Chapter 7

Committee views and recommendations

The vital role of aviation rescue and firefighting services in keeping flying passengers and crew safe should not be underestimated. A properly resourced and trained ARFFS is critical in optimising the chances of survival for travellers and crew, should the worst happen in an aviation accident.
The ARFFS also plays a fundamental role in responding to various emergencies across aerodromes, such as terminal fires, alarm activations and medical emergencies, where the ARFFS is able to promptly administer first aid and save lives.
Australia has thus far not experienced the worst of aviation accidents, and the committee hopes that this continues to be the case well into the future. It was made evident to the committee that adequate staffing and resourcing of ARFFS, as well as adequate time in which to respond to an emergency, were all key elements in reducing the risk of a catastrophic aviation incident taking place in this country.
The committee acknowledges that in many instances, Australia is meeting the minimum ICAO standards; whether these standards are appropriate for the Australian context—and for specific Australian aerodromes—is another consideration. Evidence to the inquiry made clear that there are a number of serious and ongoing concerns with the provision of ARFFS by Airservices across the 26 aerodromes at which it operates, which put the key elements of ARFF services at risk. These concerns, and the committee's recommendations, are detailed below.

International standards

The Chicago Convention and the ICAO framework, to which Australia is a signatory, sets the relevant ARFF standards to which Australia should aim to adhere, as far as is reasonably practicable. Other organisations, such as the NFPA, have also developed stringent criteria for the delivery of effective aviation rescue and firefighting services.
Despite this, Australia has lodged a number of differences with ICAO, which reflect Australia's unique requirements. It was argued consistently during the inquiry that Australia's regulatory framework—the CASRs, the MOS and other operating documents therefore do not adhere to international standards.
It was argued that this lack of adherence significantly increases the risks associated with ARFFS operations, and therefore increases the risks to the travelling public and aircrews.
The committee supports CASA reviewing and revising the CASRs, in light of the issues identified by the 2015 Review and the postimplementation review of Subpart 139.H. However, the committee notes that despite CASA's postimplementation review first commencing in 2007, drafted amendments to Subpart 139.H have not yet been released for public consultation. The committee views this as far too long a period in which to complete the review and amend the CASRs.
A considerable amount of time has lapsed since CASA's review commenced, and very significant concerns have been raised during this inquiry about Australia's lack of adherence to international standards, and the inherent risk this presents to the travelling public. The committee therefore recommends that the government undertake a major and wideranging review into Australia's adherence to the ICAO SARPs, as they relate to ARFFS. This review should consider the Australian regulatory framework—including the CASRs and the MOS—against international best practice, and consider Australia's adherence to Chapter 9 of Annex 14 of the Chicago Convention.
The review should consider any other relevant regulations, standards and procedures as required, such as those of the NFPA, and, when noncompliance with international standards is identified, reasons for this should be provided.

Recommendation 1

The committee recommends that the Australian Government conduct a review of Australia's adherence to the International Civil Aviation Organization Standards and Recommended Practices for the provision of Aviation Rescue Fire Fighting Services in Australia. The review should consider:
Subpart 139.H of the Civil Aviation Safety Regulations 1998;
the associated Manual of Standards;
Australia's adherence to Chapter 9 of Annex 14 of the Chicago Convention; and
any other relevant regulations, standards and procedures (including those issued by the National Fire Protection Association).
Where the review identifies noncompliance with international standards, the rationale for this should be explained.

ARFFS equipment and resources

The committee was concerned to hear about the considerable issues ARFFS firefighters have with the equipment, training and facilities currently in place for the ARFF service across Australia.
In particular, the committee was alarmed by the removal of rescue saws from operation, despite no replacement for the saws having yet been identified, and despite the fact that the removal meant the ARFFS was no longer compliant with the MOS. Such equipment is vital for effective responses to aviation incidents, where time is of the essence.
Further, the implementation of training for firefighters on ladders below two metres remains an ongoing concern for the committee. While the committee acknowledges the work health and safety concerns raised by Airservices, the fact remains that this limitedheight training is not reflective of operational conditions—particularly for larger aircraft. The committee trusts that Airservices will continue to look at ways that allow firefighters to train safely at height as soon as possible, whether that is via harnesses or other systems.
The ARFFS fire vehicle replacement program also appears to be taking some time to come to fruition, and is still in the early stages of a request for information after what appear to be significant delays. Noting the suggestion that ARFFS stations are already having to share vehicles, and that local manufacturers may not be able to develop these vehicles, the committee encourages Airservices to ensure that the replacement program progresses as a matter of priority.
Notwithstanding the removal of, or amendments to, the equipment and vehicles in use by ARFFS, Australia should maintain compliance with international standards and Australian regulations as far as is practicable. Firefighters strongly asserted throughout the inquiry that a lack of adherence to relevant international and other standards was placing both their safety, and the safety of others, at risk.
Given the recent changes to equipment, issues with fire vehicles, and the serious concerns raised by firefighters regarding adherence to ICAO and other standards, the committee recommends that a full audit be undertaken of the adherence of ARFFS equipment and vehicles to ICAO standards, the CASRs and the MOS. In completing the audit, consideration should be given as to whether the equipment and vehicles in place are appropriate for the aerodrome category.

