RAA Safety-Training-Compliance Coordinator appointed

[rhysmcc]

Question 1 This is ICAO document 9859

http://www2.icao.int/en/ism/Guidance Materials/SMM_3rd_Ed_Advance_R4_19Oct12_clean.pdf

 

Page 168 says:

 

Establish a key person/officer responsible for the administration and maintenance of the SMS

First I will admit, I have not read the entire document that you referred, however from what you have quoted (incorrectly), it talks about Establishing "a key person or office responsible for the administration and maintenance of the SMS", this does not need to be a stand alone position. It could also be in the form of a consulting agency.

 

There is a requirement for the person/office responsible for SMS to not hold other responsibilities that may conflict or impair his responsibilities for the administration and maintenance of the SMS.

 

However all this is moot, as it's in an ICAO document (and not even a final copy at that) and is not binding, its up to CASA to use recommendations from ICAO to design and publish their own requirements/regulations.

 

 

[Teckair]

David Issac said.... The worst they can do is remove RAAus authority to register aircraft and issue pilot certificates and then appoint an administrator of the processes. This is what they have already done in terms of aircraft registrations.

 

Apparently they can do worse than that by removing the exemptions that allow 95.10 and 95.25s to fly. This I am told has already been threatened.

 

 

[Keith Page]

David Issac said.... The worst they can do is remove RAAus authority to register aircraft and issue pilot certificates and then appoint an administrator of the processes. This is what they have already done in terms of aircraft registrations.Apparently they can do worse than that by removing the exemptions that allow 95.10 and 95.25s to fly. This I am told has already been threatened.

Yes Teckair,

 

You are looking further down the track. You are thinking.

 

Allowed to fly under 95.10 + 95.25 those exemptions removed., I have heard that quite a lot.

 

What next?????????????

 

Regards,

 

Keith Page.

 

 

[turboplanner]

SpriteAH and Rhysmcc - I provided the linkage in the form of CASA's RAA board member duties, CASA's ICAO call up and the ICAO document and the Job Specification.

 

If you want to make your own interpretations you have to live with them.

 

What is hanging over all of us is that RAA does not have a safety system in place, does not have the people on the ground auditing compliance and guiding participants, and every fatality which occurs is a potential major risk. That's the overriding urgency, but CASA are correct in what they are demanding.

 

 

[facthunter]

There is very little of what RAAus do that is ICAO compliant, It is not a requirement as it is only what happens in THIS country, so why is this particular instance the exception?. I also believe the CASA would be on thin ice requiring a SPECIFIC person to be the (only) one to do the job.

 

The model for the job ( the TASK) could be insisted on, reasonably. Does this have to be the SOLE job of ONE person? ( or is it part of one or one plus assistant .Who cares really?) . The board must have reasons to be divided on this other than sheer obstructionalism. ( I don't believe they would do that)

 

There are no GOODIES and BADDIES here so lets stop defining contributors to the discussion in those terms eh! Everyone has an equal right to express them selves here provided they are civil and respect others rights to their views. Pretty basic concept for a discussion. Nev

 

 

[rhysmcc]

SpriteAH and Rhysmcc - I provided the linkage in the form of CASA's RAA board member duties, CASA's ICAO call up and the ICAO document and the Job Specification.If you want to make your own interpretations you have to live with them.

You've done one more step and that is sharing your opinion/interpretation of said documents, your more then entitled to do so and I welcome the discussion, however on the point of whether a "Safety Manager" must be appointed who's sole focus is the SMS, your interpretation (in my opinion) is wrong.

 

What is hanging over all of us is that RAA does not have a safety system in place, does not have the people on the ground auditing compliance and guiding participants, and every fatality which occurs is a potential major risk. That's the overriding urgency, but CASA are correct in what they are demanding.

I agree 100% with you on this and it's amazing that RA-AUS has been able to get away with these poor systems, auditing and compliance for so long. A safety system must be put in place and I think Jim is on the right track on how we go about this both in respects to safety and cost efficieneny for members. Lets get the Professionals in and do it right the first time rather then run the risk of the ball being dropped.

 

Once the system is up and running, maybe a position will need to be created to provide ongoing oversight and administration, maybe this same position can also provide auditing of other operations (ie registration, training), maybe this position could also provide investigation into any RA-AUS incidents or accidents, provide safety forums and training programs. If the Board and GM decide such a position is required then proper recruitment processes should take place to insure someone of the right skill and ability is selected (who may end up being Myles should he apply).

