The opportunity to comment on the proposal for an
Australian Aerial Firefighting Operators Manual is still open. We would welcome
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.
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
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
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.
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.
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.
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.
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.
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
comments are invited on both the general concept and the content of the
would ask that you carefully read through the background information and the
Frequently Asked Questions (FAQs) below before commenting.
email your comments to firstname.lastname@example.org
. 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.
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?
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
What if I think my existing Operations
Manual is already better and more comprehensive than the Australian Aerial
Firefighting Operator’s Manual?
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. email@example.com
If I include the information in my
Operations Manual, will it be automatically approved by CASA?
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?
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 firstname.lastname@example.org
If all this material is incorporated in
my Operations Manual, can I then be taken to task or prosecuted by CASA for
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.
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
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.
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....
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?
edition is pretty basic and really only includes the minimum guidance required.
This will evolve over time.
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
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.
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
How will the Australian Aerial
Firefighting Operator’s manual be reviewed or amended?
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.
aircraft operators is vital to the continuing improvement process and we
encourage you to provide feedback and suggestions to email@example.com or firstname.lastname@example.org
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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…)