Chapter Three
Chronology of Events Following Purchase of PADS
Preliminary Training - November 1996
3.1 Training in the use of PADS commenced in early November 1996. While
most CSU operators around Australia agreed to participate in training
and in the use of PADS, a number of operators declined, primarily because
of incompatibility of aircraft. One operator declined because of a preference
to remain with the existing system, and another resigned as an area CSU
rather than use PADS on the basis that flying at 100 feet was unsafe.
[1]
3.2 It was initially assumed by Airservices staff that SAR Pty Ltd would
carry out the necessary training. As noted in a general circular by Mr
Peter Evans, General Manager of Air Traffic Services, on 28 August 1996:
'Airservices will work with Search and Rescue Pty Ltd to re-train and
re-equip all of PADS compatible Civil SAR Units in the earliest time frame.
This re-training is expected to commence in the first week of September'.
[2]
3.3 Indeed, on this same day, in correspondence concerning negotiations
on the purchase of PADS, [3] Mr Gruzman
had indicated that he would be reluctant to provide the equipment if he
were not to be involved in the training program:
A responsible Board will not purchase a product such as PADS or permit
it to be used without ensuring that adequate legally and practically
effective training is provided so that the product will be safely and
reliably utilised. We are the only organisation capable of providing
that service. [4]
3.4 However, contrary to those assumptions, Airservices Australia
appointed Mr Frank Young of Navair Pty Ltd to oversee PADS training. At the end of
negotiations on the purchase of PADS, Mr Forsyth had written to the CEO, Mr Bill Pollard:
The only matter to be resolved is the training of pilots, drop
masters and crew.
I have spoken with Frank Young about the figures [for training] quoted
in Mr Gruzman's letter. Frank's advice is that these are reasonable
prices for the proposed tasks. Would you finalise the training arrangements
with Anton Gruzman in consultation with Frank Young. [5]
3.5 The reason for Mr Young's involvement was explained in evidence
to the Committee by Airservices Australia Chief Executive, Mr Bill Pollard:
… the reason Mr Young was involved in this was that at the time
Mr Gruzman would have been most unhappy with Mr Evans or Mr Marshall,
who functionally should have had this management role. It was quite
well-known to us that they would have been unacceptable to Mr Gruzman.
However, Mr Young, at that time, was in favour with Mr Gruzman. It was
my idea, after consultation with Peter Evans, to continue to use Mr
Young to manage the training process. Mr Young had a contract that was
for 30 days work within a 90-day period at approximately $1,000 for
each day that he worked. The total value of the contract was not to
exceed $35,000. [6]
3.6 Thus it seems that the contract for training was issued to a
private company, Navair, at the request of the Airservices Chairman, on the suggestion of
the Chief Executive Officer, without any tendering process being carried out, simply
because Mr Gruzman had previously had difficulties liaising with two Airservices staff
members, Mr Tony Marshall and Mr Peter Evans.
3.7 At the commencement of training a number of difficulties were
encountered. The major problem centred on a conflict between SAR Pty Ltd and Airservices
Australia as to who held ultimate responsibility for the supervision of training
activities.
3.8 According to SAR Pty Ltd, Mr Young had interpreted his consultancy
contract in a manner so as to give him 'entire charge of the training
program', including the direction of SAR Pty Ltd staff without SAR Pty
Ltd knowledge or approval. [7] Also of
concern to SAR Pty Ltd was the fact that Mr Young's ideas on training
differed and that he had limited experience of the operation of PADS equipment.
3.9 Airservices Australia criticised the manufacturer, SAR Pty Ltd,
for not accepting the fact that problems with PADS were being encountered. According to Mr
Pollard:
The problem that we have … is working with our manufacturer. They
seem not to want to acknowledge, necessarily, that potentially there
could be problems and work with us to solve those. They simply blame
someone else or our training procedures. They could be very well right
but, until they are willing to work with us, we do not know … [8]
3.10 In the end, SAR Pty Ltd was not further involved in the training.
According to Mr Gruzman: 'SAR [Pty Ltd] was entirely excluded from either
input into or attempts to introduce PADS into service or detailed knowledge
of their problems. No request for assistance was made'. [9]
Consequently, Mr Gruzman argued, that omission was the sole source of
Airservices ensuing problems.
3.11 However, both prior to and during the training exercises,
Airservices personnel expressed concern at the manner in which the training was being
conducted and, in particular, with the level of experience and expertise displayed by
training consultants Navair.
