Notice of Proposed Amendment - Seaplane Operations - 2014

[trey kule]

Actually, the jettison-able doors make sense to me. The pfd wearing not so much.


The risk is there. But we have to stop trying to reduce all risk to zero. It just is not going to happen. Float planes will be involved in accidents. The nature of the flying. People will die. Sad but inevitable.

The last thing we need is the govt trying to find ways to save us from ourselves. Why not completely ban float operations, that way there would be no risk...

BTW...a big negative here on the egress courses. Amusement park ride, and the course info part could be put on a dvd and simply watched. IIRC they even admit it does not simulate the more critical parts of an accident in water. It is one of those neat things pilots like to do......and then justify as valuable.

Meat...I dont fly floats anymore, but I am with you. But I expect we will soon see high vis PFDs.n that way you will be seen walking aroung your float plane

[Big Pistons Forever]

BTW...a big negative here on the egress courses. Amusement park ride, and the course info part could be put on a dvd and simply watched. IIRC they even admit it does not simulate the more critical parts of an accident in water. It is one of those neat things pilots like to do......and then justify as valuable.

I would suggest that your opinion is not representative of the majority of people who have taken the course and I certainly do not agree with it. There are numerous testimonials as to its effectiveness by people who had to use the training for real.

[trey kule]

Probably you are right, but

1. A majority does not necessarily make it correct
2. I am entitled to my opinion,
3. Pilots love neat stuff...tailwheel checkouts, float ratings, upset courses, gliders, and all testify to how valuable it was...
4. I am weary of people trying to regulate common sense

In any event, disagreement is not an issue.......

[Meatservo]

I think I could get behind jettisonable doors. One of the types I fly regularly, NOT a floatplane, has them. They don't seem all that complicated.

I also took an egress course. It was kind of fun... maybe like a amusement park ride, I dunno. There was a part of it where we were bobbing in the water and had to put on the yellow inflatable vest and blow it up. That was interesting too. I kind of enjoy swimming, and I thought it was neat. Like Trey Kule says, it's hard to tell if something is useful if it's also fun.

BUT it makes a lot more sense than some of the other crap they're trying to shove down our throats like the stupid orange vests, and the various token "training" we all receive, in order to tick off boxes.

I bet that "not crashing" would save many lives in seaplanes, but if you look at any of the opportunities Transport Canada has to mitigate the risk of "crashing", it all costs money, or takes too much time away from flying the planes and making money, or would require more edumacation, or experience, or whatever, so instead they load us up with silly-looking clothing to make themselves feel satisfied that they did their best.

You want to make seaplanes safer? Start looking at the operators who pay based on mileage. Who don't give mileage-pay to pilots who turn around when they get into bad weather. Who don't pay pilots at all if they decide not to fly because weather or sea state is unsafe. Make a seaplane rating include some ground-school and give more instruction on seamanship, and weather, and tides, and the effects of wind around headlands and in fjords. Make modern instruments mandatory. Put a GPS-coupled HSI, standby horizon and a radar altimeter in all commercial seaplanes. Hire some more weather-observers for coastal areas.

All that stuff would reduce the carnage. Floatation vests are a case of closing the barn door after the horse already done runnoft.

BUT it would piss off the big operators, so instead let's just spackle another layer of plastic floating high-visibility shit over everything and everybody, so the lawyers will think we did something about the problem.

[trey kule]

When I think about these issues, I have to wonder why TC is involved at all. I am pretty certain that all these issues would have been raised in the operator's SMS program. Pretty sure TC must have seen it during their audits, were impressed by the proactive approach and action plan.

Perhaps, if there is an accident and the lawyers take the time to review the company SMS program , the lawsuits will convince some operators to spend a bit of money to save some lives.....or maybe not, if their SMS risk analysis did not find a justifiable reason to do any of these things...after all..they do cost money.

Or maybe, just maybe, the whole SMS is not the success story TC keeps telling the world it is. It should be the first step in resolving any concerns like this.

Meat you mentioned company names. Not sure that is cricket, or really fair to single one company out.
In any event, for any of these companies, one has to wonder how many pilots have brought the issue before the Safety management committee. Pilots bellyache alot. Take action very seldom. Hopefully some did take action, or maybe will. Documentation is a powerful tool.

[Meatservo]

You're right. I'll fix it.

