European Aviation Safety Agency

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1 European Aviation Safety Agency Trevor Woods Director Approvals and Standardisation Cologne, 04 April 2014 TWDD/MVH/S(0) 2014(D)51689 UK HOUSE OF COMMONS TRANSPORT COMMITTEE Mrs Louise ElIman Chair Subject: Written evidence submitted by the European Aviation Safety Agency following the evidence session on 17 March 2014 Dear Mrs ElIman, The European Aviation Safety Agency (EASA) was pleased to have the opportunity to appear in front of the Committee s second evidence session on 17 March I have attached additional information that you requested regarding EASA s response to safety recommendations on the UK offshore operations. This is set out in Annex 1. Notably, concerning the 2009 G-REDL accident, four EASA Airworthiness Directives (Agency Decisions, mandating certain continuing airworthiness actions) and one Safety Information Bulletin were issued, together with an internal gearbox collector modification, all to inspect and to improve conspicuity of gearbox particle early detection and identification. Concerning 2012 G-REDW and G-CHCN ditching cases (main gearbox lower end shaft failure and emergency lubrication failure), eleven EASA Airworthiness Directives were issued; concerning the shaft, the following has been implemented: download of vibration health monitoring data and in-flight monitoring of vibration critical thresholds; shaft non-destructive inspections and cleaning; a currently ongoing redesign of an improved shaft; five modifications affecting the emergency lubrication system; and four ancillary other modifications. Taking account of the operational conditions and specificities of offshore operations in the North Sea, EASA, together with the Member States and industry, has developed a number of rulemaking tasks, some of which also directly relate to the safety recommendations listed in Annex 1. Annex 2 provides you with an overview of the different rulemaking initiatives in this area and their expected timeline. In fact, the UK CAA is the largest and a very active contributor to the EU-EASA rulemaking teams. Member States are an integral contributor and part of the European aviation safety system for which we have a very cooperative and productive working relationship. This is enabled by the EU Regulations in place assigning specific competences to the National Aviation Authorities, to EASA and the Commission. I have provided you with an overview of this system in Annex 3 describing the roles in more detail and thereby the Tel.: +49 (0) Fax: +49 (0) trevor.woods@easa.europa.eu TE.GEN kstai acklress: [tftdi , D50452 Cnbgne, Germany Visiting aldress: Ottophlx 1 D50679 Cobgne, Germany Td.: +49(0) Fax: 449(0) (7)9 F-niafl: Info@easa.eurupa.ai Webijie:

2 way the European system works towards a high and uniform level of safety across Europe including offshore operations. Finally, I would like to assure you that the recent recommendations contained in the UK CAA helicopter offshore report are currently being assessed by EASA in exactly the same way as any recommendation addressed to the Agency by an official accident investigation board. Our initial response to them will be provided this week. With this information I am confident that the EU Safety Framework encompasses offshore helicopter safety issues, and as a result will benefit not only the safety of the UK fleet but also those of other Member States with offshore operations. Yours sincerely, Trevor Woods Annex 1 Annex 2 Annex 3 EASA Response to UK offshore helicopter Safety Recommendations Rulemaking initiatives in the domain of offshore helicopter operations Civil Aviation Safety in Europe and the role of EASA 2

