Written Evidence – Department for Transport (HCS0005)

1. Introduction

1.1.  The Department for Transport’s written evidence is limited to the factual information that it has at its disposal and that it is able to provide without prejudicing the ongoing Investigations by the Air Accidents Investigation Branch into recent accidents involving the Eurocopter Super Puma helicopter, the Civil Aviation Authority (CAA) Review into North Sea Helicopter Operations, and the Fatal Accident Inquiry in respect of Eurocopter Super Puma helicopter crash in April 2009, due to commence in January 2014.  Details of the accidents and previous air accident reports are available at http://www.aaib.gov.uk/publications/index.cfm

1.2.  The Department for Transport acknowledges that there are approximately 57,000 individuals working in the North Sea, across 600 facilities. The only viable means of transferring workers in the North Sea industry from shore to installation and from one installation to another is by helicopter. Three UK helicopter companies operate approximately 100 aircraft in support of the exploitation of oil and gas around the UK: Bristow Helicopters Ltd; Bond Offshore Helicopters Ltd; and CHC Scotia Ltd.  Main operating bases are: Aberdeen; Scatsta; Norwich; North Denes; Humberside; and Blackpool.  There are approximately 100 flights per day.

1.3.  Offshore helicopter operations represent a small section of UK aviation. However, it provides critical support to the oil and gas industry, which is of significant economic importance. It is recognised by both industry and the CAA that these non-scheduled public transport operations take place in a hostile environment and are relatively high risk. Therefore helicopter operations in the North Sea are worthy of particular attention. 

1.4.  The table below[1] details the relative passenger fatality rates per billion passenger kilometres for a number of modes of transport for the 15 year period 1995 to 2009 for which statistics are readily available.

2. Accident Statistics

2.1.  Between 1976 and 2012 there have been a total of 68 reportable accidents, of which 11 involved fatalities, in the UK’s offshore oil and gas support operations. The Chart below, which does not take account of the accidents in 2013, presents the annual accident rates. Clearly, from the early 1990s the accident rate improved markedly but has levelled off since.

2.2.  The breakdown of these accidents into those due to technical causes (e.g. aircraft/ equipment failures), operational issues (e.g. pilot error) and external factors (e.g. weather) is shown in the pie chart below.

2.3.  Of the 48% “technical cause accidents”, the three areas of the helicopter most commonly affected were:

• main rotor gearbox (31%);
• main rotor (21%);
• tail rotor (15%).

2.4.  Of the 43% “operational cause accidents”, the four most common issues were:

• pilot error (24%);
• main rotor strike (24%);
• tail rotor strike (14%);
• collision (14%).

2.5.  Of the 9% “external factors accidents”, five of the six (83%) were related to lightning strikes. The other accident involved an encounter with a water spout.

3. Regulatory Oversight

3.1.  The CAA oversight regime covers flight operations and flying training, aircraft maintenance, aerodromes and air traffic control.  Specialists also cover dangerous goods and cabin safety aspects.  Condition and suitability of helicopter landing deck areas on offshore installations are overseen by the independent Helideck Certification Agency, which is audited by CAA specialists.

3.2.  Audits and inspections take place on a rolling schedule at each company headquarters and at all operating bases against specific requirements informed by best practice judgement.  The subsequent schedule is determined against previous company performance, and the CAA will vary oversight accordingly.  Many aspects, including management arrangements, company procedures, training and records are assessed and flight checks take place on public transport flights.  The CAA maintain a close liaison is with each operator between formal visits, and regular meetings occur.  CAA inspectors are qualified and experienced personnel, trained in auditing techniques and, in the case of flight operations assessments, qualified pilots fly on selected flights to ensure safe practices and that company procedures are being followed.

3.3.  Inspectors may make “Findings of Non-Compliance” and the operator is required to resolve these issues within an agreed timescale.  “Significant Findings” are require by the CAA to be resolved immediately.  Regulatory tools for poor safety performance include an “On Notice Procedure”, temporary suspension or, ultimately, revocation of an approval.

3.4.  There are two resident foreign helicopter operators based at Norwich and Wick: NHV from Belgium; and Dancopter from Denmark.  Oversight is the responsibility of their respective National Authority and the UK can perform ‘ramp inspections’ under the International Civil Aviation Organisation protocols.  The CAA hosts a regular joint offshore National Authorities’ group involving Norway, Denmark, Belgium, Holland, Germany and Ireland, where information on operating practices is exchanged, and an informal agreement exists to attend their audits/inspections in UK.

