i/R-2/6/9/19 ROTORCRAFT - LOAD COMBINATION FLIGHT …

FERGUSON AND SONS CONSTRUCTION ROTORCRAFT LOAD COMBINATION FLIGHT MANUAL

i/R-2/6/9/19

ROTORCRAFT - LOAD COMBINATION FLIGHT MANUAL

February 22, 2017

HUGHES 369D/E/F/FF MD 600N

FERGUSON AND SONS CONSTRUCTION, LLC. 20317 S. PARKER RD

SPANGLE, WA 99031-8505


ii/R-2/6/9/19

EFFECTIVE PAGES

This listing contains all current pages, with effective dates, of this manual. It should be used after posting changes to insure the manual is complete and up-to-date. PAGE STATUS DATE PAGE STATUS DATE Preface Appendix 3 i R-2 6-9-19 Appendix 3 R-0 2-22-17 ii R-2 6-9-19 Appendix 3.1 R-2 6-9-19 iii R-2 6-9-19 iv R-2 6-9-19 Appendix 4 v R-1 5-6-18 Appendix 4 R-0 2-22-17 vi R-0 2-22-17 Appendix 4.1 R-0 2-22-17 Appendix 4.2 R-0 2-22-17 Section A A-1 R-2 6-9-19 Appendix 5 A-2 R-2 6-9-19 Appendix 5 R-1 5-6-18 Appendix 5.1 R-1 5-6-18 Section B Appendix 5.2 R-1 5-6-18 B-1 R-0 2-22-17 Appendix 5.3 R-1 5-6-18 B-2 R-1 5-6-18 Appendix 5.4 R-1 5-6-18 B-3 R-1 5-6-18 Appendix 5.5 R-1 5-6-18 B-4 R-1 5-6-18 Appendix 6 Section C Appendix 6 R-1 5-6-18 C-1 R-0 2-22-17 Appendix 6.1 R-1 5-6-18 C-2 R-0 2-22-17 Appendix 6.2 R-1 5-6-18 C-3 R-0 2-22-17 Appendix 6.3 R-1 5-6-18 C-4 R-0 2-22-17 Appendix 6.4 R-1 5-6-18 Appendix 6.5 R-1 5-6-18 Section D D-1 R-1 5-6-18 D-2 R-1 5-6-18 D-3 R-1 5-6-18 Appendix 1 Appendix 1 R-0 2-22-17 Appendix 1.1 R-0 2-22-17 Appendix 1.2 R-0 2-22-17 Appendix 1.3 R-0 2-22-17 Appendix 2 Appendix 2 R-0 2-22-17 Appendix 2.1 R-0 2-22-17 Appendix 2.2 R-0 2-22-17 Appendix 2.3 R-0 2-22-17 Appendix 2.4 R-0 2-22-17 Appendix 2.5 R-0 2-22-17 Appendix 2.6 R-0 2-22-17 Appendix 2.7 R-0 2-22-17


iii/R-2/6/9/19

LOG OF REVISIONS

Revision No. Date Page Number (s) Initials 1 5/6/18 i,ii,iii,iv,v,A-1,A-2,B-2,B-3,B-4,D-1,D-2,D-3

App5,5.1,5.2,5.3,5.4,5.5 App6,6.1,6.2,6.3,6.4,6.5

2 6/9/19 i,ii,iii,iv,A-1,A-2,App3.1


iv/R-2/6/9/19

PAGE CONTROL LIST

Remove Pages Dated Insert Pages Dated i-v 2-22-17 i-v 5-6-18 A-1 – A-2 2-22-17 A-1 – A-2 5-6-18 B-2 – B-4 2-22-17 B-2 – B-4 5-6-18 D-1 – D-3 5-6-18 App5 – 5.5 5-6-18 App6 – 6.5 5-6-18

i-iv 5-6-18 i-iv 9-6-19 A-1 – A-2 5-6-18 A-1 – A-2 9-6-19 APP 3.1 2-22-17 APP 3.1 9-6-19


PREFACE i. Title ii. List of Effective Pages iii. Log of Revisions iv. Page Control list v. Table of Contents vi. Reserved

TABLE OF CONTENTS

v/R-1/5/6/18

SECTION A: OPERATING LIMITATIONS 1. Certification 2. Persons Aboard 3. Congested Area Operations 4. Knowledge and Skills 5. Required Documentation 6. Weight and Load Combination 7. Center of Gravity 8. Other Limitations

SECTION B: LOAD-COMBINATION OPERATING INFORMATION 1. Information Peculiar to the Load Combination 2. Required Inspections 3. Static Electricity Discharges 4. Other Information Essential to Operational Safety 5. Ground-to-Air Hand Signals 6. External-Load Securing Procedures 7. Center of Gravity During Operation vs. Fuel Burned 8. Required Placards 9. Operating Procedures 10. Safety Precautions

SECTION C: INFORMATION 1. General 2. Flight and Non-Flightcrew Personnel 3. Safety Around Helicopters

SECTION D: TRAINING AND RECORDS 1. Training Requirements 2. Training Records 3. Pilot Card

APPENDIX 1. CONGESTED AREA PLAN APPROVAL

APPENDIX 2. HAND SIGNALS

APPENDIX 3. JOB PRE-ASSESSMENT CHECKLIST

APPENDIX 4. FS 5700-17 AND INSTRUCTIONS

APPENDIX 5. HUMAN EXTERNAL CARGO (HEC) OPERATIONS

APPENDIX 6. EXEMPTION FROM 133.43(a) and (b)


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RESERVED


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Section A: Operating Limitations

In addition to the operating limitations set forth in the approved Rotorcraft Flight Manual (RFM), operate this rotorcraft in accordance with the following operating limitations:

1. Certification. No person may operate this rotorcraft with an external-load unless that person holds a FAA Rotorcraft External-Load Operator Certificate and has a letter of competency or an entry in his or her logbook, as required by Title 14 of the Code of Federal Regulations (14 CFR) part 133, § 133.37(a)(2). The letter of competency or the knowledge and skill test logbook endorsement must be in that person’s possession while conducting operations under part 133.

2. Persons Aboard. No person who is not a required crewmember may fly aboard the rotorcraft unless that person performs an essential function in connection with the external-load operation. Any time an operation is performed in which another person is required on board the aircraft, the air crewmember must wear an approved safety harness while not seated with a seatbelt fastened.

