DND Aircraft Occupant Safety Policy – Implementation Guidance

Effective Date: 13 December 2019

Version in effect: 2 (revised 13 May 2021)

Reference: A-GA-005-000/AG-001 – DND/CF Airworthiness Program, Part 2, Section 1

OPI / Telephone: DTAES 7-8 / 819-939-4820

1.    Purpose

1.1     This joint Technical Airworthiness Authority (TAA) - Operational Airworthiness Authority (OAA) advisory provides guidance on the interpretation and application of the Department of National Defence (DND) Aircraft Occupant Safety Policy (OSP) – an integral part of the DND/Canadian Armed Forces (CAF) Airworthiness Program (regulatory reference 3.2.a).

1.2     This advisory is not mandatory, nor does it constitute a regulation. It describes a means acceptable to the OAA and TAA, but is not the only means to demonstrate compliance with the regulation(s). If this advisory is used, then all of its key elements must be followed.

2.    Applicability

2.1     This advisory applies to TAA and OAA personnel, fleet Weapon System Management (WSM) staff, fleet Operational Staff officers of 1 Canadian Air Division (CAD), Occupant Safety Board (OSB) members, and Project Management Office (PMO) System Engineering Management (SEM) staff involved in the process of optimizing the safety and survivability of DND aircraft occupants, in accordance with the provisions of the OSP.

2.2     This advisory applies to all newly acquired DND-Owned Passenger-Carrying Aircraft (Fixed- and Rotary-Wing), as well as to those DND-owned legacy fleets whose certification basis, at the time of acquisition, did not include a full set of contemporary Occupant Safety Airworthiness Certification Design Standards, as set out in the TAA Airworthiness Design Standards Manual (ADSM) (regulatory reference 3.2.d).

2.3     This advisory does not apply to the following RCAF-operated aircraft:

1. DND-Owned Ejection Seat-Equipped Aircraft – Ongoing mechanisms are already in place to periodically assess the safety of their occupants and related crew Aviation Life Support Equipment (ALSE). In addition, passenger ‘seat checks’ are also required prior to flying in these aircraft;
2. DND-Owned Unmanned Aircraft Systems (UAS) – Although not specifically stated in the policy, UAS are implicitly exempted by virtue of their intended role; and
3. DND-Leased Aircraft.

3.    Related Material

3.1    Definitions

1. Aircraft Occupants. All crew and passengers aboard RCAF aircraft.
2. CoA. For the purposes of this advisory, CoA refers to “Course of Action”.
3. Crew. Those occupants aboard the aircraft whose primary role is associated with the operation or mission of the aircraft. This includes the flight crew and mission crew (pilots, air combat systems officers, flight engineers, airborne electronic system operators, loadmasters, Search and Rescue (SAR) technicians or other designated crew member(s)).
4. Legacy fleets. For the purpose of this advisory, this term refers to those RCAF aircraft fleets that did not have contemporary occupant safety standards included as requirements in the certification basis when those fleets were acquired by DND.
5. Passengers. Aircraft occupants who are not designated as crew.
6. Survivable Accident. An accident in which the cockpit and/or aircraft structure remain relatively intact and the forces experienced by occupants do not exceed the survivable limits of human G-tolerance.

3.2    Regulatory References

1. A-GA-005-000/AG-001 – DND/CF Airworthiness Program, Part 2, Section 1, paragraphs 17-24 – DND Aircraft Occupant Safety Policy;
2. CANAIRGEN 05/15 – Amendment to Airworthiness Program – Occupant Safety Policy;
3. Briefing Note to the DND Airworthiness Authority – DND Aircraft Occupant Safety Policy, approved 08 January 2015 by MGen Foster on behalf of Commander of the RCAF; and
4. C-05-005-001/AG-002 – Airworthiness Design Standards Manual (ADSM), Part 3, Chapter 14, Cabin Safety and Crash Protection.
5. C-05-005-001/AG-001 – Technical Airworthiness Manual (TAM), Part 5, Chapter 1.