 

 

[Guest ozzie]

Ground 95_10?

 

Be very very carefull with that threat!

 

 

[David Isaac]

David Isaac said.... "The worst they can do is remove RAAus authority to register aircraft and issue pilot certificates and then appoint an administrator of the processes. This is what they have already done in terms of aircraft registrations."Apparently they can do worse than that by removing the exemptions that allow 95.10 and 95.25s to fly. This I am told has already been threatened.

Yes of course they could, but that would be no worse than what I suggested above, because if you cant register your aircraft and cant get a pilot's certificate the CAOs are NOT worth anything to you.

 

We wouldn't need to be concerned about any of this IF WE WOULD JUST GET OUR ACT TOGETHER AND FOLLOW PROCESS AND DO WHAT WE WERE SUPPOSED TO DO. Yes I am raising my voice ... slightly

 

 

[Keith Page]

on post 298 "nomadpete" has some information which needs a reread.

 

Proves to me -- most on this thread do not read or do not rember, they are only interested in pushing their own little agenda along blindly.

 

While the hounds run about like headless chooks, squabble and bark the fox hides and relaxes. quote (A wise man and Maj)

 

Have a re-read there are questions answered there.

 

Regards,

 

Keith Page.

 

 

[Aerochute Kev]

Keith I agree there is an agenda from one group of people, you only have to read through this thread to see it. The President has been accused of Nepotism without any evidence to back up that claim. He has been accused of "Jobs for the boys" without any evidence of that claim. I have been branded with "associating" without any answer as to who with.All in all it's a pretty disgusting, attacking threat, very short in facts to back up the attack.

However, we've come to where we've come, and I've done some thinking overnight:

 

John G, is this a fair summary of what we were talking about last night?

 

AR to Keith Page

 

While you are digging into Myles's employment history you might let us know how long he had been out of work before accepting the gift of the STCC role from Ed.

 

Turbo to AR

 

Whether he is in work or out of it is none of your business, so back off.

 

JG to Turbo

 

On the contrary Turbs it is our business when Myles claimed in his Email to the Board that he had resigned his normal "day" job to take up the appointment; when in fact he had been unemployed for a number of weeks before convincing Ed to give him the job.

 

Turbo

 

How about the hard evidence of the unemployment?

 

JG

 

I'll leave that up to the folks making the statement; however it shouldn't be too hard to prove, either he was employed or he wasn't.

 

If so, I agree, it is Alfa Romeo's responsibility to come up with the facts or apologise.

 

In thinking this over, firstly in my view this would be one of those issues I would discuss in camera within the board.

 

He had to do two things to get started on this function: Resign from the board, because we know he was a board member, and be free of any other employment.

 

He would need to confirm that he was no longer a board member, and that he was free to work.

 

I'm cautious enough to want to see the exact words in the email before deciding whether any statement was significant.

 

Aerochute Kev, and Kaz

 

That at this stage is poor speculation. The job availability would not stand up unless CASA had made it an imperative.

Yes turbo, that is pure speculation, like the majority of suggestions on this issue, as no one with the knowledge of what is actually going on is saying anything. Openness and accountability is a great thing eh?

 

 

[rhysmcc]

Yes of course they could, but that would be no worse than what I suggested above, because if you cant register your aircraft and cant get a pilot's certificate the CAOs are NOT worth anything to you.We wouldn't need to be concerned about any of this IF WE WOULD JUST GET OUR ACT TOGETHER AND FOLLOW PROCESS AND DO WHAT WE WERE SUPPOSED TO DO. Yes I am raising my voice ... slightly

CASA's website has all the information you need to understand what they can do regarding poor performance of RA-AUS in meeting it's obligations. There is no requirement to appoint an administrator, or "take-over" recreational aviation administration. It's pretty black and white what will happen if they are not happy.

 

The organisations exist to oversight members’ activities and assure CASA that activities are being conducted safely. CASA needs to be fully confident that RAAOs have the capacity to provide the safety outcomes required.If organisations can’t assure CASA of this, then CASA can’t allow the organisation to continue to administer its activities under the exemption. Without the exemption the activities allowed by it can’t occur. That is, if the organisation doesn’t assure CASA that it is meeting safety outcomes and oversighting activities, people wanting to fly under the exemption can’t.

 

Without the exemption then people wanting to fly need to meet the regulations that apply to other aviation activities.

