Notice of Proposed Amendment - Seaplane Operations - 2014

[CD]

A new regulatory change proposal is available for comment on the CARAC Activity Reporting System:

Notice of Proposed Amendment 2014-016 - Seaplane Operations

Executive Summary

Transport Canada (TC) is proposing to enhance seaplane safety by mitigating the risk of drowning for occupants of seaplanes operated commercially for both air taxi and commuter operations. Proposed amendments to the regulations would require passengers and crew to wear a flotation device when boarding a seaplane or when operating on or over water and would require mandatory emergency underwater egress training for pilots of fixed wing commercial seaplanes.

These changes are expected to increase accident survival rates for seaplane occupants following water impact.

At the same time, TC is taking the opportunity to introduce a definition of seaplanes, remove the outdated definition of personal flotation devices and update other relevant sections of the Canadian Aviation Regulations (CARs).

Background

Currently, in accordance with subsection 602.62 (1) of the CARs, operators are required to have a life preserver, an individual flotation device or a personal flotation device carried on board for each person in the aircraft, but no person is required to wear it on or over water.

In November 2009, a fatal accident of a Seair Seaplanes Ltd. DHC-2 (Beaver) occurred at Lyall Harbour, British Columbia when the plane collided with water. Six passengers perished in the crash,while the pilot and one passenger survived.

In March 2011, the Transportation Safety Board (TSB) issued a final report into this accident A09P0397. The report contained two recommendations addressed to TC with respect to emergency exits and personal flotation devices:

* Recommendation A11-05 states that the “Department of Transport requires that all new and existing commercial seaplanes be fitted with regular and emergency exits that allow rapid egress following a survivable collision with water.”
* Recommendation A11-06 indicates that the “Department of Transport requires that all occupants of commercial seaplanes wear a device that provides personal flotation following emergency egress.”

In response, TC committed to consultations through a focus group. The focus group, comprised of representatives from the seaplane industry (operators and associations), aircraft manufacturers, and TC inspectors, met in August 2011 to determine mitigation strategy to improve levels of safety for commercial seaplane operations.

With regards to recommendation A11-05 about emergency exits, the focus group concluded that the implementation was not viable at the present moment. The estimated cost of retrofitting existing commercial seaplanes with regular and emergency exits that allow rapid egress following a survivable collision with water would be very high, to the extent that companies would not be able to afford the capital cost. However, the focus group recognized that it could be possible to enhance rapid egress on new type designs. As push-out windows may not be a suitable option for all aircraft, TC continues to examine what further actions can be taken to continue improving the safety of Canadians who travel by seaplane.

With regards to recommendation A11-06 and flotation devices, the focus group recommended that seaplane pilots should receive egress training to ensure that they are aware of the hazards that can impede escape from a sinking aircraft and that all occupants of commercial seaplane operations wear a personal flotation device.

In September 2011, the Civil Aviation Regulatory Committee (CARC) accepted the recommended risk control option recommended by the focus group.

Full proposal available here...

Comments are being accepted until September 12th, 2014.

[Big Pistons Forever]

It is a good start but it is too bad that jettisonable doors/windows were not mandated. There are certified solutions available now for the 2 most common float planes in use, the Beaver and the Otter, and a simple and easily certifiable solution is available for the C 180/185.

The Cessna 206 (AKA the crowd killer) is probably unfixable, but that airplane should have been banned from commercial float ops along time ago.

[Mr. North]

Well it's about time!!!

I remember sitting in on the annual TC road show back in the spring of '07 where they said these regulations were "just around the corner" and that operators should "get ready to follow them". They got an earful from all the operators of course... But at the time TC seemed pretty resolute in that the regs were coming, it was a shame to learn of them backing off (from the pressure?). Apparently more people had to die to prompt serious change.

I haven't flown floats in a while but when I did I always wore my Mustang PFD. I took a lot of heat from employers for that, and heard every excuse as to why I shouldn't wear it. Other pilots just thought I was a safety-twit... No longer. I'm glad passengers will now be required to wear them. How many times have you looked back at your pax load, all grey haired and arthritic, and realized that the only one surviving a water egress is yourself and maybe the dude sitting in the right seat? As is promptly demonstrated in any egress training, those packaged yellow PFD's are complete garbage in an accident scenario. At least now passengers have a fighting chance.

As for every pilot taking egress training, that's just common sense. It should be a requirement to obtain a float rating, with a 5 year re-currency there after.

