The CASA sample operations manual used by the operator that allowed any aerodrome in the Enroute Supplement Australia to be used for flight training did not assure that these aerodromes were suitable for use.
To be advised.
On 23 January 2023, CASA provided the following response with respect to this safety issue.
The responsibility to assure that an aerodrome is suitable for use for flight training rests with the operator and the instructor, not CASA. The CASA sample manual itself does not “allow” the use of any aerodrome, it merely doesn’t automatically limit, prior to an operator customising the manual for their use, the use of aerodromes listed in the ERSA or other ALAs that met the CAAP 92-1(1) guidance. However, the sample manual, and subsequent operator manuals based on the sample manual, cannot limit the responsibility of the pilots under CAR 92 to ensure the suitability of any aerodrome used for taking off or landing.
If an operator chooses to include text in an operations manual, regardless of its source, they are required to ensure that it suits their circumstances. In the case of the Part 141 CASA sample manual, operators were reminded of this requirement in Sections 3 and 4 of the “Guide to the use of the Part 141 Sample Operations Manual” (in publication at the time of Soar producing their manual), in particular Section 3B1.6 of the guide which recommends operators include guidance on the issue of aerodrome suitability.
The guidance clearly indicates that standard practice would indicate that [the operator] review their own operational profiles, routes and aircraft performance, and if considered necessary, impose additional controls about what aerodromes might be used. If an operator also elects to not follow CASA’s own guidance in using CASA’s sample document, then that is a matter for the operator and not in any way attributable to CASA.
CASA considers the safety finding to be incorrect.
The ATSB acknowledges that operators are required to ensure that the text in a company operations manual suits their circumstances, and that there are reminders of this in relevant CASA guidance. However, the ATSB considers it reasonable that the author of sample documentation, in this case CASA, amend a document where errors or inconsistencies exist, especially when this may lead to a systemic reduction in safety margins. In this case, the inconsistency identified would not be suitable for use by any operator.
It is also likely that some operators have misinterpreted the text in the sample operations manual to mean that more assurances are provided for uncertified aerodromes in the ERSA, compared to aerodromes not listed in the ERSA, despite these being functionally the same. Therefore, the ATSB considers it appropriate for CASA to address this safety issue because the inconsistency identified may be present for any operators who have an operations manual based on the sample operations manual.
For this reason, the ATSB issues the following safety recommendation. The Australian Transport Safety Bureau recommends that the Civil Aviation Safety Authority takes safety action to modify the CASA sample operations manual wording for flight training operations to emphasise that aerodromes in the Enroute Supplement Australia require assessment of suitability prior to use.
CASA advised that the drafted amendments to the Part 141 Sample Operations Manual addressing this recommendation will be completed by the end of September 2024 for publication in October 2024.
The ATSB will monitor the progress of this action.
