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


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I took a Harbour Air flight recently. The pilot props an Ipad up where all can see and a quick video plays. Why not have an Ipad or similar device available for any ground personal to use? If everyone has to pile in while the helicopter is running, all the pilot has to do is ask his pax "Buckled up, good to go? Everyone watch the breifing on the Ipad?" Then go.

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Are their any pilots/operators currently using trained ground staff to conduct part or all of the compliance requirents of 703.39/723.39 Passenger Briefings?

Response from POI: i wouldn't think that will work in this case but you are welcome to try. Please keep Janice in the loop for this.

I took a Harbour Air flight recently. The pilot props an Ipad up where all can see and a quick video plays. Why not have an Ipad or similar device available for any ground personal to use? If everyone

If only it were that simple. I would say that your procedure works quite well for most fixed wing operators who generally don’t operate such wide variations in aircraft type and configurations in their fleet. Also in most cases, fixed wing pilots are able to shut down where ever they land to pick up passengers. We do actually use similar procedures (pre-recorded audiovisual briefings) for some of our operations, but in many cases it really isn’t very practical.

Because of the wide variety of aircraft types and configurations we operate the only effective means of compliance is to create an individual aircraft video briefing for each of our 13 helicopters; each one of these videos need to be approved by TC cabin safety (just like cabin safety cards). TC also requires that an air operator have approved documented procedures and training program in their COM . According to our TC Cabin safety inspectros, it is not sufficient to simply ask the passenger if they reviewed the video (as was the case on your harbour air flight)…there must be procedures in place to ensure they did (and that it was for the properly configured aircraft). This includes a means for the ground crew to advise the pilot that each passenger has indeed watched the correct video.

Many operations also require that large numbers of people be moved very short distances, with a high number and frequency of flights (using several different aircraft configurations and types). How do you deal with this situation? Do you have passengers watch all of the aircraft videos each morning? I would think this would only increase the possibility of confusion.
Have you ever had to pick up passengers in the bush, where you didn’t feel comfortable shutting down? According to TC, the air taxi regulations require that much of the briefing be given prior to boarding the aircraft (when the rotors are turning). It’s not such a big deal if you dropped them on that day, because you can usually give them the safety briefing prior to departing (before the drop off flight). But what if you are returning with a different aircraft type or configuration? The regulations require that you give them another briefing. According to TC, the regulations state, the same is true, for air taxi, if you pick them up on a different day than you dropped them.

In these cases, do you bring an additional company employee along for the ride (in your 4-6 seat helicopter) so he can exit the aircraft with his iPad and play the video for the passengers? Keep in mind according to TC and the new exemption, these people referred to as “operational personnel”, must be employees or dependent contractors of the air operator. This means many of the 3rd party contractors and clients we work with are not able to be trained under the recent exemption to give the briefing or “ensure” that passengers have watched the video. The air operator also requires documented training records for each ground person involved in either procedure.

Are there any “heli-ski guides” out there who have been trained to conduct these duties and are not employees (or dependent contractors) of the air operator? I’m pretty sure the answer is yes. Not surprising since Transport Canada’s own guidance material states the heli-ski guide can conduct the safety briefing. The link below is to TC’s Advisory Circular No. 0214, Guidelines for the conduct of Heli-skiing in Canada. This document states: “The guide may provide the heli-ski briefing as long as the pilot ensures the material is adequately covered. If possible, briefings may include tools such as a video or other graphics.”

The advisory circular was released in 2003 and is still valid.

https://www.tc.gc.ca/eng/civilaviation/standards/commerce-circulars-ac0214-1709.htm

I find this statement particularly odd since, we were told in 2012 that this was not compliant and an exemption was issued in 2013 to allow operational personnel to conduct the briefing. I ask you, did the regulations or standards change since 2003? I don’t believe they did. Then how is that TC deemed this compliant in 2003 and not in 2013? After all, there was no exemption in place.

We were also advised in 2012 that audio or audiovisual means by definition means it must be pre-recorded.The advisory circular seems to indicate otherwise. We argued that audio or audiovisual means did not indicate pre-recorded and the definitions being offered by TC were contrary to "plain language" definitions.

It’s also worth noting that watching the video on an iPad in this environment brings its own set of challenges.
• How effective is it to watch an iPad video beside a running helicopter in blowing snow, bright sun, heat, bugs and/or other elements?

• Often times these devices don’t have sufficient volume capabilities to actually hear the video well in such an environment; so should we also bring an external speaker?

• What are the odds that that your iPad or speaker batteries will actually have any significant charge at subzero temperatures?

Now let me ask you this, by implementing all of these new requirements, have we increased safety and decreased risk to our passengers? I would say no, we’ve likely done the opposite.

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E-mail received January 16, 205 from Cabin Safety Technical Team Lead, Terry Long after requesting the new exemption (since the one issued in 2013 was expiring (exemption attached):

 

I have been informed that you requested information regarding Exemption NCR-012-2013, due to expire January 26, 2015 at 23:59 EST.

Please find attached Exemption NCR-071-2014, which comes into effect January 27, 2015. This exemption will be posted on the TC website at a later date.

Regards


Terry Long
Technical Team Lead - Civil Aviation Safety Operations - Specialties
Chef d’équipe technique - Opérations de sécurité de l’Aviation civile - Spécialités
Civil Aviation | Aviation civile
Transport Canada | Transports Canada
5431 Flightline Drive, Mississauga, Ontario L5P 1A1 | 5431, promenade Flightline, Mississauga (Ontario) L5P 1A1
terry.long@tc.gc.ca

Telephone | Téléphone 905-405-3294
Facsimile | Télécopieur 905-405-3305
Government of Canada | Gouvernement du Canada

Exemption(E) - NCR-071-2014.pdf

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Just to be certain I understood the Operational Personnel requirements I asked for clarification:

Hi Terry,
I have reviewed the new exemption. It seems pretty straight forward. One thing I noticed in both the 1st exemption and this new one is the definition for ““operational personnel” means an air operators employee…”
In most cases this would not be an issue, however I can foresee situations in our industry where these trained “operational personnel” may not actually be employees of the air operator. It is not unusual for our operations to be very team oriented including cases where several subcontractors work for one client. It is also true that often times pilots are the only employee dispatched to helicopter air taxi jobs and the client (or 3rd party subcontractor, Joint Venture partner etc.) provides personnel that work with the pilot (and under his as responsibility PIC). It would be nice if these people could also be trained by the PIC (to present the Standard Safety Briefing).

Thank You,


Here is her response:

A similar question had been posed in the past regarding the meaning of “operational personnel”. It was clarified that the definition of “employee” in the Canada Labour Code applies. It is as follows:

“employee” means any person employed by an employer and includes a dependent contractor and a private constable, but does not include a person who performs management functions or is employed in a confidential capacity in matters related to industrial relations.

Dependent contractors are included in the official definition of employee. Therefore, if they work on behalf of the air operator, the air operator may designate them to provide the oral safety briefing. The air operator also has an obligation to ensure that the individual has received the required training and that all of the conditions of the exemption are met.

In the context provided below, it appears that those persons are employed by the client, not the air operator. In charter operations, a client usually pays the air operator for transportation service. It seems that those persons would not fit the CLC definition as employees of the air operator and therefore, would not meet the definition of “operational personnel” in the exemption.

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After speaking to a few colleagues I've been advised they believe that many Heli-ski operations provide one safety briefing on the first morning. Subsequent briefings are not provided daily...

Does anyone care to comment?

They are clearly air taxi

Terry Long's department uses he following statement in CARs to justify the "daily" requirement for safety briefing:

From 723.39 : Where no additional passengers have boarded the flight for subsequent take-offs on the same day, the pre take-off and after take-off briefing may be omitted provided a crew member has verified that all carry-on baggage is properly stowed, safety belts or harnesses are properly fastened, and seat backs and chair tables are properly secured.

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Pretty tight lipped in the forums. I guess the "Don't ask/Don't tell" culture is alive and well. Maybe all the Heli-ski guys are all busy right now.

 

How about those who work mineral exploration?

 

When you drop the night shift at the diamond drill and return the following morning with the day shift for crew change, do you shut down at the drill to give the night shift a passenger briefing before bringing them back to base/camp?

 

Even if you gave them one 12 hours earlier (the day before) on the same aircraft?

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