AUTHORIZATION PURSUANT TO PARAGRAPH 704.01(c) OF THE CANADIAN AVIATION REGULATIONS

CAR

Sub Req.

Requirement

Remark

§ 4b.358

(a), (b)

Seats, berths, and safety belts

The flight deck observer seat and cabin crew member seat shall be equipped with both a safety belt and shoulder harness.  See also section 605.24.

§ 4b.380

(c)

Protective breathing equipment

The requirements of section 705.71 shall apply to ensure that PBE is available for all crew members.  See also Air Carrier Advisory Circular 0108 – Protective Breathing Equipment Requirements.

§ 4b.645

(a)

Life rafts

§ 4b.646

(b)

Stowage of safety equipment – Life rafts

§ 4b.651

(h)

Protective breathing equipment

When required by the operating rules of the regulations, the supplemental and protective breathing equipment and its installation shall meet these requirements.

The requirements of section 705.71 shall apply to ensure that PBE is available for all crew members.  See also Air Carrier Advisory Circular 0108 – Protective Breathing Equipment Requirements.

602.60

(1)(e)

Requirements for Power-Driven Aircraft

In accordance with paragraph (e), a flashlight is required for each crew member.

602.86

Carry-on Baggage, Equipment and Cargo

Where carry-on baggage is to be permitted on board, procedures for its stowage in an approved location must be developed and approved.

No underseat or overhead stowage provisions have been approved on board the DC3C-BT67.

602.87

Crew Member Instructions

It is recommended that the crew member briefing requirement contained in Section 705.31 apply in place of this requirement.

605.24

(1), (2)

Shoulder Harness Requirements

In accordance with subsection (1), each seat on the flight deck must be equipped with a safety belt that includes a shoulder harness.

In accordance with subsection (2), the seat in the passenger cabin for the crew member need only be provided with a safety belt that includes a shoulder harness.  The requirement for dual upper torso straps is only required on board aircraft operated pursuant to Subpart 705 of the CARs.

605.25

General Use of Safety Belts and Restraint Systems

605.27

Use of Crew Member Safety Belts

605.31

(1)

Oxygen Equipment and Supply

605.32

(1), (2)

Use of Oxygen

704.07

(2)

Issuance or Amendment of Air Operator Certificate

There is no requirement in Subpart 704 for the operator to have a flight attendant manger as one of the approved managerial personnel.

As the Operations Manager is the responsible manager for issues relating to cabin safety, it is recommended that an interview be conducted by a Cabin Safety Superintendent in order to determine that the Operations Manager is aware of their cabin safety responsibilities and accepts those responsibilities.  The purpose of this interview is to ensure that there is a single person in the air operator’s organization who is responsible for cabin safety standards and will be the point of contact used by Transport Canada for all cabin safety related regulatory issues.

Should the Operations Manager wish to delegate those responsibilities, it is recommended that the approval process for Flight Attendant Managers be followed as identified in CBAAC 0115R2.

724.07

(1)(j), (2)(a)

Issuance or Amendment of Air Operator Certificate

Form 26-0448 Air Operator Certificate Application – Passenger Carrying Authority – Cabin Safety will need to be submitted for approval.  The section entitled “Operations With Flight Attendants” must be completed, with the following exceptions:

• Flight Attendant Manager Qualifications – as noted, this position may not need to be filled where the Operations Manager is able to fulfill their responsibilities;
• Cabin Emergency Evacuation Trainer;
• Minimum Number of Flight Attendants per Aircraft Type; and
• Carry-on Baggage Control Program.

As mentioned, it is desirable that a Cabin Safety Superintendent conducts an interview in order to determine that the Operations Manager is aware of their cabin safety responsibilities and accepts those responsibilities.  The purpose of this interview is to ensure that there is a single person in the air operator’s organization who is responsible for cabin safety standards and will be the point of contact used by Transport Canada for all cabin safety related regulatory issues.

704.21

Admission to Flight Deck

As the DC3C-BT67 is equipped with a flight deck observer’s seat, procedures will be required to address this Section.

In accordance with this section, no provision is made to permit a passenger to occupy the flight deck observer seat nor should such a procedure be approved.

704.33

Apron and Cabin Safety Procedures

The DC3C-BT67 is configured in such a way that the flight crew cannot comply with paragraph 704.33(1)(e).  This has necessitated the need for a crew member to be carried in the cabin.

The crew member shall receive training in accordance with subsection 704.33(3).  The training requirements referenced in 704.115(2)(d) shall be supplemented by the associated elements of TP 12296, Flight Attendant Training Standard.