3.3    Non-Regulatory References

1. U.S. Department of Defence (U.S. DoD) Joint Service Specification Guide (JSSG) 2010-7 – Crash Protection Handbook (Notice 2 dated 13 June 2013);
2. U.S. DoD MIL-STD-1290A, Light Fixed and Rotary-Wing Aircraft Crash Resistance (Notice 2 dated 17 January 2006);
3. Federal Aviation Administration (FAA) Advisory Circular (AC) No 25-17A, Transport Airplane Cabin Interiors Crashworthiness Handbook; and
4. FAA, National Policy Order 8020.11C, Aircraft Accident and Incident Notification, Investigation, and Reporting.

4.    Discussion

4.1    Background

4.1.1     Acknowledging that risk is inherent to all DND/CAF activities and that, in the event of a survivable accident, the Minister of National Defence has the duty of care to provide occupants of RCAF aircraft with a level of safety and survivability that is “As Safe as Reasonably Practicable” (ASARP), the DND/CAF airworthiness policy document (reference 3.2.a) sets as primary objective the provision of an acceptable level of safety for the Canadian military aviation and risk mitigation in those situations in which baseline levels of safety are not possible.

4.1.2    Enhancing military aviation capabilities, while “avoiding or mitigating potential injury to personnel and damage or loss of materiel” has been the aim of the DND/CAF Airworthiness Program since its inception. As the program matured, these efforts materialized into the integration of an Occupant Safety Policy (OSP) into its wider policy framework.

4.1.3    The OSP sets out to improve occupant safety of RCAF aircraft through a formal review process. This policy represents a safety improvement initiative that increases the probability of crew and passenger survival in the context of a survivable crash through a systems design approach, which takes into account:

1. impact protection;
2. aircraft evacuation; and
3. pre- and post-evacuation survival.

4.2    New Aircraft Fleets

4.2.1    In accordance with the provisions of the OSP, new DND aircraft acquisition projects must consider, where possible, the inclusion of contemporary occupant safety standards as requirements when drafting DND’s Request for Proposal (RFP), prior to contract award. These standards are made available by the DND/CAF Technical Airworthiness Authority in its Airworthiness Design Standards Manual (reference 3.2.d). Furthermore, DTAES 7-8 staff can provide specialist advice regarding these contemporary occupant safety standards and how they can be incorporated into the RFP and certification basis.

4.3    Legacy Fleets

4.3.1    DND-Owned Passenger-Carrying Aircraft (Fixed- and Rotary-Wing) aircraft fleets included in para 2.2 will require a fleet Occupant Safety Assessment, to identify any areas for potential safety improvement. If a design change results from this assessment, then certification requirements related to that design change would apply, as per established TAA-approved airworthiness processes.  

4.3.2    The Occupant Safety Management Team (OSMT) for each applicable fleet will identify areas for potential safety improvement, and develop Courses of Action (CoAs) to address these areas. Implementation of proposed CoAs will be dependent on technical, operational, cost, and quantified safety improvement factors.

4.3.3    All proposed CoAs are reviewed by an Occupant Safety Board (OSB), who approves the CoAs for each fleet, according to the process outlined in section 5 of this advisory.

5.    OSP Implementation Process Overview (Legacy Fleets)

5.1     The OSP implementation process for each legacy aircraft fleet will mirror the phases and follow the guidance of the Defence Management System’s Project Approval Directive (PAD). The following parties are involved in this process:

1. the Occupant Safety Management Team (OSMT); and
2. the Occupant Safety Board (OSB).

5.2.     Occupant Safety Management Team (OSMT). The OSMT is the multi-disciplinary team responsible for the initiation of the occupant safety process and the presentation of CoAs to the OSB. It is made up of working level representatives from the technical and operational communities, as follows:

1. Fleet Weapon System Management (WSM) organization, who will act as the lead organization responsible for drafting the documentation required for OSP implementation:
   1. Occupant Safety Assessment Report (OSAR);
   2. Opportunities Selection Report (OSR); and
   3. Detailed Course of Action Analysis Report (DCAR);
2. OAA-Identified Fleet Senior Staff Officer(s) (SSO), who will provide operational input and assist in analyzing the operational impact of the occupant safety observations raised by the WSM, as well as CoAs to address these observations. Wing-level operational input can also be obtained as applicable; and
3. Subject Matter Experts (SMEs) of the Directorate of Technical Airworthiness and Engineering Support (DTAES) 7-8 section, who will provide specialist advice to the other members of the OSMT with regards to the occupant safety standards, assistance on the use of various report templates, and overall guidance throughout the entire process.

