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Carry-On Baggage Requirements

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Just ask the Inspectors if they plan to enforce this at 705 level as well. As soon as they hesitate, you know they are just confirming its BS.

I would say they have been enforcing it at 705 level (for passenger compartment anyway). The thing is, there is actually a Carry-on Baggage regulation in the 705 CARs. No such regulation exists in 702/703.Under 705.42 this interpretation would be correct under the CARs. The meansof restraint would also be required to have been approved by the Minister in accordance with Chapter 551 of the Airworthiness Manual.

 

IF 702/703 operations were meant to be held to this standard then there would be a regulation that states this. The CARs were meant to be written in plain langauge, so show me where it states that a person holding a purse isn't restrained to prevent shifting during take-off, landing and in-flight turbulence! As per 602 CARS, this is the only reason for restraint.

 

 

In a recent PVI I was told that according to this strictest interpretation of CARS passenger headsets and a pilots maps fall into the same category as the purse. This is an inspector who has firm beliefs on properly secured loads in the cabin. They were giving me the distinct impression though that they thought this level of enforcement was a bit much. Apparently the Eurocopter supplied map pockets are not secure enough and even a passenger wearing the headset is against the rules never mind hanging from the hooks. It does come down to the whole "belief" thing and the indiviual who is ramping you. I desperately hope that the number of practical inspectors out there are in the majority.

 

R

 

The Cabin safety Division allocates most of it's resources to 705 airlines (check their website, it states just that), and likwise the majority of Cabin Safety Inspectors have 705 airline background and experience. The only regulation appilcable to 702/703 is the 602 regulations which is a general operating rule.

 

IMHO, this new and extreme interpretation likely stems from inspectors wrongfully applying 705 standards to 702/703 operations.

 

Carry-on Baggage

705.42 (1) Every air operator shall establish a carry-on baggage control program that is approved by the Minister in accordance with the Commercial Air Service Standards.

(2) No air operator shall permit a person to carry on board an aircraft any carry-on baggage unless that baggage has been accepted in accordance with a carry-on baggage control program and can be

(a) stowed in a compartment or overhead rack that has been approved by the Minister in accordance with Chapter 551 of the Airworthiness Manual for the stowage of carry-on baggage;

(amended 1999/06/01; previous version)

(B) stowed under a passenger seat; or

© restrained by a means that has been approved by the Minister in accordance with Chapter 551 of the Airworthiness Manual.

(amended 1999/06/01; previous version)

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After a long telephone conversation with Cabin Safety Inspector Janice Berling, (about our November 25, 2012 ramp inspection) on February 19, 2013 I sent the first of many official requests by e-mail; Here it is:

Hi Janice,

Thank you; will resubmit the Cabins Safety Cards as well as the individual Live vest instruction cards that we will provide our passengers when conducting operations when life preservers are required.

I also had a question that I forgot to ask you yesterday.; it is with regards to Carry-on baggage, equipment and Cargo as per 602.86: Yesterday, when I discussed with Terry (and yourself), she mentioned that all cargo carried must go in the cargo compartment; I just wanted to confirm with you that carry-on baggage would be allowed in the cabin, if :

 

the cargo is “stowed in a bin, compartment, rack or other location that is certified in accordance with the aircraft type certificate in respect of the stowage of carry-on baggage, equipment or cargo;

 

or

 

“restrained as to prevent them from shifting….”, “the safety equipment, the normal and emergency exits are accessible to passengers”, cargo is “packaged or covered to avoid personal injury…” and all cargo “is stowed in such a manner to allow a crew member to effectively reach all parts of the compartment with a handheld fire extinguisher”.

 

Do you agree with this? The quotations are direct exerts from 602.86. There are other requirements in 602.86, however, I don’t believe they apply to our aircraft or operations.

 

Carry-on Baggage, Equipment and Cargo

602.86 (1) No person shall operate an aircraft with carry-on baggage, equipment or cargo on board, unless the carry-on baggage, equipment and cargo are

(a) stowed in a bin, compartment, rack or other location that is certified in accordance with the aircraft type certificate in respect of the stowage of carry-on baggage, equipment or cargo; or

( B) restrained so as to prevent them from shifting during movement of the aircraft on the surface and during take-off, landing and in-flight turbulence.

