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responsibility of those involved in both organisations to liaise where they believe there may be
a joint interest or need for clarification of responsibilities to ensure that such matters are dealt
with effectively, and to ensure there is no conflict of responsibilities with the other
organisation. CAA is tasked with investigating and enforcing under the Air Navigation Order
(ANO) and with in-flight health and safety of crew under The Civil Aviation (Working Time)
Regulations 2004. Contravention of the ANO or any Regulations made under it is a criminal
offence.
47 The roles and responsibilities of HSE and CAA and a framework for liaison are outlined in a
Memorandum of Understanding (MoU) to ensure coordination of policy issues, enforcement
activity and investigation in respect of aircraft and the systems in which they operate. There
are a number of Annexes to the MoU on specific areas. For further information on the MoU,
see Appendix 1 guidance and reference material.
FURTHER ADVICE
48 Standards for ground support equipment (GSE) are given in BS EN 1915-1:2001 Aircraft
ground support equipment - General requirements - Part 1: basic safety requirements. Specific
requirements for different types of GSE are in BS EN 12312 (see Appendix 1).
49 Specific guidance on the roles and responsibilities of those involved in aircraft turnround is
given in Aircraft Turnround HSG209.
50 Documents which give general advice on working at heights are listed at Appendix 1.
Further guidance is also contained in various British and European standards on which the
Transportation Section can advise. However, not all of these documents or standards are
specific to aircraft access and will need to be interpreted in the light of the task and the law, as
summarised earlier.
51 Advice on enforcement is given in paragraphs 56 - 63 describing a number of scenarios
that inspectors may encounter, to aid the inspector when they are considering enforcement.
This is for guidance only; any enforcement should be determined by the circumstances found
on site.
52 Advice on access to aircraft can be sought from the Transportation Section in East
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SIM 05/2005/05 - Preventing Falls from Height from, or When Opening or Closing Aircraft Doors
Grinstead (503 4200) who are prepared to provide expert evidence on standards of safe
access, if required.
ACTION BY INSPECTORS
53 Inspectors are requested to:
1) apply the standards detailed in this SIM when inspecting or discussing opening
aircraft doors;
2) alert the Transportation Section to any problems which arise from applying these
standards, or any of the other advice contained in this SIM;
3) draw to the attention of the Section any new or innovative means of gaining safe
access or fall protection;
4) advise CAA of any matters of concern relating to the safety of aircraft uncovered
during inspections or investigations;
5) inform the Transportation Section when contacting CAA to raise an issue of concern.
54 As part of a longer term strategy the Transportation Section is engaging with airlines and
with vehicle and aircraft manufacturers and designers to raise awareness of requirements for
safe access. Representatives of airlines, airports and ground handlers have worked with HSE
in the development of this guidance. Inspectors are encouraged to enquire into manufacturers'
and airline guidance on such things as opening aircraft doors and positioning of access
equipment, and to ensure that safe access is covered as part of routine employee training
programmes.
55 Where inspectors consider that an airline has responsibilities for safety such as procedures
for opening aircraft doors, they should contact the Transportation Section and airline Head
Office lead PI to check the national situation before taking any enforcement action.
ENFORCEMENT GUIDANCE
56 The following is a guide to when enforcement action may be appropriate. It is based on the
intranet version of the Enforcement Management Model (EMM) current in March 2005 and
applies to situations where there is a risk of falling a distance liable to causepersonal injury.
Any action should reflect any subsequent changes to EMM. The final decision on enforcement
action should also take account of dutyholder factors and the strategic factors outlined in
paragraphs 64 - 66.
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57 Table 1 sets out some risks of serious personal injury that require immediate action, after
which further action may be necessary to secure compliance and to achieve the benchmark of
　
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