Ep. 11 – Breathalyzer and SAFA

Author: Brent Fishlock

I recently attended NBAA’s International Operators Conference and witnessed many fantastic presentations. I highly recommend the IOC to all international operators and kudos to the NBAA for putting on a great event.

One of the seminars was presented by Laurent Chapeau, who is head of the agency that administers the Safety Assessment of Foreign Aircraft (SAFA) in France. During his presentation he debunked the assumptions that France performs more SAFA inspections than other signatory countries. He also announced that starting in 2020, SAFA inspections will include a breathalyzer test of the flight and cabin crew. Other countries that are not signatory SAFA members are already performing breathalyzers randomly worldwide.

WHAT IS A SAFA INSPECTION?

Article 16 of the ICAO Chicago convention on International Civil Aviation states that “the appropriate authorities of each of the contracting States shall have the right to search aircraft of the other contracting States on landing or departure, and to inspect the certificates and other documents prescribed by this Convention.” Ramp Inspections may be performed at arrival and/or at departure of “Commercial Air Transport” and “General Aviation” aircraft. The process is described in the European Regulation document No 965 of 5 October 2012.

Members States of the SAFA program include all European countries, Australia, Israel, Morocco, Singapore, Turkey and the United Arab Emirates.

The SAFA inspection itself contains 53 inspection items which creates a ‘PoI’ or Proof of inspection document. There are 4 different categories of findings that can result from a SAFA inspection:

• Category 3: requires immediate corrective action including restriction on operation and possible grounding of the aircraft.
• CATegory 2: requires a Follow-up request on actions taken which is communicated through the SAFA database, and
• CATegory 1 and category G, neither of which require further actions.

The SAFA database provides the final version of the inspection report, which notifies the operator and its authority of the report and any findings. The operator can follow-up on their findings using the database.

WHAT ARE SOME OF THE COMMON FINDINGS?

Some common items that come up on SAFA inspections are the requirements to perform in-flight fuel checks and fuel management procedures while in the oceanic segment.

ICAO states that Operators shall establish policies and procedures to ensure that in-flight fuel checks and fuel management are performed. SAFA inspectors will check your Nav log to verify that you followed your company procedures. Inspectors have also asked to see that plots were made after oceanic waypoints. Plots are the last line of defence to ensure you have not deviated from your clearance after passing a waypoint thereby helping to prevent Gross Navigational Errors.

The finding ‘No in-flight fuel checks performed’ is a category 2 finding which requires follow-up using the SAFA database.

The SAFA inspector will also review your flight plan for PRE-flight fuel calculations.

ICAO Annex 6 Part I §4.3.6.3 and Part II §3.4.3.5.3 states:

“The pre-flight calculation of usable fuel required shall include:

• Taxi fuel
• Trip fuel
• Contingency fuel
• Destination alternate fuel
• Final reserve fuel
• Additional fuel, and
• Discretionary fuel”

Ensure your flight plans have accounted for all the required fuel. Simply having enough fuel is not sufficient for SAFA and it must be categorized properly.

Another finding that was discussed in the presentation is the use of direct routing to the alternate. This is a category 2 finding so speak to your flight planning provider and make sure this is not the case with your flight plan.

So, with regards to SAFA checks;

• It’s a good idea to prepare a checklist that covers the requirements of the inspection. Ensure your manual includes a procedure for In-flight fuel checks and fuel management and make sure you perform these checks in the oceanic segment.
• Ensure that your fuel calculation procedure on the flight plan is compliant with ICAO requirements.
• Ensure that you get ALL the weather forecasts and NOTAMs for departure, destination, and alternate airports.

Airlines have dealt with testing for years. Pilots at Japan airlines, Qatar, American Airlines and Sunwing in Calgary have been caught with blood alcohol levels. The Sunwing pilot fell asleep in the cockpit before departure and received 8 months in jail and lost his license for a year.

I couldn’t find a report of a biz jet pilot being tested or caught.

According to NBAA sources at the International Operators Conference, Dutch, German and Japanese authorities have already begun testing business jet flight crews using breathalyzers. Also, Singaporean authorities started testing at two airports, Changi and Seletar, on March 31. As I said earlier, starting in August 2020, SAFA inspections will include a breathalyzer for all pilots and cabin crew according to Mr. Laurent of the French authority.

This new policy is due to high profile accidents involving drug, alcohol and mental health issues of flight crew which were found to be contributing factors. A test result 0.02 grams of alcohol per 210 litres of breath will be considered positive, however if the local law is zero tolerance this may supersede that threshold.

If the initial test result is positive, the person will be immediately removed from duty and subject to a second test. If a crew member yields two positive results, the operator, and, in some cases, local law enforcement will be notified.