Air Operations Regulations – General Update to Helicopter Offshore Operations Part 1

Overview

The CAA is proposing to perform a general update to the Air Operating Regulations for offshore helicopters (Subpart K: Helicopter Offshore Operations) comprising a number of elements. This consultation relates to the following three elements which involve changes to the Implementing Rules:

1. Upgrade of survivability material:

Resulting from EASA Rule Making Task RMT.0120 for which UK CAA was a major driver and participant, ASD-STAN D12/WG02 Ditching Equipment was established to produce new, upgraded standards for emergency breathing systems (EBS), lifejackets, immersion suits and life rafts. The need for improved standards is set out in EASA NPA 2016-01.

This work has been completed and four new standards have been published in EN 4856:2023 covering EBS, EN 4862:2023 covering lifejackets, EN 4863:2023 covering immersion suits, and EN 4886:2024 covering life rafts. UK versions (BS ENs) of the standards have been published by BSi; the EBS, lifejacket and immersion suit standards include a national foreword relating to the need for a self-righting capability. It is understood that EASA will be publishing all of the EN standards in ETSOs.

It is proposed that the implementation timescale be set such that survival equipment meeting the new standards is effectively substituted as and when existing equipment requires replacement resulting in no significant cost to industry.

In addition, EASA RMT.0120 agreed to adopt the high visibility ‘chevron’ markings applied to the underside of offshore helicopter fuselages to assist location of capsized helicopters. It was agreed that these be applied via the air operating regulations as opposed to the Certification Specifications (CS 27/29). Most/all UK offshore helicopters already have these markings.

EASA is pursuing a similar rule making activity – see NPA 2022-11. The proposed EASA text has been adopted where appropriate.

2. Incorporation of Safety Directive SD-2022/001 - Offshore Helicopter Helideck Operations:

The background and justification for these initiatives is contained in the Safety Directive. It is normal procedure for the content of Safety Directives to be incorporated into the regulations, where appropriate, whereupon the corresponding Safety Directive is withdrawn. It is envisaged that the content of the Safety Directive will have been fully implemented before the Statutory Instrument (SI) is published, hence this update will not impose any additional cost to industry.

3. Addition of a requirement for the provision and use of an Aircraft Collision Avoidance System (ACAS):

For many years mid-air collision (MAC) has featured as one of the top seven (“the significant seven”) risks to civil aviation identified by the CAA. An internal CAA study produced in 2005 cited flight in uncontrolled airspace and mixing of civilian and military air traffic as two of the single largest factors associated with risk bearing Airproxes (during the 2001-2004 study period).

The majority of offshore helicopter operations take place off the north-east coast of the UK where both of these factors prevail. It is therefore proposed to add a requirement for ACAS II to the Air Operating Regulations in order to reduce the risk of MAC and align the regulations with current industry practice. Wording similar to the CAT.IDE.A.155 requirement for aeroplanes will be proposed for addition to SPA.HOFO.160 (new para. (d)) in order to ‘future proof’ the requirement.

Following a high profile very near miss between a military aircraft and an offshore helicopter in February 2004, all helicopters currently used for UK offshore operations are voluntarily equipped with ACAS, mostly ACAS II. Some aircraft are equipped with ACAS I, about half of which are already scheduled to be upgraded to ACAS II. A two-year period is proposed to allow time for all aircraft to be upgraded and to allow the costs to be spread.