SACAA Roadshow – Part 93 and 91 Operations

A somewhat cloudy day, in Cape Town, heralded the last day in an around the country roadshow, hosted by the South African Civil Aviation Authority. The venue being the once great SAR&H sports complex in Observatory, run down over the years and now restored to one of the great conference venues in Cape Town.

With many people indicating their intentions to attend, it promised to be well attended. However, many people failed to arrive so a small group of about 30 people were present. Those that did not attend missed a great opportunity to interact with the CAA.

The presentation started promptly at 0900, with Piet Fourie welcoming those present and describing the day’s activities.

Part 93 – Commercial Aircraft Operators Certificate (CAOC) -was dealt with first. Claude Luthaga was first to address the audience and he gave an introduction of Part 93, dealing with the various requirements and definitions. He gave a few examples of when a Part 93 operation is required, or not required, as is the case. He answered a good few questions and cleared up lots of confusion. He completed his very good presentation with the recent changes and amendments to the Part.

Shakil Sayed followed, and he dealt with the requirements of hold to get and hold and maintain a CAOC. He spoke about how to apply, the various responsible personnel required and their job descriptions, who can be full time and who can be contracted in to help. This certainly cleared up a lot of confusion, for some of those present

He followed this with a description of admin duties required, requirements for operations personnel, as well as the need to establish one’s FDP and ensure it complies with the various legislation – and where to find that. That was followed by a short description of training programmes required for the various personnel within the Company and the importance of maintaining proper records and documentation for each process that is followed.

Interestingly, he mentioned that the CAA does not approve the CAOC – it accepts it. However an Operations manual is required to be approved. Questions were raised about the difference between accepting and approval of procedures. That proved very interesting and a lot of people learnt a lot of things about the two aspects. All in all, yet again another excellent presentation.

After tea, Piet Fourie addressed that participants about maintenance matters pertaining to Part 93 operations. The requirements to have a programme, as well as for it to be approved. They described in detail the procedures, who can do this, either in-house or how to contract it out. The importance of a maintenance control manual was discussed. From experience, they recommended such a manual be outside of the operations manual, the reasons being easier to amend and reduces the need to carry a huge operations manual with you. The importance of all maintenance staff being trained on how to follow procedures within the manual, in the correct and orderly sequences was also discussed.

Eric Du Rand followed, with a talk on Safety Management Systems (SMS). No direct reference is made to SMS within Part 93 or 135, however reference is made to Part 140. That addressed several attendee’s issues. He discussed the requirements for having one in a Part 93 operation and what is needed to be addressed – 93.03.3. Such a programme is, yet again, accepted by the CAA, not approved. The importance of having Safety performance targets was discussed and various options were described how to meet and attain and improve on these. He concluded his presentation of quality systems within Part 93 and how to investigate incidents and the need for an audit programme. A comprehensive quality system is a vital aspect of any operation, especially a Part 93 system.

Eric concluded his presentation with a comprehensive discussion on how the certification process is followed to obtain a part 93 certification. He dealt with every aspect, in great detail, from when you decide to apply, how one applies and all the resources available, from the CAA to assist you to get your, and once you have it, maintain your certification. The presentation was excellent and there was good interaction from the audience. It certainly cleared up any issues, those within the audience had.

That concluded the presentations about Part 93. It was a pity there were so few commercial operators there. Those present were most impressed with the frank discussions and all left feeling a lot more positive about this Part and how to get certified and all the various processes necessary.

Solomon Banda concluded the morning’s entertainment with a presentation of ramp inspections. It was comprehensive, detailing the need to have one, when they happen and how they happen. He worked through all the forms, what they are looking for, and how not to fear a ramp inspection! It was, yet again, another really good presentation. Contrary to many pilots’ beliefs he stated the CAA is not out to catch you, but their attitude is rather one of keeping the people on the ground safe. Several questions and queries were addressed, and confusion cleared up. An interesting question from the floor, was one of the SAPS doing ramp inspections at Upington airfield. The issue of can they do one and under what authority are they acting was raised. Interestingly, it appears they are also doing them at Polokwane and Kruger International. The CAA was not aware of these going on and Piet Fourie promised those present, the CAA executive would raise the issue with the SAPS and give feedback on this contentious issue.

Lunch followed and the River Club did not fail here!

After lunch matters turned to part 91 operations and several presentations, on pertinent issues were given.