5.3.     Occupant Safety Board (OSB). The OSB is a multi-disciplinary team of senior officers and public servants from the RCAF and Materiel Group’s Aerospace Equipment Program Management (AEPM) Division responsible for overseeing the OSP program, reviewing the OSMT’s CoAs and recommendations, and providing guidance and direction at OSB Engagement events described in paragraphs 5.5.3 and 5.6.3 of this advisory. The OSB is co-chaired by the Director of Fleet Readiness at 1 CAD and the Chief of Staff of the Director General – Aerospace Equipment Program Management (DGAEPM), and includes the following members:

1. Director Technical Airworthiness and Engineering Support;
2. Director Air Readiness;
3. Director Flight Safety;
4. Director of Aerospace Requirements;
5. Senior Staff Officer Operational Airworthiness;
6. Director of subject fleet (within DGAEPM); and
7. DTAES 7-8 staff, as Board Secretary.

5.4     OSP Implementation Process Steps. As stated in paragraph 5.1 above, the process of complying with the provisions of the OSP for each legacy fleet relies on the guidance and best practices of the PAD, to develop and control all phases of the OSP-driven gap assessments and subsequent resolution. This process follows eight steps (two of which require the engagement of the OSB), grouped into three main phases, as follows:

1. Identification Phase:
   1. Occupant Safety Assessment (Step 1);
   2. Opportunities Selection (Step 2); and
   3. Presentation of Opportunities Selection Recommendations (Step 3 and OSB Engagement #1);
2. Options Analysis Phase:
   1. Detailed Course of Action (CoA) Analysis (DCA) (Step 4);
   2. Identification of Preferred CoA (Step 5); and
   3. Presentation of DCA Recommendations (Step 6 and OSB Engagement #2);
3. Implementation Phase:
   1. Implementation of OSB-approved CoAs, as applicable (Step 7); and
   2. Progress Reporting (Step 8).

5.5    Phase 1: Identification

5.5.1    Step 1: Occupant Safety Assessment. During this step, each aircraft fleet is evaluated against contemporary civilian and military standards related to occupant safety. The results of this step are documented in an Occupant Safety Assessment Report (OSAR). The fleet WSM leads the completion of the OSAR, with assistance from the OSMT. A desktop review of data is required, substantiated with photos, and – where necessary – on-aircraft evaluations to address gaps in data. WSMs will require DTAES 7-8 staff concurrence to confirm that the OSAR has been satisfactorily completed. The completed OSAR must be saved in RDIMS within AEPM library folder #1908847, with the signed version embedded in the document header. The OSAR templates contain details of the standards and how to evaluate a fleet’s partial or complete compliance to these standards. The following guidance is provided for the completion of the OSAR:

1. Contemporary Standards Groupings: the following grouping of contemporary standards are used in the OSAR templates:
   1. Emergency Egress and Equipment, i.e., emergency exits, emergency lighting, evacuation routes, evacuation slides, underwater egress, etc.;
   2. Fire Protection, i.e., smoke/fire detection and warning, fire suppression, etc.;
   3. Safety Provisions, Rescue and Survival, i.e., smoke masks, emergency oxygen, first aid kits, survival kits, life rafts, life vests, etc.; and
   4. Crashworthiness, i.e., crashworthy seats, occupant restraint systems, cargo restraints, crashworthy structures, crashworthy fuel cells, etc.
2. Evaluation Methodology: the aircraft fleet is scored against each of the applicable contemporary standards, according to the following categories:
   1. Category 4 – Satisfactory: The evidence demonstrates that the requirements within the assessment factor are met. No further work required;
   2. Category 3 – Insufficient Data: It could not be confirmed whether the design and/or operating procedures address the requirements within the assessment factor;
   3. Category 2 – Opportunity for Moderate Improvement to Occupant Safety: The design and/or operating procedures partially meet the requirements within the assessment factor, or are partially compensated by alternate features; and
   4. Category 1 – Opportunity for Significant Improvement to Occupant Safety: The design and/or operating procedures do not meet the requirements within the assessment factor.
3. Documentation Template: Two OSAR templates, which list the applicable Occupant Safety contemporary standards by fleet type, are available internally, within DND, in the AEPM RDIMS library, as follows:
   1. Rotary Wing: AEPM RDIMS #1523448; and
   2. Fixed Wing: AEPM RDIMS #1523427.