[182-SS]

I'm not convinced that making passengers wear life jackets will save lives. And in a panic situation my money is on it actually ensuring multiple deaths as we all know people will pull that cord and inflate inside the cabin.

mandating the Door STC's on commercial would definitely save lives, and the egress training for the pilots would certainly save lives as well.

[Big Pistons Forever]

And in a panic situation my money is on it actually ensuring multiple deaths as we all know people will pull that cord and inflate inside the cabin.

I disagree as there is no actual evidence to backup your opinion. Has there been even one instance where a person wearing a life jacket that they had put on before getting in a light float plane, inflated it in the aircraft after the crash but while they were still inside the cabin ?

The research clearly shows that people's first instinct after the crash is to get out. The more complicated the "get out" process is, the less likely they are to survive.

[North Shore]

As for every pilot taking egress training, that's just common sense. It should be a requirement to obtain a float rating, with a 5 year re-currency there after.

Yup! Absolutely.

[fish4life]

Do you guys do egress training with the government flying the 415's? Or are they there own kind of animal in that sense?

[Meatservo]

I'm not all that interested in spending my whole day in the machine wearing something like that. I'll have to think about it some more, but I've just never really felt all that at-risk, at least during that part of my seaplane career where I flew off inland lakes over large tracts of forest. If I flew over the ocean or beyond gliding distance of land in a single-engine machine... maybe. Well, almost certainly.

It seems like everyone is trying to dress us up in something in order to perfunctorily address someone else's idea of where the actual danger lies. I'm not sold on this actually solving anything, but if you guys are I guess it's worth thinking about I suppose. Like I said, other than some West-Coast flying I have never felt really at-risk to be honest. I took the emergency egress course and found it useful.

I need to read some more about how many of the drowning victims in seaplane crashes over the years were actually safely clear of the wreck before drowning, versus how many died of drowning in the wreck. Is this information available? Maybe large kick-out doors will mitigate the risk posed by a PFD hampering one's ability to leave the submerged aircraft.

I don't think anyone's gonna catch me wearing one of those inflatable things all day long in the cockpit. It's going to bug me, I'm going to take it off at some point, and it's going to stay off. I guess I'm just one of those guys you can't teach. I still feel perfectly safe on the apron without one of those orange things too.

Maybe we could put our heads together and come up with some kind of padded pantsuit that will protect our bodies from the pavement if we roll it into a ball on the runway. The "hardness" of the runway is a real significant risk associated with crashing a landplane, too, not to mention the increase "fire-ey-ness" of land plane accidents. Maybe some kind of vest is available to help with this, like a suspender-like vest that sprays cool fire-retardant in your face after you safely make your egress from a crashed landplane.

Worth thinking about! Look at where the risk lies! You could lie awake all night thinking about it!

[North Shore]

Fish: yes, we all did an egress course about 5 years back, and all new-hires onto the tankers or Otters do it also. Not sure if well get a refresher. However, I've been doing some float training the past two winters, and that employer was kind enough to send me and all of my students to a course.
Meat servo: I wore a Mustang 'horse-collar' for the duration of that training, all ~360 hours of it, and never really felt constrained, nor aggravated enough to throw it in the back. Au contraire, on the rare days that I forgot it, I felt somewhat naked - the same feeling as when you walk out of your house without your wristwatch.

[Jonathan Goldsmith]

how many of the drowning victims in seaplane crashes over the years were actually safely clear of the wreck before drowning, versus how many died of drowning in the wreck.

According to the amendment only 20% of deaths occured outside the aircraft and not all of those were attributed to drowning.
This proposal will clearly anger some passengers.

[Meatservo]

Well, maybe it will anger some passengers. I wish that, before I am forced to wear yet more "safety" clothing, I could be convinced of its efficacy or relevancy. So many things these days are there to satisfy some bureaucrat's need to produce a solution to a problem that looks like a solution. Regardless of whether it really is one. The real world has been subsumed by the world of appearances and paperwork solutions. I see that it's impossible to look into whether more training, or better training, or higher experience requirements, or higher weather minima for coastal/mountainous vfr flight, or higher pay to retain more experienced guys, or better instruments, will affect safety to an appreciable degree without serious industry backlash. Better for everyone to just throw some kind of clothing at the problem and see if that spackles over the visible aspects of the problem. It's just a smokescreen to make it look like the people who are considered responsible for fixing the problem have done something. We, waddling around under layers of special "safety" clothing, are the pawns who have to suffer the constant petty harassment of other people who don't understand our jobs, trying to make their lives easier by pretending to help us. The real problem isn't drowning. The real problem is crashing. How many of those 20% you quoted were involved in an accident that happened to a high-time pilot on a nice day with small waves, good visibility, high ceilings and no wind?

