FAQ n.137848

How are Personnel Carrying Device Systems (PCDS) approved?


Regulation (EU) No 965/2012 (Air Operations), CS 27.865 and CS 29.865 contain the definitions of “Simple PCDS” and “Complex PCDS”.

The following table summarises the possible post type-certification approval approaches for simple and complex PCDS:


Simple PCDS

Complex PCDS


Approval under Air Operations



  • Regulation (EU) No 965/2012 applies, in particular requirements NCO.IDE.H.100, NCO.SPEC.HEC.105, SPO.IDE.H.100 and SPO.SPEC.HEC.105.
  • GM 17 to  Annex I “Definitions” to Regulation (EU) No 965/2012 includes a list of existing available standards applicable to a simple PCDS.

Design approval / Certification


(as minor change)


(as Major Change to a Type Certificate or as Supplemental Type Certificate)

  • CS 27.865 and CS 29.865 define the conditions under which a PCDS is classified as complex and the requirements it has to meet in that case for the airworthiness certification.
  • AMC No 2 to CS 27.865 and AMC No 1 to CS 29.865  address the specificities of complex PCDS for human external cargo applications.
  • AMC No 3 to CS 27.865 and AMC No 2 to CS 29.865 contain a recognised approach to the approval of simple PCDS if required by the applicable operating rule or if an applicant elects to include simple PCDS within the scope of type certification.

The EASA Certification Memorandum EASA CM-CS-005 – Helicopter External Loads Personnel Carrying Device System is superseded by the above references

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