key elements of the maintenance suite of regulations:
- maintenance providers
- continuing airworthiness management arrangements
- maintenance programs
- airworthiness reviews
- maintenance personnel licensing for small aircraft.
I encourage you to play an active role in providing feedback when the discussion papers are out for industry consultation as each of you individually – and collectively in bodies such as this – represented here today, can provide valuable input to the successful development of new rule sets.
CASA will carefully consider the views of all interested sectors of the industry and the wider aviation community, and we will take all reasonable comments and submissions into account before any rules are finalised.
CASA recognises that there are constraints on the ability of sections of the industry to absorb extensive and rapid changes to regulations, and this is a factor CASA will carefully consider in the development of timelines for regulatory implementation.
In closing, let me to reiterate, that while the rotorcraft industry faces a time of unprecedented expansion and the challenge of regulatory change, it is at this very point that we should grasp the opportunity to face the challenges and cooperatively lay the foundations for better safety outcomes, and our complementary efforts toward the achievement of those outcomes.
I’m pleased to have participated in this forum and share some critical regulatory perspectives.
Forums like this provide excellent opportunities to share ideas and hard-won knowledge and experiences amongst and between aviation professionals at the highest level, and contribute to the knowledge-base essential to a safe and viable aviation industry.