3.12 In a report of the training weekend held on 9-10 November 1996
at Jervis Bay (NSW), Mr Marshall described some of the problems encountered:
- when the aircraft arrived there was no activity plan available;
- equipment had to be found to remove the aircraft door;
- there were insufficient tiedown components which meant that the
aircraft could not carry an extra person to act as a safety officer or training officer to
oversee operations;
- ground training on the PADS units was disjointed and unprofessionally
presented;
- the dropmaster instructor was not SAR Pty Ltd accredited;
- much of the theoretical part of the training could and should have
been carried out prior to the weekend of flying;
- poor organisation resulted in a waste of valuable flying time; and
- problems with equipment led to concerns about safety and loss
of time. [10]
3.13 Two days later, Mr Marshall again wrote to Mr Evans, this time
expressing concern about the training carried out by Mr Frank Young:
I wish to document concerns experienced with the coordination
aspects of the PADS conversion training. … The training exhibition from Navair
arranged at Jervis Bay was appalling. There was no structure, with all
"teaching" off the cuff. It was not until Airservices took control that any
order and structure was achieved. … To be asked Thursday afternoon if my staff are
available for training departing Melbourne on the next day, displays a complete lack of
organisation and unreasonable expectations of staff.
3.14 The memo written by Mr Marshall also expressed concern about the
standard exhibited by some of the contracted pilots, the fact that there
was no agreed training program, the lack of some essential safety equipment
within the training aircraft, and problems with the static line. Finally,
it recommended, inter alia, 'that Airservices participation in PADS conversion
training cease immediately' and that 'control of all CSU training be returned
to Airservices, and the present waste of financial resources be ceased'.
[11]
3.15 Similarly, a report from Dropmaster Instructor Mr Colin
Campbell, highlighted problems experienced with the November training:
… after the problems experienced at Jervis Bay … it
has now become a matter of urgency that a quick release mechanism be attached to the long
restraining strap used by the dropmaster …
… it is no longer acceptable that drop crews have to rely
on cumbersome radio equipment to communicate with each other and the pilot…
… for too long we have had a problem fitting and using
"approved" and "non-approved" tie downs…
… there are many problems unresolved regarding the PADS
static line… AIRSERVICES should never have bought PADS without resolving the static
line issue. We now find ourselves in the situation where we are not only training
ourselves with a doubtful component, we are also involved in Research and Development to
fix the problem! This is not good enough. How many more control surface strikes do we have
before CASA says enough is enough?
… after my first complaints over three weeks ago, there
are still no plans in train to implement a proper training timetable…
… any decision to press on regardless to implement the transition
to PADS as soon as possible is foolhardy and dangerous. In this unseemly
haste, safety is bound to be compromised. So far, the approach by NAVAIR
has been slipshod and thoroughly unprofessional. Slow it down or people's
lives will be put at risk. [12]
3.16 However, training was ultimately suspended not because of difficulties
encountered with Navair, but because of problems associated with the behaviour
of the static line: problems which only became apparent after analysis
of high speed photography of the PADS drops carried out by Aerospace Technical
Services. [13]
ATS Testing - November 1996
3.17 As part of the PADS training program, Aerospace Technical
Services was employed to assess the suitability and safety of the equipment by way of
photographic recording of the dispatch mechanism and, in particular, the behaviour of the
static line during each drop. Four sorties totalling 5.5 hours were flown with 10 airborne
dispatches.
3.18 The subsequent ATS report noted that of the ten deployments, partial
equipment failures occurred on six occasions. [14]
During video evidence shown to the Committee, Mr Michael Jones, Managing
Director of Aerospace Technical Services, described some of the problems
encountered during the November training. The two major concerns related
to: (1) breakage of the static line (reason unknown); and (2) touching
of the drogue line and the static line with the elevator and other parts
of the aircraft.
3.19 Mr Jones concluded: '… whilst this equipment is deployed with
an amazing amount of accuracy … the parameters for usage are very
narrow. In an environment where you are doing a real rescue and where
the weather conditions are marginal, having a set of conditions which
are no narrow is unrealistic or difficult to actually maintain'. [15]
3.20 However, according to Mr Jones, part of ATS's brief was to ensure
that the system was being used in accordance with the manufacturer's instructions.