I don't have much faith in the abilities of SMS to deal with the kind of systemic safety issues that cause seaplane accidents. SMS presupposes that everyone in the system is actually committed to improving safety and "doing the right thing", which is a pretty idea but awfully naive when you think of the difference between actually changing anything and just saying you're "committed to safety" at the morning tool-box meeting and wearing a reflective vest around the office. It would work perfectly in an imaginary world where every executive-level employee got out of his car in the morning with the intention to "do the right thing" being his only goal for that day. I think with big issues like equipment and training, they're always going to fall back on the regulator to prove they are following the rules, and the changes really need to happen at that level. Transport Canada, I think, is ultimately responsible.

[Edo]

I don't see a clear-cut definition of what a PFD is.

Does anyone have the new definition yet?

We all seem to picture a manually inflated Mustang style The NPA references recommendations from 2011 that include" "manually inflated PDF" strange there is not clear cut definition published in the current notice.

I don't even think the term PFD, is a good idea, the general public (and owners) will need some education on what is safe for a floatplane. Decades of boater safety education are going to be working against us when we tell them you cannot just grab your boating PFD.

Surprised our acronym laden regulator didn't come up with a new name.

[CD]

I don't see a clear-cut definition of what a PFD is.

The general operating rule for flotation devices is the following:

602.62 Life Preservers and Flotation Devices

(1) No person shall conduct a take-off or a landing on water in an aircraft or operate an aircraft over water beyond a point where the aircraft could reach shore in the event of an engine failure, unless a life preserver, individual flotation device or personal flotation device is carried for each person on board.

(2) No person shall operate a land aeroplane, gyroplane, helicopter or airship at more than 50 nautical miles from shore unless a life preserver is carried for each person on board.

(3) No person shall operate a balloon at more than two nautical miles from shore unless a life preserver, individual flotation device or personal flotation device is carried for each person on board.

(4) For aircraft other than balloons, every life preserver, individual flotation device and personal flotation device referred to in this section shall be stowed in a position that is easily accessible to the person for whose use it is provided, when that person is seated.

The standards of airworthiness for flotation equipment are found in Chapter 551 of the Airworthiness Manual:

551.401 Life Saving Equipment Over Water - Life Preservers
551.402 Life Saving Equipment Over Water - Individual Flotation Devices (IFD)
551.403 Life Saving Equipment Over Water - Personal Flotation Devices (PFD)

Constant wear devices are available on the market for each of the standards identified. However, all of these devices also have limitations associated with the demographics of the user, such as age and weight. For example, the UL1180 constant wear manually inflatable personal flotation devices that have become so popular in recent years (such as the Mustang line of PFDs) are restricted to users that are 16 years of age and older and weigh at least 80 pounds. I do not believe that there is a constant wear inflatable flotation device for younger users as in the marine environment (where these are intended for use), the intent is that these younger individuals wear inherently bouyant devices - not a good idea in an aircraft.

It is possible that there may be inflatable constant wear life preservers meeting the TSO for younger/smaller individuals; however, I suspect that such a market is likely very small and manufacturers are unlikely to produce them due to the cost.

If you do happen to find manually inflatable constant wear devices for younger/smaller individuals that meet one of the standards, please post an update.

As has been discussed in other threads, there is also a national exemption that permits the use of the PFD without the necessity of also carrying a TSO life preserver is found at the following link (the exemption will not be needed if the proposed regulation is eventually published):

EXEMPTION FROM PARAGRAPH 602.59(2)(b) OF THE CANADIAN AVIATION REGULATIONS

PURPOSE

This exemption permits operators of Canadian aircraft to use personal flotation devices that meet the applicable design standards specified in section 551.403 of the AWM, when a personal flotation device is carried for each person on board pursuant to section 602.62 of the CARs, notwithstanding the definition of “personal flotation device” set out in section 101.01 of the CARs.

APPLICATION

This exemption applies to an operator of a Canadian aircraft carrying a suitable personal flotation device for each person on board, depending on the size, body mass and age of the user, when conducting a take-off or landing on water or, when operating over water beyond a point where the aircraft could reach shore in the event of an engine failure. The personal flotation device shall consist of a design intended be donned prior to each flight and continuously worn or stowed in a position that is easily accessible to the person for whose use it is provided, when that person is seated.