3.5.  The CAA maintains close links with the oil and gas industry, as members of the safety steering and aviation technical groups, and manages a collaborative safety research committee to focus efforts to best benefit.

3.6.  Aviation regulation within the UK is currently evolving from a national model to a pan-European model under the auspices of the European Aviation Safety Agency (EASA).  Whilst pilot licensing and aircraft manufacture, for example, are now subject directly to EU Regulations, the requirements for operating helicopters are founded on the UK Air Navigation Order 2009 and a collaborative rule-set developed within the European region.  This differs in other countries that operate offshore helicopters in Europe because of their membership status of the EU, the variety of national legal codes and differences in the adoption of international standards.  New Regulations for Air Operations will apply across the EU from 28 October 2014

4. Offshore Helicopter Research and Safety Improvement

4.1.  Since the late 1980’s, the CAA has been leading a programme of research aimed at improving the safety of offshore helicopter operations. The motivation for this initiative came from the joint CAA/industry review of helicopter airworthiness by the Helicopter Airworthiness Review Panel (HARP), commissioned in 1982[2]. This study led to a number of research projects and other reviews which, in turn, led to a well-founded data-driven programme of work for improving offshore helicopter safety.

4.2.  The focus for HARP is to identify how new technology can be used to support and enable the introduction of enhanced standards. More recent accidents and the resulting AAIB Safety Recommendations have added impetus to these projects and have helped to support the voluntary implementation of the research results by the industry. The research areas which relate directly to AAIB Safety Recommendations are as follows:

• Health and Usage Monitoring Systems (HUMS) – development and improvement of equipment that enables technical faults to be detected before they become a hazard to flight safety.

• Helicopter ditching and water impact - leading to improved emergency flotation systems and a specification for emergency breathing systems that make helicopters easier and safer to escape from after a ditching or water impact.

• Helicopter operations to moving helidecks – development of new, scientifically derived operating limits which are directly related to the risk of the helicopter tipping or sliding while landed on a moving deck.

• Helideck lighting - development and demonstration of a new lighting scheme to improve visual cueing and reduce the risk of pilot disorientation during operations at night.

• Instrument guidance for offshore approaches - new equipment and procedures to improve the safety of offshore operations in conditions of low visibility and at night by delivering the helicopter in a stable condition at a point from which it can be safely flown to the helideck by the pilot.

• Helideck environment (e.g. turbulence, turbine exhausts) – new guidance material to improve the control of the environmental hazards to helicopter operations that exist around offshore installations.

• Helicopter Terrain Awareness Warning Systems (HTAWS) – modification of existing equipment to increase warning times available to pilots in the event of an impending impact with the sea, and reduce the ‘nuisance’ alerts prevalent in current systems.

• Helicopter triggered lightning strike forecasting – development of a new helicopter ‘triggered’ lightning forecasting system to help helicopter operators plan their flights to avoid high risk areas.

• Helicopter pilot reaction times in time-critical emergencies – establishment of realistic pilot reaction times to ensure that helicopters are designed to be compatible with human performance limitations.

• Helicopter low rotor rpm warning and protection – investigation of ways to prevent unrecoverable loss of rotor rpm enabling the helicopter to autorotate (‘glide’) in the event of total power failure.

4.3.  The largest and arguably most significant area of research has been HUMS which potentially addresses the top three technical accident causes. HUMS comprises the collection and analysis of vibration data which is then analysed to detect defects before they compromise flight safety. HUMS was voluntarily introduced by the industry with funding from the offshore oil company operators in the early 1990s following the CAA-run in-service trials. There was a significant reduction in the accident rate due to technical causes around this time and it is considered reasonable to assume that HUMS was largely responsible. However, the CAA has said, there is room for improvement in HUMS and the latest research on advanced data analysis techniques is presently being introduced, again, voluntarily by the industry again with funding from the offshore oil company operators. It is also the case that HUMS has only been applied to transmissions and its extension to rotors is being progressed, currently via participation in the AgustaWestland Rotorcraft Technology Validation Programme (RTVP) part funded by the Technology Strategy Board (TSB).

