Safety Standards Acknowledgement and Consent (SSAC)

Safety Standards Acknowledgement and
Consent (SSAC)
CAP 1395

CAP 1395
Contents
Published by the Civil Aviation Authority, 2015
Civil Aviation Authority,
Aviation House,
Gatwick Airport South,
West Sussex,
RH6 0YR.
You can copy and use this text but please ensure you always use the most up to date version and use it in context so as not to
be misleading, and credit the CAA.
First published 2015
Second edition published March 2016
Enquiries regarding the content of this publication should be addressed to: ga@caa.co.uk
The latest version of this document is available in electronic format at www.caa.co.uk, where you may also register for e-mail
notification of amendments.
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Contents
Contents
Contents ..................................................................................................................... 3
Section 1 ................................................................................................................... 5
SSAC ......................................................................................................................... 5
Introduction ......................................................................................................... 5
Intended use ....................................................................................................... 5
General requirements .......................................................................................... 6
Section 2 ................................................................................................................... 6
Risk analysis .............................................................................................................. 6
Risk analysis ....................................................................................................... 6
Likelihood scale for third party risk (non-participants) ......................................... 6
Severity ............................................................................................................... 8
Participant risk and consent ................................................................................ 9
Informing the participants .................................................................................. 10
Section 3 ................................................................................................................. 11
Application process .................................................................................................. 11
Categories of aircraft ......................................................................................... 11
Classes of aviation activity ................................................................................ 11
How to apply ..................................................................................................... 12
Section 4 ................................................................................................................. 12
Airworthiness requirements ...................................................................................... 12
Points to note ........................................................................................................... 13
Section 5 ................................................................................................................. 14
Operational requirements ......................................................................................... 14
Section 6 ................................................................................................................. 14
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Licensing requirements ............................................................................................ 14
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SSAC
Section 1
SSAC
Introduction
Safety Standards Acknowledgement and Consent (SSAC) is a means of setting out,
in simple terms, the risks involved in participating in paid recreational flights. Aircraft
operators will be able to offer flights to paying participants without having to apply the
very high safety standards normally applied to commercial flights provided that:
• The passengers are informed of the key risks involved with
participating in the activity.
• Having been informed of the risks the passengers are willing to
participate in the activity.
• The expected high level of safety to the general public, including
other airspace users, – those not participating – is maintained.
Intended use
SSAC will be used for flights that are solely for recreational value and which can
currently be conducted if they are private flights, with no money changing hands. It is
not intended to provide a cheaper alternative for operators engaged in the transport
of passengers or as a means of normalising extreme risk-taking. SSAC is being
implemented to allow a wider range of activity to take place but it is not meant to be
a replacement for Air Operators Certificate (AOC) and Certificate of Airworthiness (C
of A) operations, although we accept the boundary between the two types of activity
will have to be carefully managed. It is envisaged that flights under the SSAC
principle will normally take off and land at the same place and enable many more
people to enjoy an aviation experience.
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Risk analysis
General requirements
Applicants for permission to conduct flights under SSAC principles will be required to
show that they have analysed the hazards to participants and third parties,
established the likelihood and severity of them occurring and how they will explain
those risks to participants.
Section 2
Risk analysis
Risk analysis
Risk can be described as a calculation of the likelihood of a hazard occurring and the
severity of the outcome should it occur.
Applicants should consider all potential hazards. Potential hazards are likely to
include, but are not restricted to: engine failure, engine fire, component failure, mid
air collision, heavy landing, fuel exhaustion, pilot incapacitation, ditching and adverse
weather.
To enable a full understanding of the risks and the implementation of appropriate
mitigations, particular attention should be paid to hazards that expose other airspace
users, third parties on the ground and the paying participants to greater risks than
would be the case if the aircraft were being operated under an AOC.
Having established the hazards, applicants should then consider the likelihood of the
hazard occurring and the severity of the outcome should it occur. The following
tables and risk matrix should be used in the analysis.
Likelihood scale for third party risk (non-participants)
The tables used here are based on risk assessment criteria as set out in the ICAO
Safety Management Manual.
