Safety Standards Acknowledgement and Consent (SSAC) CAP 1395
Contents Published by the Civil Aviation Authority, 2015 Civil Aviation Authority, Aviation House, Gatwick Airport South, West Sussex, RH6 0YR. You can copy and use this text but please ensure you always use the most up to date version and use it in context so as not to be misleading, and credit the CAA. First published 2015 Second edition published March 2016 Enquiries regarding the content of this publication should be addressed to: ga@caa.co.uk The latest version of this document is available in electronic format at www.caa.co.uk, where you may also register for e-mail notification of amendments. April 2016 Page 2
Contents Contents Contents... 3 Section 1... 5 SSAC... 5 Introduction... 5 Intended use... 5 General requirements... 6 Section 2... 6 Risk analysis... 6 Risk analysis... 6 Likelihood scale for third party risk (non-participants)... 6 Severity... 8 Participant risk and consent... 9 Informing the participants... 10 Section 3... 11 Application process... 11 Categories of aircraft... 11 Classes of aviation activity... 11 How to apply... 12 Section 4... 12 Airworthiness requirements... 12 Points to note... 13 Section 5... 14 Operational requirements... 14 Section 6... 14 April 2016 Page 3
Contents Licensing requirements... 14 April 2016 Page 4
SSAC Section 1 SSAC Introduction Safety Standards Acknowledgement and Consent (SSAC) is a means of setting out, in simple terms, the risks involved in participating in paid recreational flights. Aircraft operators will be able to offer flights to paying participants without having to apply the very high safety standards normally applied to commercial flights provided that: The passengers are informed of the key risks involved with participating in the activity. Having been informed of the risks the passengers are willing to participate in the activity. The expected high level of safety to the general public, including other airspace users, those not participating is maintained. Intended use SSAC will be used for flights that are solely for recreational value and which can currently be conducted if they are private flights, with no money changing hands. It is not intended to provide a cheaper alternative for operators engaged in the transport of passengers or as a means of normalising extreme risk-taking. SSAC is being implemented to allow a wider range of activity to take place but it is not meant to be a replacement for Air Operators Certificate (AOC) and Certificate of Airworthiness (C of A) operations, although we accept the boundary between the two types of activity will have to be carefully managed. It is envisaged that flights under the SSAC principle will normally take off and land at the same place and enable many more people to enjoy an aviation experience. April 2016 Page 5
Risk analysis General requirements Applicants for permission to conduct flights under SSAC principles will be required to show that they have analysed the hazards to participants and third parties, established the likelihood and severity of them occurring and how they will explain those risks to participants. Section 2 Risk analysis Risk analysis Risk can be described as a calculation of the likelihood of a hazard occurring and the severity of the outcome should it occur. Applicants should consider all potential hazards. Potential hazards are likely to include, but are not restricted to: engine failure, engine fire, component failure, mid air collision, heavy landing, fuel exhaustion, pilot incapacitation, ditching and adverse weather. To enable a full understanding of the risks and the implementation of appropriate mitigations, particular attention should be paid to hazards that expose other airspace users, third parties on the ground and the paying participants to greater risks than would be the case if the aircraft were being operated under an AOC. Having established the hazards, applicants should then consider the likelihood of the hazard occurring and the severity of the outcome should it occur. The following tables and risk matrix should be used in the analysis. Likelihood scale for third party risk (non-participants) The tables used here are based on risk assessment criteria as set out in the ICAO Safety Management Manual. April 2016 Page 6
Risk analysis Note: The aim here is for operators to assess the likelihood of third party risk, with the focus on the qualitative descriptors, Hazard Classification and Hazard Severity parameters outlined in the tables below:. Description Qualitative Quantitative Probable Occasional Anticipated to occur one or more times during the entire system/operational life of an item. Foreseeable to occur one or more times during the entire system/operational life of an item. Probability of occurrence per operational hour is greater that 1x10-5 Probability of occurrence per operational hour is less than 1x10-5, but greater than 1x10-6 Remote Unlikely to occur to each item during its total life. May occur several time in the life of an entire system or fleet. Probability of occurrence per operational hour is less than 1x10-6, but greater than 1x10-7 Extremely Remote Not anticipated to occur to each item during its total life. May occur a few times in the life of an entire system or fleet. Probability of occurrence per operational hour is less than 1x10-7 but greater than 1x10-9 April 2016 Page 7
Risk analysis Extremely Improbable So unlikely that it is not anticipated to occur during the entire operational life of an entire system or fleet. Probability of occurrence per operational hour is less than 1x10-9 Severity Hazard classification Hazard severity Catastrophic Hazardous Multiple deaths, usually with loss of aircraft Large reduction in safety margins Crew extended because of workload or environmental conditions Serious or fatal injury to small number of occupants Major Significant reduction in safety margins Difficulty for crew to cope with adverse conditions Passenger injuries Minor Operating limitations Emergency procedures Nuisance April 2016 Page 8
Risk analysis Negligible Any other mandatory reportable event not falling within the above categories. Risk index Significance Description 3 High Unacceptable 2 Medium Tolerable based on risk mitigation 1 Low Acceptable, monitoring action required Participant risk and consent Having identified the hazard and established the risks to participants the participants must be informed of those risks. Participants need to clearly appreciate that this activity will not be conducted to commercial air transport safety standards and have a reasonable understanding of the differences in standards and what they mean in terms of risk, which can take account of any mitigations put in place by the SSAC operator. Applicants for permission to conduct flights under SSAC principles will be required to show that in explaining the risk to participants they have considered what a reasonable person's expectation for safety is and calculated the additional risk they will be exposed to, compared to the same flight or a similar operation conducted under an AOC. The risk analysis carried out should directly inform the information disclosed to the participant regarding the risks associated with this particular operation. Participants will need to give their written confirmation that they have had the risks explained to them and are willing to accept those risks and take part in the flight. Applicants for permission to conduct flights under SSAC principles have to have a process for retaining written permission that also shows how participants retain a free choice without undue pressure to participate. April 2016 Page 9