3. Congested Area Operations. Do not conduct operations over congested areas unless approved by the FAA FSDO in accordance with a Congested Area Plan (CAP) developed in compliance with § 133.33(d)(1) and (2). (See sample plan in Appendix 1.)

4. Knowledge and Skills. No person may serve as a pilot of this rotorcraft during external-load operations, unless that person has passed the knowledge and skill tests required by § 133.23 for the class of operation being conducted.

5. Required Documentation. A copy of the Rotorcraft External-Load Operating Certificate and RLCFM will be on this rotorcraft during all external-load operations.

6. Weight and Load Combination. The total weight of this rotorcraft and load combination may not exceed:

Make and model Class (Max. Gross Weights) Max. Hook Load

HUGHES 369D/E

A B/C 3,000 3,550 lbs

2,000 lbs, 1900 lbs side pull

HUGHES 369F/FF 3,000 3,750 lbs 2,000 lbs, 1900 lbs side pull MD 600N 4,100 4,500 lbs 2,143 lbs, 1900 lbs side pull

The maximum load for Class A cargo racks shall not exceed the following:

Isolair Cargo Racks 250 lbs each side, or asymmetrical load of 220 lbs

MD 500 series Tyler Bench 500 lbs MD 600 series Tyler Bench 500 lbs


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7. Center of Gravity. The location of the center of gravity (CG) for this rotorcraft and load combination must be within the CG range established during type certification (TC) under 14 CFR part 27 or 29 or special purpose certification of the rotorcraft.

8. Other Limitations.

Maximum operating altitude:

HUGHES 369D/E 14,000 ft Density Altitude

HUGHES 369F/FF 15,500 ft Density Altitude for GWT 3,200 lbs or less.

12,150 ft Density Altitude for 3,201 to 3,750 lbs GWT. MD 600N 20,000 ft HD, 20,000 Feet HP, or 17,500 AGL, whichever is lower. 14,000 ft Pressure Altitude using JP-4 or JP-8 fuels with airframe fuel Filter installed.

Airspeed: These helicopters shall be operated at a speed selected by the pilot for the best stability of the load, but not to exceed the airspeed limits specified in the approved rotorcraft flight manual. The size and shape of the cargo load shall be considered as controllability may be affected.

Winds: With winds more than 40 knots, or a 15 knot gust spread for non-human

loads, winds more than 30 knots, or a 15 knot gust spread for HEC loads, or when controllability of the load is affected, external load operations will cease. The PIC will be the final authority in this decision.

Fuel Planning: A 20-minute reserve plus fuel to complete the mission is required. For flight

planning purposes, fuel burn for the Hughes 369D/E series is approximately 27 gallons per hour, the Hughes 369F/FF is approximately 35 gallons per hour, and the MD 600N burns approximately 40 gallons per hour. Pilots should calculate actual burn rates during each flight by completing an in-flight fuel consumption check because altitude, temperature, and power settings affect burn rates. Pilots should plan to be on the ground with a minimum of 100 lbs fuel indication on the fuel quantity indicator. In addition to monitoring the fuel quantity indicator, a chronometer will be used to determine time elapsed since start of fuel cycle.


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Section B: Load Combination Information

1. Information Peculiar to the Load Combination.

A. Oscillating tendencies: The pilot must be aware of and control any tendency of the external load to oscillate. Oscillation is dependent on speed, load density, and pilot input.

B. Ground effect: The pilot should note that under most external load flight conditions, the

aircraft will be out of ground effect and will require more power to hover.

C. Density altitude: Be aware of the effects of higher power requirements.

D. Strong or gusty winds: Strong winds may affect controllability of the load as well as the aircraft. The pilot must use his discretion and good judgment to decide when to terminate the operation due to environmental conditions.

E. Abrupt control movements: Oscillations may be induced into the external load with

control movements. The use of smooth and gradual control inputs should be practiced to minimize oscillating tendencies of the external load.

F. Acceleration limitation: The load must be watched as you begin to accelerate to

determine the best airspeed for the load being carried.

G. Procedures for determining lateral and longitudinal center of gravity: The pilot must use caution when carrying internal and external loads. The pilot must use the information in the Rotorcraft Flight Manual weight and balance section as well as the limitations section to determine that all loads will remain within the CG limits throughout the entire operation. Pilots will be aware of fuel burn effects on the center of gravity of the aircraft.

H. Spinning Loads: Any load that may be conducive to a spinning action should be

suspended with a swivel to prevent the load from winding the line.

2. Required Inspections. Inspect lanyards, cargo nets, swivels, connecting devices, and cables for overall serviceability and general condition. Check cargo hook electrical and mechanical releases for proper operation prior to any Class B or C operations.

3. Static Electricity Discharges. During external loads (Class B), caution should be used to ground the hook by touching the hook to the ground to discharge the static electricity that may have built up during flight.


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4. Other Information Essential to Operational Safety

A. High tension wires: A good ground and aerial recon of the area where the work is to be performed is essential to help aid in the detection of wire hazards that may be present in the area of operations. Extreme caution should be used when working around these above ground hazards.

B. Lightning: Flights during periods of visible lightning are not recommended. If visible

lightning is within three miles of the area of operation of Class B or C loads, discontinue operations until weather conditions improve.

C. Radio communication procedures: Radios should be used during any operation to

facilitate communication between the pilot and the ground crew. A person with a radio should be at both the pick-up and drop-off points of the load. All communication should be clear and concise. Terminology should be briefed before the operation begins so that there is no miscommunication.

D. Crossing over main highways and roads: Be aware of any traffic when crossing over any

roadway or main highway. Use road guards if necessary to stop traffic. No external load can be carried over any person or property (Houses or Cars).

E. Placement of cargo: Caution must be taken not to drag the load on the surface during

external load operations. This will not only damage the cargo but will place high stress forces on the sling, which may affect the controllability of the aircraft.

F. Class A: Class A loads require extra care to remain within lateral CG limits. Also, cargo

must not block the pilot door and passengers cannot be carried when cargo blocks passenger doors.

G. HEC (Human External Cargo). See Appendix 5.

5. Ground-to-Air Hand Signals. All personnel engaged in the external-load operation will be familiar with and use the hand signals found in Appendix 2.

6. External-Load Securing Procedures.

A. Cargo nets: Nets should be used when dealing with bulky, numerous, or other items that

don’t lend themselves to being lifted easily with straps.