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Risk analysis
Note: The aim here is for operators to assess the likelihood of third party risk, with
the focus on the qualitative descriptors, Hazard Classification and Hazard Severity
parameters outlined in the tables below:.
Description Qualitative Quantitative
Probable
Occasional
Anticipated to occur one or
more times during the
entire system/operational
life of an item.
Foreseeable to occur one
or more times during the
entire system/operational
life of an item.
Probability of occurrence
per operational hour is
greater that 1x10-5
Probability of occurrence
per operational hour is less
than 1x10-5 , but greater
than 1x10-6
Remote
Unlikely to occur to each
item during its total life.
May occur several time in
the life of an entire system
or fleet.
Probability of occurrence
per operational hour is less
than 1x10-6 , but greater
than 1x10-7
Extremely Remote
Not anticipated to occur to
each item during its total
life. May occur a few times
in the life of an entire
system or fleet.
Probability of occurrence
per operational hour is less
than 1x10-7 but greater
than 1x10-9
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Risk analysis
Extremely Improbable
So unlikely that it is not
anticipated to occur during
the entire operational life of
an entire system or fleet.
Probability of occurrence
per operational hour is less
than 1x10-9
Severity
Hazard classification
Hazard severity
Catastrophic
Hazardous
Multiple deaths, usually with loss of
aircraft
Large reduction in safety margins
• Crew extended because
of workload or
environmental conditions
• Serious or fatal injury to
small number of
occupants
Major
Significant reduction in safety margins
• Difficulty for crew to cope
with adverse conditions
• Passenger injuries
Minor
Operating limitations
• Emergency procedures
• Nuisance
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Risk analysis
Negligible
Any other mandatory reportable event
not falling within the above categories.
Risk index Significance Description
3 High Unacceptable
2 Medium Tolerable based on risk
mitigation
1 Low Acceptable, monitoring
action required
Participant risk and consent
Having identified the hazard and established the risks to participants the participants
must be informed of those risks. Participants need to clearly appreciate that this
activity will not be conducted to commercial air transport safety standards and have
a reasonable understanding of the differences in standards and what they mean in
terms of risk, which can take account of any mitigations put in place by the SSAC
operator. Applicants for permission to conduct flights under SSAC principles will be
required to show that in explaining the risk to participants they have considered what
a reasonable person's expectation for safety is and calculated the additional risk they
will be exposed to, compared to the same flight or a similar operation conducted
under an AOC. The risk analysis carried out should directly inform the information
disclosed to the participant regarding the risks associated with this particular
operation.
Participants will need to give their written confirmation that they have had the risks
explained to them and are willing to accept those risks and take part in the flight.
Applicants for permission to conduct flights under SSAC principles have to have a
process for retaining written permission that also shows how participants retain a
free choice without undue pressure to participate.
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Risk analysis
Participants must be given sufficient opportunity to consider their decision in a
relaxed and unpressurised environment. Participants should not be financially
committed in any way before making the decision, for example, they should not
stand to lose a deposit or down payment if they decide not to fly. The decision
should be made as early as possible and not when the participant is about to or has
already boarded the aircraft.
Informing the participants
Applicants will be required to demonstrate that they have developed a method of
informing participants of the risks that is clear and in a commonly understood format.
Applicants should consider using practical examples and comparisons that enable
most people to relate to something they are familiar with. In particular applicants
must explain the additional risks the participant will be exposed to during the flight
compared to an equivalent flight offered by an AOC holder.
Methods to be used might include:
• Information pamphlets
• Audio briefings
• Video briefings
• Visual briefings in person by the operator.
The amount of information provided and the level of engagement with the participant
must be directly proportionate to the risk involved in the activity. Higher levels of risk
will necessitate greater engagement between the operator and the participant.
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Application process
Section 3
Application process
Categories of aircraft
All applications will follow the SSAC Framework and will be considered on a case by
case basis. Initially, the CAA will only consider applications which fall within the
categories of aircraft detailed below. As the Framework becomes more established it
is intended that the range of aviation activity be expanded to include a wider range of
aircraft. We will engage with stakeholders on how this list can be expanded.