(2) No person shall operate an aircraft with carry-on baggage, equipment or cargo on board unless

(a) the safety equipment, the normal and emergency exits that are accessible to passengers and the aisles between the flight deck and a passenger compartment are not wholly or partially blocked by carry-on baggage, equipment or cargo;

( B) all of the equipment and cargo that are stowed in a passenger compartment are packaged or covered to avoid possible injury to persons on board;

© where the aircraft is type-certificated to carry 10 or more passengers and passengers are carried on board,

(i) no passenger's view of any "seat belt" sign, "no smoking" sign or exit sign is obscured by carry-on baggage, equipment or cargo except if an auxiliary sign is visible to the passenger or another means of notification of the passenger is available,

(ii) all of the passenger service carts and trolleys are securely restrained during movement of the aircraft on the surface, take-off and landing, and during in-flight turbulence where the pilot-in-command or in-charge flight attendant has directed that the cabin be secured pursuant to subsection 605.25(3) or (4), and

(iii) all of the video monitors that are suspended from the ceiling of the aircraft and extend into an aisle are stowed and securely restrained during take-off and landing; and

(d) all of the cargo that is stowed in a compartment to which crew members have access is stowed in such a manner as to allow a crew member to effectively reach all parts of the compartment with a hand-held fire extinguisher.

 

 

Thank You,

Chad Calaiezzi

Operations Manager

 

Ph#: (866)-572-5755

Fax#:(866)-572-5752

 

 

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Here is Janice Berling's reponse to my initial request. By the way according to Cabin Safety Inspectors, securing a purse in a seat with a seat belt is not compliant either. Her e-mail was cc'd to my POI, Cabin Safety Inspector Lisa Whitton and Technical Team Lead (Cabin Safety)- Terry Long:

 

Hello Chad,

 

As per our conversation earlier today, our legal department here at Transport Canada deems that a ground handler does not meet the intent of723.39(1) The standard safety briefing shall consist of an oral briefing provided by a flight crew member or by audio or audiovisual means….

 

Currently our standards branch is working on a National Exemption to address the issue. They are aware that the exemption needs to be put in place prior to mid-march and are working hard to meet that deadline.

 

Please continue with your CAP as we have discussed previously, as it on track with the intent of the proposed exemption.

 

As we discussed, currrently your Pilots are conducting the passenger brieifings.

 

In addition, I am confirming that securing a purse or anything else that is considered as carry-on baggage in a seat with a seat-belt is not permitted. The following information explains why securing items of mass to a seat using a seatbelt is a safety issue:

 

602.86 (1) No person shall operate an aircraft with carry-on baggage, equipment or cargo on board, unless the carry-on baggage, equipment and cargo are

 

(a) stowed in a bin, compartment, rack or other location that is certified in accordance with the aircraft type certificate in respect of the stowage of carry-on baggage, equipment or cargo;

Baggage, equipment and cargo that is transported in the cabin of an aircraft must be stowed and restrained in a manner that ensures continued compliance with the applicable operating regulations (such as section 602.86) as well as the standards of airworthiness specified in the basis of certification for the aircraft.

During initial certification of an aircraft, the applicant will demonstrate that each seat will restrain its occupant under the applicable ground, flight and emergency landing loads using the restraint system provided as part of the type design. For some designs this certification will also demonstrate the retention of under seat baggage where the design provides a restraint for this baggage.

Depending on the certification basis of the aircraft, the seat certification on older aircraft may be based on analysis and static strength tests only, while current standards also include testing under dynamic conditions and the measurement of occupant human injury pass / fail criteria.

If an applicant proposed to use a seat for other than its originally certified function he / she would have to demonstrate that the changed aircraft configuration complies with the applicable standards of airworthiness. As a minimum this will require a demonstration of compliance with restraint requirements, and all emergency features and evacuation requirements that may be affected. If an item of equipment required by the certification or operating regulations is intended to be restrained on a seat, additional considerations such as access and marking requirements may also be relevant.

