We refer to the revised copy of the Air Safety Occurrence
Report
200100252 which was forwarded to us on 28 February 2002.
We note the final recommendations made in this report, in
particular R20010204, R20010205, R20010206 and R20010207 ("the
Recommendations"). We advise that the Recommendations, as currently
worded, could be misleading as to the role the Electricity Supply
Association of Australia ("ESAA") has within the Electricity Supply
Industry, its powers and capabilities.
We appreciate that this report is finalised but in light of the
Recommendations, we believe it is necessary to:
Clarify the powers of ESAA;
Clarify the role of ESAA within the Electricity Supply Industry;
and
Formally bring to your attention the capability of ESAA in acting
on the Recommendations.
ESAA's Role
ESAA is a representative and advisory body. Its members are public
and privately owned businesses involved in the generation,
transmission, distribution and supply of electricity in Australia.
Its mission is to represent the interests of those electricity
businesses in an open electricity market.
ESAA is not a regulatory body and has no powers to enforce its
advice to its members. It does, however, play a role in providing
its members with relevant information. This includes drafting
guidelines relating to safety issues in the electricity supply
industry. It is in this context that ESAA in August 1995 developed
guidelines for the use of helicopters for live line work.
Consistent with ESAA's role as a representative and advisory body,
members of ESAA are not bound in any way to accept the contents of
ESAA guidelines for inclusion in their work practices or
procedures. ESAA works closely with its members in developing
guidelines on safety issues, but ultimately whether or not members
adopt any particular work practices or procedures is a matter for
them to decide having regard to the relevant issues facing their
business.
Further Action by ESAA
It is important to emphasise that ESAA cannot enforce any of the
Recommendations with its members or be compelled to enforce them.
Neither can ESAA require any of its members to take any action in
connection with the steps that ESAA may decide to take to assist
the ATSB in implementing the Recommendations.
In the context of the comments made above, we advise that ESAA is
able to take the action detailed below to assist the ATSB in
achieving the Recommendations.
1. R20010204,20010205 and 20010207
ESAA will address the content of these three recommendations as
follows:
ESAA has a National Electricity Network Steering Committee, which
as part of its activities develops national guidelines and codes
for the electricity supply industry. This body has been consulted
and has agreed to set up a national working group to develop a
guideline for " The use of Helicopters for low level power line
inspection and maintenance work." The scope of the working group 's
task will be to develop a guideline which takes into account but is
not limited to the following issues:
1] Safety hazards when working in and around helicopters.
2) In-flight communication procedures which include crew resource
management (CRM), hazard identification and crew alerting
procedures.
3) Personnel selection training - including medical tests ie. Eye
tests.
4) Identification of fatigue in the workplace
5) Re-currency training.
Other aspects to be considered, include - minimum standards and
responsibilities, work procedures, the selection of the helicopter
and equipment, approach distances, general work practice and work
considerations ie. Weather, work team communications , public
safety and line hazard identification and also procedures in the
event of an incident.
ESAA has already gathered a range of materials from its members
dealing With the above and expects that the guidelines proposed can
be developed within 12 months. As with all such guidelines ESAA
members are free to decide whether or not to adopt them in their
work practices or procedures.
In addition to the above, ESAA will ensure that the Report as it is
described on the ATSB web-site is distributed to each of its
members.