After witnessing previous "grounding" of large operators over the last couple of years when safety concerns have been raised, do you really think its wise to try and call it a bluff?

 

Lets get some professionals in to setup the SMS, recruit the right staff to oversee/administer (not just SMS but overall safety and operations), and lets get the board focused on what they should be doing, setting strategic policy for the future of RA-AUS and not getting mixed up in the daily operations (that's what the GM and staff are for)

 

 

[turboplanner]

For those of you wanting to come up with an alternative, these things are relevant:

 

1. CASA either applied a $60,000 sanction or threatened to apply a $60,000 sanction because, over a number of years RAA has resisted setting up an SMS and employing an SMS Manager as it is required to do under the deed of agreement.

 

So those of you suggesting I'm misquoting or who don't know what "ensure" means, should note that you are not really arguing with someone on an internet, you are arguing with CASA. Certainly the CASA documents don't say "please yourself" and the ICAO document doesn't say "if you feel like it">

 

Not only that, you have put yourselves in the precarious position of arguing against a safety item in defiance of a Safety Authority.

 

I think we can safely say, that for CASA to have applied a sanction stating a specific requirement, THEY know whether they called up the ICAO clause and or issued instructions doe their organization to employ a specific person or not.

 

You can argue with CASA, but I'd suggest that would finish up costing around a quarter of a million dollars, and at the end of it you could still be facing a series of very quick audits with the final helper of being grounded until you did comply with their directive.

 

2. If RAA, through it's President responded to CASA's action by agreeing to set up an SMS and employ an SMS Manager immediately, that would constitute a contract. (You can argue whether he had the power to do so if you like) So the discussion now is leaning towards a breach of contract.

 

The outcome of that is either a contractual problem, if the President, as I maintain, had the power to make that decision, or back to square one, if he didn't. i.e. CASA would be likely to apply a $60,000 sanction as the first of a series of warnings leading to groundings unless RAA complied with what the have specified which is (a) an operating SMS and (b) an SMS Manager.

 

So you need to think that through and come to your own conclusions.

 

You can certainly condemn the current board members for continuing the veil of secrecy about the CASA meeting which, if published would have sent a message out to all FTF's and pilots everywhere to smarten up their attitude to safety, but what you are facing with CASA's demands has to be met one way or another.

 

Jim, for what you were suggesting, if a contract exists, and I think it does, you could go to CASA and tell them you believe you could get a better result by setting up the system first by and agreed date,and then employing the manager to go straight into an operations role by an agreed date.

 

They may then amend their demands and that would form an amendment to the contract, but being an organization in a high risk business which has resisted compliance for years, it may be too late for alternative paths - the directive may have come from higher up.

 

 

[Keith Page]

Turbo well put, you have a way with words.

 

People on this forum must thank you for putting a translation out there.

 

Mobs here can not see what is going on.

 

The members out there enjoying their planes, what will they do when they discover they are grounded.

 

Someone has to stick up for them

 

Regards,

 

Keith Page.

 

 

[Guest Maj Millard]

Ah excuse me ....didn't the President just hire a manager to handle the setting up of a SMS in the form of Myles ??????? ...as CASA has requested ....and didn't you all just scuttle that through politics ????.........we're shooting ourselves in the foot here aren't we ?.........Maj.....

 

 

[Head in the clouds]

Apparently they can do worse than that by removing the exemptions that allow 95.10 and 95.25s to fly. This I am told has already been threatened.

 

 

Allowed to fly under 95.10 + 95.25 those exemptions removed., I have heard that quite a lot.

Keith, I'm not sure what you've heard but there seems to be a misunderstanding here -

 

The CAOs are exemptions. They allow non-compliance with certain CARs. i.e the CARs are Regulations (1988) and you must comply with them ... unless a CAO, which is an Order, or exemption, says you don't have to comply with a Regulation.

 

These are quite different from dispensations. Some overweight/over wing loaded 95.10 and 95.25 aircraft did, for a time, fly under dispensation, which allowed them some time to be modified to fit into a/the relevant CAO. Those dispensations all expired quite some years ago unless new ones were granted that I don't know about.

 

CAO 95.25, as an exemption, has already been 'removed' (in 2011) and the aircraft that were operating under that exemption are now grouped with eLSAs, LSAs and some former GA homebuilt (CAO 101.31?) aircraft, among others, and operate under a different CAO - it's now CAO 95.55.

 

CAO 95.10 remains in place and has been unchanged for the last few years.