In evidence to the Committee Mr Jones stated that the briefing carried
out prior to the training exercise was done in a very thorough and professional
manner, and that the procedures used were not, in his opinion, a contributory
factor in the problems that emerged. [16]
3.21 The ATS report recommended, failures notwithstanding, that the equipment
be retained on the basis that the system was delivered with a high level
of accuracy. It further recommended that no further training be carried
out but that development work be done to reduce the proportion of equipment
failures. [17]
3.22 In response, SAR Pty Ltd criticised the report as
unprofessional and rejected the ATS test results. In doing so, SAR Pty Ltd noted that
while ATS had found problems with virtually all aspects of the PADS equipment, and had had
a 60% failure rate, SAR Pty Ltd itself had had over the past few months a success rate of
close to 100%. Given the high success rate achieved by the manufacturer, SAR Pty Ltd
argued that it was incumbent upon Mr Jones to ask why faults were occurring when ATS
tested the system which had not occurred previously.
3.23 Further, SAR Pty Ltd argued that the ATS report had failed to
discuss:
- the pre-existing success rate of the manufacturing company;
- the lack of training of the drop personnel;
- the use of an outdated manual;
- the dropping of unauthorised stores;
- the use of 15 degrees of flap, contrary to manufacturer's
specifications; and
- ATS's lack of knowledge of PADS. [18]
3.24 SAR Pty Ltd was highly critical of its exclusion from these tests
because it meant that there was no expert advice available to ATS to clarify
what was normal and what was not normal in the behaviour of PADS during
the drops, and because, when problems arose, the manufacturers were prevented
from observing them or playing any part in rectifying them. [19]
Testing - January/February 1997
3.25 Concern arising from problems encountered with training led Airservices
Australia to again engage ATS, after a tendering process, to carry out
further ground and flight testing on PADS 'to determine the veracity and
magnitude of the PADS deficiencies and where possible, make recommendations
for improvements and/or take corrective action to enable introduction
to service of the PADS equipment'. [20]
3.26 As part of the testing carried out by ATS, eight sorties
involving 20 dispatches of PADS equipment were planned. However, as a result of the
repeated occurrence of a number of unacceptable deficiencies, the flight program was
terminated five days before the anticipated completion date (8.3 hours flown of a planned
25 hour program).
3.27 During the tests four major unacceptable deficiencies were noted
which could have resulted in damage or even accidents to aircraft, injury
to personnel or the loss of life. (Three incidents which involved a recoil
of the static line in a forward direction were subsequently reported to
BASI [21]). In addition, a further 12
unsatisfactory deficiencies were identified which related to PADS equipment,
procedures and documentation.
3.28 In conclusion, ATS recommended to Airservices Australia that no
further PADS dropping be conducted until the deficiencies were rectified.
The report further recommended that CASA certification of the PADS static
line be withdrawn and that CASA closely monitor all future PADS development.
[22]
3.29 However, the ATS report also noted that, notwithstanding the deficiencies,
the deployment accuracy of all 20 liferafts was highly consistent and
accordingly recommended that because the PADS system had 'merit in concept',
a feasibility study should be conducted into retention and modification
of the equipment already purchased. [23]
3.30 In response to this report, SAR Pty Ltd was again critical of the
fact that tests had again been carried out by ATS in the absence of the
manufacturer, particularly as the problems that had been identified in
November had still not to their knowledge been fixed, nor had SAR Pty
Ltd been consulted about them. SAR Pty Ltd argued that, had it been involved
in the November training, further testing in January, at cost of some
$100,000 - $200,000, would not have been necessary. [24]
Service Alerts and Airworthiness Directives - February 1997
3.31 On 6 February 1997, SAR Pty Ltd requested CASA to make mandatory
seven Service Alerts that the company had issued in relation to the use
of PADS. [25]
3.32 CASA's reply came in a letter dated 12 February and dealt with the
request as follows. With regard to Service Alert Numbers 1, 2, 3 and 4,
the letter noted that because they related to the performance of PADS,
and did not deal directly with safety, CASA had no power to mandate them.
[26]
3.33 In relation to Service Alert Number 6, the letter stated: 'CASA
is not presently satisfied that the modification proposed by SAR to the
static line is an appropriate resolution to the problems associated with
the static lines. … A decision on the Airworthiness Directive will
be dependent on CASA's analysis of the results of the tests performed
by ATS and the SAR response'. [27] Similarly,
CASA reserved it decision on Service Alert Number 7, pending the ATS results.
