[Peetwo]

ARFFS Inquiry: Submission update.

The Committee Secretariat - the quiet achievers...

Today's additions:

21 Australian Airline Pilots' Association (AusALPA) (PDF 277 KB) 

Objections to The Proposed Changes

AusALPA continues to have grave reservations regarding these proposed changes
for the following reasons:

It is important to consider why these changes were proposed. ARFFS is perceived as
an expensive commodity that only proves its worth when an aircraft accident
happens on or close to the airport, and passenger and crew lives are saved. Aircraft
accidents are fortunately a rare occurrence and therefore on a cost benefit basis, the
provision of ARFFS may seem unnecessary until a major accident occurs. This is
somewhat simplistic as the ARFFS responds to standbys, medical emergencies and
domestic fires, as well as supporting the community fire services. In 2014, the
aviation rescue and firefighting services responded to some 6,700 calls relating to
airport emergency assistance.2

Australia is not meeting its international obligations, as was highlighted by the ICAO
Universal Safety Oversight Audit Programme (USOAP) in 2010 and is the least
compliant when compared to four other major “western” nations. [Note that Australia
committed to review and make any necessary amendments to the regulatory
requirements relating to ARFF provision at certified airports as detailed in CASR Part
139H (reference ICAO USOAP 2010) – merely filing a difference is not an adequate
action.] Canada is perhaps the best comparison, being a large land mass with a
elatively small population, which is also reliant on air transport. Canada has reduced
the passenger numbers for the hard trigger to 180,000 rather than increase it.

The preamble to ICAO Annex 14 Chapter 9.2 states:

“The most important factors bearing on effective rescue in a survivable aircraft accident are:

the training received, the effectiveness of the equipment and the speed with which personnel
and equipment designated for rescue and firefighting purposes can be put into use.”

The ARFFS established at the 28 airports have properly trained crews; have “state of
the art equipment’; are able to respond within 3 minutes (ICAO Standard); and have
firefighters and equipment ready “to save lives in the event of an aircraft accident or
incident occurring at, or in the immediate vicinity of, an aerodrome”.

As, Jack Kreckie, a 32 year veteran of Fire and EMS, who spent the last 28 years of
his uniformed career in ARFF, his last 15 years as a Chief Officer, and is the author
of the ARFF Chapter of the 20th Edition of the National Fire Protection Association
(NFPA) Handbook, and is a contributing author to Safety Management Systems in
Aviation, and Safety Management in Aviation, Implementation, wrote:

“The passenger demographics of today’s typical flight are comprised of much more diverse

profiles of age, health and physical condition. There are a percentage of passengers on every
flight who would be unable to evacuate an aircraft in an emergency. ARFF crews understand
that, regardless of the minimum requirements suggested by regulation or consensus
standards, they may be called upon to make entry for rescue and interior firefighting. The
survival of the occupants of the aircraft depends upon ARFF to do just that. There is a level of
expectation around the world that if an accident occurs or a fire breaks out, the ARFF crew will
respond and be prepared, equipped and trained to do whatever it takes to ensure that
passengers are safe. Safety and survival should not be based on a ‘minimum standard.’
(our emphasis). It should be based on a realistic task analysis of the specific needs, conditions
and capabilities of any airport conducting flight operations, regardless of whether the aircraft is
an air carrier or freighter.”

It is important to emphasise that the ICAO Annex 14 and MOS 139H contain the
“minimum standards” and that “best practice” as developed by the NFPA and
detailed in its NFPA 403 – Standard for Aircraft Rescue and Fire-Fighting Services at
Airports, “requires greater quantities of firefighting agent, ARFF vehicles and
addresses manpower levels” (the latter is not addressed in ICAO Annex
14/MOS139H).3

The change from “hard triggers” to “soft triggers” (if implemented) is fraught with
danger, especially since these would only trigger a risk assessment. As the
International Institute of Risk and Safety Management explains regarding the
“Limitations of Risk Assessment”:

“Risk is the combination of loss or harm and the likelihood of its realisation. But in order to

make meaningful and valuable assessments we need relevant knowledge and experience to
identify potential hazards or threats and to assess the risk likelihood and severity components.

The easiest to assess are things like slips, trips and falls that happen relatively frequently
because data is plentiful. Contrast this with major nuclear power plant disasters that are very
high in consequence but relatively rare. For these situations we need to undertake complex
analysis and scenario modelling to achieve the best-informed estimate of the likelihood of
events occurring. This happens in an environment where the overall methodology may never
be fully validated because such disasters are so rare.” 4

It, therefore, raises the question, “Is CASA confident that it has the expertise to carry
out a risk assessment of the need for ARFFS provision?” Even external risk experts
would find it difficult because “the overall methodology may never be fully validated
because such disasters are so rare.” The prescriptive (hard) triggers are, therefore, a
better safeguard.

It is recognised that at present, ARFFS provides a range of “other services” beyond
the primary role. The Australian Airport Association (AAA) wrote in its submission to
the Department’s DP:

“While the AAA understands that the expansion of non-aeronautical development at airports in

recent years has presented challenges around the definition of what constitutes an aerodrome and
therefore what ARFFSis responsible for, it is important to recognise the value provided byARFSS
carrying out these 'other' services. In providing these services to airports, ARFFS enhance the
overall safety and security of the airport community. Carrying out the duties also assist ARFFS
maintain continual familiarisation and integration with the broader airport environment, as per the
internationally recognised 'All Hazards' approach to emergency management. While the AAA
sees value in more clearly defining ARFFS responsibilities, it is important that these other
services continue to be provided at airports wherever there is clear value in doing so. Further
Departmental consultation with individual airport operators will be required before determining
a position on what services should or should not continue to be provided.”