[Edo]

CD Thanks for the info, 602.62 in my opinion is still not that clear cut in that no definition follows, even the proposed definition refers you to the Airworthiness Standards which in turn refer to to other industry standards.

I got as far into it to see that Subpart 51 has been repealed, but missed that Standard 551 has not, is this common during gazette changes?


I see the reference to UL1180 references Type II (manual inflations) but the another standard listed as acceptable is
CAN/CGSB-65.11-M88 , Personal Flotation Devices, published February 1988 and Amendments Nos. 1 through 3

I fould the info listed on the standards council here: https://www.scc.ca/en/standardsdb/standards/3567

CAN/CGSB-65.11-M88
Personal Flotation Devices

Applies to personal flotation devices (PFDs) intended for constant wear to
increase the safety of adults (persons with a body mass greater than 41 kg) in
situations where a risk of drowning exists. This standard covers devices that
are inherently buoyant (Type I) and those with combined buoyancy (Type II).

Status: Withdrawn
SDO: CGSB
Language: English
Publish date: 1988-02-28
Supersedes: 65-GP-11 (1972)
Keywords: MARINE SAFETY, BUOYANCY AIDS, SAFETY DEVICES, LIFE JACKETS, SPECIFICATIONS, DIMENSIONS, TESTING, LABELS, MARKING, CLASSIFICATION SYSTEMS
ICS Codes: 13.340.70;
Standard Number: CAN/CGSB-65.11-M88


So the underling standards council document refers to Type I - Inherently buoyant applies to adults above 41Kg.


The way i read this under the proposed amendment I can grab the PFD from the boat and constantly wear it. Please tell me this is not so.

[CD]

CD Thanks for the info, 602.62 in my opinion is still not that clear cut in that no definition follows, even the proposed definition refers you to the Airworthiness Standards which in turn refer to to other industry standards.

I got as far into it to see that Subpart 51 has been repealed, but missed that Standard 551 has not, is this common during gazette changes?

No definition is necessary as you can select any means of flotation that has been manufactured to meet one of the identified standards. This is not part of the proposed change, it has been this way since the ANO/Air Regulation days, before the CARs were published in 1996. The only difference being that the ability to select manually inflatable devices meeting the UL1180 standard was finally added to section 551.403 in 2009.

So the underling standards council document refers to Type I - Inherently buoyant applies to adults above 41Kg.

The way i read this under the proposed amendment I can grab the PFD from the boat and constantly wear it. Please tell me this is not so.

Actually, as I understand it, this is exactly why section 551.403 related to PFDs was originally added way back in the day - to permit the use of devices approved for use in the marine environment as an option to the more expensive devices approved for the aviation environment (TSO-C13 life preservers and TSO-C72 IFDs). GA pilots wanted something but didn't necessarily want to pay for the TSO'd equipment. Typically, the buoyancy provided by many of the CGSB PFDs was significantly less than the 35 pounds provided by inflatable TSO'd life preservers and IFDs. Most of the UL1180 inflatables also now provide 35 pounds, although without the self-righting ability of the TSO'd life preserver.

There have been discussions here previously about the use of "floater coats", many of which would meet the CGSB standard. Some of the discussions that included these (and the different points of view) can be reviewed at the following:

AvCanada: Have you taken an underwater egress course?
AvCanada: Change you can believe in !!!????
AvCanada: WATER OPS AND PFD'S
AvCanada: PFD advice.

[SheriffPatGarrett]

It's funny...way back when, in NFLD, we bought a surplus American military beaver(for $8,000!)
and all doors were jettisonable...to operate in Canada, we had to remove and change to hinges to DeHav standard...

Remember, in any crashes, Beaver and Otter doors jam tight, not to mention busted belly fuel tanks pissing fuel
all over red hot exhaust...We had a 350 pound Otter owner squeeze himself through the right cockpit window
of a burning Otter once...surprising how small a hole you will fit through is your ass is on fire!

You could alway kick out these DeHav doors if there was not these fixed front hinges...

[pilotidentity]

In these cold temps on the West Coast right now how many would survive in the water even if they did get out with life jackets on? Engine failures do happen in the turbine Otter and its just a matter of time before one quits over the Straight in high winds and heavy seas. Even a successful landing could have all in the water in a matter of minutes. There is no survival raft requirement. Why not? Turning a blind eye?