Recommendation 2

The committee recommends that the Civil Aviation Safety Authority conduct an audit of all Aviation Rescue Fire Fighting Service (ARFFS) vehicles and equipment currently in operation across Australia, to determine the level of compliance with the International Civil Aviation Organization standards, and associated Australian regulations and standards (such as the Civil Aviation Safety Regulations 1998 and the Manual of Standards). The audit should consider whether the vehicles and equipment adhere to the relevant ARFFS airport category at each aerodrome.

Firefighting foams

The committee was alarmed by the evidence regarding firefighting foams, and the fact that the foams in use at Australian airports may not have been tested to Australian standards. The committee notes that ICAO's international framework for testing foams may not be suitable for the conditions at local aerodromes.
Given the higher ambient temperatures in Australia, and the lack of evidence indicating whether these foams had been tested in such conditions, it appears to the committee that the foams should be tested to ensure they provide appropriate protection for Australian travellers in the event of an aviation incident.
The committee therefore recommends that CASA (in conjunction with any other relevant organisation, such as Airservices) institute a testing program for firefighting foams in use at Australian airports, utilising the ICAO testing framework as a starting point, to determine the efficacy of the foams under Australia's unique conditions.

Recommendation 3

The committee recommends that the Civil Aviation Safety Authority implement a testing program for the firefighting foams in use at Australian airports, in accordance with International Civil Aviation Organization guidelines. The testing should take place under conditions unique to Australia (such as higher ambient temperatures), to establish whether the foams operate effectively to extinguish aviation fires.

Staffing levels and task resource analyses

A matter of great importance to the committee was the issue of adequate staffing at ARFFS stations, particularly against aerodrome category. It seems counterintuitive that firefighting crews may be reduced at a time when passenger numbers are only increasing. It does not appear appropriate to the committee that staffing reductions should be taking place.
A welltrained and fullystaffed ARFFS will be essential in maintaining Australia's aviation safety record. Having the ARFFS crewed to an appropriate level will allow it to respond to aviation emergencies in a timely manner, and without additional risks to crews or travellers.
The committee therefore expresses its considerable concern that no clear evidence could be provided demonstrating that a comprehensive safety assessment was completed by Airservices (and subsequently approved by CASA), prior to the reduction in ARFF crew numbers at Brisbane Airport. The committee acknowledges that the crew levels at Brisbane may be in accordance with the category of the airport, but without the support of a thorough safety assessment, it could not be ascertained whether this level of staffing was safe—rather than just adequate.
The committee welcomed the advice from Airservices that it would undertake a TRA prior to making any staffing adjustments at Adelaide Airport. However, given the substantial volume of aircraft movements which occur at that airport during curfew, the committee is of the firm view that no reductions in staffing should be made at Adelaide Airport. The committee would not be surprised to learn that the TRA in fact supports an increase to crew numbers at Adelaide.


The committee holds great concerns over the practice of cross-crewing. While the committee holds no doubts as to the ability of ARFFS crew and officers to attend to a variety of emergencies, the committee is of the view that ARFFS staff should not be put in the stressful situation of having to attend multiple emergency events, while trying to maintain category.
Airservices even acknowledged that, with a base crew of 14 staff, a Category 10 response may not be able to be maintained if the DRV was attending to a first aid call.
Airlines are paying for a service at ARFFS aerodromes, and it is reasonable for the airlines to expect that category is maintained. Crosscrewing could therefore take away the confidence of international airlines in the ability of Australia to respond to emergencies and maintain category. Despite the fact that airlines are paying for the service, the safety of the flying public remains paramount, and airlines should have confidence that Australian aerodromes can maintain category.
As discussed below, the committee urges Airservices to undertake the TRA assessments at ARFFS stations as soon as is practicable, in order to properly ascertain the impact of crosscrewing on the ability of ARFF services to maintain category, and adequately respond to aviation emergencies.

