For the text of the proposal itself as at 1st March 2002, see airsafety.com.au/dp0109cs/dp0109cs.pdf and for the text of the proposed Airworthiness Directive, see airsafety.com.au/dp0109cs/ad0109cs.pdf

To: Bruce Byers, Specialist Engineer Crashworthiness, CASA.

Hello Bruce,

On behalf of AIR SAFETY AUSTRALIA, I have reviewed proposal DP0109CS. It is not acceptable for the reasons set out below.

Kind regards,

Boyd Munro

Copies to John Anderson, Martin Ferguson, Brian Greig, Kerry O'Brien

QUOTE

This is a proposal to compel the owners of small aircraft to fit upper-body restraints (shoulder harnesses) to all passenger seats if the aircraft are engaged in carrying fare-paying passengers.

AIR SAFETY AUSTRALIA opposes the proposal because there has been no attempt to encourage voluntary adoption of the proposal prior to making it compulsory.

It is claimed that there is a positive cost-benefit. If that is actually the case, one would expect to see lower insurance premiums for aircraft fitted with the proposed shoulder harnesses. There is wide experience with such aircraft, as the proposal itself says, and one would expect that insurers had noticed the benefits.

Are insurance premiums in fact lower for such aircraft? If so, why has this not provided adequate incentive for owners to install shoulder harnesses voluntarily? If not, does this mean that insurers do not share CASA's view about the benefits? In my own case, no insurer has ever asked me whether my aircraft are fitted with shoulder harnesses and I therefore conclude that those insurers with whom I deal do not believe that shoulder harnesses make any difference to the frequency or amount of liability insurance claims. I therefore query whether the claimed benefits are achieved in the real world. If fitment of a shoulder harness really did reduce serious injuries by 88%, the first question an insurer would ask is whether shoulder harnesses are fitted. In practice, the questions insurers ask are mostly concerned with the training and experience of pilots who will fly the aircraft.

If there really is a positive cost-benefit in this proposal, appropriate education of insurers and aircraft owners should ensure that shoulder harnesses are fitted to much more than the 10% of the fleet which this proposal seeks to compel.

AIR SAFETY AUSTRALIA is willing to play its part in educating aircraft owners once it is demonstrated that fitting shoulder harnesses does in fact reduce liability insurance premiums. Should the educational attempt fail, AIR SAFETY AUSTRALIA would then re-consider its opposition to this proposal.

AIR SAFETY AUSTRALIA also has serious technical reservations about the detail of the proposal, and points out that the Airworthiness Directive proposed is far different from the BASI recommendation, and also different from what is described in DP0109CS. This is the subject of a separate response from Jim Dawson, AIR SAFETY AUSTRALIA's Research Officer.

Boyd Munro on behalf of AIR SAFETY AUSTRALIA

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