NCC.IDE.A.220 Flight Over Water / Life Raft

Christian Wolters • 18 May 2021

in community Air Operations

2 likes

Dear Community,

I´m currently struggling with the interpretation of the regulation NCC.IDE.A.220 Flight over water and the requirement to carry life rafts. Even my following question slightly drifts into continuing airworthiness, hopefully there is experts within this community able to advise and share own experiences.

Is, or is not a raft to be installed by a Part 145 or may it be placed/stowed in a appropriate position by the flight crew?

In my specific case it is our intention to have the raft placed onboard in case a flight is intended requiring the raft. Due to limited cabin size the raft shall be left at the base if not required for the intended flight.

The TC Holder has defined a suitable place for carring a raft by placing it on a side facing seat, just strapped/belted to it while this is not defined by the AMM. The position is defined by the cabin layout plan.

Now we are into an arguement with the regulatory authority that it is is, from our side, a misinterpretation of Part NCC to have it installed by a Part 145 MRO. This would mean the operator has to consult a MRO prior each flight if the raft is to be carried or not which makes it quite complicate. Common goal to carry a raft is to save lifes in case of. Having the carriage that strict regulated will lead to many operators avoid carrying one, isn`t it?

NCC.IDE.A.100 (a) requires equipment to be approved in accordance with the applicable airworthiness requirements if:

(d) installed in the airoplane.

Technically the raft is only stowed as mentioned in NCC.IDE.A.220 (d) (2) , ".. stowed so as to facilitate their ready use in emergency".

Looking forward to your expertise and operational experience.

Sincerly, Christian

Comments (10)

Winthir Brunnbauer • 2 years ago

Hi Christian,

I would argue in a way that your life raft is essential for the over water operation itself. However, it is not part of the installation of the aircraft (provided that this is correct; which would be your NCC.IDE.A.100(a)(4) ) and it will be taken along if it is necessary for the operation.

If you fly over artic areas for instance, you need to bring along further loose equipment (ice saw, blankets, etc.) which isn't a fixed installation either. Storage might be an issue, but if the TC holder described already how this should be accomplished.

By the way:
NCC.IDE.A.100
(b) The following items, when required by this Subpart, do not need an equipment approval:
:
(6) survival and signalling equipment;

Hope that helps a bit!
Cheers,
Winthir

Christian Wolters • 2 years ago

Dear Winthir, thank you very much for your feedback, much appreciated.
To avoid any misunderstandings, surival and signalling equipment indeed does not require equipment approval while Life Vests and Life Rafts are not considered survival equipment, thats why they come with an Form1 or equivalent.

Best Regards, Chrisitan

Stefano Anello • 2 years ago

Hi Christian,

It is CAMO and Flight Ops responsibility to decide to carry the life raft or not ( aircraft overwater flight not permitted, as you know ) but,remember, the life raft removal must be performed in accordance with the AMM (Life raft is listed in IPC and there is an AMM procedure for it - it is not listed as loose equipment, like AED or FAK).
That said, a pilot can't perform the task unless they get trained by a part 145 and they get a 145 limited approval for such a simple task.
To recap:
1 - CAMO/Flight Ops decide if the raft is to be carried or not before the flight.
2 -If raft has to be removed, then a techlog entry must be issued (and HIL opened as well, usually CAT D -120 days, depends on aircraft type)
3- Pilot can remove the raft ONLY if he has a part 145 approval (this approval will be limited to this task only - you have to speak with a Part 145 to have pilots included in their MOE for performing this task ONLY.
4 -Pilot can then open HIL as per company MEL after raft removal in serviceable condition.

That's completely legal to perform, the difficult part will be have the pilot trained and provided with a Part 145 approval.

Let me know if any other help is needed.

Stefano

Christian Wolters • 2 years ago

Dear Stefano,

thank you very much for your feedback, much appreciated. I missed to say that I` m actually a CAMO employee and together with the operator it is already evaluated that on very limited flights the raft needs to be carried. But with focus on the rare need, a flexible solution is needed. If the raft is to be carried just a couple of times a year, having open MEL items is not preferred. Having the operator to consult a 145 prior eacht flight to get a raft belted to the seat is a cost intensive an complex process.