Passenger seats and restraints are specifically designed and approved for the carriage and retention of human beings. As such, they permit the use of a restraint whose shape and flexibility provide adequate occupant restraint when exposed to the applicable load conditions. If objects, other than a person, are placed in the seat and the seat restraint is used for retention, it may require additional consideration to meet the applicable requirements in the basis of certification.

As indicated above, approval to use a seat for other than its original function of retaining an occupant will require a demonstration of compliance that the installation meets all applicable requirements in the aircraft basis of certification. Additional means to successfully restrain seat loaded baggage would almost certainly be necessary. Such means, and its installation in each aircraft in which it is to be used, shall be approved by, or on behalf of, the Minister (persons delegated with authority to approve on behalf of the Minister include Design Approval Representatives (DARs) and Airworthiness Engineering Organizations (AEOs).

 

Please let me know if you have any further questions.

 

Thank you

 

 

Janice Berling

 

Civil Aviation Safety Inspector - Cabin Safety / Aviation Occupational Health and Safety

Inspectrice de la sécurité de l’aviation civile - Sécurité dans les cabines et Santé et sécurité au travail dans l’aviation

Civil Aviation | Aviation civile

Transport Canada | Transports Canada

5431 Flightline Drive, Mississauga, Ontario L5P 1A1 | 5431, promenade Flightline, Mississauga (Ontario) L5P 1A1

[email protected]

Telephone | Téléphone 905-405-3295

Facsimile | Télécopieur 905-405-3305

Government of Canada | Gouvernement du Canada

 

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Hi Janice,

I am currently working on our pre-recorded audiovisual passenger briefing. I have some additional questions for you with regards to carry-on baggage. You have been quite adamant that no carry-on baggage whatsoever is allowed onboard the aircraft. I am forwarding my request for clarification on this (and your response) as an e-mail string below.

As you are aware, we have always maintained that CARs 602.86 allows for carry-on baggage if: restrained so as to prevent them from shifting during movement of the aircraft on the surface and during take-off, landing and in-flight turbulence.

(2) No person shall operate an aircraft with carry-on baggage, equipment or cargo on board unless

(a) the safety equipment, the normal and emergency exits that are accessible to passengers and the aisles between the flight deck and a passenger compartment are not wholly or partially blocked by carry-on baggage, equipment or cargo;

(B) all of the equipment and cargo that are stowed in a passenger compartment are packaged or covered to avoid possible injury to persons on board;

I also advised you that small carry-on baggage is regularly carried on-board throughout our industry (as long as the PIC deems it secured and it doesn’t block emergency exits. When you ramp checked GKRS you advised the pilot that placing a ladies purse on the floor behind her feet was not acceptable. The pilot felt it was secured and did not block exits. You also advised me over the phone that the only place you could legally put a purse in a Bell 206 is the hat rack or the rear cargo compartment (outside of the cabin). You, yourself follow this practice when flying in TC’s Bell 206.

As part of my audiovisual project I was researching the web for other operators who have created TC approved Passenger Briefings through “audiovisual means”. I came across Niagara helicopters’ video on YouTube; I assume this video was approved by your office. Please review video through the link below. At the 47 second mark it clearly states: “We suggest bringing only essential items like your camera on-board. Once on-board, remember to tie down any loose items to prevent them from interfering with other passengers or the pilot.” The video clearly demonstrates passengers holding packsacks on their laps (holding them tightly).

Can you confirm whether carrying a packsack on your lap is accepted practice and compliant with 602.86 (and all other relevant CARs)? From the guidance I have received from you so far, I am under the impression it isn’t. If it is we will require further clarification on what is and isn’t acceptable to be compliant.

 

http://www.youtube.com/watch?v=tWV-U1T0_2I

 

Thank You,

 

Chad Calaiezzi

Operations Manager

 

Ph#: (866)-572-5755

Fax#:(866)-572-5752

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Good morning Chad,

 

Thank you for providing me with the video you have found on You Tube, we at TC have not been provided with the video for review.

 

I am confirming that carrying a packsack on your lap is not in compliance with 602.86.

 

Thank you.