5.5.2     Step 2: Opportunities Selection. All OSAR observations of categories “3”, “2” and “1” must be analyzed to determine those cases for which status quo is acceptable, those that require further assessment by means of a more detailed options analysis methodology, and those that will result in fleet optimization opportunities. The results of this step are documented in an Opportunities Selection Report (OSR). The fleet WSM will lead the process of completion of the OSR, though the full OSMT should be engaged in the development and confirmation of the OSR content. WSMs will require DTAES 7-8 staff concurrence to confirm that the OSR has been satisfactorily completed. Once all OSRs have been completed, a one-page summary workbook will be created to consolidate all OSAR observations with their recommended CoAs. Completed OSRs and their one-page summary workbooks must be saved in the AEPM RDIMS folder #1908844, with the signed version of the OSR embedded in the document header. The following guidance is provided for the completion of an OSR and a one-page OSR summary workbook:

1. Evaluation Methodology: OSAR observations will be individually documented in the OSR, as follows:
   1. Each OSAR observation is allocated a category title and number (e.g., 1.9.7: Emergency Exit Access);
   2. Each category title will have an associated Opportunity Description and OSAR Score table, which starts with a brief introduction noting shortfalls, associated safety concerns and any partial mitigation that may be in place, and ends with a recommended CoA. The following factors will be considered in evaluating the proposed CoA: Technical Impact, Operational Impact, Rough Order of Magnitude (ROM) cost/Level of Effort (LOE), Schedule, and Feasibility of the proposed implementation measure(s). The OSR template has more details regarding these factors. After the evaluation is complete, one of the following CoA choices will be recorded in the appropriate OSR box:
      1. No further action required (maintain status quo);
      2. Implement procedural mitigations;
      3. Implement technical solutions fully within the WSM's domain of influence (i.e., scope of airworthiness and financial means);
      4. Gather more information/monitor developments (e.g., verify if other countries are working on similar solutions); or
      5. Proceed to Detailed CoA Analysis (DCA) (Step 4), if none of the other CoAs in the table is a clear-cut way forward.
   3. ROM costs should be sourced for suggested solutions.
2. Documentation Template: The OSR template is available internally, within DND, at AEPM RDIMS #1846501. The template of the one-page OSR summary workbook is available at AEPM RDIMS #1908876.
3. Action Following Completion of OSRs: As soon as the OSRs have been completed and consolidated, prior to OSB Engagement #1 (Step 3), they will be sent, together with the one-page OSR summary workbook, to the OSB through DTAES 7-8 staff. However, before the OSB is assembled to assess the OSRs, the WSM staff is encouraged to immediately start the implementation of those OSMT-defined solutions that are within their airworthiness authority and financial means. 

NOTE:  Solutions that have already been implemented by the time the WSM presents the OSRs to the OSB, in Step 3 (as applicable), can be updated with relevant completion information, as opposed to planned solutions.

5.5.3    Step 3 and OSB Engagement #1 – Presentation of the Opportunities Selection Report Recommendations: The OSMT engages the OSB after providing them with the OSRs and their one-page summary workbook for review. The OSB decides whether the OSR will be accepted secretarially, or whether an assembled OSB meeting is required for a formal WSM presentation of recommendations. If a formal presentation is required, the WSM will prepare the slide deck, which will be saved in the AEPM RDIMS #1908844 folder, and formally present it to the OSB. Other OSMT members may attend the meetings as required. DTAES 7-8 staff, in their role of OSB Secretary, will document each meeting in approved meeting minutes, including references to opportunities that have been approved secretarially. Further guidance is as follows:

NOTE:  Formal OSBs are generally assembled twice a year, one in the spring and one in the fall.

