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Capt. Claude Godel OST 06-5

CRD to NPA-OPS 45 JAR OPS 1.311 Minimum number of cabin crew required to be on board an aeroplane during ground operations with passengers. Capt. Claude Godel OST 06-5. Reminder. JAR-OPS 1.311 is proposed in order to:

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Capt. Claude Godel OST 06-5

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  1. CRD to NPA-OPS 45JAR OPS 1.311Minimum number of cabin crew required to be on board an aeroplane during ground operations with passengers Capt. Claude Godel OST 06-5

  2. Reminder • JAR-OPS 1.311 is proposed in order to: • Allow some operational flexibility in regard of the requirements of JAR-OPS 1.990 in the particular situation when the aeroplane is on ground. • Avoid situations where, on ground, passengers are left inside an aeroplane with not enough supervision and assistance by the Cabin Crew. OPSG

  3. Comments received • 22 comments were received: • 7 comments agree with the proposed text • 8 comments support the ETF concerns. They were partially accepted permitting to reach an acceptable compromise with the ETF representatives. • The last 7 comments were answered individually. OPSG

  4. ETF (1) and Czech Rep. comments Required improvement of the wording was accepted, text reworded as: …the number of cabin crew present in the passenger cabin may be reduced below the number determined by JAR-OPS 1.990(a), (b) and (c). … Clarification achieved by adding: (c) If the number of cabin crew is determined by using JAR-OPS 1.990(d) [unforseen circunstances] the alleviation permitted by using JAR-OPS 1.311 is not allowed. OPSG

  5. ETF comments (2) Required pre-flight safety briefing by the purser was added in the conditions of paragraph b): iv) The pre-flight safety briefing and checks have been completed. OPSG

  6. IAA comment IAA considered the formula to determine the minimum number of Cabin Crew too complex. The text was reworded for more clarity: The minimum number of cabin crew required in these circumstances shall be one per pair of floor-level emergency exits on each passenger deck, or one for every 50, or fraction of 50, passengers present on board, whichever is greater, provided that:… OPSG

  7. INAC comment • INAC required one Flight Crew in the cockpit. • OPSG declined because: • 1.311 is not allowed during refuelling, the risk is therefore acceptable without a flight crew member on board, provided the minimum number of cabin crew are present • i) The operator has established a procedure for the evacuation of passengers with this reduced number of cabin crew that has been accepted by the authority as providing equivalent safety; • That procedure should cover the problem of CC/ground staff communication. OPSG

  8. KLM comment • KLM requires to alleviate the proposed rule to: • only one CC per pair of floor-level emergency exit • allow during refuelling • OPSG declined: • 50 passengers for one Cabin Crew is a recognized standard • the specific risk associated to refuelling is clearly highlighted in every aeronautical rule material and cannot be ignored. OPSG

  9. Transavia comment Transavia requires the possibility to have some of the CC “at the stairs on the ramp”: OPSG declined: The minimum Cabin Crew should be on board. Cabin Crew are not trained to take care of passengers on the apron and may not be responsible for that. OPSG

  10. DGAC France comment DGAC France requires more precision about the responsibility of deciding an emergency evacuation and the establishment of communication between crew and ground personnel. OPSG declined: The comment doesn’t relate directly to the intended purpose of 1.311. It may be possible to develop it further as a separate NPA. OPSG

  11. INAC comment INAC considers that the wording in Appendix to JAR-OPS 1.305 excludes the presence of at least one Flight Crew on the flight deck. OPSG declined: The proposed text is clear : (7) The minimum required number of cabin crew specified by JAR-OPS 1.990 must be on board and be prepared for an immediate emergency evacuation; It doesn’t exclude the fact that there may be flight crew on board. OPSG

  12. ETF and others comments on Appendix to JAR-OPS 1.311 Those comments are a consequence of the changes required in the rule text. They were partially accepted . The text was amended in line with the JAR-OPS 1.311 rule text modifications. OPSG

  13. Conclusion Final version of the NPA introduces a framework in regard of what is reasonable on ground. The procedures of a majority of operators were since ever compliant with that new rule. But specific situations, like the end of disembarkation, are now more clearly defined. Some operators may have to adapt their practice to comply with JAR-OPS 1.311. OPSG

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