3 Safety Rec No. Recommendation Summary of actions taken UNKG It is Recommended that the European Aviation Safety Agency (EASA) EASA issued Emergency Airworthiness Directive evaluate the efficacy of the Eurocopter programme of additional inspections E on and enhanced monitoring and, when satisfied, make the Eurocopter Alert Service Bulletin mandatory by issuing an Airworthiness directive with immediate effect UNKG S1 It is recommended that Eurocopter with the European Aviation Safety EASA issued Airworthiness Directive E Agency (EASA), develop and implement an inspection of the internal dated 23 April 2009 (superseded since by EASA components of the main rotor gearbox epicyclic module for all AS332L2 and AD E on ). EC225LP helicopters as a matter of urgency to ensure the continued airworthiness of the main rotor gearbox. This inspection in addition to that specified in EASA Emergency Airworthiness directive E, and should be made mandatory with immediate effect by an additional EASA Emergency Airworthiness Directive. UNKG It is recommended that the European Aviation Safety Agency, in conjunction Safety Information Bulletin (SIB) No on with Eurocopter, review the instructions and procedures contained in the 21 August Standard Practices Procedures MTC section of the EC225LP and AS332L2 helicopters Aircraft Maintenance Manual, to ensure that correct: identification of the type of magnetic particles found within the oil system ol the power transmission system is maximised. - Annex 1 EASA Response to Safety Recommendations 01/04/ REW. - Crashed into sea following gearbox failure and rotor head separation. 16 POB - All killed UNK It is recommended that the European Aviation Safety Agency, in conjunction Design review performed in collaboration with with Eurocopter, urgently review the design, operational life and inspection Eurocopter,confirmingthevalidityofEASA processes of the planet gears used in the epicyclic module of the Main Rotor Airworthiness Directive E at that time Gearbox installed in AS332L2 and EC225LP helicopters, with the intention of (superseded since by EASA AD E on minimising the potential of any cracks progressing to failure during the ) service life of the gears.

4 Safety Rev No. Recommendation and Short Version of Reply Recommendation assessment - -- procedures UNKG It is recommended that the European Aviation Safety Agency (EASA) A test programme on Main Gear Box component re-evaluate the continued airworthiness of the main rotor gearbox fitted degradation modes was done by Eurocopter. In to the AS332 L2 and EC225 helicopters to ensure that it satisfies the addition, EASA is5ued Airworthiness Directive (AD) requirements of Certification Specification (CS) and EASA 2012-o129-E on Notice of Proposed Amendment UNKG It is recommended that the European Aviation Safety Agency require Rulemaking Tasks RMT.0249 (start date 2014, end date the trash sensor in helicopters, fitted to stop a Cockpit Voice 2016), RMT.0308 (start date 2016, end date 2019). Recorder in the event of an accident, to comply with EUROCAE j ED6ZA. - number UNKG2O11M34 It is recommended that the European Aviation Safety Agency (EASA) Audit of Eurocopter Design Organisation Approval review helicopter Type Certificate Holder s procedures for evaluating Part 21.A.3 are comprehensive and appropriately used. (DOA) in April EASNs audit confirmed that the defective parts to ensure that they satisfy the continued airworthiness manufacturer was able to demonstrate that its requirements of EASA Part 21A.3. for compliance with the requirements of UNKG be completed Mid The reported results will be published on the EASA website. It is recommended that the European Aviation Safety Agency research Launched research project Vibration Health methods for improving the detection of component degradation in: Monitoring and Alternative Technologies (Tender ehcopter epicyclic planet gear bearings. - EASA.2012.OP.13). The research projects will

5 Safety Rec No. Recommendation and Short Version of Reply Recommendation assessment UNKG It is recommended that European Aviation Safety Agency require: Design review performed. Improvements made to type in manufacturers of Emergency Locator Transmitters (ELTs)/Personal question. Other types are checked and found in : Locator Beacons (PLBs) units to add details, where absent, of the compliance. correct use of the antenna to the instructions annotated on the body of such beacons. - - amber 18/02/ REDU - Descended into the sea close to offshore platform. A/c remained afloat but tail cone separated and sank. 18 POB - All rescued. UNKG when the system is selected OFF, or a failure mimics this condition. This completes the other already existing system conditions that trigger indication of this alarm in case of inhibited, failed or inoperative TAWS. The retrofit of the fleet with the modification has been made available with Airbus Helicopters Service Bulletins No. EC dated and No. EC It is recommended that the European Aviation Safety Agency The EC225 TAWS system has been modified by Airbus requires that crews of helicopters, fitted with a Terrain Awareness Helicopters, providing upgraded design standard for all and Warning System, be provided with an immediate indication newly produced EC225 helicopters. Among various design when the system becomes inoperative, fails, is inhibited or selected improvements, it provides lighting command of the TAWS OFF. light of the helicopter Caution and Warning Panel dated UNKG It is recommended that the European Aviation Safety Agency: Review performed and EASA accepted a means of reviews the acceptability of crew-operated ON/OFF controls which deselecting such a system but only with certain conditions. can disable mandatory helicopter audio voice warnings. UNKG It is recommended that the European Aviation Safety Agency ensures that helicopter performance is taken into consideration when determining the timeliness of warnings generated by Helicopter Terrain Awareness and Warning Systems. EASA is awaiting results from studies which may allow redefining the Helicopter Terrain Awareness and Warning System (HTAWS) standards, especially for offshore operation, as the report FDP-CAA-Report Report for UK Civil Aviation Authority on Class A Terrain Awareness Warning System (TAWS) for Offshore Helicopter Operations, which is currently interim and hence subject to change.