 

Note that all CAOs are being removed progressively, so this is nothing to be alarmed about, it is just part of the progression from CARs (1988) to CASRs (1998) which will bring our Regulations, and the numbering of them, into line with the FARs of USA.

 

Here is a link to the current effective CAOs, note 95.25 doesn't exist anymore, 95.10 does and 95.55 is your product of choice for Rec 2 seaters for now ...

 

 

[poteroo]

Stop blaming the CFI's for the accident and fatality rates. We can only lead a horse to water - after that, well...................Darwinian theory takes over!

 

If you all believe that CFI's should become the policemen - then ask CASA to delegate us the powers of an FOI. We'll very reluctlantly do it - but you'll hate us for the significant constraints you'll suffer. You've no idea where this would lead - but it likely won't be comfortable.

 

Insofar as the instigation of SMS at FTF level - don't expect this to show results in under several years. It's already installed in GA - but it seems people are still breaking aircraft at the same rate. Increased safety training will only influence the new generation of students. It takes time for education to work. The quick fix is to ground everyone! The hardcore 'alphas' out there will be impervious to it all anyway. The timid and less competent pilots already flying will probably accept upskilling, and some might even quit because it all seems so 'unsafe'.

 

RAAus just has to get it's act together and create the SMS as required. However - these SMS need to be consistent across the industry. I don't think asking each FTF to whip up their own is the way. About the same value as everyone keeping quite different student records I'd say.

 

If you think safety is a pain, try having an accident!

 

happy days,

 

 

[turboplanner]

Turbo, You do not need a stand alone manager. It needs to have a focal. It could be the GM, Ops or Tech, or board individual for that matter. Jim.

Jim, if you want to defy CASA, you will need to get to the base documents.

 

Some people have started debates on the meaning of my words. They were just my descriptions, and a detailed discussion would sort out between us what was meant.

 

I assume you've made the above interpretation on the links I posted here.

 

I spent several hours locating board member duties, and CASA requirements which called up an ICAO document, and stopped looking after I was able to get a chain of responsibility from the ICAO document to the board member.

 

If you are going to pull on CASA, playing on individual words, then you will have to do some more work and find the base Act which spells out CASA's powers over the Sport Aviation Bodies, and it's links to what is spelled out in the ICAO document. While I expect the words to be the same, that's not always the case with CASA - for example you can take the broad description of something from the VFG, then go to the ACT and find a more detailed description.

 

So I'd advise checking the base documents first for the key word, rather than rely on what you have already seen.

 

 

[rhysmcc]

For those of you wanting to come up with an alternative, these things are relevant:1. CASA either applied a $60,000 sanction or threatened to apply a $60,000 sanction because, over a number of years RAA has resisted setting up an SMS and employing an SMS Manager as it is required to do under the deed of agreement.

Where do you get this information? Requests by members for a copy of the Deed of Agreement (which from earlier posts indicate your not a current member) have been met with a firm no, based on "confidentaly" clauses. Are we meant to take your word on the fact such agreement includes a requirement for a SMS Manager to be appointed?

 

So those of you suggesting I'm misquoting or who don't know what "ensure" means, should note that you are not really arguing with someone on an internet, you are arguing with CASA. Certainly the CASA documents don't say "please yourself" and the ICAO document doesn't say "if you feel like it"

You're quoting a document which is still only a draft by ICAO which has NO regulatory authority, to base your requirement that RA-AUS must have a sole manager responsible for the SMS. This is the issue I am disagreeing with, as reading the same documents as you, can not come to this black and white conclusion. I am not disagreeing with you regarding the need (and requirement) for a SMS or the urgency of having it setup and complied with.

 

Not only that, you have put yourselves in the precarious position of arguing against a safety item in defiance of a Safety Authority.I think we can safely say, that for CASA to have applied a sanction stating a specific requirement, THEY know whether they called up the ICAO clause and or issued instructions doe their organization to employ a specific person or not.

 

You can argue with CASA, but I'd suggest that would finish up costing around a quarter of a million dollars, and at the end of it you could still be facing a series of very quick audits with the final helper of being grounded until you did comply with their directive.

Unless you're here on behalf of CASA, then no I (and as far as I can tell, other posters) are not arguing with CASA, but YOU'RE interpretation of their position.

 

2. If RAA, through it's President responded to CASA's action by agreeing to set up an SMS and employ an SMS Manager immediately, that would constitute a contract. (You can argue whether he had the power to do so if you like) So the discussion now is leaning towards a breach of contract.