Task resource analysis

The committee recognises that staffing profiles cannot address every possible risk in the aviation sector, and that the allocation of resources needs to be proportionate to the assessed level of risk. To this end, the TRA is an invaluable tool in ensuring that the ARFFS is suitably resourced to perform its functions in the event of the worstcase emergency.
However, it was apparent that Airservices had yet to fully implement the TRA process which had been incorporated into the ICAO standards a number of years ago.
The committee therefore welcomes the advice of Airservices, that it and CASA both support the introduction of the ICAO TRA standards into the Australian regulatory framework. The committee was also pleased to hear that Airservices would look to utilise the TRA framework at every ARFFS location, commencing this year.
The committee also notes that CASA has indicated that its proposed changes to Subpart 139.H include additional requirements for ARFFS providers to apply the ICAO resourcing model at each ARFFS location. The committee supports this approach, and hopes that CASA progresses its amendments to the regulations as a matter of some urgency.
Given the demonstrated importance of the TRA process, and the support for the TRA from all key stakeholders, the committee recommends that CASA continue with its proposed amendment to the CASRs, and mandate that the TRA process—as prescribed by ICAO—is used at all ARFFS aerodromes to determine the suitable staffing levels at each aerodrome. In undertaking the TRA, consideration should be given to the category of the airport.

Recommendation 4

The committee recommends that the Civil Aviation Safety Authority mandates that Aviation Rescue Fire Fighting Service (ARFFS) providers use the Task Resource Analysis (TRA) methodology, as prescribed by the International Civil Aviation Organization, to determine the suitable staffing levels for ARFFS at all aerodromes in Australia where an ARFFS is provided. The TRA should take into consideration the category of each aerodrome.


There were concerns raised consistently during the inquiry that changes to staff numbers had occurred without appropriate consultation by Airservices with operational experts.
A number of firefighters made the point that firefighters with a broad range of knowledge and skills were well placed to consider risks within the ARFFS framework. However, it was suggested that Airservices were excluding such key personnel from consultation and risk assessment processes.
This was evidenced by the fact that Airservices had not heeded the calls from the UFUA and other bodies, over a number of years, to undertake the TRA process at ARFFS stations. Concerns were also raised over the fact that there was a lack of publicly available documentation regarding risk assessments and other processes.
The committee views consultation by Airservices with firefighting crews on the ground as vital to the development of effective TRAs, which accurately reflect the reality of delivering aviation emergency services. Constructive and collaborative consultation is also key to ensuring the best outcomes for all parties, as it allows for a suitable contest of ideas.
The committee therefore recommends that CASA mandate that the TRA process must involve appropriate consultation by Airservices with ARFFS staff and officers (and where necessary, their union representatives), at all stages of the TRA process. This consultation should be transparent, and the outcomes of any meetings made publicly available as soon as is practicable.

Recommendation 5

The committee recommends that the Civil Aviation Safety Authority mandate that the Task Resource Analysis (TRA) process undertaken by Airservices must involve appropriate consultation, via the direct engagement of Aviation Rescue Fire Fighting staff and officers at all stages of the TRA process. The consultation should be transparent, and the outcomes made publicly available as soon as is practicable.

Legislating staffing levels

It became apparent during the inquiry that changes to staffing levels in ARFFS crews could occur without appropriate oversight, via changes to regulations and operating procedures. This has resulted in calls for ARFFS staffing levels to be legislated.
Legislating for staffing levels would limit the ease with which staffing amendments can occur. Such amendments could move Australia further away from the ICAO standards, and the recommended NFPA standards.
Legislating for appropriate staff levels also means that the provision of ARFF staff at each aerodrome cannot be changed without parliamentary scrutiny, and without engagement of the relevant stakeholders. It would also seem appropriate to the committee that the staffing levels placed in legislation reflect the outcomes of the TRA process at each aerodrome.
The committee is therefore of the view that the staffing levels against each aerodrome category for the provision of ARFFS should be enshrined in legislation, and recommends that the government introduce legislation which stipulates the minimum ARFFS staffing level against aerodrome category. The legislation should apply to all aerodromes where an ARFF service is provided, and should take into consideration the findings of TRAs conducted at each ARFFS airport.

Recommendation 6

The committee recommends that the Australian Government introduce legislation which stipulates the minimum Aviation Rescue Fire Fighting (ARFF) staffing level in accordance with airport category, at all Australian aerodromes where an ARFF service is provided. The legislated staffing levels should reflect the outcomes of the Task Resource Analysis at each aerodrome.