724.33

Passenger and Cabin Safety Procedures

704.34

Briefing of Passengers

724.34

Briefing of Passengers

This requirement for standard safety briefings imposes all of the briefing elements of section 724.34 of the Standard.  In particular, subparagraph 724.34(1)(a)(vii) states that the standard safety briefing shall include:

"...the location of any emergency equipment the passenger may have a need for in an emergency situation such as the ELT, fire extinguisher, survival equipment (including the means to access if in a locked compartment), first aid kit and life raft..."

Subparagraph 725.43(1)(a)(viii) excludes these briefing elements where flight attendants are required to be on board.  Aeroplanes operating in compliance with the Authorization also have an additional crew member on board the aircraft who has been assigned duties in the interest of the passengers.  Therefore, it is deemed appropriate to provide relief from the briefing requirement of subparagraph 724.34(1)(a)(vii) and the operator may exclude this element from their standard safety briefing.

704.35

Safety Features Card

724.35

Safety Features Card

704.66

Protective Breathing Equipment

The requirements of section 705.71 shall apply to ensure that PBE is available for all crew members.  See also Air Carrier Advisory Circular 0108 – Protective Breathing Equipment Requirements.

704.83

Hand-held Fire Extinguisher

There must be a minimum of three hand fire extinguishers carried:

• One on the flight deck; and

• Two in the passenger cabin (one near each forward and aft Class A cargo compartment).

It is recommended that these extinguishers contain Halon 1211 or approved equivalent agent.

704.84

Equipment Standards and Inspection

724.84

Equipment Standards and Inspection

704.115

Training Program

Training for cabin crew members who have been assigned duties in the interest of the passengers has not been established in Subpart 704 as historically, these crew members were not an identified required crew member on board aircraft operated pursuant to this subpart.

For this reason, it is necessary to identify training requirements based, in part, upon existing regulatory requirements within Subpart 704 and supplemented by requirements from Subpart 705.  In the case of a cabin crew member, this crew member is being assigned duties to be performed in the interest of the passengers on board an aircraft and shall be trained in accordance with paragraphs (d) and (e) of subsection 704.115(2).

Cabin crew member training will also be subject to the requirements of 705.124(1)(b) and 705.124(2)(b).

724.115

(1), (2), (25), (30)

Training Programs

Training for cabin crew members who have been assigned duties in the interest of the passengers shall be in accordance with subsections (1), (25) and (30) of section 724.115.

In accordance with the provisions of subsection (2), the air operator may contract cabin crew member training to another organization provided the conditions of subsection (2) are complied with.

The training elements identified in subsection 724.115(30) shall be linked to the corresponding training elements and supplemented where required by the training contained within TP12296, Flight Attendant Training Standard - Initial.  Those training elements are as follows:

Part One – Aviation Indoctrination

• 1.2 Regulatory Overview

Part Two – Roles and Responsibilities

• 2.1 Air Operator;
• 2.2 Crew Members;
• 2.3 Transport Canada – Aviation Inspector

Part Three – Safety Procedures

• 3.1 Crew Coordination
• 3.2 Communication
• 3.3 Surface Contamination
• 3.4 Briefings
• 3.5 Safety Checks
• 3.6 Passenger Handling
• 3.7 Passenger and Crew Member Seats and Restraints
• 3.8A.1 – 3.8A.4 Carry-On Baggage
• 3.9 Electronic Devices
• 3.10 Service to Passengers on the Ground
• 3.11 Fuelling with Passengers Onboard
• 3.12 Pre-Take Off & Pre-Landing
• 3.14 Apron Safety
• 3.15 Turbulence
• 3.16 Crew Member Incapacitation
• 3.17A.1, 3.17A.3 – 3.17A.4 Flight Deck Protocol
• 3.20 Oxygen Administration

Part Four – Emergency Procedures

• 4.1 Firefighting
• 4.2 Smoke/Fumes in the Cabin
• 4.4 Evacuations

Part Five – Equipment Overview

• 5.1 General

Part Six – Aircraft Specific

• 6.1 Physical Description
• 6.3 Communication Systems
• 6.4 Lighting Systems
• 6.6 Oxygen Systems
• 6.8 Exits
• 6.9 Unique Features

Part Seven – Drills

• 7.1 Public Address and Interphone System Drills
• 7.2 Passenger Briefing Drills
• 7.3 Aircraft Exit Operation Drills
• 7.4 Evacuation Drills
• 7.5 Raft Drill
• 7.6 Life Preserver Drill
• 7.8 Firefighting Drills
• 7.9 Oxygen Equipment Drill

Part Eight – Aviation First Aid

• All subparts required in accordance with Aviation Occupational Safety and Health (AOSH) Regulations.  See subsection 10.3(1) – Trained Employees of the AOSH Regulations.

