During the course of the investigation, the Bureau of Air Safety
Investigation issued two Interim Recommendations (IRs). These
recommendations are reproduced below. Pertinent comments in
response to the recommendations and the Bureau's classification of
each response are also included.
"IR970173 (issued 6 February 1998)
The Bureau of Air Safety Investigation recommends that
the Australian Maritime Safety Authority:
- make it mandatory for all ship helicopter landing sites to have
a non-slip surface;- make changes to the publication "Ship - Helicopter Transfers,
Australian Code of Safe Practice" to clearly reflect this
requirement; and- check compliance with this requirement during ship
inspections."
AMSA response 1, in part, stated:
"Thank you for your letter of 6 February 1998, advising
of the Bureau's interim recommendation IR970173.AMSA is fully committed to ensuring safe procedures in all areas
of maritime operations and for this reason will endeavour to
implement your interim recommendation to the maximum extent
possible taking into account practical considerations. Comments on
specific areas of the recommendation are as follows.
- make it mandatory for all ship helicopter landing sites to have
a non slip surfaceMarine Orders Part 57 (Helicopter operations) makes it mandatory
for the master of a ship not to permit the transfer of persons and
goods between helicopter and ship unless certain arrangements,
equipment, instructions and training have been provided. The Marine
Orders further amplify this requirement by stating that
arrangements, equipment, instructions and training that comply with
the Australian Code of Safe Practice for Ship-Helicopter Transfers
or the International Chamber of Shipping Guide to Helicopter/Ship
Operations will be regarded as meeting the requirements. The Code
and Guide both state that helicopter landing sites should have a
non slip surface.- make changes to the publication "Ship - Helicopter Transfers,
Australian Code of Safe Practice" to clearly reflect this
requirementMaritime legislation is moving away from prescriptive type
requirements towards more responsibility being placed upon the
operator to conduct operations safely within a safety regulatory
framework. The framework provides the operator with guidance on how
to comply with safety requirements but does not rule out other
appropriate measures that provide the same level of safety. This of
course places a heavy duty of responsibility on the operator to be
able to demonstrate that any departure from the guidelines provides
at least the same level of safety as if the guidelines were fully
complied with. For this reason AMSA would be reluctant to change
the present Code of Safe Practice to make it more prescriptive.- check compliance with this requirement during ship inspections
Unfortunately for a number of reasons this recommendation is not
practical. For any ships using helicopter transfer for pilot
boarding the inspection would be after the fact and would not
assist in ensuring compliance. The majority of ships do not have
dedicated HLS's and masters can state that they do not normally
undertake helicopter operations and if they intended to do so would
then prepare the landing site accordingly.Regardless of the foregoing comments AMSA believes that the
reports received by BASI and our own intelligence suggests that
there may be a concern in the area of safe ship/helicopter
operations and the full compliance with safe operating practices by
those involved. In order to comply with the spirit of your
recommendation and in order to address the possible non compliance
by operators with the Code of Safe Practice AMSA intends to take
the following action.A Marine Notice will be issued advising masters, owners, agents
and marine pilots of the specific occurrence and other reported
incidents associated with the lack of a non slip surface on
shipboard helicopter landing sites. The notice will advise that the
provision of a non slip surface for helicopter landing sites is
considered to be of paramount importance in ensuring the safety of
ship/helicopter operations and that all ships will be expected to
take appropriate action to ensure that a non slip surface is
provided for the helicopter landing site prior to allowing such
operations to be conducted.Agents for ships proceeding to Australia will be requested to
bring this notice to the attention of masters prior to arrival at
the first Australian port and marine pilot providers will be
advised that AMSA expects them to advise ship masters of this
requirement in their initial contact with the ship. A copy of the
Marine Notice will be forwarded to BASI as soon as it is
promulgated. A copy of Marine Orders Part 57 together with the
Australian Code of Safe Practice for Ship-Helicopter Transfers will
be forwarded to the publishers of "Guide to Port Entry" which is an
international publication widely used by a majority of the world's
shipping. I trust that these measures, together with the present
regulations, satisfy the requirements of the interim
recommendation".
AMSA response 2 stated:
"On 31 March 1998 we wrote to you regarding action to
be taken by AMSA following BASI interim recommendation IR970173.As advised, this Authority has issued a Marine Notice advising
masters, ship owners, agents and marine pilots of the importance of
providing a non-slip surface on HLS's and of the occurrence of the
relevant accident and other similar reported incidents".
Response classification: CLOSED - ACCEPTED
"IR970174 (issued 6 February 1998)
The Bureau of Air Safety Investigation recommends that the Civil
Aviation Safety Authority require helicopter operators involved in
ship-helicopter transfers to include in their operations manual the
requirement to only use helicopter landing sites with non-slip
surfaces."
CASA response, in part, stated:
"The recommendation is based on a number of factors
related to the accident of Hughes 369 helicopter VH-WHP on board a
ship on 17 July 1997. The BASI analysis of the accident appears to
lead to the assumption that the major cause of the accident was the
lack of a non-slip surface on the shipboard helicopter landing
site. CASA agrees that the lack of a non-slip surface was a factor
in the accident but contends that the major factor was the absence
of the pilot from the controls in circumstances conducive to
slippage of the helicopter on the ship's deck.CASA does not agree that helicopter operations should be
prohibited from landing at marine landing sites without non-slip
surfaces when, in the opinion of the pilot, such operations can be
conducted in safety. CASA considers that the guidance contained in
CAAP 91-2(1) and in the Australian Code of Safe Practice for
Ship-Helicopter Transfers relating to non-slip surfaces is adequate
for normal operations.Accordingly, CASA does not intend to restrict the operations of
helicopters involved in marine transfers but will instead focus
attention on factors to be considered before a pilot leaves the
controls of a helicopter while it is running".
Response classification: OPEN
Local safety action
The operator of the helicopter has since amended the Company
Operations Manual to take into account the lessons learnt from this
accident. Company pilots are now required to remain at the controls
of the helicopter while the engine is operating. If passenger
considerations require, an attendant will be carried to assist with
embarkation and disembarkation.