6 -- Safety Rec No. UNKG-2O ½.4 I Recommendation and Short Version of Reply It is recommended that the European Aviation Safety Agency reviews the frequency of nuisance warnings generated by Terrain Awareness and Warning System equipment in offshore helicopter operations and takes appropriate action to improve the integrity of the system..,.. _j... K r. Recommendation assessment EASA is involved in the UK CAA-run joint industry Helicopter Safety Research Management Committee (HSRMC) research programme. The project EGPWS Warning Envelopes comprises the development of improved classic model EGPWS warning envelopes for offshore helicopter operations, and effectively addresses a number of AAIB safety recommendations. So far, based on flight data, revised and new warning envelopes have been tested and have demonstrated a worthwhile improvement in performance in terms of warning time and improved nuisance alert rate. An interim report has been circulated in February Following this, the project was successfully extended to cover a second helicopter type. The next step in the project will be to examine the form and format of the associated warnings. In addition, further simulator trials are envisaged. Progress on these areas will be subject to availability of resource/funding. EASA monitors the project progress as member of the HSRMC. The final report will be published once available.

7 UNKG r It is recommended that the European Aviation Safety Agency modifies Potential safety benefit not supported by SAE 5- European Technical Standard Order (ETSO) 2C70a and ETSO 2C505 to 9A Safety Equipment and Survival Systems H include a requirement for multi-seat liferafts, that do not automatically deploy; Committee work. their Sea Anchor, to include a label, visible from within the inflated liferaft, reminding the occupants when to deploy the Sea Anchor. Safety Rec No. Recommendation and Short Version of Reply Recommendation assessment UNKG It is recommended that the European Aviation Safety Agency, in conjunction See UNKG with the Federal Aviation Administration, defines standards governing the content, accuracy and presentation of obstacles in the Terrain Awareness and Warning System obstacle database for helicopters operating in the offshore environment. UNKG EASA supports EUROCAE activity to review ED- 112 on parameters to be recorded. It is recommended that the European Aviation Safety Agency establishes the Rulemaking Task RMT.0308 will address the feasibility of recording, in crash-protected memory, status indications from update of the flight parameters list (start date each avionic system on an aircraft. 2016, end date 2019). UNKG It is recommended that the European Aviation Safety Agency considers: Rulemaking task RMT.0120 addresses this amending certification requirements for rotorcraft, that are certified in recommendation. Both future and retroactive accordance with ditching provisions, to include a means of automatically certification requirement are being considered. inflating emergency flotation equipment following water entry. See Annex 2 for details on RMT UN KG It is recommended that the European Aviation Safety Agency requires Eurocopter to review the design of the fairings below the boarding steps on A5332 and EC225 series helicopters to reduce the possibility of fairings shattering during survivable water impact and presenting sharp projections; capable_of damaging_liferafts. EASA requested Airbus Helicopter to confirm that the failed fairings comply with the certification structural ditching provisions and assess whether they could even demonstrate higher structural resistance. Airbus Helicopters have provided a report, dated 2013, by which they show positive safety structural margins on the fairings to ultimate loads of the certification ditching conditions (CS & 801 requirements), i.e. using a 1,5 safety factor.

