Interpreting SFAR 73 in the UK

What is SFAR 73?

After a spate of R22 accidents (from when it was first certified onwards) the FAA issued a Special Federal Aviation Regulation known as SFAR 73. SFAR 73 details training requirements for pilots of both R22 and R44 helicopters. The SFAR is an addendum the FAA Title 14 CFR 61, it does not apply to pilots who are not licenced by the FAA unless the national authority they are licenced by decides to adopt it.

The UK CAA make comment in AIC 70/2000 [Pink 5] that the items required by SFAR73 are covered in our training syllabus and the subsequent yearly LPC required on type.

The CAA, after reviewing the differences between the FAA and CAA helicopter pilot licence training and flying instructor experience requirements, concluded that the adoption of a similar programme in the UK was not warranted.

The list of current UK AICs can be found by following this link

Significant Dates in the history of SFAR73 (includes NTSB safety recommendations)

Date	Expiry [If Applicable]	Summary	Supporting Evidence
27 Oct 1982	N/A	NTSB Safety Recommendation A82-143-144 published
21 Jul 1994	N/A	NTSB Safety Recommendation A94-143-145 ublished
6 Jan 1995	N/A	NTSB Safety Recomendation A95-1-8 published
10 Jan 1995	N/A	Special Airworthiness Information ASW-95-91 published.
01 Mar 1995	31 Dec 1997	SFAR 73 Issued as an Emergency Rule.	The 339 accidents since certification mentioned in the SFAR73 documentation.
02 Apr 1996	N/A	NTSB Special Investigation Report 9603 Robinson Helicopter Company R22 Loss of Main Rotor Control Accidents
30 May 1996	N/A	NTSB Safety Recommendation A96-9-13 published
21 Nov 1997		Notice of Proposed Rule Making [NPRM] to extend the date of expiry of SFAR73 and to change the experience requirements for pilots of R44 helicopters and credit them with some of their R22 time towards the experience requirements of SFAR73.
31 Dec 1997	31 Dec 2002	Final Rule on NPRM to make SFAR73-1
14 Nov 2002		A Proposed extension to the existing SFAR73-1
31 Dec 2002	31 March 2008	Final Rule on NPRM with some rejected comments from Robinson on why SFAR73-1 should not apply to the R44.
31 March 2008	30 June 2009	Expiry Date Change and reword the heading in section 3. Renumbered SFAR73-2
29 May 2009	Permanent	Change to make the SFAR non expiring.

Requirements of SFAR 73

Minimum experience required to operate an R22 or R44. Training requirements to be met if those minima are not met. One of the documents mentions the 100 accidents between 2005 and 2008 and that none of them were things that used to catch out pilots prior to SFAR73 and as such it is working so it should be extended

Flight Manuals

There are two Airworthiness directives which modify the R22 and R44 flight manuals, these ADs reference SFAR73 but they are not part of it.

R44 POH
The limitations section of the R44 flight manual was modified by FAA AD 95-26-05 at the same time as the R22 manual was changed however that that was rescinded by FAA AD 95-26-05R1 on 6 July 2004.

R22 POH
The limitations, normal procedures and emergency procedures sections of the R22 flight manual are modified by FAA AD 95-26-04

It would appear that the limitations section modifications are for flight in windy/ gusty conditions and give the pilot a reduction in limits unless he or she has

• Been trained in line with the requirements specified in SFAR 73
• AND has 200Hrs in Helicopters or more
• AND 50Hrs on type.

This implies that all three conditions must be met in order to comply with the AD that forms part of the limitations section of the flight manual and as such, must be obeyed.

CAA Requirements on Airworthiness Directives

The CAA postiion on ADs can be seen on the CAA website and the most significant part would appear to be

For products of non-UK design the CAA requires compliance with the ADs issued by the National Aviation Authority (NAA) of the State of Design.

.

CAA Letter to Owners

The CAA issued on the 11th October 1995 a letter to owners which details how pilots are deemed to have complied with the ADs in the flight manual in the UK it can viewed on the CAA website.

In short this means that until you have 200hrs and 50hr on type you must observe the limits specified in FAA AD 95-04-14 (which is superseded by FAA AD 95-26-04 mentioned above) when flying an R22.

You can check current CAA Leters to Operators on the CAA website.

Summary

In summary SFAR73 does not apply to UK licenced pilots.
The FAA ADs which embody flight manual limitations changes do apply to UK registered R22s (and previously did to R44s).
The SFAR 73 training requirement in those ADs is deemed to be complied with by virtue of being UK trained.