ARRFS establishment threshold

Since the 2015 Regulation Policy Review, there has been ongoing discussion as to the appropriate trigger for establishing an ARFF service.
The proposal to increase the passenger trigger threshold from 350 000 to 500 000 was met with considerable concern from key stakeholders, including firefighters, and Minister McCormack's decision to retain the original threshold was welcomed.
However, the use of a hard trigger continues to be of particular concern given the ongoing increase in passenger numbers—an increase which shows no sign of abating. The committee questions whether the 350 000 passenger trigger remains suitable, given it was first implemented in 2002, and there is an everincreasing need for ARFFS to respond to nonregulated emergencies and other calls for assistance.
The committee echoes the calls for Australia not to increase the threshold, as to do so could move Australia further away from ICAO's international standards, and is likely to see even less passengers covered by an ARRF service. The committee calls on the government to commit to making no amendments to the establishment (and disestablishment) triggers at this time.
The move to a riskbased assessment for establishing an ARFF service appears logical, and was supported by Airservices in its submission to DIRDC. Support for the riskbased approach was also offered by other key stakeholders, including the UFUA. An assessment of risk would better consider the individual circumstances of each airport, such as the operational environment of an airport, and may determine that ARFFS should be established at aerodromes where currently none exists.
A risk assessment would also assist in clarifying the timeframes in which an ARFFS must be established. Currently, there is a time lag between the passenger trigger being reached—and importantly, sustained—and the establishment of the ARFF service. A risk assessment approach could better clarify whether an aerodrome should have an ARFFS, and would allow for the relevant safety case to commence development immediately, as safety concerns are identified.
It appears evident to the committee that there are considerable safety benefits in moving away from a hard trigger for ARFFS establishment. In light of the significant support for a riskbased assessment to ARFFS establishment, and the fact that this approach could consider the need for a dedicated ARFF service at an aerodrome holistically, the committee recommends that DIRDC complete a review into the current establishment criteria for ARFFS.
The review should seek to determine whether the current methodology of utilising passenger numbers allows for sufficient provision of ARRFS across Australian aerodromes, particularly in light of increasing passenger numbers in recent years.

Recommendation 7

The committee recommends that the Department of Infrastructure, Transport, Cities, and Regional Development undertake a review of the current establishment criteria used for determining whether to implement an Aviation Rescue Fire Fighting Service (ARFFS). The review should consider whether the current methodology of utilising passenger numbers allows for sufficient provision of ARFFS across Australian aerodromes, in light of increasing passenger numbers in recent years.

Division of responsibilities at airports

It was made clear to the committee that ARFFS is responding to a significant number of emergencies, not related to its core, regulated functions. These nonregulated functions are no doubt important, particularly with regard to first aid assistance. However, the increasingly large commercial areas of airports and other nearby developments are seeing the number of nonregulated responses increase considerably.
As was noted by Airservices, it may not always be appropriate for the ARFF services to respond to fire alarms at nonaviationrelated commercial developments—a job that is perhaps better suited to state and territory fire services.
In light of crosscrewing and other staffing pressures, it is apparent that attendance at nonregulated emergencies and the deployment of the ARRFS domestic response service is placing considerable strain on ARFFS resources. Further, it has not been clearly established exactly what resources are required for attendance at nonaviation, domestic emergencies, with an associated lack of clarity around the division of responsibilities between airport operators and state fire services.
Similar to the fact that a TRA is required to determine the appropriate level of staffing for the ARFFS, a similar process should take place to determine what resources are needed to attend to nonregulated, nonaviation emergencies—a Domestic Response Service TRA (DRS TRA). This analysis would help to identify gaps in the provision of services against category.
The DRS TRA may identify that additional resources are required, to ensure that the ARFFS can maintain category while also attending to other emergencies—or may identify that other services, such as state fire services, would be better suited to attend some nonregulated events (and therefore, what interaction may be needed between ARFFS and state fire services). The staffing TRAs and DRS TRAs should therefore complement each other, and identify the appropriate level of staffing at an ARFF station that would allow all relevant emergencies to be responded to.
In light of the above, the committee recommends that the government, in consultation with the relevant regulatory bodies, mandate for the establishment of a DRS TRA. This TRA should determine the additional ARFF crews required for responses to nonaviation emergencies across the aerodrome, over and above the staff required for an ARFF station to maintain category in the case of an aviation emergency.

Recommendation 8

The committee recommends that the Australian Government mandate the establishment of a Task Resource Analysis for Domestic Response Services responding to emergencies at aerodromes (DRS TRA). The DRS TRA should determine the additional Aviation Rescue and Fire Fighting (ARFF) staff required for responses to nonregulated ands nonaviation emergencies across the aerodrome, over and above the staff required for an ARFF station to maintain category in the case of an aviation emergency.

2015 Regulation Policy Review and CASR amendments

The committee is of the view that the 2015 Regulation Policy Review completed by DIRDC brought forward a number of sensible suggestions which would improve the administration of ARFFS.
In particular, the committee sees benefit in clarifying the roles and arrangements between the state and territory fire services and airport operators in the provision of ARFFS—this would also assist with the assessment of the DRS TRA. Further clarity over the definition of an aerodrome, to better reflect the core aviation activities of ARFFS, would also complement the DRS TRA process.
The committee encourages DIRDC to progress with these amendments by consulting with key stakeholders about the changes, and bringing forward legislative amendments in due course.

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