8 Safety Rec No. Recommendation and Short Version of Reply Recommendation assessment UNKG : It is recommended that the European Aviation Safety Agency, in conjunction Rulemaking tasks RMT.0120 includes investigating with the Federal Aviation Administration, review the design requirements and multiple facets of the problem, including advisory material for helicopters to require delethalisation of the fuselage tol structural design aspects and possible expansion prevent damage to deploying and floating liferafts following a survivablej of the ditching envelope. See Annex 2 for details - water impact. on RMT UNKG2O1FO71 It is recommended that the European Aviation Safety Agency reviews the Rulemaking tasks RMT.0120 addresses these : location and design of the components and installation features of recommendations (See Annex 2 for details on Automatically Deployable Emergency Locator Transmitters and Crash RMT.0120). Position Indicator units, when required to be fitted to offshore helicopters, to ensure the reliability of operation of such units during and after water impacts UNKG It is recommended that the European Aviation Safety Agency ensures that a EASA involved in working groups 59 (Cabin Safety) requirement is developed for all emergency equipment, stowed in deployable of the SAE (Society of Automotive Engineers). survival bags, to be capable of being easily accessed and utilised by the Inputs on survival equipment are included and gloved hands of a liferaft occupant whilst in challenging survival situations form the basis for CS-ETSO amendments (C13f, when a liferaft may be subject to considerable motion in cold, wet and dark c69c and 2C7Oa). conditions.

9 10/05/2012 G-REDW - Ditching following gearbox oil pressure warning. 14 POB - All rescued. Safety Rec No. Recommendation and Short Version of Reply Recommendation assessment UNKC It is recommended that the European Aviation Safety Agency requires Eurocopter to review the design of the main gearbox emergency lubrication system on the EC225 LP Super Puma to ensure that the system will provide the crew with an accurate indication of its status when acuvated. I I The root cause of the in-flight EMLUB false alarm was identified in wiring discrepancies between the electrical outputs of the Air & Glycol pressure-switches of the EMLUB system and the helicopter wiring harness connecting the switches to the EMLUB electronic card. This design non-conformity only existed on helicopters equipped with pressure-switches manufactured by one sensor supplier. Additional investigation revealed that the average engine bleed air pressures for the EMLUB air circuit were lower than the certified design; this might bring a potential for triggering the Air and Glycol pressure-switches thresholds in some marginal flight conditions. To address the issues, Eurocopter designed a batch of modifications, which restore safe operation of the EMLUB system for the full EC 225 LP flight envelope, consisting in the introduction of a new glycol pump, new Air and Glycol pressure-switches, wiring harness modification and improved EMLUB electronic board. The above is mandated via AD , which supersedes previously issued EASA AD and AD F, and requires a new amendment of the REM_emergency procedures.

10 Safety Rec No. Recommendation and Short Version of Reply Recommendation assessment UNKG It is recommended that the European Aviation Safety Agency EASA issued on 17 January 2014 the AD requires the manufacturers of aircraft equipped with a Type , regarding the Crash Position Indicator 503 Crash Position Indicator system, or similar Automatically Deployable Emergency Locator Transmitter, to review and System (CPI). amend, if necessary, the respective Flight Manuals to ensure they contain information about any features that could inhibit [automatic deployment. 22/10/2012 G-CHCN - Ditched following indications of MRGB lubrication failure. 19 P08 - All rescued.

