AIRWORTHINESS COMMUNICATION

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1 SAFETY REGULATION GROUP AIRWORTHINESS COMMUNICATION 2009/08 Applicability: Owners and Operators of Commercial Air Transport Helicopters DEMONSTRATING COMPLIANCE WITH JAR-OPS AND ANO ARTICLE 19(8) WHEN CARRYING PERSONAL LOCATOR BEACONS 1 Introduction 1.1 Following an accident in the North Sea where the deployment and operation of Emergency Locator Transmitters (ELT) / Personal Locator Beacons (PLB) was required, the Air Accidents Investigation Branch (AAIB) made a recommendation to the CAA regarding the carriage and use of any radio location devices which do not form part of the aircraft s equipment. 1.2 This AIRCOM provides helicopter operators with guidance on the general considerations associated with the carriage of personal locator beacons and an acceptable means to demonstrate compliance with JAR-OPS and ANO Article 19(8). 1.3 Locator beacons used for compliance with the provisions of JAR-OPS and JAR-OPS must be EASA/CAA approved Emergency Locator Transmitters (ELT) and are not covered by this AIRCOM. All locator beacons that are carried for other purposes are to be treated as Portable Electronic Devices and for clarity are referred to as Personal Locator Beacons (PLB) in this AIRCOM. 1.4 Two possible (alternative) means of demonstrating compliance with JAR-OPS with respect to the carriage of PLBs are described in this AIRCOM. Section 4 details how this analysis may be achieved at an equipment level and Section 5 references the alternative processes necessary to achieve the equivalent by conducting tests at an aircraft level. 2 References JAR-OPS 3 CAP 393 ETSO EUROCAE ED-14F EUROCAE ED-62 EUROCAE ED-130 Commercial Air Transportation (Helicopters). The Air Navigation Order and The Regulations. European Technical Standard Order. Environmental Conditions and Test Procedures for Airborne Equipment. Minimum Operational Performance Specification for Aircraft ELTs. Guidance for the use of Portable Electronic Devices (PEDs) on Board Aircraft. RTCA DO-294C Guidance on Allowing Transmitting Portable and DO-307 (Cng 1) Electronic Devices (T-PED) on Aircraft. 1 of 8

2 3 Recommendations 3.1 The following aspects of PLB assessment are key to the safe and effective operation of the equipment: General Analysis Considerations It is not necessary for the organisation undertaking the analyses described in this AIRCOM to be an EASA Part-21 approved design organisation (DOA) Data Submission The helicopter operator should forward the data associated with the completed PLB carriage analysis to the CAA Assigned Flight Operations Inspector. The data should cover all types of PLB that have been assessed for carriage, including those that have been rejected as not being found compatible with the requirements of JAR-OPS Any data associated with future PLB assessments should also be forwarded to the CAA when completed. The CAA will keep a record of this data and make the non company-specific content of it available upon request to other helicopter operators intending to use the same PLB Required Reporting Action If a helicopter operator elects to use a PLB that has been shown to comply with this AIRCOM and subsequent incidents of inadvertent activation occur, a Mandatory Occurrence Report (MOR) must be raised. Further information on this may be found in CAP 382 The Mandatory Occurrence Reporting Scheme and AIRCOM 2009/06 European Requirements To Share Mandatory Occurrence Reporting (MOR) Data PLB Production Consistency Operators should satisfy themselves that PLBs assessed in accordance with this AIRCOM are representative of the equipment that the manufacturer will subsequently supply. PLBs are unapproved items and are therefore not usually available with an EASA Form 1 or equivalent release. In order to provide maximum confidence in the consistency of manufacture to a specific design, they should be procured from reputable sources, such as those holding Part-21 or equivalent approvals for the manufacture of approved aerospace equipment. In the absence of such approvals, evidence of manufacturing consistency such as certificates of conformity, Product Acceptance Test results etc., should be sought. Possession of an appropriate third party certification standard, such as AS9100 or an ISO9000 approval, with an appropriate scope, can be used to provide additional confidence. 2 of 8