3.34 However, in a second letter of the same date, CASA noted that it
had been presented with 'compelling evidence [in the ATS report of 11
February 1997] that the PADS static line, which is aircraft equipment,
can create an unsafe condition to aircraft during PADS dropping activities.'
Rejecting the changes proposed by SAR Pty Ltd in Service Alert Number
6 because, according to CASA, the unsafe condition would not be overcome,
CASA proposed under Civil Aviation Regulation 37A, to issue an Airworthiness
Directive on 19 February 1997 unless SAR Pty Ltd was able to present a
valid technical argument to the contrary. [28]
3.35 In a letter of objection to CASA's proposed action SAR Pty Ltd
argued that:
CASA proposes to effectively ban our development and use of PADS by
properly trained and certificated operators using proper equipment and information in
properly configured aircraft with conventionally rotating propellers on the basis of
tests:
- conducted by a person without the requisite qualifications and with
an interest in defeating PADS
- on outdated equipment in unknown condition
- dropped by untrained personnel who have an interest in preventing the
orderly introduction of PADS
- using an outdated manual with knowledge that essential safety
features were unknown to the test crews
- without access to the PADS Training Video
- using unauthorised modifications
- conducted in the utmost secrecy
- without us as manufacturers having any opportunity to observe the
tests
- in an aircraft with counter-rotating propellers
- in an aircraft deliberately configured contrary to our printed recommendation
… [29]
3.36 Then, on 16 February 1997, SAR Pty Ltd issued a statement that the
156 static lines provided under the purchasing contract to Airservices
Australia, were 'illegal, bogus and potentially dangerous' because the
tape supplied by the subcontracting company, Sala International Pty Ltd,
was 'Military Specification Polyester Webbing' rather than the nylon webbing
that had been specified by SAR Pty Ltd. While the breaking strain of polyester
webbing exceeds that of nylon, 'elongation of polyester webbing is approximately
half that of nylon webbing'. [30] The
statement gave detailed reasons to explain how the error arose.
3.37 In a letter to CASA, SAR Pty Ltd claimed that the implications of
this error were far reaching and, in particular, that all flight testing
by ATS on PADS was consequently invalid. In denying responsibility for
the error, SAR Pty Ltd blamed CASA for failing to detect the bogus part.
[31]
3.38 Further to this, SAR Pty Ltd argued that ATS should be held liable
for compensation to Airservices Australia for the cost of testing PADS
because ATS did not follow up its own recommendation of 19 November 1996
that there be an investigation of the materials used for the static lines.
In addition, Mr Gruzman argued, ATS should not be involved in any further
PADS testing. [32] As a general disclaimer,
SAR Pty Ltd argued that it had 'acted honourably and efficiently and in
full compliance with its obligations as a manufacturer'. [33]
3.39 Airservices Australia, however, did not agree with SAR Pty Ltd.
According to a media report, Airservices held the view that the equipment
had been purchased in good faith from the manufacturer and had subsequently
been found to not meet the specifications of the original contract. [34]
3.40 More significantly, however, information received by CASA from
Sala International suggested that the information provided by SAR Pty Ltd with regard to
the 'bogus part' was not in fact correct. In a letter to Mr Gruzman, Mr Frank Grimshaw,
General Manager of the Airworthiness Branch of CASA, wrote:
Your advice that the static lines provided to Airservices
Australia were made from non-specified material with a lower stretch than the specified
material is indeed cause for concern. The matter will be addressed by CASA. However, while
the degree of stretch of the static line may well be a factor, there is no evidence that a
tape with less stretch than specified will exacerbate the unsafe condition.
Further information from Sala International leads me to believe that,
contrary to the advice provided by you on 16 February 1997, the static
line material used in the static lines provided to Airservices Australia,
is in fact Nylon and may in fact meet the specification. [35]
3.41 Having regard to all the information provided by SAR Pty Ltd,
CASA formally issued an Airworthiness Directive, effective from 20 February 1997, which
stated:
The Static Line described in HSJ AVIATION drawing 0856 is prohibited
from use in the release of Precision Aerial Delivery System (PADS), except
for actual rescue tasks where PADS is used because of discernible risk
to life or health of persons requiring assistance. [36]
3.42 In practice, the Directive makes it an offence to use the
static line in association with PADS in any circumstances, with exception of a real
emergency. This means that neither Airservices Australia nor SAR Pty Ltd can use the
static line for training or for testing without first obtaining a permit to fly from CASA.
