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Use Of Trained Ground Staff/escorts To Complete Passenger Briefings As Per 723.39

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You could argue that the rules just lay the responsibility on the commander, no matter who does it.

 

"The pilot-in-command shall ensure that passengers are given a safety briefing in accordance with the Commercial Air Service Standards"

 

phil

I agree with you 100 per cent and i have discussed this with them. Cabin safety in Toronto don't believe there is any room for pilot discretion, despite the fact the PIC is ultimately responsible. Briefings must be completed by the pilot of the flight or conducted by "pre-recorded" audio or audiovisual means.

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If you're in Toronto, whty not have a chat with Richard Pearce? He may be able to chat with them on your behalf.

 

It doesn't say pre recorded in the rules, it just says audio or audiovisual. Given that the law must be interpreted in plain words, ground crew speaking to a passenger is the same thing as "audio".

 

phil

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Given that the law must be interpreted in plain words, ground crew speaking to a passenger is the same thing as "audio".

 

phil

Hence, there a much larger issue to be concerned about.

I have already discussed this with them. Even forwarded them the definitions from Merriam Webster dictionary.

We have seen a pattern of this type of thing over the past few years.

 

As for discussing it with Mr. Pearce, I could do that, as I know him from past TC dealings, but I have included several inspectors from TC including our POI, technical team lead and several others. No one has advised they are in disagreement with the Cabin Safety inspectors or the legal department (who ultimately advised them that it must be prerecorded).

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Exert from HAC HeliSki best practices: Whereas the pilot must give or supervise at least the CARs related briefing, the heli-ski briefing may be accomplished by the guide. Where possible, briefings may include tools such as a video or other graphics.

 

Interesting. According to TC cabin safety in Toronto it must be completed by the pilot or by pre-recorded audio or audiovisual means.

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Furthermore, TC must review and approve the pre-recorded "audio or audiovisual" presentation before it can be used and your COM can be amended to allow for briefings to be conducted through audio or audiovisual means.

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Received by e-mail today. See attached exemption that we were advised would be published by mid - march 2013:

 

"This message is with regard to passenger briefings, specifically, a new exemption and the recently received videos on CD:

 

  1. Exemption:

 

Attached is a copy of the national exemption pertaining to use of a trained company employee, other than flight crew, to provide passengers with the required pre-take-off passenger briefing when conducting short successive flight operations without shutting down the engine between flights. This exemption was signed June 26, 2013 and is valid until January 26, 2015.

A helicopter operator can exercise the relief provided by this exemption when the published conditions, which include the associated approvals, are met.

  1. Video’s on CD:

 

On June 20, 2013, I received the CD containing videos intended to provide audio/visual passenger briefings referenced in an e-mail from Expedition Helicopters dated June 5, 2013. An e-mail received on June 10 2013 indicated that Expedition found discrepancies in some of the videos, and that another CD would be sent to us. We waited for the correct information.

On June 21, 2013, the second CD arrived at this office. We were unable to view any content of this CD. Our IT department has now determined that there were technical problems with the CD. IT was only able to recover a few files, but we cannot confirm that all was recovered, intact.

 

 

As a result of the new exemption, there are now additional ways to ensure that the required passenger briefing is provided for short successive flight operations without shutting down the engine between flights:

 

  1. meet the conditions of the exemption and use a trained company employee to provide the passenger briefing; or
  2. continue working on the audio/visual means and develop the procedures necessary to implement this process.

 

 

If you wish to exercise the exemption, we look forward to receiving the amendments to the company training program and company operations manual.

 

If you wish to continue to develop the audio/visual means, due to the CD technical problems mentioned above, please resubmit all the videos by portable electronic means.

 

 

 

Please let me know how you would like to proceed, and feel free to contact me if you have any questions.

