Commercial and Business Aviation Advisory Circulars

Compliance with Regulatory Requirements Respecting Survival Equipment

PURPOSE

This revision to Air Carrier Advisory Circular (ACAC) is intended to notify air operators that the Exemption to Section 705.95 of the Canadian Aviation Regulations dated April 11, 1997, has been cancelled and replaced with the Exemption dated March 10, 1998. The ACAC also explains the reasoning behind the decision to replace the Exemption.

This ACAC replaces ACAC 0122 dated June 2, 1997.

REFERENCES

• Sections 602.61, 602.63 and 705.95 of the Canadian Aviation Regulations;
• Subsection 725.95(2) and paragraphs 725.95(2)(b)(k) and (l) of the Commercial Air Service Standards.

BACKGROUND

The requirement that a radar reflector and fishing kit be contained in life-raft survival kits was introduced with publication of the Canadian Aviation Regulations (CARs). These regulations also increased the required water supply to a two day supply of water or means for desalting or distilling salt water, for each person, calculated using the overload capacity of the life-raft.

Following publication of the CARs, air operators identified several concerns regarding the Survival Equipment requirements and their implementation.

It was determined that a Survival Equipment working group would be established to consider all the associated issues and concerns.

In the interim, the Director General, Civil Aviation issued an Exemption conditionally authorizing installation of the additional survival kit contents within 12 months from the date of issuance of the Exemption, April 11, 1997. In response to concerns that the additional equipment would not fit into life-raft survival kits, the Exemption further authorized air operators to carry equipment that could not be contained in those kits in a separate auxiliary survival pack not attached to the life-raft.

The validity period of the Exemption was due to expire in March 1998, and there has been an unavoidable delay in convening the working group. In consideration of the above facts, as well as regulatory harmonization and the operational considerations associated with the supply and servicing of equipment overseas, it was determined that the Exemption to section 705.95 of the Canadian Aviation Regulations should be replaced.

ACTION

The April 11, 1997 Exemption to section 705.95 of the Canadian Aviation Regulations has been cancelled and replaced by the Exemption dated March 10, 1998, issued by the Director General, Civil Aviation (DGCA). The replacement Exemption conditionally authorizes air operators engaged in airline operations to operate an aircraft with survival kits which do not include a radar reflector and fishing kit. The Exemption further authorizes air operators to carry water, or a means of desalting or distilling salt water sufficient to provide at least one pint of water per person at the rated capacity of the life-raft. This is a lesser quantity of water than is currently required by paragraph 725.95(2)(k) of the Commercial Air Service Standards but is equivalent to the amount required under the former Air Navigation Order legislation.

Where the water, or water desalting or distilling equipment cannot be accommodated in the survival kit that is attached to the life-raft, the carriage of an auxiliary survival pack containing these items is authorized. The auxiliary pack may be carried separate from the life-raft provided that it is capable of being readily and quickly attached to the life-raft.

Note: Where the weight and/or bulk of desalting tablets is a concern, the air operator may wish to consider other types of desalting equipment. Manual desalters have been approved for use in both civilian and military life-rafts. These devices offer a reasonably compact and light weight alternative to desalting tablets.

CONCLUSION

This Circular is to inform air operators that the April 11, 1997 Exemption to section 705.95 of the Canadian Aviation Regulations has been cancelled and replaced by the Exemption dated March 10, 1998, issued by the DGCA pursuant to section 5.9(2) of the Aeronautics Act.

M.R. Preuss
Director
Commercial and Business Aviation