COMPANY MINIMUM STANDARDS FOR rotary winG AIRCRAFT OPERATIONS
- GENERAL
1.1.This document may set requirements supplemental to applicable law. However, nothing herein is intended to replace, amend, supersede or otherwise depart from any applicable law relating to the subject matter of this document. In the event of any conflict or contradiction between the provisions of this document and applicable law as to the implementation and governance of this document, the provisions of applicable law shall prevail.
1.2.Deviations from the requirements stated in this Contract shall require formal approval by the Company.
1.3.The Contractor and Contractor Sub-contractors shall comply with Company Standard Operating Procedures (SOPs), Company Customer Requirements, or other documents developed and agreed between the Contractor and the Company to provide specific direction for the conduct of Company business.
- AUDIT REQUIREMENTS
2.1.The Company shall commission pre-use, pre-tender and recurrent Shell Aircraft International (SAI) audits of Contractor prior to approving the use of the aircraft Contractor. These audits will include assessments of the Contractor’s capability, aircraft types and equipment fit and their suitability for the intended task. The frequency of recurrent audits will be determined by Company on the basis of risk, exposure, usage and performance of the air operation, including response to previous audit recommendations, but in any case shall not exceed 2 years.
2.2.All contracts with direct or subcontracted aviation content shall be categorized as High HSSE risk unless otherwise agreed with the Company.
2.3.Deviations from Contractual Allocation of Risk (CARM) requirements shall be agreed with the Company.
- SAFETY AND QUALITY MANAGEMENT
3.1.Regulatory Requirements
3.1.1.Contractor shall comply with applicable national regulations as these relate to Contractor and associated air operations infrastructure safety management systems.
3.1.2.Where national regulations have not yet been mandated for safety management systems, advisory material and other guidance material produced by the applicable national regulator(s), together with the guidance from Company, shall be implemented to meet the requirements for Corporate Safety Managements System and Hazard Management.
3.2.Safety Management System Elements
3.3.Subject to the requirements as defined by Company, Contractor and their contracted aircraft Contractors shall demonstrate to an acceptable level how the following SMS elements and relationships have been effectively implemented within their operations:
3.3.1.Leadership Commitment
3.3.2.Policy, Objectives and KPI’s
3.3.3.Resources
3.3.4.Communication to and from workforce
3.3.5.Procedures
3.3.6.Management of Change process
3.3.7.Quality Assurance
3.3.8.Safety Reporting and Investigation\
3.3.9.Hazard/Risk Management Process
3.3.10.Regular Senior Management Review
3.4.The Contractor’s bridging documents shall be prepared using the UA Aviation HSE Case as a reference including the applicable best practice bow-ties and Hazard and Effects table controls and recovery measures.
3.5.Where the Contractor does not have an acceptable Change Management process, reference shall be made to the Management of Change section of the Shell HSSE Control Framework HSSE & SP Management System Manual for guidance.
3.6.Hazard/Risk Management Process
3.6.1.Regardless of the size of the Contractor, its SMS is required to include a Hazard Management Process. The systems and procedures used will vary and need to be aligned to complement the other elements of the SMS. The Hazard Management Process shall contain the elements listed below:
3.6.1.1.Define the scope of the activity
3.6.1.2.Identify and record hazards
3.6.1.3.Conduct risk analysis
3.6.1.4.Identify controls to manage hazards
3.6.1.5.Reference control to Company procedures and assign responsible individual
3.6.1.6.Record in remedial action plan
3.6.1.7.Management Review Process
3.6.1.8.QA system - update checklists
3.6.1.9.Confirm implementation and effectiveness of controls
3.6.1.10.Safety Reporting and Investigation
3.6.1.11.Validate existing controls or develop new controls
3.6.1.12.Process new hazards
3.6.1.13.Management of Change Process
3.6.2.The Hazard Management process is to identify and address both generic and location specific hazards. The hazards shall be recorded in a hazard register in a format that:
3.6.2.1.Shows the risk assessment score assigned to each hazard;
3.6.2.2.Links the hazards to specific controls and recovery measures;
3.6.2.3.Provides a document reference for the control and recovery measure;
3.6.2.4.Assigns a responsible individual to each control.