Risk analysis Participants must be given sufficient opportunity to consider their decision in a relaxed and unpressurised environment. Participants should not be financially committed in any way before making the decision, for example, they should not stand to lose a deposit or down payment if they decide not to fly. The decision should be made as early as possible and not when the participant is about to or has already boarded the aircraft. Informing the participants Applicants will be required to demonstrate that they have developed a method of informing participants of the risks that is clear and in a commonly understood format. Applicants should consider using practical examples and comparisons that enable most people to relate to something they are familiar with. In particular applicants must explain the additional risks the participant will be exposed to during the flight compared to an equivalent flight offered by an AOC holder. Methods to be used might include: Information pamphlets Audio briefings Video briefings Visual briefings in person by the operator. The amount of information provided and the level of engagement with the participant must be directly proportionate to the risk involved in the activity. Higher levels of risk will necessitate greater engagement between the operator and the participant. April 2016 Page 10
Application process Section 3 Application process Categories of aircraft All applications will follow the SSAC Framework and will be considered on a case by case basis. Initially, the CAA will only consider applications which fall within the categories of aircraft detailed below. As the Framework becomes more established it is intended that the range of aviation activity be expanded to include a wider range of aircraft. We will engage with stakeholders on how this list can be expanded. Microlights Amateur-built aircraft Balloons Airships Gliders Simple (single-piston aircraft) as defined in supplement 2 to A8-25 up to 5700 kg Classes of aviation activity SSAC applications will be categorised into distinct classes of aviation activity, as outlined in Paragraph 2 of the SSAC Framework. Activities within each distinct class of Aviation activity are considered to have highly similar levels of risk. Examples of categorised Classes of Aviation Activity that have already been established are: Class 1: Wing-walking Class 2: Experience flight in an Historic (single engine piston) warbird April 2016 Page 11
Airworthiness requirements How to apply Applications for SSAC will follow the following steps: Applicant proposes activity to be conducted and includes basic details such as, type of aircraft, pilot experience, and maintenance regime. Applicant carries out evidence based risk assessment of the activity and identifies level of risk to participants, other airspace users, and third parties on the ground. Applicant develops the procedure by which participants are informed of the risks and their consent obtained. The CAA will then assess the application using the classes of aviation activity outlined in the SSAC Framework. Section 4 Airworthiness requirements Operators must consider the airworthiness requirement applicable to the particular activity. There may be additional risk implications which may need to be advised to the participant. These risks should be evaluated by the operator, the Continuing Airworthiness management organisation (CAMO) and the maintenance organisation. For aircraft operating on a Certificate of Airworthiness, the airworthiness standards and limitations associated with the C of A must be maintained. No further airworthiness considerations are required. For non-c of A aircraft, it will greatly assist in expediting your application if you address the points below (relating to increased utilisation and the potential increased risk associated with this): April 2016 Page 12
Airworthiness requirements Points to note The anticipated utilisation of the aircraft in the SSAC role as compared with current utilisation. This includes assessment of the proposed changes in operation such as increased circuit flying, shorter flights, more aerobatic flying etc. Proposed changes to the maintenance programme as a result of the change in usage for the aircraft based on above. This may involve changes to inspection/check intervals, routine maintenance intervals and health monitoring methods along with changes to the handling of defect reports. Modifications fitted on a trial basis should not be considered for SSAC usage. Results of a review of all applicable airworthiness directives (including MPDs) for the aircraft to determine whether revisions to the methods of compliance or inspection intervals are justified, or any currently permitted alternative means of compliance remain applicable for SSAC operation. Proposed revisions to aircraft placarding. Maximum occupancy levels are already specified for an ANO Certificate of Airworthiness, Permit to Fly aircraft or equivalent and any change to these maximum occupancy levels requires an application for an addendum to the relevant AAN. As far as possible the application will be handled as a documentation change. Final acceptance of the airworthiness case under the current Certificate of Airworthiness, Permit to Fly or equivalent along with any additional limitations will be indicated by a letter to the approved person or organisation and may be used in support of the operator case to satisfy the requirements for operation. April 2016 Page 13
Operational requirements Section 5 Operational requirements Operators must consider the operational requirement applicable to the particular class of aviation activity and identify any additional risks that need to be advised to the participant. The applicant, having identified the risks may use enhanced operational procedures to mitigate those risks. The proposed Operational Procedures should include: An Operations Manual setting out operational procedures to be used Aircraft type-specific operational information Training (including Pilot competency, Pilot currency) Safety Management System Procedure for informing Participants under the principles of SSAC and obtaining informed Participant s consent Operational procedures required to mitigate any additional risk to third parties on the ground and in the air, such as keeping clear of congested areas or flying over the sea.. Section 6 Licensing requirements In establishing the risks and explaining them to participants, operators will have to show that they have calculated the additional risk participants will be exposed to compared to the same flight conducted under an AOC. It follows that any additional risk and explanation for pilot licensing will be minimized if operators engage the use of pilots that hold at least a UK Commercial Pilots Licence as this aligns an A to A- April 2016 Page 14
Licensing requirements AOC. However we recognise that there could be applications from operators to apply SSAC who wish to use pilots that have many hours of experience on the type (or similar) and don t hold a professional licence - these will be considered on a case-bycase basis in accordance with the principles above. April 2016 Page 15