B. Lifting straps / slings/ spiders: Straps should be used on large objects that can be secured and prevent shifting during flight. These straps should be rated at two and one-half times the weight of the item being lifted.


B-3/R-1/5/6/18

C. Pilot responsibility: It is the responsibility of the pilot to ensure that the cargo is secured in a proper manner prior to the beginning of the operation. The pilot can delegate this responsibility to the ground personnel only if they are properly trained on the rigging of external loads for flight. As with all operations, the pilot should watch the load during the initial pickup, transition to forward flight, forward flight, and during deceleration and landing. It is very important that the ground crew observe the load during all phases of the operation so that they can notify the pilot of any changes or movement of the cargo.

7. Center of Gravity during operation vs. fuel burned. The center of gravity will move as fuel is burned off, it is the pilot’s responsibility to operate within the CG limitations of the aircraft.

8. Required Placards.

A. Fuselage: Place a placard for the maximum external-load weight on each side of the

fuselage near the cargo hook for B and C loads or basket if a Class A load.

B. Instrument panel: Install an instrument panel placard describing load class approval and passenger occupancy limitations.

9. Operating Procedures.

Class A: Compute center of gravity and performance planning to ensure that you operate

within the limitations of the RFM for the entire flight. Brief crewmembers (if applicable). If crewmembers are to be carried in the passenger compartment, it is important that the Class A load does not interfere with emergency egress procedures. If egress routes are obstructed, crewmembers will not be carried. If crewmembers are to be carried externally, ensure that appropriate safety restraints are available and that the crewmember is connected to the aircraft intercom system if needed. Compute required fuel for the flight and load aircraft in accordance with the checklist in appendix 3.

Class B: Compute center of gravity and performance planning to ensure that you operate

within the limitations of the RFM for the entire flight. Compute required fuel for the flight and load aircraft in accordance with the checklist in appendix 3. Brief all crewmembers on rigging, load hook-up, load drop off, and emergency procedures. Ground crewmembers should have radio communication with the pilot if at all possible. If radio communications are not possible, crewmembers must be familiar with visual signaling techniques. After directing the helicopter into position, one ground crewmember should remain within sight of the pilot to give positive direction with hand signals, or remain in direct radio contact with the pilot, while an appropriate number of other crewmembers attend to the cargo hookup. Hasten all hookups made to the helicopter while it is in a hover to minimize the time the hookup personnel spend


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underneath the helicopter. If performing a hookup without the aid of a ground guide and without using direct visual operational contact, an air crewmember should lie prone on the floor and look downward from the passenger compartment doorway to observe the actions of the ground crewmembers; this crewmember can direct the pilot via the intercom. Ground personnel at the drop off point should communicate the position of the load to the pilot to ensure it remains clear of obstacles and to indicate when the load is safely on the ground or in the proper position and ready to be released.

Class C: Compute center of gravity and performance planning to ensure that you operate within the limitations of the RFM for the entire flight. Compute required fuel for the flight and load aircraft in accordance with the checklist in appendix 3. Brief all crewmembers on rigging, load hook-up, load drop off, and emergency procedures. Ground personnel at each end of the pulling operation will have direct radio communications with the pilot at all times, as well as a spotter on the ground that will follow the aircraft and observe the load if practical. Because the aircraft is grounded to the earth with the load, the pilot must be advised of changing weather conditions and operations must be suspended if lightning is observed in the local area.

10. Safety Precautions.

Class D: No Class D operations will be conducted.

The operating limitations as set forth in section 1 and the load combination information contained in section 2 are the conditions under which I will conduct this rotorcraft external-load combination operation.


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Section C. General Information

Prior to starting any external load operation, complete the Job Pre-Assessment checklist in Appendix 3. All personnel associated with an external-load operation should be familiar with the following information.

1. General. Serious injuries and fatalities may occur if personnel are not trained on the proper method for approaching or leaving the rotorcraft. The simplest method of avoiding accidents of this sort is to have the rotors stopped when non-flight personnel are working around the rotorcraft. Because this is not always practical, it is essential that all persons associated with helicopter operations be aware of all possible hazards and instructed in how to avoid them.

2. Flight and Non-Flightcrew Personnel. Instruct persons directly involved with loading or unloading personnel, rotorcraft servicing, rigging, or hooking up of external-loads, etc., in their duties. It would be difficult to cover each type of crew training related to the safe operation of helicopters; however, some areas to cover include:

A. Ground crew: Instruct LZ attendants and rotorcraft servicing personnel in safe means of

accomplishing their specific duties. This includes:

(1) Keeping persons scheduled to board and unauthorized persons away from the helicopter landing and takeoff areas.

(2) Briefing boarding personnel on the best way to approach and board a helicopter

whose rotors are turning.

B. Servicing: Proper procedures for rotorcraft servicing include the following:

(1) Stop the helicopter rotor blades and properly ground both the rotorcraft and the refueling unit. Check for proper fuel grade and any required additives.

(2) Refueling the rotorcraft while the blades are turning (hot refueling) may be practical

for certain types of operations. However, this can be extremely hazardous when safe procedures are not followed. Refueling personnel should be knowledgeable about proper refueling procedures and properly briefed for specific makes and models of rotorcraft. If the pilot is in the aircraft, refueling personnel must communicate with the pilot by radio or using hand signals during hot refueling.

(3) Position refueling units to ensure adequate rotor blade clearance; keep persons not

involved with the refueling operation clear of the area. Verify disconnection and securing of all refueling equipment away from the rotorcraft prior to rotorcraft movement. Always ensure that proper fire extinguishing equipment is readily available when refueling.

(4) Prohibit smoking in and around the rotorcraft during all refueling operations.


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C. Rigger Training: External-load rigger training is possibly one of the most difficult and continually changing aspects of the helicopter external-load operation. A poorly rigged cargo net, light standard, or load pallet could result in a serious accident. It is imperative that all riggers be thoroughly trained to meet the needs of each external-load operation. Since rigging requirements may vary several times in a single day, proper training is of the utmost importance to safe operations.

D. Pilot at the Flight Controls:

(1) Often, the job requirements will require a “quick turnaround” ground operation to

avoid delays and to minimize stop/start cycles of the engine. As part of this quick turnaround, the pilot will sometimes leave the cockpit with the engine running and rotors turning. Such an operation can be extremely hazardous if a gust of wind disturbs the rotor disc, or if a flight control moves, causing the rotor system to generate lift. Use extreme caution when refueling in this manner. If environmental conditions are questionable, the pilot must remain at the flight controls.