3.6.3.The hazard register can be within the SMS Manual, in an appendix, in a separate document (e.g., Safety Case) or in a software tool as suits the Contractor.
3.6.4.A Contractor may have one generic hazard register covering its whole operation or a number of location or mission specific registers. In either case, controls identified for location specific hazards are to be assigned local responsibility.
3.6.5.The Hazard Management process shall be demonstrably linked to the Contractor’s Change Management Process, its Safety Reporting and Investigation process and to the QA system. This ensures that the hazard management process is triggered by relevant changes within the company, by reported incidents and occurrences and that the controls developed by the process are verified by QA audit and by the investigation process. Those parts of the process indicated, shall also be subject to periodic management review.
3.6.6.The Contractor shall document all hazards associated with the performance those services. The risk of these hazards shall be assessed using the Shell Risk Assessment Matrix (RAM). The Contractor shall:
3.6.6.1.Manage hazards having risks in the dark and light blue areas of the RAM through the effective implementation of their Corporate SMS.
3.6.6.2.Document and implement controls and recovery measures in a Hazards and Effects table or equivalent methodology for hazards in the yellow area and in block 4A of the RAM.
3.6.6.3.Document Safety Bow-Ties or equivalent methodology for all hazards which are rated in the red area or in blocks 5A and 5B of the RAM. These should be aligned with the UA Aviation HSE Case best practice bow-ties in order to facilitate the development of the Bridging Document.
3.7.Corporate SMS and Hazard Management Requirements
3.7.1. The exposure based requirements given in the table below are acceptable means of meeting the SMS requirements of this Agreement:
Services / Exposure / SMS RequirementHelicopter:
- Personnel and cargo transport onshore and offshore;
- External load carriage including Heli-Assist Seismic and Helirig operations;
- Pipeline survey and other inspection and survey operations onshore and offshore; Geophysical survey;
- Helicopter External Transport Service (HETS) Class D helicopter evacuation;
- Medical evacuation (Medevac).
Total flight exposure to an Contractor for single or combined Shell Business Units of 100 hrs or more per year for all RW ops. / A Corporate SMS, including a Hazard Management process i.a.w. paragraph 3.6 covering the contracted and related aviation activities, implemented effectively within 6 months of contract award (or as specified by Shell) :
Additionally:
Airborne Geophysical Survey complete and document a project specific IAGSA Risk Assessment for review by Shell prior to commencing operations.
Seismic, Helirig, or HETS complete and document a project specific OGP Risk Assessment for review by Shell prior to commencing operations.
Pipeline Survey complete and document a project specific hazard assessment that includes location, route and type/activity specific content for review by Shell prior to commencing operations.
Call Off contract
Total flight exposure to an Contractor for single or combined Shell OU’s.
Less than 100hrs per year for all RW ops. / A corporate SMS, including a Hazard management process i.a.w. paragraph 3.6 shall be preferred when selecting an Contractor, but recognising the possible short term use of the Contractor and low exposure, a commitment to develop an SMS, with sustained progress, measured through the audit process, is acceptable.
Airborne Geophysical Survey, Pipeline Survey, Seismic, Helirig, or HETS requirements as stated above.
One Time Charter / Corporate SMS, with Hazard management process i.a.w. paragraph 3.6 preferred, but not required. A robust flight safety program will be assessed alongside the other requirements for One Time charter.
3.7.2.The Contractor shall develop a Bridging Document to demonstrate how their corporate SMS links to the UA Aviation Safety Case and HSE-MS. UA Aviation Logistics will provide the necessary materials and guidance to complete the Bridging Document. This shall be complete before the commencement of the Contract unless otherwise agreed.
3.8.Quality Assurance
3.8.1.Contractors shall develop, document and implement a quality assurance system, covering all flight operations and maintenance activities, modeled after ISO9001:2000 or equivalent. It shall include an internal evaluation program that ensures the conduct of organization-wide internal audits encompassing all safety and quality critical operations, and includes planned auditing of processes, procedures, documentation, training and records. Audit activities shall be scheduled and conducted at planned intervals to establish conformity with regulatory and management system requirements. Results of previous audits, including implementation and effectiveness of corrective action, shall be included within the scope of the program. The program shall be managed at the local operational level and be subject to periodic review by the Contractor’s management.
