The opportunity to comment on the proposal for an Australian Aerial Firefighting Operators Manual is still open. We would welcome your input.

 

Background

The Civil Aviation Safety Authority (CASA), the National Aerial Firefighting Centre (NAFC), state and territory fire and land management agencies and the aviation industry have been working cooperatively through a number of regulatory and associated issues affecting aerial firefighting in Australia.  Some of these issues flow from inconsistencies in regulations and interpretation of regulations, as well as from varying operating practices between state and territory agencies and aircraft operators.

There has also been some inconsistency in the use of Operations Manuals by aircraft operators to properly guide their personnel in safe and effective service delivery of specialist operations. It would be fair to say that some aircraft operators use Operations Manuals very effectively, whilst others maintain manuals to meet a legal requirement (but may well still have good quality documentation elsewhere).

One of the proposals to partly address these issues is the development of some standard provisions for inclusion in the Operations Manuals of aircraft operators delivering aerial firefighting services in Australia.  These standard provisions would form an Australian Aerial Firefighting Operator’s Manual.

NAFC, state and territory fire agencies and CASA are of the view that the aircraft operator’s Operations Manual should provide the primary guidance to the aircraft operator’s personnel as to how to deliver aerial services safely and effectively. The Operations Manual should be clear, comprehensive and of a high quality. The Operations Manual must also, of course, be integrated with the operator’s other safety management and quality management systems.

The standard aerial firefighting provisions that would be contained in an Australian Aerial Firefighting Operator’s Manual are intended to assist aircraft operators to prepare high quality Operations Manuals.

A preliminary draft version of the Australian Aerial Firefighting Operator’s Manual has been produced to illustrate the concept and to obtain feedback and comment.  The preliminary version is available for download below (scroll o the bottom of the page).  This version of the manual would very much be intended as a first step.  At this stage the draft manual provides the absolute minimum content considered appropriate for inclusion in an aircraft operator’s Operations Manual.  It is planned to continue to evolve the document to a more comprehensive best-practice approach over time.

It needs to be stressed that the development of these standard provisions for inclusion in aircraft operator’s Operations Manuals is not the only measure being considered. A series of other actions, including regulatory change proposals, are also being examined and progressed.

The firefighting provisions are intended to provide guidance to aircraft operators and their personnel to operate aircraft safely and effectively. As far as practical, material that would normally be included in fire agency standard operating procedures, for which those agencies are responsible, has not been included but is referred to where appropriate. This also avoids duplicating sources of information and consequent issues with version control.  Inevitably however there is some overlap of information – this is particularly likely to occur, for example, where agency personnel may be involved as aircraft crew – such as in hover-exit operations.

 

Your comments

The manual is still in development and a preliminary edition available for download at the link below (under the FAQs) is a draft that has been produced for comment.   Comments from aerial firefighting operators are sought before finalising a first edition.

Your comments are invited on both the general concept and the content of the preliminary draft.

We would ask that you carefully read through the background information and the Frequently Asked Questions (FAQs) below before commenting.

Please email your comments to manual@nafc.org.au .   Some really useful input has already been received. There is no particular deadline for comment – further input is always welcome, but sooner rather than later is always best! This will help us to make sure that we can properly take account of your input in proceeding to the next step.

Some of the questions you might have about the proposed manual may be answered in the FAQs below.

 

As an Aircraft Operator, would I be required to use this material in my Operations Manual?

No, you may prepare your Operations Manual as you wish, provided it meets the requirements of the CASA regulations, but the material provided in the Australian Aerial Firefighting Operator’s manual does provide guidance as to the minimum standard of Operations Manuals expected by contracting agencies and by CASA.

 

How would I include these provisions in my Operations Manual?

This really depends on the structure of your existing Operations Manual and your business’s safety management and quality management systems. You could copy and include individual extracts at appropriate places in your existing Operations Manual or include the complete firefighting manual as an Attachment (with appropriate references in the Operations Manual).

 

What will it cost to use the Australian Aerial Firefighting Operator’s Manual?

The manual is provided as a service to the Australian aerial firefighting industry and there is no cost to Australian aircraft operators or foreign operators providing services within Australia.  The material may be reproduced freely by these aircraft operators for incorporation in their internal operational documentation and training material.  For other uses of the material, please contact NAFC.

 

What if I think my existing Operations Manual is already better and more comprehensive than the Australian Aerial Firefighting Operator’s Manual?