11 Annex 2 Rulemaking initiatives in the domain of offshore helicopter operations. Proposed changes to Certification Specifications (CS-27 & CS-29) related to Ditching, water impact and Occupant Survivability. Following the creation of the Agency, some on-going helicopter ditching related rulemaking and research activities being performed by UK-CAA and Joint Aviation Authorities (JAA) were transferred to the Agency. Proposed rule changes that were already mature and could be easily implemented were immediately progressed by the Agency, culminating in changes to advisory material (FAA AC Change ), and formally adopted in EASA CS-27/29 at Amendment For other proposals, Task 27/ (later identified as Rulemaking Task RMT.0120) was created on the Agency s rulemaking inventory for planning and monitoring purposes (see below). Regulation on Air Operations Commission Regulation (EU) No 965/2012 on air operations already covers helicopter operations in different hostile environments, like off-shore operations. They also include the requirement for the aircraft operator to have a safety management system and ensure that the personnel receive continuous training according to their operating environment. However, these rules are not yet applicable in the UK, as the UK, alike other Member States, filed a general derogation to these rules until an available opt out period ends. These common rules will generally apply in the UK as of 28 October It is worth noting, though, that the UK has declared the intention to continue to apply national requirements to helicopter off-shore operations, following the provision of article 6(4) of Regulation (EU) No 965/2012. Regulation on Operational Suitability Data (OSD) The implementing rules on OSD were recently introduced by European Union (EU) Regulations No 69/2014 (Part-21), No 70/2014 (Aircrew) and No 71/2014 (Air Operations) being effective as of 17th February 2014 with the objective that the aircraft manufacturers are required to establish certain data that is considered important for safe operation of the type. This data will then be approved by the Agency under the type certificate and shall be used by operators and training organisations. Draft Regulation on Helicopter offshore operations : RMT.0409 The key factor of Rulemaking task RMT is the introduction of additional safety requirements (like a specific approval for offshore operations) for hostile and non-hostile sea areas. These requirements take account of best practices, latest safety recommendations and new technology. The EASA task is expected to be finalised by the end of 2014 or beginning The resulting EU Regulation is expected in the first half of Draft Regulation on Ditching & water contact : RMT.0120 Rulemaking task RMT.0120 is taking a broad review of helicopter ditching, water impacts and survivability and aims to both enhance existing design standards and to make recommendations to further enhance equipment standards and operational rules, where appropriate. Significant changes to the helicopter design standards currently being assessed include among others: creating a new requirement to mitigate the consequences of water impact; enhance existing water stability requirements to reduce the possibility of capsize following a ditching; the side-floating concept; various cabin safety improvements to aid egress. This task is currently scheduled to publish a Notice of Proposed Amendment (NPA) for public consultation in March 2015 and it is expected to be completed in June 2016.

12 It needs to be highlighted that RMT.0120 is also looking at retroactive application of any new rules to the existing helicopter fleet. Any proposals will however be subject to a regulatory impact assessment. The publication of the Terms of Reference that formally launched the Rulemaking Task occurred in October httq://

13 Annex 3 Civil Aviation Safety in Europe and the role of EASA The civil aviation safety system in Europe, as established by Regulation (EC) No 1592/2002 in the meantime repealed and replaced by Regulation (EC) No 216/2008 establishes different roles for the European Commission, the European Aviation Safety Agency (EASA) and National Aviation Authorities (NAA5), such as e.g. CAA UK. These roles differ in what relates to the preparation and adoption of the legal framework and to the application of the legal framework. EFFA states, including Norway, implement the EU Regulations under terms established in the European Economic Area (EEA) Agreement. Of the two traditional roles of NAA5, the regulatory (the preparation and adoption of the legal framework) and the executive (application of the legal framework), the first has been almost completely transferred to the European level, and the second remains, with few exceptions, within the national sphere. EASA also assists the European Commission in monitoring the application of the European legislation by Member States and its NAA5. The Regulatory Function: Adoption and Amendment of the Legal Framework According to Art 100 (2) of the Treaty on the Functioning of the European Union the European Parliament and Council have received the competence to lay down appropriate provisions for air transport. As regards civil aviation safety, the European Parliament and Council have exercised this competence and adopted common rules in the field of civil aviation safety (Regulation (EC) No 1592/2002, in the meantime repealed and replaced by Regulation (EC) No 216/2008). The national legislators remain competent to legislate civil aviation safety outside the scope and applicability of this Regulation. This is the case e.g. for products carrying out military, customs, police, search and rescue, fire fighting, coastguard and similar activities or services, as well as products as listed in Annex II of Regulation (EC) No 216/2008 and most of the operation of those. In Regulation (EC) No 216/2008, the European Parliament and Council have delegated to the European Commission the competence to adopt a number of implementing rules (Commission Regulations), including rules on initial and continuing airworthiness, aircrew and operations. In that context, the EASA supports the European Commission in preparing proposals for the amendment of Regulation (EC) No 216/2008 (to be adopted by the European Parliament and the Council) or for implementing rules or amendments thereto (to be adopted by the Commission). To this end, the EASA issues opinions to the European Commission. In addition, the European legislator has tasked the EASA to issue, by itself, non-binding material to support the competent authorities in the application of the common EU rules and to ensure harmonised application of it. To this end, the EASA issues by decision of its Executive Director certification specifications, acceptable means of compliance and guidance material. EASA issues acceptable means of compliance and guidance material to Regulation (EC) No 216/2008 and its implementing rules.2 Acceptable means of compliance are non-binding standards to illustrate means to establish compliance with these Regulations. Guidance material is non-binding material that helps to illustrate the meaning of a requirement or specification and is used to support the interpretation of these Regulations. EA5A also issues technical standards, that can be used by organisations for the purpose of certification (so called certification specifications), as well as acceptable means of compliance and guidance materials thereto.