[Mr. North]

You pose some valid arguments Meatservo. Don't get me started on hi-vis vests in the far north where I'm typically the only aircraft on the ramp. I'm pretty sure I won't run myself over!

Unlike hi-vis vests though, I think these modern PFD's are quite useful. I know what you mean when you say you don't feel "at risk" so why bother? It's rather cliché, but no one plans to have an accident. It's always "the other guy" who dumps it in the lake, yet this could very well be you or I one day (knock on wood). From my experience in egress training it's far better to be wearing your PFD than wasting valuable seconds searching for it under your seat while water pours in. You could also be injured during the accident sequence. A sudden impact with water could cause the control column to slam forward and break your hand. Would you be capable of searching for your PFD, egressing the aircraft, and extricating passengers with one good arm? I've tested these scenarios myself at egress training and it's not easy...

There will always be risk in what we do, and there's no way to legislate it out completely no matter how hard the government may try. That being said, I think these new regs have some merit. It should have been law long ago.

[Meatservo]

I guess since I already know I'm probably not going to wear one, I'm just trying to drum up a justification for my bad attitude.

I find choice of clothing to be highly personal. By all means, reduce government and company liability in the case of an accident by compelling passengers to wear them at all times. It doesn't even really matter if they die or not, because wearing the safety garments themselves reduces liability to the company and the government even if they do. That's why no-one is willing to seriously consider whether there is a risk that they will inflate the garment before leaving the aircraft: it simply doesn't matter. This rule is made to insulate desk-workers from liability. Not you, though: you still crashed a plane. You're liable anyways. Better hope the bureaucrats are right about the risk, because if they're not, you'll wish you HAD drowned.

You're also right, that everyone thinks it will never happen to them. But that's pretty much how ANY pilot is able to get out of bed.

They can make all the rules they want; I however will remove the vest, or the silly hat, or the reflectors, the minute the door is closed if they bother me and get in my way. Maybe I'll get used to it like North Shore did. Maybe I won't. I'll decide when the time comes. Until then, I intend not to crash, on wheels or on floats.

[Rowdy]

Why are four point harnesses not mandatory in the two front seats of 703 aircraft? Certainly the evidence is there to support that change.

Most of the drownings occur because the front seat passengers are unconscious from their little meeting with the dash or instrument panel. Myself included. Fortunately I did not end up upside down in the water or I wouldn't be here. I also wouldn't have two plates and a whole whack of screws if I had been wearing a 4 point..

I am however glad to see egress training becoming mandatory for commercial ops!

[Cat Driver]

Four point harness for crew would be a relatively easy retrofit for commercial airplanes.

Quick release doors are dog nuts simple to install and use.....hell my Cessna 150 Aerobat had them.

[182-SS]

And in a panic situation my money is on it actually ensuring multiple deaths as we all know people will pull that cord and inflate inside the cabin.

I disagree as there is no actual evidence to backup your opinion. Has there been even one instance where a person wearing a life jacket that they had put on before getting in a light float plane, inflated it in the aircraft after the crash but while they were still inside the cabin ?

The research clearly shows that people's first instinct after the crash is to get out. The more complicated the "get out" process is, the less likely they are to survive.

Your right I haven't provided "Actual evidence" to back up my opinion. And Neither have you......(to which you would reply with... Touche)

how many of the drowning victims in seaplane crashes over the years were actually safely clear of the wreck before drowning, versus how many died of drowning in the wreck.

According to the amendment only 20% of deaths occurred outside the aircraft and not all of those were attributed to drowning.
This proposal will clearly anger some passengers.

So according to this stat, only 20% of deaths are outside the aircraft. So here is a statistic for you, 80% are either already dead or didn't get out and died. What use is a life jacket if you cant get out. Even low profile ones, I have them so I know, they are bulky and get caught up in the seat belt and anything it touches.
better seat belts and quick release doors will save lives, and if they do that then yes having that life jacket once you get out will probably save many lives, but not until then.
I wholeheartedly agree with you on the Cessna 206, that is a death trap on floats for passengers.