3 3.1.5 Shelf Life and Extended Use Considerations Extended use or storage of a PLB may result in inadvertent activation, failure to activate or erroneous operation. Helicopter operators should seek the advice of the PLB manufacturers to determine the appropriate shelf life, the maximum carriage life and the appropriate maintenance programme for any PLB that will be carried. This information should be incorporated into the relevant procedures. The helicopter operator should also monitor PLBs for signs of damage, e.g: Deterioration of seals. Cracked casings. Illegible instruction label. Damaged switch guards. PLBs showing signs of damage that may affect their operation or activation shall not be carried Use of Approved ELTs as PLBs If the helicopter operator intends to use an approved (ETSO d) ELT as a PLB, then some credit may be possible for that existing qualification. The following considerations are then applicable: a) ED-62 is an equipment specification only. It does not infer any suitability or approval to fit onto a particular aircraft. b) In demonstrating compliance with ED-62, the ELT will have undergone some environmental qualification. However the following should be considered: not all of the environmental qualification tests in ED-14 are required by ED-62, some remain optional; the specified test categories may differ from those in this AIRCOM; ED-62 references an earlier version of ED-14 (ED-14C). A review of the manufacturer s data, such as the Declaration of Design and Performance (DDP) will be required to determine the extent of the declared environmental qualification and a comparison made with those listed in Appendix 1 of this AIRCOM. c) Manufacturers holding the ETSO authorisation will be approved production organisations. The consistency of manufacture to a controlled design configuration, as discussed in Section of this AIRCOM, can therefore be considered assured. 4 Determination of Unlikely Inadvertent PLB Activation 4.1 This Section describes how the helicopter operator can assess the PLB to determine whether it is likely to inadvertently activate. Should a helicopter operator elect to perform the equipment level analysis in accordance with this 3 of 8

4 Section, additional aircraft level testing as specified in Section 5 will not normally be required. 4.2 However, should a helicopter operator become aware of transmission characteristics associated with inadvertent activation of a PLB that could pose a significant hazard to their aircraft, the helicopter operator should undertake further analysis to determine whether or not the potential threat to airworthiness can be adequately mitigated. NOTE: Compliance with JAR-OPS 3.110/ANO Article 19(8) cannot be shown for PLBs that have the potential to significantly affect the overall airworthiness of an aircraft. 4.3 In demonstrating that the inadvertent activation of a PLB is unlikely, human factors and environmental factors should be considered. 4.4 Human Factors Aspects The PLB under assessment should be examined to determine that inadvertent activation is unlikely. For example, there should be no switches that could be operated unintentionally. 4.5 Environmental Test Conditions Appendix 1 lists the ED-14F environmental test criteria and provides guidance on which categories within them are considered to apply to PLBs carried in large rotorcraft and which are not. The listed environmental categories may be sufficient to complement an application for a no hazard, no credit carriage of these devices on a large rotorcraft and to assist in a demonstration that the PLB is unlikely to be inadvertently activated, nor present a hazard to the rotorcraft whist in its inactive state. An environmental qualification checklist has been provided at Appendix 2. 5 Aircraft Level Testing 5.1 In lieu of conducting the analysis at an equipment level, on-aircraft testing representative of transmitting PLBs may be conducted. These tests are performed to demonstrate that, should the PLBs be activated, the aircraft systems will not suffer from adverse interference effects as a result of the resultant transmission from inside the rotorcraft. 5.2 Guidance on testing to demonstrate the aircraft s tolerance to radio frequency transmissions from inside the aircraft can be found in industry documentation such as EUROCAE ED-130, or RTCA DO-294C and DO-307 (Chg 1). 5.3 If the PLB transmits on 121.5MHz it will also be necessary to show that the requirements of JAR-OPS 3.850(c) (the ability of the radio communication equipment to communicate on 121.5MHz) are still met. 4 of 8

5 6 Queries 6.1 Any queries as a result of this AIRCOM should be addressed to Airworthiness Strategy and Policy at the following address: Requirements@caa.co.uk Padhraic Kelleher Head of Airworthiness Date 18 September 2009 Recipients of new AIRCOMs are asked to ensure that these are copied to their 'in house' or contracted organisations, to relevant outside contractors, and to all members of their staff who could have an interest in the information or who need to take appropriate action in response to this Communication. Review Aircraft Certification September of 8