The first was an excellent presentation by Danie Heath, an area controller at Johannesburg centre. He spoke on behalf of SASAR, he, being one of the senior search masters. His talk was a quality presentation about search and rescue, and it was a pity, so few pilots were there to listen to it.

He started by describing how a search is initiated, the various steps followed and processes done to look for a missing aircraft, right up to the time the wreck is located and then the search is wound down and completed. The amount of work involved is quite scary. Even social media is followed to obtain information!

He went on to highlight several problems and issues they have found over the years.

How many pilots know how to use their first aid kit? Have you ever opened it and tried to use it? Try it in flight and see if you are able to.

The need to carry an extra power pack with you and keep it charged. Nowadays many searches involve the use of mobile devices and they are useful to locate people and talk so. So keep an extra battery handy.

If you are stuck at your wreck at night, do not point your torch at the search helicopter. The chances are the pilot has night vision goggles and you will blind them. Rather point it to the ground around you. The crew will see the light pattern much easier.

On a lighter note, if you are going away for a few days, with your “wife” and you don’t want your wife to know, you need to plan to tell someone, so should you go missing, SASAR is able to find this out. So many calls have been made to missing pilot’s families for information and they did not know what the pilot was actually up to!

Did you also know, that in terms of legislation, conducting your own private search is illegal?

He went on to discuss protocols about social media and the need to not reveal names and types of aircraft on them, until there has been official statements released. This being done out of respect for families of the missing people. How many times to we read names of pilots and passengers involved, before their next of kin have heard, or the next of kin read about it from social media. NO NAMES EVER until official statements.

He concluded his presentation with urging pilots to always tell someone, either via a flight plan, preferably, or even a friend where you were going. Ensure that someone keeps track of your progress – preferably ATS and he highlighted the need to ensure you cancel your search and rescue, especially at small and remote airfields.

Claude Luthaga followed and addressed the issue of Airspace Infringements and the problems they pose. He highlighted his talk, with two short videos on aircraft that entered the Standstead and Heathrow CTR’s and the problems that arose. He addressed the means of how to reduce these, including proper planning, carrying accurate maps and speaking to ATC, when near controlled airspace. He advised those present that the CAA takes airspace infringments seriously, they are investigated and the necessary sanction will follow. He could highlighted the importance of maintaining situational awareness at all times.

Piet Fourie then gave a short and concise talk on maintenance issues and the problems that the CAA is finding. How many pilots know that when they take their aircraft to an AMO, they AMO will only do what they are told to do? So next time you blame the AMO for not doing something on your aircraft, rather look at yourself. Did you make a note of the snag in the flight portfolio and did you ask the AMO to look at it? He highlighted the need to keep accurate details of snags and to follow up on any action. The pilot in command is responsible for this and in general aviation, that is often the owner !!

Eric du Rand concluded the days entertainment with a fantastic, and entertaining, presentation called “The weakest link”. He gave a talk on human factors and gave some frightening statistics to illustrate his points. He discussed how accidents happen, whey they happen and then spoke about the culture of non-reporting and the need to get away from this.

Some stats he mentioned included:

Jan 2018-2019 56% of accidents were caused by flight crew

In the last 5 years, 47% of accidents can be traced back to poor airmanship or technique. In the past year, 18% of accidents were due to failing to maintain flying speed,16% of accidents were caused by failing to maintain directional control at take-off. 9% were as a result of disregard of regulations and/or procedures and Spatial disorientation caused 5% of the accidents.

These were some scary facts and the talk concluded with a very healthy and lively discussion about how to improve safety in general aviation. There was general consensus on many points and some differences on others. The highlights were:

- The role of the CAA and the need for it to encourage a safe culture

- The need for self-improvement and continuing learning, once you have attained your license.

- The desire to learn and improve of new policies, procedures and equipment.

- Airmanship – what it entails and how to become a better pilot

- Professionalism – even a general aviation pilot should act professionally at all times

- Honest self-reflection

- Making good judgement calls. When, how and what these involve.

- The need for a safety culture.

That concluded what can only be labelled as a truly successful day. The CAA deserves thanks for bringing down some excellent speakers, who gave some good and frank presentations. The venue was perfect and all those that attended it, left knowing that they had gained more knowledge, understood more about Parts 91 and 93 and that the CAA does care, believe it or not.

It was a pity that so few pilots, and indeed instructors, bothered to attend this presentation. They missed out on the opportunity to learn a lot more. Even more bothersome was the lack of attendance by some flying clubs’ personnel. Ones hopes that this is just an oversight, not an indication of their approach to general aviation.