Pilot – June 2018

32 | Pilot June 2018 | pilotweb.aero

I

sometimes rent a helicopter from my
friend Kevin Foster, who runs Moorgoods
Helicopters way up on the cloud-line
on Bodmin Moor and provides the only
place in Cornwall where you can learn
to fly a piston-engined helicopter. Between
us we’ve been flying helicopters for the
thick end of sixty years, and we speak the
language – if Kevin’s not there, I wheel the
machine out of the hangar, fill in the docs,
do the Check-A and fly away.
Not this time. Kevin was waiting for me
when I arrived, and under his arm was
a thick book bearing the portentous title
‘Moorgoods Helicopters Ltd, Part-ORA
Approved Training Organisation Manual’.
“Read this,” he said. “Then sign it.”
Now this was a sizeable volume running to
138 pages, closely typed and seriously short
on laughs. It told me that this manual was
to be read and understood by every pilot,
and signed every year. So I furnished my
autograph with a flourish, then thought I’d
better sit down and flick through it. I’m glad
I did, because I’ve never read a bigger load of
old hogwash in all my born days.
The distribution list specifies, inter alia,
the Accountable Manager, the Compliance
Monitoring Manager, the Safety Manager, the
Head of Training, and the Administration.
Well, Moorgoods Helicopters Ltd is a one-man,
one-helicopter operation and Kevin Foster
runs it with one hand while concentrating
largely on his main business, which is nothing
to do with flying. He is Managing Director of
Moorgoods Helicopters Ltd, has commercial
and instructor tickets and does helicopter
work on the side. The specific duties of every
manager are set out in detail in the manual.
Much responsibility falls on the Compliance
Manager (Kevin) who has a whole catalogue
of boxes to tick. The Compliance Manager
is responsible to the Accountable Manager
(Kevin) who nominates the Safety Manager
(Kevin) and the Safety Committee (all
Kevin). The organisational management
section defines hazard and risk management,
covering page after page with boilerplate
and specifying that the Safety Manager must
keep a Hazard Log which must be reviewed at
every meeting of the Safety Committee to see
that it complies with the Safety Performance
Indicators. In case of an incident, the Safety
Manager prepares a report for the committee,

the Board (Kevin) reviews the findings and

makes recommendations to the Accountable

Manager (see above). Heavens above, I’d

love to be a fly on the wall at some of these

meetings. For the avoidance of doubt, the

corporate hierarchy is set in stone in the

manual: the CFI (Kevin) reports to the Head

of Training (Kevin) who is responsible to the

Accountable Manager (that’ll be Kevin). The

Safety Manager and the Compliance Manager

also report to the Accountable Manager...

This EASA-mandated manual is of course

full of important safety information. I should

not take recreational drugs, it tells me.

I should not carry people who are hog-

hollerin’ drunk; glad they mentioned it. I

should check the fuel, show passengers how

to open the doors, and above all, read the

manual. There’s an Emergency Response

Plan which informs me to ‘make a verbal

call for help (Help!), phone up the rescue

services, and if there’s a fire, use a fire

extinguisher on it'. Good thinking, Batman!

Alongside this 138-page wonder is the

Risk Assessment, which is kept as a separate

manual because it is subject to change, and

if it was included in the main manual Kevin

would have to pay a fee for every alteration!

Here I learn lots of useful things. There’s

a risk of injury from slipping over, so no

running on the helipad. Here’s a sample:

‘Nature of hazard – sloping ground. Nature

of risk – roll over. Existing mitigation – carry

out correct on-slope landing techniques.’

Lord save us, if only everyone read this,

accidents would be nothing but a memory.

Kevin uses nearby Bodmin airfield for

refuelling, so he had to produce a full Risk

Assessment for helicopter operations there,

too. It says they can have windshear and

turbulence, which ‘may be encountered in

strong winds’. The mitigation is to ‘exercise

caution taxying to the apron and refuelling’,

and the Further Mitigation Required is to

‘obey wind limits as per Flying Manual’.

Controlled flight into terrain is a risk because

there are hills around, and the nature of the

risk is defined as ‘death or serious injury’.

To avoid this, the document advises pilots

to ‘maintain good VFR’. In order to avoid

ground vehicles passing along a road close to

the runway threshold, the Risk Assessment

warns pilots to ‘check for approaching

traffic near the undershoot of the relevant

runways’. There’s a danger of aircraft crash

and possible fire from hitting the ground or

buildings; the specified mitigation is to keep

a safe distance from them.

You know what this puts me in mind of?

The scenes in George Orwell’s Animal Farm

where, while the other animals toiled in the

fields, the pigs covered pieces of paper closely

with writing, and the paper was then burned

in the furnace – and nobody knew why, but

it was very important. I’ve been to Cologne

and met the people who are responsible

for this stuff, and they’re an unimpressive

bunch, many from countries with little or no

general aviation – but there are hundreds of

them, and only one of Kevin. Unlike the CAA,

EASA carries no liability insurance, so every

action and every word that comes from the

Agency is designed to absolve it from blame if

something goes wrong. When lawyers write

safety regulations, common sense is on a

hiding to nothing.

From Kevin’s standpoint, the time invested

in the manual was worth it because it is

an insurance requirement to guard against

liability claims. His involvement in aviation

has been developed through his time in the

RAF, aircraft sales, parachute dropping,

instructing and charter, all without accident

or claims against him. Long may it continue.

Why did I have to sign now? Well, said

the Accountable Manager, this was the all-

singing, all-dancing improved and updated

version, and I ought to sign before it was

rendered redundant. As soon as EASA gets

around to establishing the specification for a

Declared Training Organisation, Moorgoods

Helicopters will become one of those, which

not only means there need be no book of

rules, but cuts the fees by ninety per cent.

That worries me. I feel really safe after

reading a big fat manual. Can I possibly be as

safe when I have no Compliance, Safety, and

Accountable Managers telling me which leg

to put into my trousers first in the morning?

Doing it by the book

Pat has worked as a journalist on three

continents and is a fixed-wing pilot and former

Pat Malone helicopter instructor with 1,500 hours TT

The Malone Column

When lawyers write

safety regulations,

common sense is on a

hiding to nothing