Carry-On Baggage Requirements

[Winnie]

This can be said for other things as well.

 

Our principal inspector decided to monitor our training this year, so he came to our simulator sessions and "monitored" 4 training flights and 4 PPC's, then he sent another inspector to monitor, and he sat in on 6 or 7 PPC's as well, this with having an ACP in the sim as well.

 

Are they not trusting that the ACP is doing his job??

 

A tad over the top if you ask me, as well as putting additional pressures on the crews, this also cost a pretty penny, with overtime etc. One inspector was in Dallas over the Thanksgiving Weekend... Can't say he's not getting overtime pay.

 

One inspector went so far as to say that the schedule was not good enough, and actually demanded scripts for the PPC, multiples actually, but scripts according to the ACP manual are only required for 705 rides, which none of us are doing... Funny thing is that if we had done the PPC's in the aircraft all crews would have done exactly the same ride, but in the sim they had to be different, and they actually wanted us to vary the trips so that the candidate had not done the approaches before.

 

Arguments also ensued over which airport VISUAL scenery was approved for IFR flights, and to what "degree" of IMC the flights were to be conducted under.

 

The one inspector that came down for the second group actually admitted that they (4 inspectors) had come down for their own training and did their PPC's to an "unapproved scenery" airport. (They were from a different region)

 

How is that for regional disparity??

 

I am not against monitoring, I am actually all for total insight, but don't set additional standards, be it for lose items in the cabin, training hours, training standards or PPC standards. Certain inspectors need to get off of their "I am from the Government" horse, and stand back and remember that they once too were just mere mortals like the rest of us, and actually started out in industry as well.

 

Cheers

H

 

PS

Sorry for hijacking your thread Freewheel

[Freewheel]

E-mail sent to Director of Operations East, Yves Lemieux, Oct 24/13

 

Hi Yves,

Please see the link below to a video showing an MB105 being operated (by Transport Canada Aircraft Services Directorate on behalf of Coast guard).

The video consists of two passengers carrying cameras in their hands during both take-off and landing (recording throughout both).

Based on the guidance we have received from you by e-mail ( and re-confirmed over the phone 2 days ago), this is blatant noncompliance with 602.86(1).

I have cc'd terry Long and Ken Walsh, as I believe ken is the POI for this operator.

I will be reporting this non-compliance to enforcement this afternoon.

http://youtu.be/YXYFSnwvfZM

[Freewheel]

Sent to Yves Lemieux Oct 24/13

More TC ASD Non-Compliance 602.86?

while the bell 206 type certificate actually approves cargo in the entire cockpit/cabin by stating as per FM.

The BO 105 type certigicate clearly states maximum baggage: In small baggage compartment (20 KG/44lbs).

 

So I wonder how the Canadian coast guard restrains baggage in the cabin of their BO 105?

 

Check out the baggage loading in cabin at 2:35 mark of video.

http://youtu.be/xcGRHfOPX-w

 

Here is a screenshot along with another pic of someone exiting with carry-on

These items photos and videos will also be reported to enforcement this afternoon.

 

This is not a game.

 

[Freewheel]

Sent to Yves Lemieux Oct 24/13

More TC ASD Non-Compliance 602.86?

while the bell 206 type certificate actually approves cargo in the entire cockpit/cabin by stating as per FM.

The BO 105 type certigicate clearly states maximum baggage: In small baggage compartment (20 KG/44lbs).

 

So I wonder how the Canadian coast guard restrains baggage in the cabin of their BO 105?

 

Check out the baggage loading in cabin at 2:35 mark of video.

http://youtu.be/xcGRHfOPX-w

 

Here is a screenshot along with another pic of someone exiting with carry-on

These items photos and videos will also be reported to enforcement this afternoon.

 

This is not a game.

 

[Freewheel]

Sent to Yves Lemieux Oct 24/13

More TC ASD Non-Compliance 602.86?

while the bell 206 type certificate actually approves cargo in the entire cockpit/cabin by stating as per FM.

The BO 105 type certigicate clearly states maximum baggage: In small baggage compartment (20 KG/44lbs).

 

So I wonder how the Canadian coast guard restrains baggage in the cabin of their BO 105?

 

Check out the baggage loading in cabin at 2:35 mark of video.

http://youtu.be/xcGRHfOPX-w

 

Here is a screenshot along with another pic of someone exiting with carry-on

These items photos and videos will also be reported to enforcement this afternoon.

 

This is not a game.

 

[Freewheel]

Received from Yves Lemieux Oct 24/13

 

Thank you Chad for bringing this to my attention.

As you know, the process we follow when an apparent non-compliance is uncovered/observed, we bring it to the attention of the operator for action and if appropriate, request a Corrective Action Plan.