1. Evaluation Methodology: The OSB has the option to decide which parts of a fleet’s OSR they wish to be briefed on in a formal setting. The OSB may adopt one of the following decisions with regards to the opportunities presented in the OSR:
   1. Amend OSR;
   2. No further action required (maintain status quo);
   3. Gather more information/monitor developments;
   4. Proceed to Detailed CoA Analysis (DCA) (Step 4); or
   5. Proceed to implementation (Step 7).
2. Documentation Templates: A template for the PowerPoint slide deck is available internally, within DND, at AEPM RDIMS #1887836.
3. Action Following Completion of OSB Engagement #1: After this OSB engagement is complete and the OSR approved, the OSMT must make any required changes to the OSR in a subsequent version of the document in RDIMS.

5.6    Phase 2: Options Analysis

5.6.1    Step 4: Detailed Course of Action Analysis (DCA): This step allows the OSMT to assess and identify the best methods to address those OSB-approved observations in the OSR for which a DCA has been recommended. The results are documented in a DCA Report (DCAR). The fleet WSM leads the completion of the DCAR. To confirm the satisfactory completion of the DCAR, DTAES 7-8 staff’s concurrence is required for Step 4, as well as at the end of Step 5 (below), when the DCAR is considered fully completed and ready for submission to the OSB for review. The DCAR must be saved in AEPM RDIMS within folder # 1908866, with the signed version of the DCAR embedded in the document header. The following guidance is provided for Step 4:

NOTES:  
1.   Each individual observation must have at least one corresponding CoA meant to mitigate, or potentially eliminate, the observation.
2.  CoAs can be technical or operational in nature, or a combination of both. Status quo is also a valid CoA that can be explored.

1. Evaluation Methodology: The Detailed CoA Analysis involves two key sub-steps:
   1. CoA Development and Risk Assessment. This sub-step requires that, for each observation flagged for DCA during the OSR process, an occupant safety hazard risk assessment is conducted in order to quantify the degree of safety improvement. This involves using the TAM risk tables to determine the severity, probability and initial Occupant Safety Hazard Risk Index (OS HRI) of the existing observation condition, as well as the residual OS HRI if the chosen CoA was implemented. The following guidance is provided:
      1. To determine the initial OS HRI of the existing observation condition:
         1. Hazard Severity: based on the worst case scenario of survivable accident, use Figure 5-1-2-5 – Survivability Hazard Severity Definitions from Part 5, Chapter 1, Section 2 of the TAM (reference 3.2.e.) to select the corresponding hazard severity, and provide substantiation;
         2. Hazard Probability: based on fleet-applicable accident sequence analysis, use the definitions provided in Figure 5-1-2-6 – Survivability Hazard Probability Definitions from Part 5, Chapter 1, Section 2, of reference 3.2.e to select the appropriate probability, i.e., the one that creates the hazard effect as a result of a significant aircraft accident, and provide substantiation; and
         3. Initial Hazard Risk Index (HRI): using the Risk Index scenarios provided in Figure 5-1-2-4 – Risk Index, of reference 3.2.e, select the initial HRI value defined by the intersection between the Severity and Probability components.
      2. To determine the residual OS HRI of a proposed CoA, complete the same process as for the initial OS HRI, but take into account changes in severity and/or probability due to mitigation factors inherent in implementation of the safety improvement CoA. Select the residual OS HRI defined by the intersection between Severity and Probability using the same Figure 5-1-2-4 of reference 3.2.e, based on the mitigated severity and probability levels.

   NOTE:  The survivability severity, probability and risk index figures of the Part 5, Chapter 1, Section 2 of the TAM (reference 3.2.e) are also available internally, within DND, on the Map Online intranet site of the AF9000 Quality Management System of the Director General – Aerospace Equipment Program Management, in the EMT01.003 procedure “Airworthiness Risk Management Process”.