So there is my Stats, and my opinion. I did start my last post with "I'm not convinced" but you cut that out of the quote. Yes I'll be the first to admit, or actually say Opinions can be wrong, but you have done nothing to support your opinion, and it is just that, your opinion.

[xsbank]

With 4 point harnesses you also need a headrest on your seat.

Meat, the PDFs are not uncomfortable, I wear one whenever I am outside on my boat and I have never been prevented from doing any work or maneuvers by it. As I don't fly floats any more I have never flown with one.

One fact about cold water, when you fall in it, if it is cold enough you have an uncontrollable gasp reflex, which generally means you drown. If you can pull the toggle, you might be able to recover. If you are working outside on the coast in the fall or winter, often there is nobody else on the dock with you as you pump your floats and clean the wings.

[CD]

Interesting observations on survival aspects in the NGAS CL415 accident report that was released on August 28th:

2014-08-28 - Overloading a central cause of 2013 water bomber accident on Moosehead Lake, Newfoundland and Labrador

Loss of control and collision with water
Government of Newfoundland and Labrador
Air Services Division
CL-415, C-FIZU
Moosehead Lake, Newfoundland and Labrador
03 July 2013

Summary

On 03 July 2013, at about 1415 Atlantic Daylight Time, the Government of Newfoundland and Labrador Air Services Division Bombardier CL-415 amphibious aircraft (registration C‑FIZU, serial number 2076), operating as Tanker 286, departed Wabush, Newfoundland and Labrador, to fight a nearby forest fire. Shortly after departure, Tanker 286 touched down on Moosehead Lake to scoop a load of water. About 40 seconds later, the captain initiated a left‑hand turn and almost immediately lost control of the aircraft. The aircraft water-looped and came to rest upright but partially submerged. The flight crew exited the aircraft and remained on the top of the wing until rescued by boat. There was an insufficient forward impact force to activate the onboard 406-megahertz emergency locator transmitter. There were no injuries to the 2 crew members. The aircraft was destroyed. The accident occurred during daylight hours.

1.15 Survival aspects

In 2011, NGAS provided flight crews with underwater escape training through the Fisheries Marine Institute of Memorial University of Newfoundland. This was a one-time opportunity, and there was no plan to incorporate this type of training on a recurring basis. The PNF recalled this training and used it during this accident.

The flight crew’s life vests were loosely placed in storage containers adjacent to each crew seat. After the aircraft came to rest, the PF’s life vest floated away and could not be retrieved.

The life raft was located in the rear of the fuselage, on the right side, opposite the rear cargo door (Photo 5). The raft was held in place by a ratcheting-type mechanism, which was not conducive for ease of removal. This mechanism had informally been identified by NGAS flight crew as a concern both in 2011 and again in 2012, at which time an alternate method of securing the raft in place was proposed. The ratcheting-type method of securing the life raft was still being used during the 2013 firefighting season.


The rear portion of the fuselage was partially submerged, and due to the difficulty gaining access to the life raft, the flight crew determined that it was unsafe to retrieve it.

According to NGAS’s Operations Manual, pilots are to receive instructions on the location and operation of all emergency equipment on an annual basis. Training aids, such as life preservers and life rafts, shall be available and relevant to the training program being presented. Where practical training is required, it is to be done during initial training and every 3 years thereafter. NGAS had not provided specific training on the operation of the life vests or the life raft, or on how to enter the life raft while in the water.

Aviation Investigation Report A13A0075

[xsbank]

Good to be talking about this stuff - pilots hate change, yet our whole entire flying careers are all about change. You'd think we'd be better at accepting it...

In my day, a "Crowd-killer" was a 207, and yes, the 206 is an asinine aircraft on floats. I have somewhere north of 500 hours on them, mostly floats, and I never felt good in the sucker, I was sure I would have an issue with the lack of a starboard door. I certainly got fed up with having to climb over or under the sucker to get to the right side. And don't mention the electric flaps and the stupid flap/door switch on the back doors. They should all be crushed.

[Taiser]

I'm doing my float endorsement right now and am wearing one of those inflatable jobs. Honestly I got no issue wearing it. I don't even notice I have it on after a few minutes. I'm also planing on egress training because I think it's a great idea. I DO have a problem with regs forcing people to do these in these instances. Lately it's gotten out of control. People aren't drowning every 5 minutes because a float plane flips!!!

Jettisonable doors? Really? You have to be kidding?? We are being regulated to death in this country... Over the top regulations and "Think of the Children!!" thinking is why I can't play lawn darts anymore...