The Deed of Agreement is the contract, agreed to by RA-AUS and CASA, without reading or having access to such agreement I would not be able to say what has breached it. However if it is as you say (and again, we have no way of knowing since nothing has been offically disclosed to the members) and CASA made these demands which the President agreed to, again would not be a breach of contract as the President does not have the authority to sign such contract on behalf of members.

 

So you need to think that through and come to your own conclusions.

I have, however I have not reached the same conclusion as you, therefore I must be wrong

 

 

[Guest Andys@coffs]

You know what people, instead of side B continuously calling Side A D!ckheads I've an alternate suggestion that may well break the deadlock!.....why don't Side B who are all yelling loudly that there is only Ed's way forward ring Lee Ungermann and discuss it with him...as I did.... earlier this week.

 

You will find that no matter what conclusions you have come to based on 2nd or 3rd hand emails and documents they don't actually align with what CASA's wants RAAus to do right this moment!. If I was to paraphrase (and please get this for yourself rather than just take me at my word) CASA want action rather than inaction, they want us moving to align with our obligations. <EDIT for clarity I'm pretty sure CASA see this and the board determination as to the "what we do" as interesting, but not Action as they want....we must shortly move from "the what, and the who and the how", to "the when" and start progressing down the timeline>

 

If you do ring as I suggest, ask, as I did, is Myles the only possible solution to the problem that will stave of immediate CASA action, Is <gasp!> an organisation such as Aerosafe who have done this work before many times an acceptable solution to CASA.......

 

The board as I see it have 3 choices:-

 

1) Ignore the governance issues and employ Myles. We may get what CASA is looking for

 

2) Go through a recruitment process and employ the successful candidate. We may get what CASA is looking for, better chance than 1 in my view, but it will take a while to happen, which is a risk in itself. <EDIT this is not to say Myles is substandard, he may very well be the outcome of this step, but today we just don't know if he is the A team or the D team>

 

2) Use Aerosafe, who have done this before. We will get what CASA are looking for, if we do as they task us to do. Part of that might be employing another employee, or it may be an alternate solution, or who the hell knows right now, but They have done this before.

 

Aerosafe have been used by RAAus in the past with very strong endorsement and encouragement by CASA. You wont have heard much because like any consulting engagement it will only deliver a capability outcome if we followed through and did what they set us up to do....and we didn't, so that failure was our issue not Aerosafe

 

So, with the 3 alternates you do the risk analysis and tell us what should be done......It looks really obvious to me! But first check on your facts with the man who really matters here....not you...not me...not any of us!!!

 

Some have commented that consultants are "robbers dogs".... Please, like everything in life you get good and bad, furthermore a good consultant cant make gold from sh!t, you will only get as good an outcome as the effort we put into making the engagement good. In my professional experience consultants absolutely have their place. Every time your GP sends you to a specialist he is sending you to a consultant, an expert in a specific field........Would anyone really argue that all Doctors who are specialist are "robbers dogs" and to be avoided no matter what your need is.......They do cost, but in life anyone with superior life experience and specialist skills costs more. Its why kids in coffee shops get paid a fraction of what people with a profession are paid..

 

Please, this name calling is not changing anything lets argue the facts, after you have the info first hand!

 

Andy

 

 

[Guest ozzie]

About the most sensible post i've read yet on this.

 

We did not get in this mess from old boys operating within the rules so fixing it may need to be done same. If person who lept in is keeping CASA at bay then good. Back it up with the Pro outfit and work out who to go with in Sept.

 

Best thing to do now is start leaning on those that need moving on and give them a little shove toward the door.

 

 

[turboplanner]

Andy, I'm surprised at you; one minute you and the group you are a part of are roundly criticising board members for failure of due process, and now we find you've taken RAA into complete anarchy by bypassing the board and contacting CASA yourself. Not only that but recommending 10,000 members do the same.

 

How can the board members negotiate with CASA day by day with a chirping chorus ready to cut the ground out from underneath them.

 

Same goes for getting involved in the staff politics.

 

If you have a committee or a board of management, you have to allow them to do their business.

 

I know what you wanted to get across, but not everyone understands.