   2. Cost-Benefit Analysis: The purpose of this sub-step is to determine the cost of implementing proposed CoAs and ultimately identify the CoA that yields the best cost-benefit results. This sub-step is repeated for each OSR opportunity that was selected for DCA. The following guidance is provided:
      1. To calculate the costs for each CoA, estimate the resources required for its implementation (manpower, initial cost of parts, Integrated Logistics Support, non-recurring engineering, in-service support costs, etc.), quantify the resulting operational impact (downtime, operational limitations/restrictions, etc.), and combine these factors to obtain an overall cost;
      2. To determine the amount of occupant safety risk reduction for each CoA, use the numeric scale provided in Figure 1 to quantify the risk reduction and apply the formula:
         Occupant Safety Hazard Risk Reduction = Initial OS Hazard Risk Index value – Residual OS Hazard Risk Index value
      3. To determine which CoA provides the best cost-benefit results, plot the implementation cost of each CoA against the OS Hazard Risk Reduction level achieved, if implemented.
2. Documentation Templates: The template for a DCAR is available internally, within DND, at AEPM RDIMS library #1762266; and

5.6.2     Step 5: Identify Preferred CoA: During Step 5, the OSMT compares all CoAs identified in Step 4 for each applicable OSAR observation, and determines a preferred CoA, as well as an indicative/preliminary implementation plan. These details are recorded in the DCAR initiated in Step 4, with final concurrence from the DTAES 7-8 staff. Further guidance is as follows:

1. Evaluation Methodology: Once the plot of cost of each CoA vs the Hazard Risk Reduction level is completed for a particular opportunity, as per para 5.6.1.a.2.C, the optimum CoA is identified, based on the best OS hazard risk reduction to cost ratio;
2. Documentation Template: Same as Step 4.

5.6.3     Step 6 and OSB Engagement Point #2 – Presentation of DCA Recommendations: The OSMT provides the DCAR (i.e., the results of Steps 4 and 5) to the OSB for review through DTAES 7-8 staff. The OSB decides whether the DCAR will be accepted secretarially, or whether an assembled OSB meeting is required for a formal WSM presentation. If a formal meeting is required, the WSM will prepare the slide deck, which will be saved in the AEPM RDIMS #1908866 folder. Other OSMT members may attend the meetings as required. DTAES 7-8 staff, in their role of OSB Secretary, will document each meeting in approved meeting minutes, including references to opportunities that have been approved secretarially. Once the OSB engagement is complete, the OSMT will make any required amendments to the DCAR in a subsequent version of the RDIMS document. Further guidance is as follows:

1. Evaluation Methodology: As stated in paragraph 5.5.3, the OSB has the option to decide which parts of a fleet’s DCAR they wish to be briefed on in a formal setting. The OSB decision choices for the preferred CoAs provided in the DCAR are:
   1. Amend the DCAR;
   2. No further action required (maintain status quo); or
   3. Proceed to implementation (Step 7).
2. Documentation Template: The template for the PowerPoint slide deck is available internally, within DND, at AEPM RDIMS #1908868;
3. Action Following Completion of OSB Engagement #2: Once this OSB engagement complete and the DCAR approved, the OSMT must make any required changes to the DCAR in a subsequent version of the document in RDIMS.

5.7     Phase 3: Implementation

5.7.1      Step 7: Solution Implementation: The WSM starts acting on the implementation of approved CoAs from Step 3 (OSB Engagement #1) and Step 6 (OSB Engagement #2), according to agreed timelines and established DND processes for design changes and/or operating procedures. The OSMT should be kept involved in the implementation process, by means of regular meetings and/or regular updates.

5.7.2     Step 8: Progress Reporting: WSMs are required to communicate any progress of OSB action items resulting from Steps 1 through 7, as part of their Technical Annual Airworthiness Report (AAR (Tech)). DTAES 7-8 staff will track OSB action items and overall OS program progress, using the Occupant Safety Opportunities Tracking Tool (OSOTT) at AEPM RDIMS #1952622, and provide updates to OSB when requested.

6.     Evolution of Contemporary Safety Standards

6.1      The TAA and the OAA recognize the fact that the contemporary occupant safety standards included in the ADSM and, consequently, the OSAR checklists, represent a snapshot in time, and that constant efforts will be required to evolve the OSP over time.

6.2      To address this staggered approach, the following measures have been set in place:

1. DTAES 7-8 staff will periodically update the OSAR checklists and, with assistance from the TAA staff, synchronize these changes with the ADSM update;
2. DTAES 7-8 staff will notify WSMs of these updates and of the subsequent requirement to re-assemble an OSMT, as required; and
3. WSMs will lead the re-assembled OSMT, and revisit the affected portions of their OSAR and resumption of the Steps 1 through 8 of the implementation cycle, as required.

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