4.4.  Some proactive research has also been undertaken, the most notable example of which is the application of Flight Data Monitoring (FDM) to offshore helicopter operations. This highly successful research project resulted in implementation of the scheme including all of the UK offshore helicopter operators and its addition as a Recommended Practice for Flight Data Recorder (FDR) equipped helicopters in ICAO Annex 6 Part III. Through the routine analysis of aircraft FDR data, the monitoring of pilot performance in terms of compliance with operational standards and good airmanship, FDM has the capability of reducing the number of accidents due to operational causes.

4.5.  In respect of external cause accidents, the CAA has recognised the need to address lightning strikes. Helicopters have the ability to ‘trigger’ lightning, and a helicopter triggered lightning forecasting system has been developed by the UK Met Office under a CAA-led research project. The system has shown significant promise when applied to data from past lightning strikes and is presently undergoing in-service trials with the UK offshore helicopter operators.

4.6.  Also undergoing in-service trials is the first production version of the new helideck lighting system developed under a CAA-led research project. This new scheme directly addresses two of the more recent accidents, one of which involved fatalities, and the offshore oil industry has committed to voluntarily retrofit this equipment. In the photographs below, at top left is an actual photograph of a prototype of the new system, with a ‘simulation’ of the old scheme produced by photo editing at top right; the lower photograph is a close up of the production version of the equipment recently installed on the Centrica CPC-1 gas platform in Morecambe Bay.

4.7.  In addition to addressing the causes of accidents, research has also been undertaken in response to developments in the offshore industry. A current example is the work being performed on the anti-slip properties of aluminium helidecks. A potential future area of work falling within this category that is under consideration is the issue of turbulence generated by offshore wind turbines; this is a concern for the helicopters used to winch maintenance personnel onto them.

4.8.  Also on the subject of future work, in addition to the extension of HUMS to rotors previously mentioned, another significant area of research identified by HARP as yet unaddressed and that arguably deserves some attention is that of usage monitoring. This comprises the monitoring of the use of the helicopter, largely in terms of the combination of manner and duration of flight, in order to validate the design assumptions that lie behind the safe-lives allocated to components, and which should form a key part of the continued airworthiness programme for an aircraft. Practical considerations have prevented any real progress in this area prior to the introduction of flight data monitoring, but consideration should now be given to reviewing the state of the art, especially in view of recent accidents which have highlighted scope for improvement in the general area of continued airworthiness.

4.9.  In summary, for a number of projects,  the research is essentially complete and the focus has switched to promoting and supporting implementation by producing and publishing guidance material, influencing the industry and, where appropriate, by lobbying for changes to the requirements at EASA.

5. Helicopter Safety Research Management/Coordination/Funding

5.1.  The UK helicopter safety research programme, Section 4.2 of the Civil Aviation Authority Safety Plan 2011 to 2013 (available at www.caa.co.uk) has been jointly funded and monitored by the CAA-run Helicopter Safety Research Management Committee (HSRMC). The HSRMC was originally set up by CAA in the late 1980's to manage a joint CAA/UK Government/UK oil industry research fund that was created to progress the HARP recommendations following the loss of 45 lives in the BV 234 Chinook accident in 1986. The committee is still thriving and has evolved over time expanding its membership to include the UK MoD, the UK helicopter operators (BHA), the European Aviation Safety Agency (EASA), the Norwegian CAA, the Norwegian oil industry (OLF), and the European Helicopter Association (EHA). A recently joined member (post the fatal Cougar Helicopters accident in Canada) is the Canada – Newfoundland/Labrador Offshore Petroleum Board (C-NLOPB) who bring yet another perspective to the work of the committee.

5.2.  To date, the committee has overseen around £10M of research funding spread over a wide range of helicopter safety issues, covering reactive initiatives resulting from the HARP Report and subsequent AAIB Safety Recommendations, proactive research and work in support of the introduction of new technology. Currently, the extramural costs associated with new projects are provided by external contributors, normally HSRMC members. The intramural costs of managing and administering research projects, and of running the HSRMC, are borne by the CAA. This arrangement helps to ensure that those who benefit from the research bear a fair share of the costs, and also ensures the ‘buy-in’ necessary for the research to be implemented as evidenced in the examples earlier in this paper.

5.3.  NB: CAA is participating in the EASA-led European Helicopter Safety Team (EHEST) initiative. Although offshore helicopter accidents have been included in the associated data analysis exercise, the focus of EHEST is primarily on smaller helicopters and the onshore operations more prevalent across the European Union. EHEST is unlikely to adequately address the needs of UK offshore helicopter operations.

December 2013