I have checked the AMM carefully and it does not specify any installation or removal procedure. Thats what struggles me. Of course the raft is considered in the MMEL as well as an IPC item.

Bringing all of that together you see the complexity slightly changes with by its perspective.
I guess I will check with the TC-Holder again on the certification basis. Having the crew to be trained to open and close a pax belt is not my preferred way to continue. Hopefully my point is not seen as a grumbler but main goal is to have the crew and passengers being safe in case of an emergency the most easy and comfortable way, of course compliant to Part-CAMO and NCC rules.

With best regards, Christian

David Innes • 2 years ago

Hi Christian.
A potentially complex subject, but the need for a Part-145 may originate in how the installation was approved originally. If it was via the type design or a modification, then I can sympathise with your authority's view. The fitting (installation) and removal of parts in accordance with design data is a maintenance task (generally), unless the design approval holder explicitly states otherwise in the design data. But we both need to refer to a design /certification expert to take this further ...

Christian Wolters • 2 years ago

Thank you David,

I fully agree. I will check more detailed with the TC Holder.

Best Regards, Christian

Sergio Gonçalves • 2 years ago

Hi Christian,

I don't see why the crew cannot place the life raft on board! This is not a maintenance task as far as I know. Otherwise you will need your CAMO to issue a Work Order to an approved part-145 and there should be a Release to Service and an entry in the Techlog. This is not what is written in NCC.IDE.A.100.

It seems there is a confusion here between Flight Operations and the Maintenance Tasks on the life rafts (inspection and overhaul of the life rafts as per AMP and according to AMM, MPD, etc.). The NCC.IDE.A.100 regulation refers to Flight Operations and in summary says you must have a certain amount of life rafts on board prior a flight under certain conditions.

Also, the location and quantity of the life rafts depends on the cabin configuration and should be described in the Supplemental Maintenance Documentation.

You will need to do a HIL entry if the number of life rafts does not meet the MEL requirements (damaged or unserviceable life-raft). This is the only case where you will need a Part-145 to remove and install it onboard.

Now, if your CAMO believes there is a risk of damage to the equipment, then your crew should be trained to stow properly the life raft and that should be enough, but this is not a Part-M or Part-145 requirement.

I hope this helps.

Christian Wolters • 2 years ago

Dear Sergio,

Thanks for your input.
This is exactly what needs to be specified. Equipment intended to be installed need of course a approval for that installation (NCC.IDE.A.100 (a)(4)). But is a raft to be installed or just placed or stowed? The interpretation of "installed" drives the disprepance i guess.

It is not a issue to issue a WO and order the raft to be placed by the MRO but as mentioned with a previous comment on Stefanos input it quite escalates the complexity as prior each flight a raft is required to be carried on board a MRO is needed. This results into ferries to MRO and increased operational costs with no increasing safety. As long the unit is monitored in regards to TBO , e.g. the safety standard remains the same. Please correct me if im wrong. Thats in the end why I looking for the communities input.

Thanks again and best regards, Christian

Sergio Gonçalves • 2 years ago

Dear Chris,

I understand indeed the confusion with the word "installed". This is obviously the wrong interpretation of the wording.

Take the Flash Lights in the cockpit for example, they are also a piece of safety equipment "installed" in the cockpit. When the pilot uses it, can he put it back?! Yes, they do the preflight check and put it back.

Same for the fire extinguishers or portable O2 bottles. If the crew needs to check the gauges before the flight, which are often not visible, do they carry a maintenance action? No. They just stow it back in its position.

Now, if the flash lights are damaged or inoperative, then they must be repaired / overhauled by a part -145 and installed with a Release to Service.

Again, I don't understand such a restrictive interpretation of the word "install" for the life rafts, it just doesn't make any sense, see the example of the flash lights. This restrictive interpretation should be used ONLY for maintenance inspections and overhaul tasks. Not for normal flight operations.

But well, we could carry this discussion for ages. This is my interpretation and I'm sorry that I can't help you any further.
Sergio

Christian Wolters • 2 years ago

Hi Sergio,

thank you very much. In the meantime I have got official response from the TC-HOlder that the raft is intended to be installed by the crew and the raft, despite any equipment approval, is considered loose equipment. Hopefully this will satisfy the CAAs concerns and end the discussion.

@Everyone, thanks again for your professional inputs. Much appreciated.

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