Approval of equipment used for carriage of persons external to a rotorcraft - Draft Advisory Circular 21-32 v1.0

This consultation sought feedback on our draft advisory circular (AC) about the approval of equipment used for carriage of persons external to a rotorcraft. It was open for public consultation from 26 November through to 20 December 2024.

We sought feedback on guidance regarding the various pathways and options for the airworthiness approval of personnel carrying device systems (PCDS) used with Human External Cargo (HEC) capable rotorcraft when performing HEC operations.

About this consultation

AC 21-32 v1.0 has been developed to address certain requirements identified by Parts 133 and 138 of CASR operational rules. Specifically, the need for certain equipment used for the carriage of persons external to a rotorcraft to have an airworthiness approval under Part 21 of CASR.

This activity represented the 2nd consultation on this AC following an initial consultation in October 2021. The revised guidance material included the following additions based on the previous feedback:

• adoption of the EASA terminology of simple and complex Personnel Carrying Device Systems (PCDS)
• inclusion of a frequently asked questions (FAQ) section
• improved clarity regarding what standards are acceptable – including a list of standards that have been pre-assessed by CASA
• the addition of a baseline standard for a litter system.

The consultation sought general feedback on the effectiveness of the revised guidance material and its ability to clarify the compliance pathways in accordance with Part 21 of CASR.

In total, there were 6 responses to the draft AC, one received from an aerial work operator, 2 received from Part 21 design organisations and 3 from 'other' respondents.

The feedback received was broad in nature and mostly targeted core issues of the policies introduced by Parts 133 and 138 of CASR.

Respondents raised a few important issues and concerns relating to the guidance material requiring further consideration.

Many of the points raised were very precise against the intricate detail of the guidance. The following is a summary of the main themes:

• The guidance was confusing and difficult to interpret. The complexity of the regulatory pathways and the associated language were deemed too intricate. Alternate guidance specifically for Part 133 and 138 operators would be useful.
• A desire for increased harmonisation between FAA and EASA guidance and increased flexibility for Australian manufacturers and operators.
• A need for a public register or data repository of equipment that is approved or may be approved in the future by CASA.
• The guidance does not do enough to clarify the policy on what constitutes 'installation' of equipment.
• The guidance does not clarify the fatigue requirements for approved equipment.

Respondents were supportive of the inclusion of a baseline standard for a litter system and recognised that while complex in nature, the policy and subsequent guidance does provide greater flexibility and choice to operators.

We have reviewed the responses in relation to the AC and have made amendments where required; the AC is now published as version 1.0.

The comments received that did not specifically address the guidance but regarded general CASA policy will be passed to the relevant area within CASA for further review.

We have issued an instrument to allow operators to seek approval from CASA to use existing equipment up until June 2026.