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Project AS 07/14 - Post-implementation review (PIR) - Subpart 139.H - Aerodrome rescue and firefighting services
The Civil Aviation Safety Regulations 1998 (CASR) Subpart 139.H, Aerodrome rescue and firefighting services, and the Manual of Standards (MOS) Part 139.H, Standards applicable to the provision of aerodrome rescue and fire fighting services, were implemented in 2005. These regulations were amongst the first rule parts to transition from the former Civil Aviation Regulations 1988 (CAR) and Civil Aviation Orders.
The Subpart 139.H legislative framework applies to organisations that are approved as an aerodrome rescue and firefighting service (ARFFS) provider at aerodromes.
CASA committed to conducting a comprehensive review of the rules in 2007 that would look at ensuring the rules were effective in protecting the delivery of a safe ARFF service for the benefit of the travelling public, while not creating complexity or unnecessary operating costs.
Over time, CASA has become aware of some issues that could be better addressed in the rules.
Further, the Australian Government Department of Infrastructure, Transport, Regional Development and Communications conducted an independent review and consultation on the current Part 139.H ruleset in December 2015, and the resulting recommendations need to be incorporated in the ruleset.
This ruleset will be transitioning to have its own part, moving from subpart 139.H of the Part 139 regulations to Part 176. Having Part 176 as a standalone regulation will aid clarity and ensure we can easily identify and update the ARFFS standards in line with international standards.
Consultation on the new Part 176 will commence no earlier than July 2021 on our Consultation Hub.
A review of the rules is also an opportunity to better align them with international best practice and current ICAO standards, as well as industry developments and technological improvements that have occurred since the rules were first developed.
The updated rules will also seek to address:
- the ongoing prescription of legacy practices that pre-empted the implementation of Subpart 139.H of CASR
- prescriptive standards and practices that should be performance-based so as to permit flexibility in delivery methodology and a reduction to industry in service delivery costs
- requirements in the MOS Part 139.H that, in some instances, exceed equivalent requirements in Annex 14 to the Convention on International Civil Aviation (the Chicago Convention) without clear justification
- MOS requirements that relate to the provision of aerodrome infrastructure for rescue and firefighting that are beyond the direct control of the ARFFS provider
- standards and practices that are duplicated across various chapters of the MOS Part 139.H, which is some instances are also ambiguous and require legal interpretation
- standards and practices that don’t reflect the operating requirements for current-generation rescue and fire fighting service providers.
The overall aim of the project is to complete a comprehensive post-implementation review of the Regulation and the MOS Part 139.H. CASA intends to issue a Notice of Proposed Rule Making (NPRM) that will set out regulatory options for industry to consider. Amendments to the Regulation and MOS Part 139.H, including creating the standalone Part 176, may result in the requirement to amend the existing suite of advisory materials related to Subpart 139.H.
The project objectives include to:
- identify key challenges facing industry, in order to propose policy improvements that will maintain current safety standards while ensuring CASA meets its national and international responsibilities as a safety regulator
- complete a gap analysis of the existing MOS Part 139.H—against Annex 14 of the Chicago Convention (and supporting Annexes), the Airport Services Manual Part 1 (Rescue and Fire Fighting) and related Advisory Circulars—to ensure the MOS Part 176 will continue to meet Australia’s international responsibilities to ICAO
- consider the approach taken by other regulators worldwide, with the aim of ensuring that the MOS Part 176 remains aligned with the best practices of leading aviation countries whilst being tailored to suit operating conditions unique to Australia
- consider the training and qualification/competency framework for aviation firefighters applied by other regulators or service providers worldwide, and review the Australian qualification framework that applies to the fire and rescue industry
- review existing draft amendments to the MOS Part 176 and reconcile these against the gap analysis.
Legal drafting of the Part 176 regulation and Manual of Standards is underway. The drafts will be reviewed by the independent Aviation Safety Advisory Panel (ASAP) for advice, then released for public consultation.
CASA will review all comments, and any suggested changes by CASA resulting from the feedback will be reviewed by the ASAP for recommendations before final drafting.
This project is associated with:
- Subpart 139.H of CASR - to become Part 176
- MOS Part 139.H - to become Part 176
|Consultation updates in 2018|
|Project AS 07/14 - Post-implementation review (PIR) – Subpart 139.H - Aerodrome rescue and firefighting services||Project amended.||31 July 2018|
|Consultation updates in 2015|
|Project AS 07/14 – Post Implementation Review (PIR) of Civil Aviation Safety Regulations 1998 (CASR) Subpart 139.H in respect of the Manual of Standards (MoS) Part 139H – Standards Applicable to the Provision of Aerodrome Rescue and Fire Fighting Services||Project was amended 18 September 2015.||18 Sept 2015|
|Consultation updates in 2007|
|Project AS 07/14 - Post-implementation review of CASR Subpart 139.H||Project approved.||9 Oct 2007|
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Project Leader: Anna Mitchell - Aviation Safety Inspector (Emergency)
Project Sponsor: Branch Manager, Flight Standards