Recurrency training and drills in aircraft emergencies were not required for reissue of an aerial platform shooting permission. Some shooters last conducted training about 20 years prior, during initial issue of their permissions.
The ATSB is satisfied that the changes introduced in CASR Part 138 and the associated Manual of Standards on 02 December 2021 will resolve this safety issue.
Issue finalisation date: 22 December 2021
In January 2021, the Civil Aviation Safety Authority (CASA) advised that the new Civil Aviation Safety Regulations Part 138 – Aerial work operations would commence on 2 December 2021. Part 138 will require that, where an aerial work operator carries a task specialist, the operator’s operations manual will need to describe how it trains that person to ensure that they are competent in carrying out the normal, abnormal, and emergency procedures relevant to the task specialist role. The operator will also need to describe who will conduct the training of the task specialist and what the minimum qualifications are, for a person to fulfil the role of a task specialist trainer.
CASA also advised that section 25.02(1) of the of the Part 138 Manual of Standards will require:
For subregulation 138.580 (3), the operator must ensure that, before performing unsupervised duties on a flight (the relevant duties), a task specialist is competent in carrying out the operator’s normal, abnormal and emergency procedures for the aircraft and the operation that are relevant to the task specialist’s duties for the flight (the relevant procedures).
Civil Aviation Safety Regulation (CASR) Part 138 was issued in December 2021. CASR 138.580 (3) reads:
(3) The Part 138 Manual of Standards may prescribe requirements relating to training and checking that must be completed by a task specialist for a flight.
The Part 138 Manual of Standards at 25.02(1) reads:
For subregulation 138.580 (3), the operator must ensure that, before performing unsupervised duties on a flight (the relevant duties), a task specialist is competent in carrying out the operator’s normal, abnormal and emergency procedures for the aircraft and the operation that are relevant to the task specialist’s duties for the flight (the relevant procedures).
Note The competency check in a simple operation may take the form of a pre-flight briefing by the pilot in command. But the operator should be satisfied that such a briefing can adequately cover the relevant procedures, and that the task specialist is competent to carry out them out.
The safety issue stated that recurrent emergency training was not required for aerial shooters to renew their licences, and this is still the case. However, the requirement of CASR Part 138 MOS 25.02(1) for an operator to ensure competence in emergency procedures creates a requirement to demonstrate competence in emergency procedures for all task specialists who wish to exercise the privileges of their licences or approvals. For example, with reference to this collision with terrain (AO-2019-025), if the operator was required to check competence in emergency procedures, in addition to briefing emergency procedures, the consequences would have almost certainly been lower for the task specialists aboard.