 

 

Yours truly,

 

 

Terry Long

 

Technical Team Lead - Civil Aviation Safety Operations - Specialties

Chef d'équipe technique - Opérations de sécurité de l'Aviation civile - Spécialités

Civil Aviation l Aviation civile

Transport Canada l Transports Canada"

Helicopter passenger briefing exemption - 703.39(1) - English - June 26 2013.pdf

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Finally some common sense from TC !!! :rolleyes:

I disagree. Common sense would dictate that trained ground personnel fall within the definition of Audiovisual means making this exemption completely unnecessary and a waste of time and resources (since the regulation allows for it already).

 

Maybe this is why you can't get your new licence or endorsements within a reasonable time frame: TC is allocating resources to completely unnecessary tasks.

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Merriam Websters definition of audiovisual:

 

au·dio·vi·su·aladjective \ˌ-dē-(ˌ)ō-ˈvi-zhə-wəl, -zhəl, -zhü(-ə)l\

1: of, relating to, or using both sound and sight

2:designed to aid in learning or teaching by making use of both hearing and sight
3: of or relating to both hearing and sight
au·dio·vi·su·al

adjective \ˌd-ē-(ˌ)ō-ˈvizh(

 

CARs doesn't say ground crew are equivalent to audiovisual means. I think the difference between ground crew personnel and an audiovisual presentation is significant. Once an av tape/dvd/whatever is approved, it doesn't change from one presentation to another. Not the case for a person doing it by wrote. ****, I rarely give the same spiel every time... :lol:

 

Seeing as CARs doesn't allow for ground crew to do briefings, I think it makes sense that TC allows for an exemption process that will allow for it. The ideal would be for CARs to be amended to allow for trained ground crew to give briefings, but we all know how long that process can take. I think the actual rule that requires a member of the crew that will be on the actual flight the briefing is being given for is excessive, to say the least and makes no sense in the context we work in. Another example of a rule tailored for the airlines being applied accross the board... <_<

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Merriam Websters definition of audiovisual:

 

au·dio·vi·su·al adjective \ˌȯ-dē-(ˌ)ō-ˈvi-zhə-wəl, -zhəl, -zhü(-ə)l\

 

1: of, relating to, or using both sound and sight

 

 

 

 

 

2:designed to aid in learning or teaching by making use of both hearing and sight

 

 

 

3: of or relating to both hearing and sight

 

 

au·dio·vi·su·al

adjective \ˌȯd-ē-(ˌ)ō-ˈvizh(

 

CARs doesn't say ground crew are equivalent to audiovisual means. I think the difference between ground crew personnel and an audiovisual presentation is significant. Once an av tape/dvd/whatever is approved, it doesn't change from one presentation to another. Not the case for a person doing it by wrote. ****, I rarely give the same spiel every time... :lol:

 

Seeing as CARs doesn't allow for ground crew to do briefings, I think it makes sense that TC allows for an exemption process that will allow for it. The ideal would be for CARs to be amended to allow for trained ground crew to give briefings, but we all know how long that process can take. I think the actual rule that requires a member of the crew that will be on the actual flight the briefing is being given for is excessive, to say the least and makes no sense in the context we work in. Another example of a rule tailored for the airlines being applied accross the board... <_<

Who says the CARs don't allow for ground crew to do briefings? The CARs state that the PIC shall ensure that each passenger receives a briefing that meets the Standard. The Standard states the briefing must by conducted by a flight crew member OR by audio or audiovisual means. OR means one or the other...look that up in the dictionary while you are at it.

 

As Mr. Croucher points out:Given that the law must be interpreted in plain words, ground crew speaking to a passenger is the same thing as "audio". In most cases it would likely be "audiovisual" actually. Doesn't your Dictionary definition also demonstrate this? Ground crew speaking to passengers while giving a briefing (and possibly using a Cabin safety Card to demonstrate location of equipment etc.) certainly are related to and using sound and sight.

 

Neither the regulation, nor standard states that a briefing needs to be TC approved or pre-recorded.

 

You also point out that rarely does a briefing being given by a person remain identical from one presentation to the next. This is true whether we are talking about the PIC, or ground crew (so how does that mean anything?). Who cares as long as all items are covered?

 

This exemption serves no purpose.

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