(2) Safe operating procedures include pilots remaining at the flight controls whenever the

engine is running, and rotors are turning if possible. This is especially important when operating near people that are not familiar with helicopter operations.

If it is necessary to leave the controls of a running machine, the pilot should:

(i) Ensure that the controls are secured in accordance with the RFM, and

(ii) Reduce rotor and engine RPM to the minimum recommended settings.

E. External-Load Signalmen Should Know the Following:

(1) The general lifting capability of the helicopters involved: This knowledge is

essential because some operators have models of helicopters that have almost identical physical characteristics, but different lifting capabilities.

(2) The Pilots: The safest plan involves standardized procedures for pickup and release

of sling loads. Without standardization, the hookup person is required to learn the technique used by each pilot. The hookup person should insist on standardization of pilot techniques for any sort of emergency that may occur while personnel are beneath the helicopter.

(3) The Cargo: Many items carried externally are very fragile. The hookup person must

be familiar with potentially hazardous materials (hazmat) and aware of the nature of the potential hazard. Explosives, radioactive materials, and toxic chemicals are examples of possible hazmat. Title 49 of the Code of Federal Regulations (49 CFR) part 172, §§ 172.101 and 172.102 contain the hazmat commodity lists, this information can be found in the ERG (orange book). Carriage of


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hazmat in 14 CFR part 133 operations requires FAA and DOT authorization. In addition to knowing the nature of the cargo, hookup personnel should receive training and be familiar with the types of protective gear, clothing, and actions that are necessary for safe operation, prior to handling hazardous materials.

(4) The Appropriate Hand Signals: When not using direct radio communications

between ground and flight personnel, assure that pilots and ground personnel understand meaning of hand signals before operations commence.

(5) Emergency Procedures: Ground and flight personnel should fully agree to and

understand all necessary actions to take by all concerned in the event of emergency. This prior planning is essential in avoiding injuries when emergencies do occur.

(6) All Aspects of the External-Load Operation Being Conducted: The pilot

conducting the external-load operation will complete a detailed briefing for all personnel, no matter how remotely involved in the operation, prior to starting the operation.

3. Safety Around Helicopters. Instruct all persons who board a helicopter while its rotors are turning in the safest means of doing so. If at the controls, the pilot may not be able to conduct a boarding briefing. Therefore, the individual who arranged for carriage of the personnel or the individual assigned as the LZ attendant should accomplish this. The exact procedures may vary slightly from one model helicopter to another, but in general, the following should suffice.

A. Boarding:

(1) Stay away from the rear of the helicopter.

(2) Crouch low before walking under the main rotor.

(3) Approach from the side or front, but never out of the pilot’s line of vision, and only

when the pilot has indicated that it is safe to walk beneath the turning rotors.

(4) Hold firmly to hats and loose articles.

(5) Never reach up for or run after a blown-away hat or other object.

(6) Protect your eyes by wearing eye protection, shielding them with your hand, or by squinting.

(7) If suddenly blinded by dust or a blowing object, stop, crouch lower, or sit down, and

await help.

(8) Never grope or feel your way toward or away from a helicopter.


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B. Briefing: The pilot must make the pre-takeoff briefing. The type of operation will

determine what sort of briefing is given, but the briefing should always include:

(1) The use and operation of seatbelts for takeoff, en route, and landing. Place emphasis on how to release the specific kind of seatbelt installed in the particular rotorcraft. Helicopters do not always use automotive type releases; for instance, some belts use buckles that rotate to open.

(2) The location and use of flotation gear and other survival equipment that might be

onboard, and how and when to “abandon ship” if a ditching is necessary.

(3) For flights over rough or isolated terrain, tell all occupants where maps and survival gear are located.

(4) Instruct each person onboard in what actions and precautions to take during an

emergency, and how and when to exit after landing in the event of an emergency. Ensure that passengers are aware of the location of fire extinguishers, pyrotechnic signaling devices, life preservers, and other survival equipment. Explain the location and methods of opening normal and emergency exits. The FAA encourages use of a diagram or pictorial display on a passenger briefing card.

(5) Prohibit smoking within 50 feet of a rotorcraft.

C. Conditions of Landing: The conditions of the landing determine what passengers should

hear in a departing briefing. For example, if on a hill, depart cross-slope or downhill. If this involves walking around the helicopter to avoid the area of lowest rotor clearance, always go around the front, never the rear.


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Section D. Training and Records All Ferguson and Sons Pilots will be trained annually. Training will be documented and kept in the individual Pilot Record. 1. Pilots will receive initial and annual recurrent training in the following subject areas prior to

performing any external load operation with Ferguson and Sons.

a. Knowledge and skill training

b. Demonstrated proficiency with precision vertical reference load placement

c. Proper load configuration, use, and application of Class B HEC (if applicable)

d. Installation, inspection, and operation of secondary safety devices

e. Acceptance or rejection criteria of all attaching means to include long lines, remote hooks, general rigging, chairs, harnesses, and HEC safety equipment

f. D-ring reversal/dynamic rollout during long line or side pull operations

g. Hazard identification, risk analysis, and mitigation

h. Crew resource management (CRM)

i. Communication procedures

j. Normal/abnormal and emergency procedures pertinent to Class B HEC (if applicable)

k. Operating in the wire environment hazards

l. Fuel Management procedures


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Record of 133 Training Name: Duty Position: PIC

Training Received Base Month:

MD 500:

Model MD500

Initial

Recurrent

Knowledge Test

Curriculum Segments: Instructor: Date: Basic Knowledge Test Vertical Ref. Load Placement Load Config to include HEC Rejection Criteria for rigging to include HEC

D-ring reversal and load loss Hazards and risk mitigation CRM Communications Normal/abnormal and emergency proc.to include HEC

Operating in the wire environment hazards

Fuel Management

Form FC-TR133


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Ferguson and Sons 133 Letter of Competency (Pilot Card)

FRONT BACK


Congested Area Plan Approval

(Submit in duplicate)

Appendix 1

Appendix 1/R-0/2/22/17

Name, Address, Telephone Number of Operator:

Name, Address, Telephone Number of Contractor:

Rotorcraft Identification Number: N

Rotorcraft Make and Model:

Rotorcraft Airworthiness Category (Normal, Restricted, Transport):

Pilot Name and Certificate Number:

DATES AND TIMES OPERATION WILL BEGIN AND TERMINATE: Date Time begin Time end

Name, title, and telephone number of appropriate official of the local subdivision who has agreed to exclude unauthorized persons from the operational area, if applicable:

Copy of agreement attached?

