Project OS 10/01- Flight Data Recorders
Project closed 26 August 2011
Flight Data Recorders
Issue 1 - Flight Data Recorders - Obligation on Operators to Retain Data after Certain Events - Proposed minor amendment to CAO 82.5
Project OS 10/01 was initiated in January 2010 to address certain deficiencies in Australian aviation legislation identified during the ICAO audit of February 2008. The deficiencies related to the preservation of all related flight recorder records, including any associated flight recorders. Also, the safe keeping of such records pending their disposition as determined in accordance with ICAO Annex 13.
In order to address the identified legislative deficiencies, CASA is proposing to incorporate remedial policy into legislation. CASA notified all AOC holders (to whom CAO 82.5 applies) in writing about its proposal and invited stakeholder comments for the purpose of consultation. The period for response has now closed. Two responses were received; the comments will be reviewed in consideration of making the proposed amendment to CAO 82.5
Issue 2 - Flight Data Analysis Program (FDAP) - Requirement for Guidance Material
Standards Development Branch received a request via SFR from the Executive Manager, Operations to assist with the development of guidance material in support of FDAP implementation for industry and CASA inspectorate staff..
CASA field offices are conducting assessments on RPT operator's Safety Management Systems (SMS), including FDAP. Three associated disciplines (Air Transport Inspectors, Airworthiness Inspectors and Flying Operations Inspectors) require guidance in a number of areas that pertain to FDAP, including:
- Acceptability of fleet sampling size
- Acceptance of Flight Operations Quality Assurance or Flight Data Monitoring as opposed to the term FDAQP
- Acceptance of a single source of data download from the DFDR as opposed to a mandatory source (DFDR) and a secondary data source (QAR or equivalent)
- The minimum period for download of data
- Minimum inputs or data steams considered adequate for a meaningful FDAP
- Requirements for ageing aircraft that may not be suitable or able to install Quick Access Recorders (QARs).
CASA produced CAAP SMS - (1), in January 2009. It outlines the elements and framework of a SMS, including a FDA program. However, that information is limited and provides little guidance for the implementation or assessment of an FDA program.
Standards Development intends to produce and publish a new CAAP that specifically provides guidance for the implementation and assessment of FDA programs. This will provide a transparent and seamless process for all stakeholders.
Issue 3 - Minor amendment to CAO 20.18 - Acceptance of aircraft as certified by the manufacturer with regard to FDR operation
Paragraph 6.3 of CAO 20.18 requires that the FDR be operated continuously from the commencement of taxiing under the aircraft's own power until the end of taxiing after landing. In some aircraft strict compliance with this requirement is not possible as the FDR may cease to record while the parking brake is applied. However, the non-compliant aircraft are compliant with the operational requirements for flight recorders extant in their country of manufacture.
It is therefore proposed to amend paragraph 6.3 to require that the FDR be operated continuously as a minimum from the start of the take-off roll until the end of the landing roll, which will accord with FAR requirements. This proposed legislative change will legitimise current non-compliant aircraft with minimal detriment to aviation safety. It will also avert the need for Exemption issue, with the attendant workload and costs.
The cost to the industry of enforced strict compliance with current paragraph 6.3 would be significant in terms of retrofitting for minimal gain in the availability of useful recorded data and has not been considered.
Issue 4 - Australian Rule Making Decision - Cockpit Voice Recorders (CVR) and Digital Flight Data Recorders (FDR), (ICAO Amendment 34 to Annex 6 Part I, ICAO Amendment 29 to Annex 6 Part II, ICAO Amendment 15 to Annex 6 Part III)
In March this year ICAO informed CASA of the outcomes adopted by its Council at the seventh meeting of its 189th Session on 26 February 2010. ICAO has adopted amendments to the flight recorder provisions in Annex 6. CASA is now required to notify any disapproval, differences and compliance with ICAO.
When adopting the amendment, the Council prescribed 12 July 2010 as the date on which it will become effective, except for any part concerning which a majority of Contracting States have registered their disapproval before that date. In addition, the Council resolved that Amendment 34, 29 and 15 to the extent it becomes effective, will become applicable on 18 November 2010. CASA notified ICAO of a late response.
The amendment relating to flight recorder provisions addresses problems arising from the recovery of data from flight recorder systems, their obsolescence, the lack of data in accidents to small aeroplanes, and the need to prescribe recording of data link communications and include, among others: provisions for cockpit voice recorders; flight data recorders; data link recorders; combination recorders; recorders for small aircraft; and discontinuation of magnetic tape recorders.
CASA's proposed Part 91, General Flight and Operating Rules (GOFR) will be at variance with the current flight recorder requirements of ICAO Annex 6, Part II as it does not require FDR carriage in aircraft engaged only in GA operations. This will also be the case with regard to the future requirements of Amendment 29 to the Annex.
The main changes to Annex 6 are proposed for 2016, it will capture large and small aircraft. For small aircraft, it means they will be fitted with a FDR, and turbine powered small aircraft are to be retrofitted. There is currently no equivalent requirement. The provision for large aircraft includes:
- to have an expanded parameter list
- increased sampling rate
- longer cockpit voice recording duration
- record datalink messages; and
- have dual location recorders.
There is also an interim provision for certain recorders to be phased out by 2011.
A targeted cost benefit analysis has recently been completed for the significant amendments to Annex 6. However, a complete detail of differences needs to be undertaken to allow an exhaustive cost benefit analysis. As part of the conglomerated project, the total cost versus benefit will be examined and the ramifications for all stakeholders considered. Subsequently, Standards Development will then make a recommendation for rulemaking in relation to CVRs and FDRs.
CASA will then be in a position to notify ICAO of any disapproval, differences and compliance with Annex 6.
Note: Airborne Image Recorders (AIRs) will not be considered as part of this project but may be considered by CASA at a future time pending the results of a Cost Benefit Analysis (CBA).
The issues identified will be treated as project phases. Firstly, in part, the proposed changes outlined would alleviate some current compliance issues for Australian operators.
Also, it will make the development and assessment of a critical SMS element, FDAP, a seamless process that provides enhanced safety outcomes and greater compliance. This will greatly benefit all stakeholders.
Lastly, the proposed changes will significantly benefit CASA by ensuring it meets with its current and future international obligations under the Chicago Convention.
As a result of this project CASA Operations may need to update the AOCM.
The normal CAO consultative procedures will be applied in accordance with the SDM.
The amended terms of reference for this project were approved by Peter Boyd on 23 November 2010.
CAO 82 series and CAO 20.18
Project Leader: Mal Read
Project Stakeholders: Greg Hood - EM CASA Operations and Rick Leeds, Manager Airworthiness & Engineering Branch
Project Sponsor: Peter Boyd , EM Standards Development & Future Technology Division
Standards Officer: Peter Robbins
Standards Consultative Committee (SCC)
|Consultation updates in 2011|
|Project OS 10/01 - Flight Data Recorders||This project is now closed.||26 Aug 2011|
|Final CAAP SMS-4(0) - Guidance on the establishment of a Flight Data Analysis Program (FDAP) - Safety Management Systems (SMS)||This final CAAP has been published.||17 Aug 2011|
|DRAFT CAAP SMS-4(0) - Guidance on the establishment of a Flight Data Analysis Program (FDAP) - Safety Management Systems (SMS)||Comments on this draft CAAP are to be forwarded to Mal Read - firstname.lastname@example.org by close of business 3 August 2011||20 Jul 2011|
|Consultation updates in 2010|
|Project OS 10/01 - Flight Data Recorders||Project approved.||7 Jan 2010|