705.28

Seats for Cabin Safety Inspectors

As there is no similar provision in Subpart 704 to provide an inspector with a seat outside of the flight deck, this section is being imported from Subpart 705 to provide for safety oversight and for evaluating compliance with cabin safety requirements.

705.31

Crew Member Briefing

As there is no provision in Subpart 704 to address crew member briefings and 602.87 is limited in scope, this section is being imported from Subpart 705.

725.31

(1), (2)

Crew Member Briefing

The air operator shall develop crew member briefing in accordance with this standard.

705.41

Flight Attendant Stations

As there is no provision in Subpart 704 to identify the seating requirements for the carriage of cabin crew members, this section is being imported from Subpart 705.

725.41

(1)

Flight Attendant Stations

The basis of approval for the cabin crew member station shall be in accordance with Section 705.41 of the CARs and Section 725.41 of the CASS.

Condition 6 of STC ST00435DE for the DC3C-BT67 stipulates that the left aisle seat at station 402.5 is to be disabled.  While this seat would be the most appropriate for selection by the operator due to the location of the communications equipment and unrestricted access to the main passenger door, the STC does not currently permit its use. 

With this seat disabled, the next available seat for the air operator to consider for the crew member station is the left window seat.  There is concern over the use of this seat due to the potential for interference from the folded down aisle seat back during an emergency evacuation.

705.67

(d), (e)

General Requirements

705.71

Protective Breathing Equipment

The requirements of section 705.71 shall apply to ensure that PBE is available for all crew members.  See also Air Carrier Advisory Circular 0108 – Protective Breathing Equipment Requirements.

The reference to section 705.93 in subparagraph 705.71(3)(b)(iv) is not relevant as section 704.83 identifies the required number of fire extinguishers in the passenger compartment.

705.73

Interphone System

As there is no provision in Subpart 704 for cabin to flight deck communication systems, the requirements of 705.73 are being imported.

705.74

Public Address System

As there is no provision in Subpart 704 for a public address system, the requirements of 705.74 are being imported.

It has been determined that where the additional crew member station is located within the passenger cabin, no public address system access is required for the additional crew member.

705.76

Lavatory Fire Protection

As there is no provision in Subpart 704 for lavatory fire protection, the requirements of 705.76 are being imported.

705.79

Flashlight Stowage

As there is no provision in Subpart 704 for flashlight stowage, the requirements of 705.79 are being imported.

Paragraph 602.60(1)(e) requires that a flashlight be available for each crew member.

705.90

(2), (3)

First Aid Kits

As there is no provision in Subpart 704 relating to the location and marking of the first aid kit required by subsection 724.84(3), the requirements of 705.90(2) and (3) are being imported.

705.104

(1)(a), (2)

Flight Attendant Requirements

The DC3C-BT67 is configured in such a way that the flight crew cannot comply with paragraph 704.33(1)(e) to exercise oral and visual supervision of the passengers.  This has necessitated the need for a crew member to be carried in the cabin when passengers are carried.

705.109

(1)

Flight Attendant Qualifications

As there is no provision for the qualification of crew members assigned duties to be performed in the interest of passengers in Subpart 704, the requirements of 705.109 are being imported.  Line indoctrination training for the cabin crew member is not required.

725.113

(5)

Validity Period

As there is no provision related to the validity period of “training”, other than annual training, in Subpart 704, the validity period requirements of 725.113(5) will be imported.

705.124

(1)(b), (2)(b)

Training Program

As there is no provision in Subpart 704 specifying the training required for crew members assigned duties to be performed in the interest of passengers, these elements of 705.124 will be imported.

Approval of the training programs shall remain in accordance with 704.115.

725.124

(39)

Training Program

This additional training requirement specified in 725.124 has been identified as necessary to comply with paragraph 704.115(2)(e).

705.139

Flight Attendant Manual

As there is no provision in Subpart 704 relating to a manual for crew members assigned duties to be performed in the interest of passengers, the requirements of 705.139 will be imported.

There is no need to publish a separate document for the use of the crew member, provided that the content requirements of TP 12295, as applicable to the operation, are contained within the Operations Manual and the crew member is issued with this manual in accordance with 704.122(1).