List of streets or roads that will be blocked during operation, if applicable:

Ingress/egress routes, if applicable:

(If appropriate) This operation has been coordinated with the following air traffic control facilities:

Description and weight of loads to be carried:

Class:

Description:

Length of attaching means (includes hook and cable):

Weight of load:


Appendix 1.1/R-0/2/22/17

Physical size of load:

List of buildings that must be either partially or entirely unoccupied by persons:

Building description/address:

Owners:

Telephone number:

Load penetration (for occupied buildings):

How many floors could the load penetrate if dropped from the highest point of lift above the building? floors

What is maximum height the load will be lifted above building? feet

Are charts, maps, and/or diagrams attached?

Narrative description of pickup site, route, delivery site, and plan for ceasing operation if unauthorized persons enter operational area:

Local law enforcement agency notified and point of contact established.

(Use additional sheets as necessary.)

[Company official’s signature]

[Title]

[Date]


Appendix 1.2/R-0/2/22/17

SAMPLE DIAGRAM OF CONGESTED AREA PLAN


Appendix 1.3/R-0/2/22/17

LETTER OF AGREEMENT FOR CONGESTED AREA

Personnel of the [name of the political subdivision] agree to exclude all unauthorized persons from the operational area described on the attached CAP, which was prepared for rotorcraft external-load operations. I understand that the operations will be conducted on [dates] and remove the operator’s responsibility to exclude all unauthorized persons from the operational area.

[Name of official]

[Title of official]

[Date]



Appendix 2.

Hand Signals


Appendix 2.1/R-0/2/22/17


Appendix 2.2/R-0/2/22/17


Appendix 2.3/R-0/2/22/17


Appendix 2.4/R-0/2/22/17


Appendix 2.5/R-0/2/22/17


Appendix 2.6/R-0/2/22/17


Appendix 2.7/R-0/2/22/17



APPENDIX 3

JOB PRE-ASSESSMENT CHECKLIST Pilot will review and initial each item on the checklist

1. Pilot assigned to job will access their level of skill to insure they have the experience and skill

set to safely accomplish the job.

2. These areas of concern will be addressed before each job;

A. Type of area and terrain the job will be conducted in

B. Whether or not a Congested Area Plan (CAP) is required 1. Date CAP submitted to FSDO 2. Date CAP approved by FSDO

C. Type of load being flown, and hazards associated with it (i.e. sheets of plywood versus water bucket)

D. Length of Long Line required for the operation and type of rigging needed to accomplish the job

E. A weight and balance will manually be filled out for the minimum and maximum weights expected for the job as CG ranges can and will shift with Gross Weight. An applicable copy of the Aircraft weight and balance chart will be available in the Load Manual.

F. The applicable Performance Chart for the Job will be available in the RFM. PIC will manually compute max gross weight and max weight on the hook before each lift using the FS 5700-17 form and attach it to this checklist (see appendix 4). Consideration will be given to other than normal conditions encountered, and weights will be adjusted as needed. A good rule of thumb is to download 5 to 10 percent if other than optimal conditions are encountered. This safety margin will be entered in block 8 of the FS 5700-17 if applicable.


Appendix 3.1/R-2/6/9/19

G. Pilot will shut down to refuel Aircraft unless the mission requirements dictate otherwise and hot refuel procedures can be accomplished without compromising safety.

H. A 20-minute reserve plus fuel to complete the mission is required. For flight planning purposes, fuel burn for the MD 500 series is approximately 27 gallons per hour, the 530F/FF is approximately 35 gallons per hour, and the MD 600N burns approximately 40 gallons per hour but pilots should calculate actual burn rates during each flight by completing an in-flight fuel consumption check because altitude, temperature, and power settings affect burn rates. Pilots should plan to be on the ground with a minimum of 100 lbs fuel indication on the fuel quantity indicator. In addition to monitoring the fuel quantity indicator, a chronometer will be used to determine time elapsed since start of fuel cycle.



PA OAT

PA OAT

INTERAGENCY HELICOPTER LOAD CALCULATION

5 FUEL WT ( gallons X lbs per gal)

6 OPERATING WEIGHT (3 + 4 + 5)

Non-Jettisonable Jettisonable

PILOT SIGNATURE HazMat

MGR SIGNATURE


Appendix 4.1/R-0/2/22/17

INSTRUCTIONS

A load calculation must be completed for all flights. A new calculation is required when operating conditions change (± 1000’ in elevation or ± 5oC in temperature) or when the Helicopter Operating Weight changes (such as changes to the Equipped Weight, changes in flight crew weight or a change in fuel load).

All blocks must be completed. Pilot must complete all header information and Items 1-13. Helicopter Manager completes Items 14 & 15.

DEPARTURE – Name of departure location and current Pressure Altitude (PA, read altimeter when set to 29.92) and Outside Air Temperature (OAT, in Celsius) at departure location.

DESTINATION – Name of destination location and PA & OAT at destination. If destination conditions are unknown, use MSL elevation from a map and Standard Lapse Rate of 2o C/1000’ to estimate OAT.

Check the box in Line 1 (Departure) or Line 2 (Destination) to indicate the most restrictive values used to obtain Computed Gross Weight in Line 7b.

HELICOPTER EQUIPPED WEIGHT – Equipped Weight equals the Empty Weight (as listed in the Weight and Balance Data) plus the weight of lubricants and onboard equipment required by contract (i.e. survival kit, rappel bracket).

FLIGHT CREW WEIGHT – Weight of the Pilot and any other assigned flight crewmembers on board (i.e. Co-pilot, flight engineer, navigator) plus the weight of their personal gear.

FUEL WEIGHT – Number of gallons onboard X the weight per gallon (Jet Fuel = 7.0 lbs/gal).

OPERATING WEIGHT – Add items 3, 4 and 5.