AusALPA agrees that the value of these “essential services” must be considered in
the assessment of ARFFS provision.

It has been further proposed that the ARFFS regulatory framework be updated to
specify that state and territory fire authorities are not required to hold separate CASA
approvals to assist Airservices in the provision of ARFFS. The AAA provided this
answer in its same submission.

“In considering this amendment to the regulatory framework, the AAA believes it would be

prudent to consider the existing emergency management arrangements in place across the
jurisdictions. The AAA understands that in the event of an aviation accident, national and state
emergency management arrangements (as a general principle) require all relevant state
emergency authorities (police, fire and ambulance) to respond to the accident. These state
agencies are not responding to a call from assistance fromAirservices, they are responding in
accordance with established emergency management arrangements in that jurisdiction that are
articulated through legislative provisions and Aerodrome Emergency Plans.”

AusALPA supports this general position and recognises the need for close cooperation
and, where required, specific training for the local fire fighters in assisting the ARFFS
established at the airport.

AusALPA does not support the additional proposal from the AAA, as written, that:

“For those airports that may not warrant ARFFS under the new risk-based framework, it would be

useful for those airports to still be able to demonstrate that ARFFS functions could be carried out by
the local fire authority. This may be particularly useful for those airports that wish to attract certain
airline services that may expect a level of ARFFS to be provided. The AAA would support regulatory
changes that would allow for state/territory fire authorities to be able to more readily provide ARFFS
to airport operators.”

ARFFS is a specialised form of firefighting and those involved need to be properly
trained and practiced and have the proper equipment, if it is to be effective. Even driving
on the airport movement area requires special knowledge. Furthermore, it is unlikely that
the ICAO Annex 14 /MOS 139H response times will be met, unless an emergency is
declared in advance. This proposal would only be acceptable if CASA (with specialised
expert assistance) was to approve such ARFFS provision in accordance with the current
MOS139H standards.

Conclusion
ARFFS provides an essential safety and potentially lifesaving service for the flying public
and the aircrew, which include our members and those of other IFALPA Member
Associations, who operate to/from Australia. AusALPA believes that ARFFS provision
should be established in accordance with the ICAO standards.

The current regulatory framework already means that Australia is not compliant with the
ICAO standard for the establishment of ARFFS and is the least compliant when
compared with Canada, New Zealand, UK and the US. Australia gave an undertaking to
review the MOS 139H after its noncompliance was highlight by the ICAO USOAP 2010
audit. The inference was that Australia would move to a closer compliance (such as
Canada) not adopt proposals that would make it less so.

Furthermore, adopting a risk assessment methodology to a catastrophic, though
fortunately a rare event (at least so far in Australia), is, according to the experts, flawed.

The proposal to replace these services, in some locations, with local (domestic)
firefighting services should only be approved if these services meet the same standards
as specified in Annex 14 Chapter 9/MOS139H, including the designated response
times. Finally, though somewhat outside the Association’s direct expertise, it
understands that ARFFS, where located, provide substantial “other services”. On these
grounds, any future proposal to adversely change the triggers for the
establishment/disestablishment of ARFFS in Australia should be rejected.

22 Mr Glen Barker (PDF 479 KB) 

Conclusion

Anyone around long enough, such as career firefighters, some for 20 to 30 years or more service
have seen the wheel go around several times. Airservices employs a new CEO, AGM, HR Manager
who think “staff numbers are too high, let’s have a restructure, culling process, voluntary
redundancies, run the service down to save money” to then find out in a few years’ time, when a
new contract manager is engaged, that the manning is too low, staff numbers need to be bolstered,
vehicles are getting old, the staff are aging and there has been no future proofing of the business
model.

The Staff at Adelaide ARFF have highlighted within this submission some glaring instances where
Airservices are non-compliant with regards to Regulations, Procedures and Australian Standards. We
have also highlighted a need for a review between the relationship of Airservices and the regulator
CASA. Dispensation from a regulatory requirement should be temporary and not be seen as a “get
out of jail free” card. Once issued it should be a priority to have it cleared to then comply with the
regulation.

From the outset Adelaide ARFF have been upfront and honest to try to achieve a collaborative
approach to rectify the shortcomings with the current strategic direction Airservices is taking. Whilst
ARFF staff were fighting for a 2%/year pay rise during Enterprise Agreement negotiations ARFF and
Airservices senior management were slapping each other on the back and rewarding themselves
with considerable bonuses. This was in direct contrast to their undelivered achievable outcomes,
excessive expenditure and budget blowouts.

On a final note ARFF Adelaide are serious about providing a safe and compliant service which not
only maintains the safety of people we are here to protect but also of ARFF staff. Adelaide ARFF
need to increase the provision of service to include a Domestic Response Vehicle (DRV) in line with
other Australian capital city Airports. This DRV can then be utilised to provide Category 7 coverage
during curfew and maintain Category 9 during non-curfew which enables ARFF to comply with CASRMOS-
139H.

The interested staff at Adelaide ARFF thank you for your consideration of our submission.

Glen Barker
4th March 2019.

23 Mr Karl McDonald (PDF 51 KB) 

24 Mr Kiegan Rice (PDF 53 KB) 

 


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