No problem, that is to be encouraged.  In the interests of safety and efficiency across the industry as a whole, we hope that you would be prepared to share the information for inclusion in future versions of the Australian Aerial Firefighting Operator’s manual.  manual@nafc.org.au

 

If I include the information in my Operations Manual, will it be automatically approved by CASA?

Whilst there is no automatic approval of Operations Manuals as such, CASA does intend to accept the Australian Aerial Firefighting Operator’s manual as suitable standard material for inclusion in Operations Manual.  This should certainly make the process of obtaining an AOC, or having your AOC amended, simpler and cheaper.

 

If I make changes to my Operations Manual to incorporate the firefighting provisions, will I need to get my Operations Manual approved again by CASA?  What will that cost?

CASA has advised that there are no additional costs charged by CASA to Operators when reviewing and enhancing their Operations Manuals.

 

I have identified an error or potential improvement in the manual......

Please do let us know at manual@nafc.org.au  

 

If all this material is incorporated in my Operations Manual, can I then be taken to task or prosecuted by CASA for non-compliance?

CASA has advised that it is not CASA policy to take punitive action where an operator is attempting to raise its standards above the minimum or where a contract requires a higher standard than the CASA minimum. CASA encourages operators to address risks by raising standards and is actively promoting the introduction of Safety Management Systems to drive this.

At the end of the day, once the material is incorporated in an Operations Manual, the procedures become that aircraft operator’s own procedures. An aircraft operator should always endeavour to comply with their procedures unless there is a good reason to do otherwise.

NAFC, CASA and state/territory agencies would be pleased to understand the reasons for any non-compliance and the need, if any, to modify or amend procedures.

 

Will contracting agencies require aircraft operators to use the Australian Aerial Firefighting Operator’s Manual?

Not necessarily. NAFC and state and territory agencies do consider that having a comprehensive, high quality Operations Manual, along with other systems, is important to an aircraft operator in ensuring safety and efficiency. These agencies are therefore considering appropriate future contract requirements in this regard. Contracting agencies are conscious however of not telling aircraft operators how to run their business or of getting directly involved in the regulatory side of things.

In the meantime, it is reinforced that the Australian Aerial Firefighting Operator’s manual does provide guidance as to the minimum standard of Operations Manuals currently expected by contracting agencies and by CASA.

 

The Australian Aerial Firefighting Operator’s Manual contains background and overview information that would not normally be part of a concise Operations Manual....

That’s true, but our experience indicated that there was a continuing problem with aircrew and other aircraft operator personnel fully understanding the context of firefighting operations.  This in turn has led to compromised safety and efficiency. On balance it was considered best to include the background information to assist aircraft operators in inducting and briefing their personnel.  

 

What’s missing, at this stage?

The first edition is pretty basic and really only includes the minimum guidance required. This will evolve over time.

Ideally future versions of the Australian Aerial Firefighting Operator’s manual will contain more guidance regarding aircrew and ground crew competencies, minimum experience requirements and currency where appropriate.  Consideration is currently being given to better ways of defining competencies for firefighting, rather than relying on minimum experience. This will be developed and included over time. In the meantime aircraft operators should ensure their Training and Checking system will provide their personnel with the competencies to undertake the required tasks safely.

If you think there are any other big topics missing please do let us know.

 

There is a conflict between the Australian Aerial Firefighting Operator’s manual and my current Operations Manual, or a conflict between the manual and state/territory agency standard operating procedures.

Aircraft Operators should routinely apply whichever procedure offers the highest level of safety.  Please do let us know of any conflicting procedures or opportunities to define the safest or best-practice procedure.

 

How will the Australian Aerial Firefighting Operator’s manual be reviewed or amended?

It is intended that development of the manual will continue after each fire season to improve procedures in the light of experience and where appropriate to further standardise procedures across Australia.  It is planned that a new consolidated version will be published approximately once per calendar year.  The latest version will be available for download at the NAFC website www.nafc.org.au

If any important safety-related issues are identified, new versions or amendments will be published in a timely manner.

Input from aircraft operators is vital to the continuing improvement process and we encourage you to provide feedback and suggestions to manual@nafc.org.au or info@nafc.org.au

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Download the current version of the Australian Aerial Firefighting Operator’s Manual by clicking on the document title under Downloads below.  To view the document you will need Adobe Reader, which is available for free by clicking here. (we suggest you untick the boxes that will download additional software along with Reader, unless you actually want that software…)