7a. PERFORMANCE REFERENCES – List the specific Flight Manual supplement and hover performance charts used to derive Computed Gross Weight for Line 7b. Separate charts may be required to derive HIGE, HOGE and HOGE-J. HIGE: use Hover-In-Ground-Effect, External/Cargo Hook Chart (if available). HOGE & HOGE-J: use Hover-Out-Ground-Effect charts for all HOGE operations.

7b. COMPUTED GROSS WEIGHT - Compute gross weights for HIGE, HOGE and HOGE-J from appropriate Flight Manual hover performance charts using the Pressure Altitude (PA) and temperature (OAT) from the most restrictive location, either Departure or Destination. Check the box in Line 1 (Departure) or Line 2 (Destination) to indicate which values were used to obtain Computed Gross Weight.


Appendix 4.2/R-0/2/22/17

WEIGHT REDUCTION – For Federal Contract work, the Government Weight Reduction is required for all “non- jettisonable” loads. The Weight Reduction is optional (mutual agreement between Pilot and Helicopter Manager) when carrying jettisonable loads (HOGE-J) where the pilot has total jettison control. The appropriate Weight Reduction value, for make & model, can be found in the current helicopter procurement document (contract).

ADJUSTED WEIGHT – Line 7b minus Line 8.

GROSS WEIGHT LIMITATION – Enter applicable gross weight limit from Limitations Section of the basic Flight Manual or the appropriate Flight Manual Supplement. This may be Maximum Gross Weight Limit for Take-Off and Landing, a Weight/Altitude/Temperature (WAT) limitation or a Maximum Gross Weight Limit for External Load (jettisonable). Limitations may vary for HIGE, HOGE and HOGE-J.

SELECTED WEIGHT – The lowest weight, either line 9 or 10, will be entered for all loads.

Applicable limitations in the Flight Manual must not be exceeded.

OPERATING WEIGHT – Use the value entered in Line 6.

ALLOWABLE PAYLOAD – Line 11 minus Line 12. The maximum allowable weight (passengers and/or cargo) that can be carried for the mission. Allowable Payload may differ for HIGE, HOGE and HOGE-J.

PASSENGERS AND/OR CARGO – Enter passenger names and weights and/or type and weights of cargo to be transported. Include mission accessories, tools, gear, baggage, etc. A separate manifest may be used.

ACTUAL PAYLOAD – Total of all weights listed in Item 14. Actual payload must not exceed Allowable Payload for the intended mission profile, i.e. HIGE, HOGE or HOGE-J.


General

APPENDIX 5

HEC (Human External Cargo)


HEC loads have been developed for use in utility work, law enforcement, and search and rescue. Ferguson and Sons Construction has gained an excellent reputation with it’s customers as a safe and innovative company leading the way to more efficient use of helicopters.

Persons Authorized

Any person who has not been trained and qualified per this manual, or other similar training program approved by Ferguson and Sons to meet the level of safety and professionalism expected for these types of operations will not be allowed to fly external load configurations.

Security

Ferguson and Sons will ensure that all pertinent locations can be effectively monitored for safety of persons or property on the surface. Ferguson and Sons will use personnel from contractors or law enforcement/rescue agencies briefed on securing the area of operations for traffic control of vehicles on the surface. The safety and security of persons or property on the surface will be priority always.

Communications

Ferguson and Sons will ensure that an effective plan of communications has been established for all participants during external load flight operations.

The ideal standard of communications consists of the following:

At least one radio in each aircraft capable of communicating with ground operations and personnel suspended to the line.

At least one radio for each person suspended on the line capable of communicating with ground operations and the PIC.

At least one radio for the person in charge of the ground operations capable of communicating with personnel on the line and the PIC.

During some specialized operations the use of two-way radio communications may pose a hazard to electronic equipment or persons involved in the mission. Examples of these would be:

Working with energized power lines or equipment that could be affected by radio transmissions.


Appendix 5.1/R-1/5/6/18

In these or similar situations, the use of predetermined head signals, hand signals, or light signals will be used. If at any time communication cannot be effectively maintained, the operation will be halted.

Briefing of Personnel

Prior to any flight operations a safety briefing shall be held between all personnel to be involved with the operation. Any time a significant change in the operation or conditions occurs that has not been covered in the daily briefing, an additional safety briefing will be held prior to resuming operations. The briefing shall include, but not limited to, the following items:

• The plan of activities

• Weather conditions and forecast (when to stop operations)

• Emergency procedures/Emergency action plan

• Aircraft staging areas

• Takeoff procedures

• Approach and landing procedures

• Communications

• Specific job activities

• PPE

• Halting of the operation

• Risks to personnel involved and mitigation procedures if necessary

• Maximum weight of loads to be carried and center of gravity verification

• How to control non-participating persons

• Working around a running helicopter

• The use and inspection of any special equipment or rescue devices

• Any comments or pertinent safety issues directly related to the specific job (i.e.

HEC)


Appendix 5.2/R-1/5/6/18

Human External Cargo Operations General

The following methods described in this section shall be the guide lines to be used to complete the various operations safely.

All human external cargo operations will follow these basic procedures:

• Performance. The PIC will ensure that the HEC load will be able to be lifted

“Out of Ground Effect” while operating in the “Continuous Power Range” (Green Arc). If at any time, due to changing environmental conditions, the load requires “Take Off Power” (Yellow Arc), the HEC operation will be suspended and the load will be reduced. If the load cannot be adjusted to permit operations in the continuous power range, the operation will be halted.

• Risk Management. Ferguson and Sons PIC and the personnel involved will conduct a thorough evaluation of the operations to be conducted and the potential risk, if any.

• Briefing. Ferguson and Sons PIC will give a thorough briefing specific to the

operation (see Briefing of Personnel page 5.1).

• Communication. Communications must exist at all times between the PIC and persons on the load line. This can be accomplished through use of radios, head signals, hand signals, or intercoms. If communications cannot be maintained, the operation will be halted.

• Attaching Means. Ferguson and Sons requires that the external load

attaching system have two distinct, and separate, actions required to release the load line. Furthermore, Ferguson and Sons requires a secondary point of attachment so that the primary load carrying device (cargo hook) is not the sole attaching means. This is accomplished by using a Belly Band (PSD). The load line will be connected to the main cargo hook and the PSD.


Appendix 5.3/R-1/5/6/18

Lifting Equipment & Rigging General Requirements

The basic equipment standards will meet the following guidelines for all lifts. Any additional equipment necessary for specific missions will be listed within those portions of this manual.