To do this, the person wishing to use the static line must prove to CASA that the unsafe
condition has been overcome.
3.43 In late February, SAR Pty Ltd wrote to CASA requesting further information
on what was needed before the Airworthiness Directive could be lifted
and PADS training be resumed. [37] In
his reply, Mr Grimshaw explained:
Before the Airworthiness Directive can be revoked, CASA must be satisfied
that the unsafe condition has been rectified. To this end it would be
necessary for SAR Pty Ltd to change the static line and demonstrate
that the modified static line will not recoil, such that the line strikes
any part of the aircraft and that the end of the static line will not
pass forward of the rear of the tailplane following any 'delayed release'.
Alternatively, SAR Pty Ltd may demonstrate that the PADS release mechanism
has been modified so as to ensure that there will not be any failure
to immediately release which would cause the static line to stretch
and thus recoil. [38]
3.44 The letter from CASA also explained that any other person or
organisation which owned any PADS units was also able to propose a means of demonstrating
that the unsafe condition with the static line had been rectified. Thus it is also open to
Airservices Australia to proceed in this manner so that training can recommence.
Stalemate
3.45 There now exists a very expensive stalemate. CASA has issued an
Airworthiness Directive preventing the use of PADS, except in life-threatening
emergencies. Airservices Australia is unable to carry out any further training and, more
importantly, is unable to use the equipment it purchased with the expectation of having it
fully functional within 90 days of delivery, unless it takes on a development role and can
find a way of rectifying the unsafe condition. SAR Pty Ltd, while debating endlessly with
CASA over the issuing of the Airworthiness Directive, has not so far made any effort, to
the Committee's knowledge, to overcome the unsafe condition.
3.46 Neither party in this stalemate accepts responsibility for the fact
that the equipment purchased by Airservices Australia is currently unable
to be used - it lies idle in a warehouse in Melbourne. SAR Pty Ltd maintains
that the problems lie with the operators not with the system. The Chief
Executive of Airservices Australia, when asked who was responsible for
the PADS equipment not being in a serviceable condition at the time of
purchase, stated: 'I would hold the manufacturer responsible'. [39]
Footnotes
[1] Rural and Regional Affairs and
Transport Legislation Committee Examination of Additional Estimates, op cit, pp.
1895-1901.
[2] Electronic Memo dated 28 August 1996
(04:26 pm EST) from Mr Peter Evans, General Manager, Air Traffic Services, Airservices
Australia, to 'Subscribers' et al. Rischbieth, Item 10 (Folder 2).
[3] Electronic Memo dated 28 August 1996
(05:28 pm EST) from Mr Paul Woodham, Facilities Management Division, to Mr Bill Pollard,
Chief Executive, Airservices Australia. Rischbieth, Item 10 (Folder 2).
[4] Undated letter (fax-dated 16 February
1997) from Mr Laurie Gruzman, SAR Pty Ltd, to The Hon Mr Justice William Fisher, Chairman,
CASA, et al, p.3. Faxed to the Committee on 17 February 1997.
[5] Letter dated 6 September 1996 from Mr
John Forsyth, Chairman, Airservices Australia, to Mr Bill Pollard CEO, Airservices
Australia. Rischbieth, Part 1 (Folder 1).
[6] Evidence, p. RRA&T 111.
[7] Letter dated 12 September 1996 from Mr
Anton Gruzman, SAR Pty Ltd, to Mr Bill Pollard, CEO, Airservices Australia. Rischbieth,
Part 1 (Folder 1).
[8] Evidence, p. RRA&T 47.
[9] Undated letter (fax-dated 16 February
1997) from Mr Laurie Gruzman, SAR Pty Ltd, to The Hon Mr Justice William Fisher, Chairman,
CASA, et al, p.3. Faxed to the Committee on 17 February 1997.
[10] Electronic memo dated 12 November
1996 from Tony Marshall, SAR, Airservices Australia, to Peter Evans and attached report Precision
Aerial Delivery System Training of Dropmaster and Pilot Instructors 9th - 10th November
1996. Rischbieth, Item 10 (Folder 2).
[11] Airservices Australia Electronic memo
Sent 14 November 1996 (04:40pm EST) from Tony Marshall to Peter Evans. Rischbieth, Item 10
(Folder 2).
[12] Report dated 14 November 1996 Concerns
with Navair PADS Training as at 14 November 1996, Colin L Campbell, Dropmaster
Instructor. Rischbieth, Item 10 (Folder 2).