3.8.2.The Contractor shall ensure that the QA program is under the sole control of a Quality Manager or the person to whom the management function for the program has been assigned and shall have a system for ensuring that it includes the use of control processes that are sufficiently detailed to ensure that all operations and maintenance functions are evaluated. QA/Quality Control (QA/QC) departmental procedures, duties, responsibilities, and reporting relationships shall be described in the Operations Manual, Maintenance Management Manual (MMM) or a separate QA/QC manual as appropriate.
3.8.3.Contractors shall implement a compliance monitoring system that includes all aspects of company operations including flight operations, maintenance operations, and ground servicing operations. The activities to be checked shall be selected based on hazard analysis and historical incidents and near misses.
3.9.Environmental Management
3.9.1.Environmental management controls shall at all times be in compliance with local and or national regulatory requirements. Unless otherwise specifically addressed under separate system controls (e.g. ISO 14001), environmental management controls shall be integrated within an Contractors HSE policy and procedures, and shall be demonstrated as meeting Shell HSE and/or Environmental Control requirements.
3.9.2.Controlled companies and their contracted aircraft Contractors shall demonstrate to an acceptable level how the following environmental control system elements have been effectively implemented within their operations:
3.9.2.1.Emissions to the atmosphere (operational efficiency);
3.9.2.2.Aircraft noise;
3.9.2.3.Waste Management;
3.9.2.4.Utilities (Water and Energy) Management;
3.9.2.5.Contamination Control (of Land/Water);
3.9.2.6.Emergency response and incident reporting.
3.10.Incident and Accident Reporting Requirements
3.10.1.Notwithstanding the Contractor’s regulatory, local and/or national legislative Mandatory Occurrence Reporting obligations, Shell requires that owned and contracted Contractors provide reports to the Company contract manager (within 24 hours) in the event of the following occurrences:
3.10.1.1.Aircraft Accident, or;
3.10.1.2.Serious or Significant Incident, or;
3.10.1.3.Near Miss;
3.10.1.4.Air Safety Reports (having imminent Airworthiness or Safety of Flight implications).
3.10.1.5.Note: These standards are based on ICAO Annex 13, Aircraft Accident and Incident Investigation, and adapted to align with the Shell Group Incident Classification, Investigation and Reporting Guide at:
3.10.2. Incidents, near misses, and unsafe conditions shall be reported in accordance with the UA Aviation Incident Reporting Matrix.
3.11.Enhanced Operational Controls
3.11.1.Enhanced operational controls shall be introduced where deemed appropriate due to unusual activity, geography, environment or other risk factor conditions extant within the operational area. The specific nature of these controls shall be agreed with the local controlled company contract manager.
3.11.2. A tool for Enhanced Operational Control documentation is available from UA Aviation Logistics.
3.12.Drugs and Alcohol Policy
3.12.1.Contractors and Sub Contractors shall have formally documented policies on the use/abuse of alcohol, medical drugs and narcotics. Guidance is to be provided on what the Contractor considers to be acceptable by way of alcohol consumption. Additionally, guidance should be given to staff on which commonly available medical drugs, prescribed or otherwise, may impair an individual’s ability to perform in the cockpit or workplace. In all cases the Contractor shall comply with any National legislation/guidelines.
3.13.Performance Indicators
3.13.1.Contractor shall develop, document, monitor and act upon an appropriate range of performance indicators. The minimum requirements in this respect shall be agreed with the Company.
3.14.Fuel Quality Control
3.14.1.Fuel quality control is the responsibility of the refiner, bulk storage, delivery and receiving elements of the fuel logistics chain. Contractor shall, to the extent that it is reasonably practical to do so, ensure that adequate fuel quality control procedures are established in the logistics chain immediately prior to the point at which fuel is received and by default the point at which the Contractor becomes the owner of that fuel.
3.14.2.Fuel Quality shall be assured prior to delivery to the aircraft.