• For a cargo line, the general lifting capacity shall meet or exceed the working load by a

5-to-1 safety factor.

• For a HEC load line, the general lifting capacity shall meet or exceed the working load by a 10-to-1 safety factor.

• The lifting harnesses, baskets, platforms, and straps shall be in good condition and have

appropriate load ratings. All equipment will be inspected according to the manufacture guidelines. Any defective equipment will be repaired or replaced prior to starting work.

Portable Safety Devices (PSD) used for HEC Operations

Inspection, installation, and use of a PSD will require specific training. The PSD will be inspected for the following:

• All webbing and straps for tears, abrasions, and loose or missing threads. Unusual wear

in all areas where hardware meets the fabric, rope, webbing, and straps. Check all rings, and latching items for dings, dents, and nicks. Ensure locking mechanisms are functioning according to manufacturer instructions.

• The PSD will be installed and removed in accordance with any manufacturer instructions.

It may be installed only on an aircraft type approved by the manufacturer. The PSD will be installed without the need for a logbook entry.

• The release handle will be accessible to the pilot while at the controls. The HEC line will

be attached to the PSD so that the weight of the load is not supported by the PSD, but by the primary cargo hook. When the cargo hook is released, the weight of the load will transfer with a minimum amount of fall into the PSD.

• The PIC should verify that the PSD is installed correctly and the HEC line is properly

attached prior to use. The band should be installed without interfering with any electrical or mechanical cables, or hydraulic lines. The band must not affect the operation of the cargo hook. The release mechanism will be checked for operation prior to use.

Abnormal Procedures

If any abnormal procedures occur, the PIC will land the HEC personnel to the ground.


Appendix 5.4/R-1/5/6/18

Cargo Hook Failure

If the cargo hook is inadvertently released and the HEC load transfers to the PSD, the PIC will land the HEC personnel safely to the surface as soon as practical.

Emergency Procedures

If any aircraft emergency occurs during flight while carrying a HEC load, the operation should be terminated by landing the HEC personnel in the nearest safe landing area. If during an emergency the aircraft must be landed immediately due to an engine failure, or catastrophic control malfunction, HEC personnel may need to be jettisoned.

PSD Emergency Jettison Procedure

The HEC load is a Class B jettisonable load. If the PIC must jettison the load due to a catastrophic emergency, pull or activate the PSD release first, prior to release of the cargo hook. Attempt to set HEC personnel on the ground prior to release of the cargo hook.

PIC Checklists

Aircraft:

• Weight and balance computed • Aircraft performance computed • Verify operation of release devices • Verify Belly Band (PSD) properly installed • Engine Power Assurance Check completed

Personnel:

• Verify persons to be carried on the load line have been briefed • Confirm specific duties and responsibilities • Communications check, audio and or visual • Review emergency procedures specific to the operation • Review potential risk and mitigation procedures with the crew • Review installation of the PSD and the HEC line attachment.


Appendix 5.5/R-1/5/6/18

Human External Cargo (HEC) Pilot Qualifications

Flight experience requirements for pilots conducting HEC operations with Ferguson and Sons Construction, LLC are listed below:

• 2000 hours PIC in helicopters • 500 hours vertical reference long line experience as PIC • 200 hours PIC in make, model, series of aircraft to be flown

In addition to the requirements above, each PIC will pass a written and practical examination with the Chief Pilot at Ferguson and Sons. The Chief Pilot will issue a letter of competency indicating compliance with the provisions of FAR Part 133. The PIC shall have completed the Ferguson and Sons training program and demonstrated proficiency at each task prior to performing those HEC operations on a Ferguson and Sons job. Recurrent training will be conducted for all pilots at least every 12 months. After 12 months, any PIC who has not attended recurrent training will not be assigned HEC duties until the proper training has been completed. See Appendix 5.6 for an example, front and back, of a Ferguson and Sons letter of competency (Pilot Card).

Qualifications for HEC Crewmembers

HEC crewmembers will be required to demonstrate or show proof of their ability to perform to an acceptable level of safety and performance. This can be accomplished through several means:

• Showing proof of completion of a contractor approved training program • Completing the Ferguson and Sons Helicopter Line Worker training program covering

the procedures in this manual and the Ferguson and Sons line worker training manual

The PIC will have the authority, at their discretion, to prohibit any HEC crewmember from participating in any operation in the interest of safety.



August 23, 2018

Aviation Safety 800 Independence Ave Washington, DC 20591

Exemption No. 17958 Regulatory Docket No. FAA-2018-0459

Mr. Jay Ferguson Owner Ferguson and Sons Construction, LLC 5225 Butte Rd Emmett, ID 83617

Dear Mr. Ferguson:

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision By letter dated April 18, 2018, you petitioned the Federal Aviation Administration (FAA) on behalf of Ferguson and Sons Construction, LLC (Ferguson) for an exemption from §§ 133.43(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). After the review of your request, the FAA has determined the petitioner needs an exemption from 14 CFR §§ 91.9(a) and 133.43(a) and (b) to the extent necessary to allow Ferguson to continue the use of Onboard Systems Supplemental Type Certificates (STC) SR01778SE and SR00892SE, and Mechanical Specialties, LLC’s STC SR02493SE for the attaching means and appropriate rotorcraft flight manual supplement (RFMS) for human external cargo (HEC) operations. Ferguson will use company-owned McDonnell Douglas (MD) 369 Series and 500N Type Certificate Data Sheet (TCDS) number H3WE helicopters authorized in Ferguson’s Letter of Authorization (LOA) aircraft listing. Ferguson makes this request because of the unavailability of FAA-approved attaching means for the MD series helicopters.

AFS-18-121452-E


Appendix 6.1/R-1/5/6/18

The FAA has issued a grant of exemption in circumstances similar in all material respects to those presented in your petition. In Grant of Exemption No. 17901 (copy enclosed), the FAA found that the public interest is served by operators who conduct specialized operations that help maintain the United States electrical power grid.

The petition also described how some HEC operators have been using a Portable Safety Device (PSD), also known as a Belly Band System or emergency anchor, as a backup system to the primary hook. However, these systems are not eligible for certification under 14 CFR part 27 or 29 as they are not permanently installed, nor are they currently required to be used during HEC operations. PSDs are not designed to be a backup to the primary hook or hoists to make the system compliant with § 27.865 or § 29.865. Nevertheless, in the absence of attaching means certified for HEC, the FAA has determined that using a PSD in addition to the primary hook to avoid an adverse effect on safety for HEC operations reduces the risk of injury or death following a failure of the primary hook’s quick release mechanism.

