The concern related to the operator’s safety culture and safety management system.
It has come to our attention that there may be a safety concern in relation to the safety management systems of [operator], the operator of an [aircraft type] which is being assembled in [location] to be placed on the Australian register.
The information implied that the operator does not have an established safety management system and there is no Just Culture within the organisation. This has led to situations where pilots have been under commercial pressure to fulfil the commercial aspects of contracts, leading to safety being compromised.
The company operates [aircraft type] for various organisations around the world under specific contracts, with the hiring organisation selecting the specifications of the [aircraft] depending on the contract being operated.
When the company operates this [aircraft type] on short term contract, the hirer often does not understand the safety implications of these decisions. This often means that there is no requirement for additional safety prerequisite such as reverse thrust on the engines or an internal electrical power for night operations to run the large light displays. This often leads to a generator being strapped to the back of the gondola.
It also came to our attention that the ground operators have to refuel the aircraft by hand using 5 gallon drums with limited quality control. This is often done during a hot refuel and the refueller must hold the 5 gallon drum above their head to perform the refuelling.
Safety Management System and Just Culture
We have a long standing 'informal' Safety Management System, constituted of our policies, training, review mechanisms, internal reporting and review. All of the pilots assigned to the Australian operation have completed Cockpit Resource Management Training and have just completed a refresher course in [location] with a major airline/CASA approved training provider.
While a formal Safety Management System is not required by CASA, we nevertheless are planning to implement one and currently are liaising with CASA regarding the program contents and structure.
We refute the suggestion that we do not have a 'Just Culture'. This statement is unsupported by any evidence or specificity and is therefore difficult to address. Nonetheless, we have a record over the last 20 years that demonstrates that safety is not and will not be compromised by our company in our efforts to keep the client satisfied. Pilots and all other crew members are encouraged to raise any issues about safety or any other matter. We have a clear policy that pilots have the responsibility for all flying decisions and can decline to fly if unsafe to do so.
Suggestion as to dealings with a hirer
We refute the inference that hirers who hire our company on short term contracts can influence safety matters. Our standard operating procedures do not change depending on the length of the customer contract or the identity of the customer.
Suggestion as to ‘Additional Safety Requirements’
The REPCON report suggests that there are 'additional safety requirements' for the aircraft that are not being implemented. The examples cited are not correct. The [aircraft type] is type FAA certified and under that certification does not require reverse thrust. The aircraft being operated in Australia meets all the requirements of the type certification.
This aircraft has an APU for internal illumination. The APU is certified by the FAA and has a CASA type certification validation, and is part of the FAA type approved certificate data sheet.
Refuelling practices
The REPCON report is incorrect in relation to what is said about hot refuelling. The practice of 'hot refuelling' is specifically forbidden by our company rules and it is also forbidden in our CASA Operations Manual.
We do not undertake this method of refuelling.
We use normal aviation practice with regard to fuel management. We strain and test fuel in the aircraft for water and use test strips/paste to check for any presence of water in any aviation fuel water we purchase.
We do allow the use of 5 gallon cans so that the person refuelling can adjust his position if the [aircraft type] moves slightly, due to a shift in wind direction while it is moored to the mast. All fuelling is supervised and logged.
CASA has reviewed the REPCON and is satisfied with the operator's response.