[13] Evidence, p. RRA&T 10.
[14] ATS Flight Test Report
Photographic and Safety Chase Airservices Australia - PADS Document Number
ATSSYD/PROJ/FUT/FLIGHT TEST PT 1 (23), Executive Summary, p. 3.
[15] Evidence, p. RRA&T 80.
[16] Evidence, p. RRA&T 81.
[17] ATS Flight Test Report, op
cit, Executive Summary, p. 3. See also Evidence, pp. RRA&T 77-85.
[18] Undated letter (fax-dated 16 February
1997) from Mr Laurie Gruzman, SAR Pty Ltd, to The Hon Mr Justice William Fisher, Chairman,
CASA, et al, p. 5. Received by the Committee on 17 February 1997.
[19] Ibid, p. 6.
[20] Aerospace Technical Services Report
001/97 to Airservices Australia Flight Test and Consultancy Report - Precision Aerial
Delivery System (PADS), 11 February 1997, p. 3.
[21] Letter dated 13 February 1997 from Mr
Michael Jones, Managing Director, ATS, to Director Bureau of Air Safety Investigation.
[22] Aerospace Technical Services Report
001/97, op cit, pp. 1-2.
[23] Ibid, p. 2.
[24] Undated letter (fax-dated 16 February
1997) from Mr Laurie Gruzman, SAR Pty Ltd, to The Hon Mr Justice William Fisher, Chairman,
CASA, et al, p.6. Faxed to the Committee on 17 February 1997.
[25] Service Alerts comprise information
issued by a manufacturer about an aircraft component which may be submitted to CASA for
the issuing of an 'Airworthiness Directive' under CAR regulation 37A. CASA is only
entitled to issue an AD in relation to an item of aircraft equipment if it considers that
an unsafe condition exists, is likely to exist or is likely to develop in relation the
equipment.
[26] Alert Number 5 was subsequently
withdrawn by SAR Pty Ltd.
[27] Letter dated 12 February 1997 from Mr
Frank Grimshaw, General Manager, Airworthiness Branch, Airservices Australia, to Mr
Laurence Gruzman, SAR Pty Ltd, commencing: 'I refer to your facsimile letter to Leroy
Keith …', p. 2.
[28] Letter dated 12 February 1997 from Mr
Frank Grimshaw, General Manager, Airworthiness Branch Airservices Australia, to Laurence
Gruzman, Chief Pilot, SAR Pty Ltd, commencing: 'As discussed with you on 5 February 1997
… '.
[29] Letter dated 13 February 1997 from Mr
Laurence Gruzman, SAR Pty Ltd, to Mr Andrew Snedden, Committee Secretary, pp 1 - 2.
[30] Fax-dated letter of 16 February 1997
from Mr Laurie Gruzman, SAR Pty Ltd, to The Hon Mr Justice William Fisher, Chairman, CASA,
p. 1.
[31] Undated letter (fax-dated 16 February
1997) from Mr Laurie Gruzman, SAR Pty Ltd, to The Hon Mr Justice William Fisher, Chairman,
CASA, et al, p. 6. Faxed to the Committee on 17 February 1997.
[32] Ibid, pp. 7 - 8.
[33] Fax-dated letter of 16 February 1997
from Mr Laurie Gruzman, SAR Pty Ltd, to The Hon Mr Justice William Fisher, Chairman, CASA,
p. 3.
[34] Sydney Morning Herald 18
February 1997, p. 6.
[35] Letter dated 18 February 1997 from Mr
Frank Grimshaw, General Manager Airworthiness Branch, CASA, to Mr Laurie Gruzman, SAR Pty
Ltd. Faxed to the Committee 5 March 1997.
[36] Commonwealth of Australia, Civil
Aviation Safety Authority, Schedule of Airworthiness Directives, Civil Aviation Orders
Part 107, AD/PADS/1 Precision Aerial Delivery System (PADS) Static Line 4/97TX.
[37] Letters dated 27 February 1997 from
Mr Laurie Gruzman, SAR Pty Ltd, to The Hon Mr Justice William Fischer, Chairman, CASA, et
al.
[38] Letter dated 3 March 1997 from Mr
Frank Grimshaw, General Manager, CASA, to Mr Anton Gruzman, Chief Executive, SAR Pty Ltd,
p. 2. (Faxed to the Committee by CASA on 19 March 1997.)
[39] Evidence, p. RRA&T 201.