Having reviewed your reasons for requesting an exemption, we find that—

• They are similar in all material respects to relief previously requested in the enclosed Grant of Exemption No. 17901;

• The reasons stated by the FAA for granting the enclosed Grant of Exemption No. 17901

also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to Ferguson. Under the authority contained in 49 U.S.C. §§ 106(f), 40113, and 44701, which the Administrator has delegated to me, I hereby grant Ferguson and Sons Construction, LLC an exemption from 14 CFR §§ 91.9(a), and 133.43(a) and (b) to the extent necessary to allow Ferguson to continue the use of Onboard Systems STC’s SR01778SE and SR00892SE, and Mechanical Specialties, LLC for their STC SR02493SE on company-owned (MD) 369 Series and 500N (TCDS #H3WE) helicopters authorized in Ferguson’s LOA aircraft listing to perform Class B human external cargo operations, subject to the conditions and limitations described below.

Conditions and Limitations 1. Ferguson must follow the procedures set forth in the Rotorcraft Flight Manual (RFM) and

Rotorcraft Flight Manual Supplement (RFMS), Rotorcraft Load Combination Flight


Appendix 6.2/R-1/5/6/18

Manual (RLCFM), Supplemental Type Certificate (STC) and Instructions for Continued Airworthiness (ICAs) that are specific to external cargo operations.

2. This exemption requires using an emergency anchor (Belly Band system) as a Portable

Safety Device (PSD) as a secondary attachment that secures the HEC in the event of a failure of the primary quick release device.

3. Ferguson must follow the instructions for continued airworthiness for the attaching means

assembly.

4. Under this exemption, there will be two Quick Release Systems (QRS): one for the primary hook and one for the PSD. The mechanical control for the hook(s) shall have a dual-action quick-release device readily accessible to either the pilot or crewmember.

5. Class B HEC operations may be conducted during day VFR only.

6. Prior to conducting any HEC operations, pilots and crewmembers will familiarize

themselves with Ferguson’s procedures as set forth in its RLCFM.

7. Prior to any Class B HEC operation, the pilot and all crewmembers must have established a clear method of communication. This may consist of hand signals, two-way radio communications, or both. Communications must be tested prior to each operation. When there are communication failures or confusion, operations must be suspended until clear communications are restored.

8. Ferguson must conduct a daily Class B HEC briefing attended by all persons involved in

the operations for that particular day. The briefing should cover concerns, identified risks, and hazards. Additionally, this briefing will cover:

a. Defining the core operational and individual tasks for the day; b. Identifying specific hazards; c. Discussing hazard and risk mitigation; d. Communication issues; e. Weather conditions and forecasts (e.g., wind gusts, lightning, or other weather

factors that could increase risk); f. Any revisions to the site-specific safety plan; g. Universal “go/no-go” authority; h. Pre-operation reconnaissance flight; i. Personal protective equipment (PPE) appropriate for the task; j. Reviewing key points of the Emergency Action Plan; and


Appendix 6.3/R-1/5/6/18

k. Weight and Balance (W&B) calculation.

9. Pilots must receive initial and annual recurrent documented training in the following subject areas prior to HEC operations under this exemption:

a. Knowledge and skill training;

b. Demonstrated proficiency with precision vertical reference load placement; c. Proper load configuration, use, and application of Class B HEC; d. Installation, inspection, and operation of secondary safety device(s); e. Acceptance or rejection criteria of HEC attaching means to include long lines,

chairs, and/or harnesses; f. D-Ring Reversal/Dynamic Rollout During Winching or Long Line Operations; g. Hazard identification, risk analysis, and mitigation; h. Crew Resource Management (CRM); i. Communication; j. Normal/abnormal and emergency procedures pertinent to Class B HEC

operations; k. Electrical wire environment hazards; and l. Fuel management.

10. Crewmembers working on or around the helicopter must receive initial and annual

recurrent documented training by a competent person in the following areas: a. Acceptance or rejection criteria of HEC attaching means to include long lines,

chairs, and/or harnesses; b. Task-specific operations; c. Hazard identification, risk analysis, and mitigation; d. CRM; e. Communication:

i. Emergency procedures pertinent to Class B HEC operations; ii. Ground;

iii. Flight; f. Mock-up training and review of:

i. Rigging inspection and acceptance or rejection criteria of equipment; ii. Communication procedures;


Appendix 6.4/R-1/5/6/18

iii. Simulation of task (both crew and pilot tasks); and g. Documented completed proficiency on all of the above.

11. Pilots operating under this exemption must have previous HEC experience working for

Ferguson.

12. Pilot and crewmembers must be trained in the use and operation of the installed attaching means, PSD, and associated quick release systems. That training must cover procedures for emergency release of the PSD and the primary attaching means in case either system fails.

13. Ferguson must perform periodic inspection of the PSD equipment, including the

following:

a. Inspect and maintain the PSD to ensure correct functionality, and that the PSDs will not interfere with the safe operation of the helicopter;

b. Ensure the PSD materials meet the accepted industry standard of National Fire Protection Association (NFPA) 1983, or equivalent;

c. Check PSD installation to ensure it conforms to manufacturer, OSHA, NFPA and ASTM standards and instructions for continued serviceability;

d. Check the quick release device for both the primary attaching means and the PSD to ensure proper functionality;

e. Review and check the ability to jettison the load without interfering with the safe operation of the helicopter; and

f. Check the PSD to ensure there is no sudden and/or unacceptable shift in the center of gravity.

14. Ferguson may exercise the privileges of this grant of exemption within sterile areas that

are not over person(s) or property on the surface that are not directly associated with the HEC operation.

15. Before conducting HEC operations, Ferguson must provide a copy of this grant of

exemption to those person(s) being carried external to the aircraft.

16. Before conducting HEC operations, Ferguson must provide a copy of this grant of exemption to its responsible Flight Standards District Office.


Appendix 6.5/R-1/5/6/18

This exemption terminates on August 31, 2020, unless sooner superseded or rescinded.

Sincerely,

/s/

Rick Domingo Executive Director Flight Standards Service

Enclosure

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