 

 

[turboplanner]

Stop blaming the CFI's for the accident and fatality rates. We can only lead a horse to water - after that, well...................Darwinian theory takes over! If you all believe that CFI's should become the policemen - then ask CASA to delegate us the powers of an FOI. We'll very reluctlantly do it - but you'll hate us for the significant constraints you'll suffer. You've no idea where this would lead - but it likely won't be comfortable.

 

Insofar as the instigation of SMS at FTF level - don't expect this to show results in under several years. It's already installed in GA - but it seems people are still breaking aircraft at the same rate. Increased safety training will only influence the new generation of students. It takes time for education to work. The quick fix is to ground everyone! The hardcore 'alphas' out there will be impervious to it all anyway. The timid and less competent pilots already flying will probably accept upskilling, and some might even quit because it all seems so 'unsafe'.

 

RAAus just has to get it's act together and create the SMS as required. However - these SMS need to be consistent across the industry. I don't think asking each FTF to whip up their own is the way. About the same value as everyone keeping quite different student records I'd say.

 

If you think safety is a pain, try having an accident!

 

happy days,

Poteroo, if I was a volunteer auditor (which is not likely) and I was on the way to audit your outfit my heart would be very light. From the very responsible posts you have made, for years now, I would know that I could do the audit and find virtually nothing wanting - all ticks, and I would know I could get a cup of coffee and learn something new.

 

If I did it again in three or six or 12 months, I know I would get the same results.

 

The auditing process, if done correctly, quickly points to the safe operations, and the ones which need attention - it's a great system, if done correctly.

 

If I was asked to recommend two people who could set the safe standards for each aspect of flying and ground operations, my choice would be yourself and Motzart Merv.

 

Great success could come if we targeted the issues which actually need work.

 

 

[drifterdriver]

Hi Keith

 

With all the rumour and innuendo going around I'd like to ask a favour if I may. The latest scare mongering gossip doing the rounds is that recently Myles sent a less than complimentary email about the safety compliance training position (including his role in it) to numerous parties including yourself and CASA. In the interests of hitting this latest bit of rubbish on the head could you please clarify that this didn't happen? I think we're all getting sick and tired of these unsubstantiated claims and it'd be great to clear the air on at least this one.

 

Thanks

 

Nick

 

 

[Dafydd Llewellyn]

Keith, I'm not sure what you've heard but there seems to be a misunderstanding here -The CAOs are exemptions. They allow non-compliance with certain CARs. i.e the CARs are Regulations (1988) and you must comply with them ... unless a CAO, which is an Order, or exemption, says you don't have to comply with a Regulation.

 

These are quite different from dispensations. Some overweight/over wing loaded 95.10 and 95.25 aircraft did, for a time, fly under dispensation, which allowed them some time to be modified to fit into a/the relevant CAO. Those dispensations all expired quite some years ago unless new ones were granted that I don't know about.

 

CAO 95.25, as an exemption, has already been 'removed' (in 2011) and the aircraft that were operating under that exemption are now grouped with eLSAs, LSAs and some former GA homebuilt (CAO 101.31?) aircraft, among others, and operate under a different CAO - it's now CAO 95.55.

 

CAO 95.10 remains in place and has been unchanged for the last few years.

 

Note that all CAOs are being removed progressively, so this is nothing to be alarmed about, it is just part of the progression from CARs (1988) to CASRs (1998) which will bring our Regulations, and the numbering of them, into line with the FARs of USA.

 

Here is a link to the current effective CAOs, note 95.25 doesn't exist anymore, 95.10 does and 95.55 is your product of choice for Rec 2 seaters for now ...

Almost, but not quite right:

 

All CAOs are not exemptions - but all the 95-series ones are. Every CAO has in its heading, the regulation that gives it a head of power. If you look at CAO 95.55, its head of power is CAR 308(1). There are a considerable number of CAOs, from the 20 series thru to the 108 series; most of them are NOT exemptions. If you look up CAO 108.56, its head of power is CAR 38.

 

Now, if you look up CAR 308(3), you will see that exemptions issued under CAR 308(1) may be subject to conditions. This is the head of power for the conditions set by CASA for the application of the exemptions listed in CAO 95.55

 

Hope this helps clarify the subject.

 

 

[Ballpoint 246niner]

About the most sensible post i've read yet on this.We did not get in this mess from old boys operating within the rules so fixing it may need to be done same. If person who lept in is keeping CASA at bay then good. Back it up with the Pro outfit and work out who to go with in Sept.

Best thing to do now is start leaning on those that need moving on and give them a little shove toward the door.

SPOT ON!!!