You have included Ken Walsh, ASD's POI. I will forward your email to the TTL responsible for ASD.

Yves

[Freewheel]

Sent to Enforcement Ontario Region October 24/13

 

I would like to report a Non-compliance with CARs 602.86(1).

 

Please review the e-mail and Youtube Video link below.

According to guidance we have received (from the Director of Operations East, Yves Lemieux and Technical Team Lead of Cabin Safety Terry Long), carrying a camera in your hand or on your lap during take-off and Landing (in a helicopter) is not in compliance with 602.86 (1).

 

Our organization strongly disagrees with this interpretation, however we will continue to report these violations to ensure our organization are being held to the same standard under the law, as all operators in Canada. I have provided (to Mr. Lemieux)dozens of videos and pictures of numerous operators (across the country) operating in similar fashion and in non-compliance with 602.86(1) (according to Yves Lemieux).

 

If Mr. Lemieux is correct, then widespread Non-compliance exists in the Commercial Helicopter Industry in Canada; it will also have a dramatic effect on helicopter operations in Canada. We feel he may shut down many helicopter operations operating quite safely today. It certainly makes a large portion of our operations impossible to conduct in compliance.

 

Systemic issues like this are rarely solved through individual enforcement action, however, we feel with TCCA’s inaction, we have no choice but report. We will be submitting dozens of reports to you (involving dozens of operators from all regions) over the next few days. I will also compile all of my communications with TC on this subject and forward them to you.

 

If you wish to review the communications that I have had with Transport Canada with regards to 602.86, please visit the following web link to a well-known helicopter forum, where pilots and other industry stakeholders have open and clear discussions. I have posted most of our communications on the forum.

 

Mr. Lemieux also refers to the issue within our industry as widespread Wilful non-compliance on more than one occasion. We feel this is contrary to your enforcement policy.

 

I would also suggest you review the comments from other pilots; I think it paints a good picture of what really is going in our industry.

 

Since the forum started, August 27, 2013, there have been 11000 views and 155 posts from pilots across the country in a variety of sectors.

 

The President of the Helicopter Association of Canada has also joined me in opposing this new and extreme interpretation from the Ontario Region; his e-mail is also posted on the forum.

 

If you have any questions or concerns, please don't hesitate to contact me.

http://forums.verticalmag.com/index.php?showtopic=21819&page=1

[flingwinger]

Chad, I support your cause but I do not believe reporting others to transport enforcement is a good maneuver. I can however see where you are coming from with the unfairness of the TC inspectors in your region and also support your demand for an answer. These new (interpretations) 'regulations' are unfounded and inconsistent with industry practices for decades. They will affect our industry in a negative way if they were to hold up.

[Freewheel]

Chad, I support your cause but I do not believe reporting others to transport enforcement is a good maneuver. I can however see where you are coming from with the unfairness of the TC inspectors in your region and also support your demand for an answer. These new (interpretations) 'regulations' are unfounded and inconsistent with industry practices for decades. They will affect our industry in a negative way if they were to hold up.

I understand your lack of support for reporting other operators. This is not normally the way we handle such situations. I normally could care less what happens at your organization...unless of course I'm losing business to you because TC allows you to operate differently than I.

 

We were advised by several inspectors during a recent PVI that the only way we would get this dealt with was to complete a flight with carry-on in front of them and record it. They would then call enforcement. We did such a flight with track and balance equipment and a camera held by a person in the front. They immediately called their supervisors who advised that because the flight was under a maintenance release it was compliant. They stated that had it been a commercial flight we would be non-compliant. I asked for a CARs reference that supported this claim... But they are unable to provide one. Why, because this is all BS.

 

We may consider such a flight in the future...but this getting expensive. It seems we can't get charged even if we try.! if so I'll post the flight and we will report ourselves. Would that make you feel better? It seems like a messed up system that requires a person self-incriminate himself to get an answer from TC.

 

My question to the inspectors was, why should I need to do this flight, I only need to check my competitors own websites and marketing material to find pictures and videos of these supposed no compliances you discuss. I didn't post these items publicly, the operators themselves did. Don't worry I won't be spying on your operations and reporting . No need to.

 

It should be an interesting week at the tribunal when the entire industry receives enforcement action. I'll buy the beer after if you guys can forgive me.lOL.

[Freewheel]

IMHO, if there is a CARs violation here it is to:

 

Requirements for Standards Incorporated by Reference

 

103.01 (1) This section applies in respect of standards made by the Minister and incorporated by reference into these Regulations.

(2) The Minister shall not make a standard or an amendment to a standard unless the Minister has undertaken consultations with interested persons concerning the standard or the amendment in accordance with the procedures specified in the publication entitled CARAC Management Charter & Procedures.