6 1 Applicable Environmental Test Conditions APPENDIX The following ED-14F environmental test categories are considered to be representative of the environment of a large, unpressurised rotorcraft operating offshore. When used as a basis for the environmental qualification of the locator beacon they should provide sufficient assurance that the locator beacon, will not inadvertently activate nor present a hazard to the rotorcraft whilst in its inactive state. 1.2 An alternative test (or set of tests) can be proposed where it can be substantiated that the following categories are not representative of actual rotorcraft operations and that the alternative test is appropriate. 1.3 Environmental test regimes other than ED-14F may be used if they can be shown to be equivalent. Section Environmental Test Category Explanation Of Category 4 Temperature & Altitude B2 Equipment that is operated in non-pressurized and non-controlled temperature locations on an aircraft that is operated at altitudes up to 25,000 ft (7,620 m). 5 Temperature Variation B Equipment that is operated in a non-temperature-controlled or partially temperature controlled internal section of the aircraft. 6 Humidity C Equipment that may be required to be operated under conditions such that it is subjected to direct contact with outside air for periods of time in excess of that specified for the standard humidity environment. 7 Operational Shock & Crash Safety B Equipment tested for standard operational shock and crash safety. 8 Vibration U Equipment to be operated in helicopters with unknown rotor related frequencies. If the vibration environment is known, and the relevant equipment specification requires a service life test, the robust test can be made to represent a service life test by adjusting the test levels and/or the test times using accepted fatigue scaling relationships. 9 Explosive Atmosphere A Env II Equipment to be operated in rotorcraft where, in normal operation, the temperature of any surface will not rise to a level capable of causing ignition, nor will any operating part cause ignition. Environment II is an atmosphere in which flammable mixtures can be expected to occur only as a result of a fault-causing spillage or leakage. Equipment shall meet the standards and test procedures for any one of the explosive atmosphere categories (paragraphs 9.4.1, or 9.4.3). 10 Waterproofness S Equipment operated in locations where it may be subjected to the forces of a heavy stream of fluid such as would be encountered in aircraft de-icing, washing or cleaning operations. 6 of 8

7 11 Fluid Susceptibility F Equipment operated in locations where fluid contamination could be commonly encountered. Testing to cover the relevant fluids identified in Table 11-1 of ED-14F. 12 Sand & Dust D Equipment that is operated in locations where it is subjected to blowing dust in the course of normal aircraft operations. 14 Salt Fog T Equipment that is operated in locations where it is subjected to a severe salt atmosphere, such as equipment exposed directly to external unfiltered air on hovering aircraft that may operate or be parked near the sea. 15 Magnetic Effect Z Compass safe distance of greater than 0.3m. 20 RF Susceptibility T Test level for equipment with moderate criticality intended to withstand the external RF environment.. 21 RF Emissions M Equipment that is operated in the passenger cabin where electromagnetic apertures are significant but not directly in view of radio receiver antennas. 24 Icing A Equipment that is operated in locations where it may be subject to the effects of external ice or frost adhering to it. 25 ESD A Electronic equipment that is installed, repaired, or operated in an aerospace environment. 26 Fire & Flammability C Non-metallic equipment, component parts, sub-assemblies operated in pressurized or non-pressurized zones and non-fire zones with largest dimension greater than 50 mm. 2 Expected Performance Under Environmental Test Conditions 2.1 The PLB should be subjected to the tests listed above in a non-transmitting state. 2.2 The PLB will be considered to have passed these no-hazard, no-credit tests if exposure to the environmental condition defined above does not result in PLB transmission. 2.3 Additionally, for tests 15, 20 and 26 the PLB shall have no effect beyond the limits specified in the tests. 3 Non-Applicable Environmental Test Conditions 3.1 The following ED-14F environmental condition test sections are not considered relevant to the subject locator beacon when carried onboard a large rotorcraft: 13 Fungus Resistance. 16 Power Input. 17 Voltage Spike. 18 Audio Frequency Conducted Susceptibility (Power inputs). 19 Induced Signal Susceptibility. 22 Lightning Induced Transient Susceptibility. 23 Lightning Direct Effects. 4 Removing the power supply 4.1 Alternative means that prevent inadvertent transmission of these devices such as removing/disabling the power supply may be considered. 7 of 8

8 Environmental Qualification Checklist APPENDIX 2 Section Environmental Test Category Pass/Fail Test Report Reference 4 Temperature & Altitude 5 Temperature Variation B2 6 Humidity C 7 Operational Shock & Crash Safety 8 Vibration U 9 Explosive Atmosphere B B A Env II 10 Waterproofness S 11 Fluid Susceptibility F 12 Sand & Dust D 14 Salt Fog T 15 Magnetic Effect Z 20 RF Susceptibility T 21 RF Emissions M 24 Icing A 25 ESD A 26 Fire & Flammability C Signature Company Position 8 of 8

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