14 The applicable legal framework on 23 August 2013 On 23 August 2013, Regulation (EC) No 216/2008 was in force, including the common rules on airworthiness, as implemented by Regulation (EU) No 748/2012 (as last amended) and Regulation (EC) No 2042/2003 (as last amended). The common rules on aircrew (Regulation (EU) No 1178/2011) were in force and applicable in the UK on 23 August 2013, with a few exceptions related to paragraphs which application was delayed under the derogations foreseen in the Regulation. Also the common rules on air operations (Regulation (EU) No 965/2012) were in force at the time, however not yet applicable in the UK, as the UK filed a general derogation to these rules. These common rules will generally apply in the UK as of 28 October However, it is worth noting that the UK has declared the intention to continue to apply national requirements to helicopter off-shore operations, following the provision of article 6(4) of Regulation (EU) No 965/2012. Therefore, on 23 August 2013, helicopter air operations were subject to national legislation. The Executive Function: ApQlication of the legal framework In line with the general principle of de-centralised application of common EU rules, the above legal framework is applied at national level. To this end, Members States have designated an authority (or several authorities) as competent for certification and oversight of products in their registry and organisations located in their territory. As an exception to this principle, the European legislator has identified a few areas where a centralised application of the common EU rules is more efficient. In those cases the legislator has designated the EASA as the competent authority for certification and oversight. These areas are mainly the following type certification and the continuing airworthiness of such typer approval of design organisations and their oversight; approval/oversight of organisations which have their principal place of business in a 3rd country (for instance maintenance organisations, training organisations); and approval/oversight of production organisations located in the territory of the Member States (and therefore normally subject to the approval/oversight of national authorities), for which the competent Member State has asked the EASA to be the competent authority. It follows from this that, at the date of the recent offshore accidents, EASA was competent for the type certification and continuing airworthiness of the aircraft (including helicopter) type and approval of design organisations, while the NAA5 were competent for the certification of individual aircraft, their maintenance, training approval and licencing of maintenance staff and aircrew. Fallow uu of Safety Recommendations Regulation (EU) No 996/2010 establishes, in article 18, the follow-up process related to safety recommendations. Consequently, the Agency procedures have been aligned with those requirements. Thus, the handling of and responding to safety recommendations, in both an expeditious and responsible manner, constitutes one of the pivotal responsibilities of EASA. Each incoming recommendations is acknowledged and receives a first reply within 90 days. The originator is then updated of any progress until the action is closed. The Agency publishes an annual review of the safety recommendations with a statistical overview of the situation.

15 EASA, in its role as the responsible EU body, can receive world-wide safety recommendations, leading to an average of about 100 recommendations per year. Each individual recommendation is not just evaluated in relation to the specific accident but also in the global context of the aviation system. These are processed, taking into account their different nature and urgency, hence ensuring that every recommendation receives a closing response and the progress of the actions taken is monitored (be it the establishment of a new Rulemaking Task, another research activity or the issue of an Emergency Airworthiness Directive, mandating immediate action, within 24 hours, if need be). Action can also consist of an input to the European Aviation Safety Plan which helps prioritise EASA s safety tasks and those of Member States. This process ensures that the obligation related to the safety recommendations follow-up, as laid down by the Member States in European Regulation (EU) No 996/2010, is fully met.