Early in 2014, the National Transportation Safety Board (NTSB) released special investigation report (SIR) number SIR-14/01 detailing investigations of 78 ag accidents that occurred during 2013. All of these accidents involved some aspect of agricultural operations, pilot training, or other crop protection activities. Not all these accidents occurred during a part 137 operation but were tied to the ag industry close enough to warrant investigating their causes.

NAAREF submitted a third follow-up letter during June 2018 to inform the NTSB of the actions being taken on the Board’s safety recommendations. Detailed information on the NAAREF response was reported in the June 14, 2018 eNewsletter. Last week NAAREF received a letter from the NTSB regarding our handling of Safety Recommendations A-14-28 through -31. The letter from the NTSB can be read in detail by clicking here.

The recommendations and their comments on the recommendations are listed below:

A-14-28. Guidance for fatigue management is lacking for agricultural aircraft operations, and such guidance could help operators and pilots develop effective strategies to reduce the likelihood of fatigue, dehydration, hunger, and other physiological factors that can negatively affect a pilot’s concentration, decision-making, and performance.

NTSB responded that the topic of fatigue in ag aviation was covered with the help of a specialist in sleep medicine in addressing topics such as recognizing and coping with fatigue, medical symptoms of fatigue, dangers of fatigue, importance of sleep, common misconceptions about sleep aids, fatigue mitigation practices for agricultural operations, and circadian rhythm. A fatigue module was produced for the 2015-2016 PAASS Program; a fatigue brochure titled “Combatting Fatigue in Agricultural Aviation”; and magazine articles were published. NTSB stated that these actions satisfy the intent of Safety Recommendation A-14-28 which it now considers “Closed—Acceptable Action.”

A-14-29. Risk management guidelines and best practices specific to agricultural aircraft operations are necessary tools to help operators and pilots mitigate the unique risks associated with their operation. Risk management is a decision-making process by which pilots can systematically identify hazards, assess the degree of risk, and determine the best course of action.

NTSB responded that on the topic of risk management, NAAREF presented a module in the 2016-2017 PAASS Program on agricultural operations-specific risk assessment and mitigation strategies that addressed this recommendation. These topics were in multiple Fly Safe safety alerts and Agricultural Aviation magazine and a video was produced about the hazard of operating in low-level airspace.

On December 21, 2017, the FAA informed NTSB that they intended to publish a Safety Alert for Operators (SAFO) on this topic. NTSB responded that pending the completion and distribution of the SAFO, the Safety Recommendation A-14-29 remains classified “Open—Acceptable Response.”

A-14-30. A resource that contains detailed information related specifically to agricultural aircraft inspection, maintenance best practices, and quality assurance can reduce the likelihood that unsafe practices may be introduced and perpetuated.

NTSB responded that during the 2017-2018 PAASS Program, NAAREF presented a human factors module that included a discussion of accidents in which improper maintenance was a safety issue, and identified best practices for conducting effective aircraft inspection and maintenance quality assurance. These topics were also featured in various Fly Safe and Agricultural Aviation magazine articles.

On June 29, 2018 the FAA notified NTSB that they had published Information for Operators (InFO) 17016, titled “Agricultural Aircraft Inspection and Maintenance Quality Assurance Programs,” which provides guidance for ag operators on maintenance quality assurance and inspection programs. NTSB responded that the actions taken by NAAREF, along with FAA’s InFO satisfy Safety Recommendation A-14-30, which is classified “Closed—Acceptable Action.”

A-14-31. Standards and procedures are essential for safe operations. Without a resource that contains detailed information related specifically to agricultural aircraft operations, knowledge and skills test topics in existing FAA guidance materials, unsafe, nonstandard practices can be introduced and perpetuated.

NAAREF reported to NTSB that it is working with the FAA to develop guidance on Part 137 knowledge test subject areas and skills-test items. The guidance we develop will include reference material and a checklist which will be distributed to industry via the PAASS Program, Agricultural Aviation magazine, e-newsletter articles and the NAAA website.

FAA notified NTSB that they have updated AC 137-1B to include information on the knowledge and skills test. They also updated their Order 8900.1 guidance for FAA inspectors on administering these tests. NTSB responded that pending the development and distribution of the reference material and checklist, Safety Recommendation A-14-31 remains classified “Open—Acceptable Response.”