2022-04

RESPONSE to Safety Recommendation:

Operator’s second response to former AAIASB [now HARSIA] Safety Recommendation 2022-04 was received by email on 13/7/2023.

[Operator’s second response]:

“ According to the latest amendment Nr. 31 of OM-PART A, which was submitted to HCAA on May 23, 2023, the paragraph (5) in question was changed as follows:

(5) When a flight crewmember is required to operate a helicopter, following completion of a Type Rating (by an ATO) or the conversion course and the associated line flying under supervision, is not to be designated to commence a revenue or hired flight before he achieves the requirements on flight hours on the type as is referred below according to the total helicopter PIC flight experience.

(i) has achieved 20* flight hours totally on the type within a period of 60 days and performed at least 20* sectors, only for Cdr with less than 2000 flight hours as PIC on helicopters, as well as for Cdr not having previous experience on Single-Pilot Operations.

(ii) has achieved 10* flight hours totally on the type within a period of 60 days and performed at least 10* sectors, only for Cdr with more than 2000 flight hours as PIC on helicopters.

* (The amount of flight hours and sectors, which are referred on sub-paragraphs 5.2.1.B. (5)(i) & (ii) as above, is included into the Line Training during the conversion course of the Pilot).

b) The Company's Operating Manuals have been prepared and each new manual is issued as provided for in European Legislation (EU) 965/2012, following the structure according to article MLR.101 and the prescription of article MLR.100 and AMC 3 thereof.

The contents of the Manuals are in accordance with the provisions of the requirements of the applicable International, European and National Legislation, as well as with the terms and conditions of the Company's Certificates and Approvals, as described in the Statement of Compliance signed by the Accountable Manager (Compliance Statement in §1.6 of the Company's Organization Management Manual (OMM)).

The Company's manuals are subject to the following controls:

Internal audits at least two (2) times a year according to the Company's annual Audits Program by the Compliance Monitoring Manager.

Annual audits during inspections of the Company by APA Inspectors.

In addition, the Company accepts audits by external auditors for the benefit of our customers with high requirements but also for the benefit of our various partners in order to choose us for their air transport or for their cooperation with us respectively.

In case of :

- a finding during the above audits,
- change of Legislation,
- new HCAA requirements,
- changing the Company's procedures (Change Management),
- Identification of an ambiguity which needs to be clarified,

the competent Director of the Company's operational Sector, depending on the case, in collaboration with the Compliance Monitoring Director, proceed with the required Amendment and after the final approval by the Accountable Manager, the amendment is submitted to the HCAA in accordance with the procedures laid down in the Legislation.

Our Company will continue to work continuously to improve the image of its Operation Manuals in terms of compliance with the requirements of the applicable International, European and National Legislation, but also in terms of the clarity of the wording of their content. ”

[Hellenic Air and Rail Safety Investigation Authority (HARSIA) assessed this response on 10/8/2023 as "Adequate" and changed the SR 2022-04 status to "Closed" with the letter: HARSIA/1254/10.08.2023]


HISTORY:
Operator’s first response to AAIASB SR 2022-04 was received by email on 08/9/2022.

[Operator’s first response]:

“ You are kindly requested to read the following:

As it is referred on OM-PART A, §5.2.2 :

«5.2.2 Qualification to act as Pilot-In-Command/Commander
(ORO.FC.105 & 205)

“I Fly” shall only designate a flight crew member to act as pilot-in-command/ commander when he/she has:

5. Completed the “I Fly” Conversion Course, through a subcontracted ATO;
6. Acquired adequate knowledge of the route or area to be flown and of the aerodromes, including alternate aerodromes, facilities and procedures to be used;
7. Completed a Line Training
8. Completed the “I Fly” command course if upgrading from co-pilot to pilot-in-command/commander. »

and on OM-PART D / Appendix R, §1.2 it is stated:

1.3 « Command Course (ORO.FC.205)
For helicopter operations, the command course shall include at least the following elements:
(7) training in an FSTD, which includes line oriented flight training (LOFT) and/or flight training;
(8) operator proficiency check, operating as commander;
(9) command responsibilities training;
(10) line training as commander under supervision, for a minimum of:
(iii) 20 flight hours including at least 20 sectors, in the case of less than 2000 flight hours experience; and
(iv) 10 flight hours, including at least 10 sectors, in the case of more than 2000 flight hours experience;
(11) completion of a line check as commander and demonstration of adequate knowledge of the route or area to be flown and of the aerodromes, including alternate aerodromes, facilities, heliports, landing sites and procedures to be used and
(12) crew resource management training. »

According to the above, the criteria for assigning the duties to the Pilot-in-Command (PIC) are only mentioned in the Operations Manual Part A, while in the Operations Manual Part D only the Command Course is described, the completion of which is one of the conditions for the designation as Pilot in Command.

Additionally,

The minimum flight experience of the PIC for the undertaking of commercial flights is stated identically in OM-PART A, §5.2.1.B.HELICOPTERS (5) and in OM-PART D/ Appendix R/§1.1.( c )(5) , as below:

«(5) When a flight crewmember is required to operate a helicopter, following completion of a Type Rating (by an ATO) or the conversion course and the associated line flying under supervision, is not to be designated to commence a revenue or hired flight before he achieves the requirements on flight hours on the type as is referred below according to the total helicopter PIC flight experience.

(i) has achieved 20 flight hours totally on the type within a period of 60 days and performed at least 20 sectors, only for Cdr with less than 2000 flight hours as PIC on helicopters.

(ii) has achieved 10 flight hours totally on the type within a period of 60 days and performed at least 10 sectors, only for Cdr with more than 2000 flight hours as PIC on helicopters.

(iii) has achieved 100 flight hours on the type and/or in the role (no time limit);»

The above is a statement of the flight hours that the PIC must have completed upon completion of Conversion training and on-line training before being assigned the duties of PIC for commercial flights, recording the Company's policy to the strictest of Legislation which requires a minimum of ten (10) hours including a minimum of ten (10) flight sectors in accordance with ORO.FC.205 Command course.

As a conclusion, we believe that there is not any conflict between the OM – PART A and the OM – PART D of the company regarding the criteria for the assignment of Captain duties, as it is stated on the Safety Recommendation 2022-04.”

[Hellenic Air and Rail Safety Investigation Authority (HARSIA), with its document 455/07.04.2023, had assessed the first response as "Not adequate" and the status of recommendation 2022-04 as "Open", stating that the described corrective action is not acceptable because in paragraph (5) of page 4 of the addressee's corrective actions it is not clear that the reported flight hours take place in Line Training. Also, the addressee's first response did not specify what actions the Organization will follow in accordance with the issued safety recommendation.]