• Microlights
• Amateur-built aircraft
• Balloons
• Airships
• Gliders
• Simple (single-piston aircraft) as defined in supplement 2 to A8-25 up
to 5700 kg
Classes of aviation activity
SSAC applications will be categorised into distinct classes of aviation activity, as
outlined in Paragraph 2 of the SSAC Framework. Activities within each distinct class
of Aviation activity are considered to have highly similar levels of risk. Examples of
categorised Classes of Aviation Activity that have already been established are:
• Class 1: Wing-walking
• Class 2: Experience flight in an Historic (single engine piston) warbird
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Airworthiness requirements
How to apply
Applications for SSAC will follow the following steps:
• Applicant proposes activity to be conducted and includes basic
details such as, type of aircraft, pilot experience, and maintenance
regime.
• Applicant carries out evidence based risk assessment of the activity
and identifies level of risk to participants, other airspace users, and
third parties on the ground.
• Applicant develops the procedure by which participants are informed
of the risks and their consent obtained.
The CAA will then assess the application using the classes of aviation activity
outlined in the SSAC Framework.
Section 4
Airworthiness requirements
Operators must consider the airworthiness requirement applicable to the particular
activity. There may be additional risk implications which may need to be advised to
the participant. These risks should be evaluated by the operator, the Continuing
Airworthiness management organisation (CAMO) and the maintenance organisation.
For aircraft operating on a Certificate of Airworthiness, the airworthiness standards
and limitations associated with the C of A must be maintained. No further
airworthiness considerations are required.
For non-C of A aircraft, it will greatly assist in expediting your application if you
address the points below (relating to increased utilisation and the potential increased
risk associated with this):
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Airworthiness requirements
Points to note
• The anticipated utilisation of the aircraft in the SSAC role as
compared with current utilisation. This includes assessment of the
proposed changes in operation such as increased circuit flying,
shorter flights, more aerobatic flying etc.
• Proposed changes to the maintenance programme as a result of the
change in usage for the aircraft based on above. This may involve
changes to inspection/check intervals, routine maintenance intervals
and health monitoring methods along with changes to the handling of
defect reports.
• Modifications fitted on a trial basis should not be considered for
SSAC usage.
• Results of a review of all applicable airworthiness directives
(including MPDs) for the aircraft to determine whether revisions to the
methods of compliance or inspection intervals are justified, or any
currently permitted alternative means of compliance remain
applicable for SSAC operation.
• Proposed revisions to aircraft placarding.
Maximum occupancy levels are already specified for an ANO Certificate of
Airworthiness, Permit to Fly aircraft or equivalent and any change to these maximum
occupancy levels requires an application for an addendum to the relevant AAN.
As far as possible the application will be handled as a documentation change.
Final acceptance of the airworthiness case under the current Certificate of
Airworthiness, Permit to Fly or equivalent along with any additional limitations will be
indicated by a letter to the approved person or organisation and may be used in
support of the operator case to satisfy the requirements for operation.
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Operational requirements
Section 5
Operational requirements
Operators must consider the operational requirement applicable to the particular
class of aviation activity and identify any additional risks that need to be advised to
the participant.
The applicant, having identified the risks may use enhanced operational procedures
to mitigate those risks. The proposed Operational Procedures should include:
• An Operations Manual setting out operational procedures to be used
• Aircraft type-specific operational information
• Training (including Pilot competency, Pilot currency)
• Safety Management System
• Procedure for informing Participants under the principles of SSAC
and obtaining informed Participant’s consent
• Operational procedures required to mitigate any additional risk to
third parties on the ground and in the air, such as keeping clear of
congested areas or flying over the sea.
.
Section 6
Licensing requirements
In establishing the risks and explaining them to participants, operators will have to
show that they have calculated the additional risk participants will be exposed to
compared to the same flight conducted under an AOC. It follows that any additional
risk and explanation for pilot licensing will be minimized if operators engage the use
of pilots that hold at least a UK Commercial Pilots Licence as this aligns an A to A-
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Licensing requirements
AOC. However we recognise that there could be applications from operators to apply
SSAC who wish to use pilots that have many hours of experience on the type (or
similar) and don’t hold a professional licence - these will be considered on a case-bycase
basis in accordance with the principles above.
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