 

 

Janice Berling

 

Civil Aviation Safety Inspector - Cabin Safety / Aviation Occupational Health and Safety

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Sent March 21/13 (cc'd TC Inspectors Terry Long, Lisa Whitton, Jamie Bionda, Bill Turcotte & Fred Jone - Pres. HAC):

 

Hi Janice,

Thank you for the clarification. While TC may not have reviewed the video, I expect that, at the very least the company was asked to provide a script to Cabin safety (for review) to obtain approval to complete passenger briefings through “audiovisual means” in their Operations Manual (as was the case with Expedition). The script allows for certain items, and advises they must be tied down. From what you have advised me, there is no approved place to “tie down” baggage in the cabin. I find it hard to believe that TC has not reviewed the Passenger Safety Procedures of a high profile tour operator located in Southern Ontario; from I have been advised a TC review is required for approval. I suggest that quite recently, someone at TC believed that this practice as compliant with CARs 602.86.

 

I am in no way passing judgement on your interpretation or the operator who created this video. I am sure they, (and many other operators) believe this to be acceptable as per CARs 602.86. (Coincidentally, Niagara Helicopters is owned by Helicopter Transport Services, the only other helicopter company currently operating out of CYMO – our direct competitor).

 

I simply need to clearly understand what is (and isn’t) acceptable. In my opinion, TC’s current interpretation will have a significant impact on many operations and industry including Forest Fire Fighting, Forestry, Mineral Exploration, Aerial mapping, aerial inspection and surveillance, Aerial Photography,Wildlife Management, sightseeing etc.

 

1)Can you confirm that you are telling me that no items are allowed in the cabin of the Bell 206/206L/407 whatsoever (unless stored in the hat rack)?

I am currently communicating with our Bell representative. He has advised that he believes there are indeed allowances for cargo on the seats; he will respond to me with the weight limits for the seat. The Flight Manual lists acceptable weight limits for the floor at 75 lbs per square foot. The only question is what is an approved method of securing the load as per CARs 602.86.

 

2) This is also applicable at all times, whether passengers are onboard or not. Correct?

 

3) This is also applicable to aerial work under CARs 702. Correct?

 

4)The script clearly states “we suggest bringing only essential items like your camera on-board.”…Is a camera acceptable? Most passengers bring cameras (of varying sizes)

 

5)How about an infrared camera like used regularly on Forest Fire Contracts?

 

6)GPS? Laptop used for navigating/mapping/surveying etc.?

 

7) OMNR Map kit/ Fire Boss map kit/documents

 

8)Chainsaws and axes?

These tools are often loaded on aircraft when hover exits are required on forest fires and many other Air Taxi jobs (under exemption attached). In this case chainsaws and axes are often lowered or dropped to the passengers after they exit the helicopter from the hover; these tools are crucial to clear a landing area for the helicopter. In my experience, it has been at the discretion Pilot in Command to ensure the items are secured in the cabin to prevent from shifting and being a hazard (until they are required to be dropped). The PIC also has the responsibility to ensure exits are not blocked.

 

8)Net Gun/Tranquilizer gun used for animal capture…?

I could go on and on…

 

8) Are you able to provide me with another CARs reference or supporting documentation that supports your belief that a pilot cannot secure an item in the cabin or seat of the aircraft if it is not “stowed in a bin, compartment, rack or other location that is certified in accordance with the aircraft type certificate in respect of the stowage of carry-on baggage, equipment or cargo;”?

 

 

Regards,

 

Chad Calaiezzi

Operations Manager

 

Ph#: (866)-572-5755

Fax#:(866)-572-5752

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Sent to Bell Helicopters Representative Tom Grover March 25, 2013:

 

Hi Tom,

Further to our phone conversation last week , with regards to carriage of cargo/baggage in the cabin of Bell 206 Jetranger, Bell 206 Longranger and Bell 407, I am requesting information on this subject. At Todd’s suggestion, I am also cc’ing Richard Airlie. I believe the two were speaking last week with regards possible future aircraft acquisitions.