3.14.3.Fuel, once delivered to the aircraft, is also subject to fuel quality control checks. Contractor shall take daily samples from each aircraft sump drain (or, in the case of large aircraft, from each main tank group) and locally managed fixed and mobile storage facility prior to the first flight of the day; these samples shall be retained for 24 hours or until the next sample is taken prior to flight. Sample jars shall be clearly labeled such that the aircraft (and drain point) or storage container from which the sample was taken can be clearly identified.
3.14.4.Fuel samples shall be inspected and tested for water and contaminants using Shell Water Detector capsule kits or equivalent aids. Fuel sample water detection aids are subject to shelf-life limitations, and these shelf-life limits shall be observed.
3.14.5.Bulk Storage and Delivery System shall be tested and results recorded.
- AIRCRAFT OPERATIONS GENERAL
4.1.Pilots and other flight crew experience and qualification levels
4.1.1.The Contractor shall ensure that the flight crew of an aircraft:
4.1.1.1.hold the license, medical certificate and ratings (including radiotelephony license unless it is included in the pilot license) required by national regulations;
4.1.1.2.meet all recency requirements of the national regulations;
4.1.1.3.meet the license, medical and rating requirements specified in Annex 1 to the Convention on International Civil Aviation when operations are conducted outside of the national airspace of the State of issue of the flight crew license;
4.1.1.4.has fulfilled the requirements of the Contractor's ground and flight training program;
4.1.1.5.have successfully completed the proficiency requirements for that type of aircraft; and
4.1.1.6.can demonstrate the capability to speak and understand the language used for radiotelephony communications;
4.1.2.The Contractor shall ensure that each cabin crew member has fulfilled the requirements of the Contractor's ground and flight training program; and
4.1.3.The Contractor shall ensure that each crew member, other than a flight crew member or a cabin crew member, who is assigned duties onboard an aircraft during flight time has fulfilled the requirements of the Contractor's ground and flight training program.
4.1.4.The table at Appendix 01 stipulates the required flying experience and qualifications of pilots before they can fly Shell Company or Contractor(s) passengers, either on ad hoc charter or under contract.
4.1.5.Where these requirements cannot be met dispensation based on mitigating factors shall be sought from the Company. Where this is requested, full details of an individual’s experience and qualifications under the headings shown in the tables shall be submitted to the Company for assessment and consideration prior to agreeing or otherwise such a dispensation.
4.2.Alternative to Company experience level requirements
4.2.1.As an alternative to pilot experience levels and in line with Shell’s move towards competency based training, it may be possible to replace the requirement for defined pilot experience levels with suitable progression through a Company approved Contractor’s Training Management System. In order for this to be achieved the following conditions shall be met:
4.2.1.1.Establishment of a formal modular competency based progression scheme for pilots from basic (ab-initio/new-hire/conversion) to command and for aircraft type conversion.
4.2.1.2.An “In depth” audit of the Contractor’s training system shall be conducted by SAI to include:
4.2.1.2.1.Content of the training syllabus, to include comprehensive flight and ground training, particularly for entry at the CPL stage and a formal progression scheme for pilots from basic (ab initio) to command, approved by the Regulatory Authority of the country;
4.2.1.2.2.observation of CRM/LOFT Training, preferably in a simulator;
4.2.1.2.3.examination of training records with emphasis on a structured command course;
4.2.1.2.4.base and Line training staff with defined competencies who themselves are regularly checked.
4.2.1.2.5.formal recording of the application from the Head of Aircraft Services/Aviation Focal Point, acceptable resolution of audit findings, approval and recurrent audit requirements;
4.2.1.3.an ongoing Company audit plan to ensure continued compliance with the above.
4.3.Alternative to time on type requirements
4.3.1.When a new aircraft type is introduced on contract, it may be necessary to reduce the total time on type requirement. This shall be considered only after approval of the Contractor's type conversion scheme, and will be reviewed on a case-by-case basis. In any such case prior approval by Company is required which shall be agreed in writing.
4.4.Use of Freelance Pilots
4.4.1.Freelance pilots shall not normally to be employed on Shell contracted flights. There are, however, occasions on the smaller operation where their use cannot always be avoided. In such cases the freelance pilots may be used provided they: