Carry-On Baggage Requirements

[Freewheel]

Turns out there is an LSTC for the Life Raft Mounting Bracket (attached).

MBB 105 LSTC Liferaft Mounting Bracket.pdf

[Wiggins]

How would they get it out of the baggage compartment in the event of an emergency water landing?

Sorry it was a bit of sarcasm. Float kits are usually certified with a raft installation. I'm quite sure it is perfectly legal..

[Freewheel]

Biggest problem is the word "Interpretation"...

It should not be an individuals "interpretation" of the intent of the law.

 

In the US they have a legal department at the FAA that produces "Interpretation" to all FAR's... These "Interpretations" are considered gospel in the US, and the "Interpretation does NOT vary by region to the extent it does in Canada.

Cheers

W.

 

Agreed. The HAC has identified this problem in our industry for many years. It certainly doesn't seem to be getting any better. This is just one small example of a much larger issue. Lately it seems the disparity is not confined from one region to the next but exists within regions (from one inspector to the next).

 

This disparity makes it very difficult for us to do our jobs (in compliance) just as it makes it difficult for inspectors to do thier's.

 

I don't know about you but I know many pilots and inspectors who have worked in more than one region. Many pilots work for more than one company and many companies have operations in multiple regions. There leads up overall confusion and ultimately what Mr. Lemieux refers to as willfull mon-compliance. I disagree most of us want to follow the law.

 

I have even been told by some operators that they interpret some regulations a certain way at one base (let's say in Quebec), yet another way at there other base (let's say in Calgary). This is done to keep their local inspectors happy since each gas a different "interpretation".

 

No wonder their pilots are confused...

[Freewheel]

So can this problem be corrected?

Here are some suggestions for a way to start.

 

1) acknowledge there is a problem

2) listen to stakeholders who proactively report these independant issues

3) identify the root cause

4) be accountable

5) introduce effective corrective actions

6) effectively distribute information about known issues and corrective actions

7) enforce the rules equally amongst all stakeholders

 

 

Sound familiar? If not, it's time to start checking the TC Civil Aviation Website a little more often and in-depth.

Seems pretty basic and straightforward to me.

[helicopterjim]

So can this problem be corrected?

Here are some suggestions for a way to start.

 

1) acknowledge there is a problem

 

 

So if the problem is Transport Canada .... do we proceed with all the rest of the steps?

[Cambox]

Remember that Transport Canada Aircraft Services Directorate (ASD) and/or Canadian Coast Guard (CCG) are NOT part of Transport Canada Civil Aviation. Not nice to get the wrong people in trouble.......

 

R...

Pictures attached:
1)another canadian coast guard BO 105 (operated by Transport Canada) with yellow bag in cabin
2) passenger exiting cabin of Coast Guard BO 105 (operated by Transport Canada) with large briefcase (rotors turning).
How did he stow or restrain the carry-on baggage?

[Freewheel]

Remember that Transport Canada Aircraft Services Directorate (ASD) and/or Canadian Coast Guard (CCG) are NOT part of Transport Canada Civil Aviation. Not nice to get the wrong people in trouble.......

 

R...

First of all, I have nothing but respect for those operating the Coast Guard Aircraft in the arctic. If anyone understands the challenges they face, it is commercial helicopter pilots. For each CCG aircraft operating in the arctic, there are many commercial machines operating.

 

Your post seems to acknowledge that they are doing something illegal (and they are aware of it). I can't say for sure what these pilots think, but I do know that I have demonstrated that this type of aircraft loading occurs regularly across VFR Heli ops in Canada. If you look back at my posts, you will see I am not picking on TC, but trying to demonstrate the culture that exists. If this truly is in non-compliance, then the issue is a systemic one. Individual enforcement action will do nothing to correct this widespread non-compliance; TC must identify the root cause and implement widespread long term corrective actions.

 

To infer that there are entire sectors of the industry who would be “willfully non-compliant” is in contrast to TCs own Enforcement Policy “Transport Canada's aviation enforcement policy recognizes the fact that “voluntary compliance” with the regulations is the most progressive and effective approach to achieving aviation safety. It is assumed that most people are rational, responsible, law abiding citizens in their own right and self-interest, and share an interest and commitment to the aviation community.” It seems to me that jumping to willful non-compliance conclusions is not at all consistent with this policy. I have provided TC with dozens of examples of non-compliance throughout our industry; to infer that these people are willfully non-compliant is to infer that the above statement is not true.

 

The fact that you point out that TCADS is not TCCA also seems to demonstrate the organizational issues at TC; while they may be a different division, they still fall under the responsibility of TC and the Deputy Minister of transport. If their own air operations don't know the CARS then TCCA is failing at fulfilling there responsibilities of monitoring and ensuring compliance throughout our industry.

[Freewheel]

As for getting "the wrong people in trouble". I am not the one who originally posted these originally posted these photos and Videos online. You can thank the Government of Canada (TC, the Canadian Coast Guard and Natural Resources Canada) fir posting these items online (supposedly showing these pilots conducting operations in violation of CARs 602.86 according to Yves Lemieux and Terry Long).

 

If these pilots truly do believe they are operating in violation of the CARs, they have no one to blame but themselves for getting in trouble.

[Freewheel]

I was going to post the track and balance scenario, but thought better of it thinking there must be some kind of exemptions for maintenance flights. I have in the past smoothed a rotor on an R22 with a Chadwick which does not support a 12 volt system . So I was in the A/C with a 24 volt battery between my feet, the DAU on my lap and the strobe in my hand. By the letter of the law i should have stuffed it all under the seat (stowed). It is however a little dangerous to try and get that equipment out in flight.

So...today we conducted a couple of take-off and landings, with Track and Balance equipment and strobe light held by an AME in front seat. This was completed under surveillance of several Transport Canada inspectors, and the flight was recorded. When they discussed with their superiors, they were advised that this was compliant since the flight was conducted under a conditional maintenance release.

 

Does anyone know where the CARs state you are not required to comply with the 600 series CARs when conducting maintenance test flights? If so, does it specify which other regulations aren't applicable when conducting a flight under a conditional maintenance release? By this reasoning it seems to me you could fly low over built area on maintenance test flights. Absurd.

[Phil Croucher]

But those flights were not public transport ones, either, Shirley?

 

phil