 

Currently, Section 6 of the Aircraft Flight Manual states that there is a Cabin Floor Load Limit of 75 lbs per square foot (Bell 206L), but I don’t see any specific discussion as to whether or not these aircraft are approved for carriage of baggage in the cabin.

 

I also notice that in the Bell 206L4 Product Specifications (Marketing Packages), Page 4 states the “Approximate Cargo Space: the Aft Cabin :2.2 cubic meters; LeftFront 0.6 cubic meters. Page 4 of the Bell 407 Product specifications states: Approximate Cargo Space: Aft Cabin 2.4 cubic meters, Left Front: 0.6 cubic meters.

We have been having a discussion with TC Cabin Safety in Toronto with regards to this concern and I have forwarded a string of e-mails that discusses the possible regulatory issue. I apologize there is reference to a couple of other topics in the e-mails, but I am sending the entire string to avoid the possibility of comments being taken out of context. The e-mails are below this one; start at the bottom and read up. In the e-mails we have received from TC, I believe the inspector is stating that the Bell 206L cannot carry baggage in the cabin based on the standards of airworthiness specified in the basis of certification for the aircraft. We believe that CARs 602.86(2) lays the responsibility on the Pilot in Command to ensureall of the equipment and cargo that are stowed in a passenger compartment are packaged or covered to avoid possible injury to persons on board”.

 

Some of the questions we have for Bell are:

 

  1. The marketing data and Product Specifications seems to imply that the aircraft is approved for carriage of Cargo in the cabin; is this in fact the case?
  2. Can Baggage or Cargo be placed on the floor of the aircraft as per the standards of airworthiness specified in the basis of certification for the aircraft?
  3. If so, is there a Maximum Weight that can be placed on the floor (or are we ok just to use the 75 lbs. per sq. ft rule).
  4. Can Baggage or Cargo be carried on the seats of these aircraft?
  5. If so, what are the limits?
  6. Do you believe a pilot can use a seat belt to secure small baggage in the seat to comply with CARs 602.86 (2)?
  7. If so, Limits?
  8. Can Cargo nets be secured to seat belt anchor points to secure baggage in the rear cabin?
  9. Do you have any other suggestions as to how cargo may be secured in the cabin?
  10. We are aware of the recently released SI for aft facing seats Cargo Tie down provisions, which permits helicopter operation to carry cargo and passengers in the rear cabin at the same time, but TC seems to be questioning the ability to carry cargo in the rear cabin ever based on “the standards of airworthiness specified in the basis of certification for the aircraft” (unless this SI has been carried out).The question is can we ever carry cargo in the cabin without BHT-206-SI-2051 being carried out? (i.e. even with no passengers).
  11. The SI, as you are aware, only covers the cargo on the mid-section seats. What about carriage of Cargo/baggage on REAR FWD facing seats?

Thanks,

 

Chad Calaiezzi

Operations Manager

 

Ph#: (866)-572-5755

Fax#:(866)-572-5752

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Sent To Bell Helicopters Representatives March 25, 2013:

Hi Tom and Richard,

 

Based solely on your past industry experience (of course), are either of you able to offer your professional opinion on how most operators in Canada transport all of their aircraft spares and operational equipment, when ferrying from job site to job site, in this series of helicopters (and others)?

I understand that cargo compartments and baskets are usually utilized (as is the case at Expedition),but due to the versatility of the helicopter and wide range of operational requirements, there is great deal of this cargo that must be transported. I am referring to cargo like Cargo nets, bambi buckets, longline, sling gear, ladders, aircraft fluids and greases, servicing and handling equipment, portable refuelling equipment, wash buckets etc…

 

 

Thank You,

 

Chad Calaiezzi

Operations Manager

 

Ph#: (866)-572-5755

Fax#:(866)-572-5752

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It has been pretty much industry standard practice to carry operational equipment, spares and personal baggage in the cabin if the baggage compartment is full when ferrying to and from the job site. In addition, you have to respect the maximum weight limits of the baggage compartment and normally operation gear, spares and personal baggage will exceed this limit so some has to be carried in the cabin. I would further suggest this applies to all makes and models of helicopters, not just Bell Helicopter products.

 

Regards

 

Tom Grover

Sr. Customer Service Engineer

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