Annual proficiency checks

The relevant section of the regulations is Part 137. 240 which is available from the CASA website www. casa. gov.

au/aoc/ag.

Firstly, pilots in the employ of a Part 137 AOC holder must be checked by their chief pilot – now known as the head of flight operations or HOFO – or an ag ATO or a pilot who holds both a current instructor rating and a current agricultural rating (CASR Part 137. 240 (3)).

Secondly, pilots not in current employment and chief pilots or HOFOs can be checked by an ag ATO, a pilot who holds both a current instructor rating and a current agricultural rating, or a person who is entitled to conduct an aeroplane flight review for CAR 5. 108 (ie a CPL biennial) (CASR Part 137. 240 (4)).

If pilots have not completed 50 hours flight time in can conduct APCs (via their CAR 5. 108 biennial approval) – despite the fact they have no experience in application operations – is of concern. While ag ATOs are currently very active in providing an excellent service to cover as many pilots and chief pilots as possible, additional guidance material from CASA would have been very welcome.

The ability of a non-ag pilot to assess what an ag pilot needs to do in the low-level environment is compromised before the start of any check, and advice from CASA – developed in conjunction with AAAA and experienced ag pilots and ag ATOs – could still make a significant improvement to the role of the APC to aerial application safety.

The legal implications of a non-ag rated instructor engaging in a check at low-level should also be reviewed by CASA and advice provided to industry.

For example, a lot of the risk management proficiency that should be checked in an APC because of its fundamental contribution to safety could be embodied in a review of job planning before any flight. A non-ag instructor may not have the understanding of the industry to perform this sort of valuable assessment.

While AAAA is only too aware of why this flexibility was included in the regulation (ie the lack of ag ATOs in many areas), it is important for CASA to work with industry to fill the information and guidance gap for non-ag instructors application operations in the previous 12 months, then the APC must only be conducted by an ag ATO or a pilot who holds both a current instructor rating and a current agricultural rating. (CASR Part 137. 240 (5)).

The content of the APC must include the pilot demonstrating that they are familiar with the systems, normal and emergency flight manoeuvres, performance, fuel consumption rates and weight and balance requirements for an aeroplane that they fly (CASR Part 137. 240 (9)).

The regs note that an APC may be conducted by observation from the ground and may include a review of GPS datalogs, job planning and post flight records.

Importantly, the regs ensure that an APC for Part 137 counts as a replacement for the need for a biennial flight review for CAR 5. 108 (CASR Part 137. 240 (10)).

APC records are also required to be kept for 36 months by the operator.

If a pilot is found to have failed an annual proficiency check, appropriate retraining and re-checking must be carried out.

The intention of the annual proficiency check is a welcome addition to AAAA efforts over recent years to ensure that application pilots continue their professional development and maintain high flying standards throughout their careers.

However, due to the lack of ag ATOs in Australia (only about four active), the possibility that some checks may have to be carried out by instructors/schools who who may find themselves with a request to conduct a Part 137 APC.

The annual proficiency check provides an opportunity for business owners, chief pilots and pilots to ensure they are capable of operating at the essential high standards for aerial application operations. The APC should be embraced by all in the industry as another tool in our constant striving for improved safety.

At the end of the day, any opportunity to test the standards to which you operate as a pilot and potentially improve your performance helps tip the odds in your favour of ‘flying to come home’.

Senate Inquiry

AAAA made a detailed submission to the recent Senate Inquiry into CASA and gave evidence to the committee’s public hearing.

The heart of AAAA’s submission is the need for urgent improvement in CASA’s management systems to reinforce a cost-cutting drive that is essential to make CASA more responsive to industry needs.

See www. aph. gov. au and go to the Senate Committee on Rural Affairs and Transport – Inquiry into the Administration of CASA and related matters. o Australian Aviation is proud to be the official supporting journal of the Aerial Agricultural Association of Australia. The views in this column are those of the AAAA, and not necessarily Australian Aviation’s.