CASA EX91/24 – Use of Certain External Load Equipment in SAR and Medical Transport Operations – Exemption Instrument 2024

The instrument defines a discrete vocabulary and architecture for a time‑limited exemption regime. Core concepts are: relevant equipment, relevant helicopter, relevant operation, relevant operator, relevant permission, working load limit, attachment items, and references to the Part 133 MOS and Part 138 MOS (s 3). Each term has operational effect because the exemptions and conditions apply only where those defined terms are satisfied.

Relevant equipment is defined narrowly. It means articles, appliances, parts or materials that are not part of the aircraft approved design; that are used in SAR or medical transport operations for carrying a person external to a rotorcraft or restraining a person at an open door; and that are not approved under Part 21 of CASR (s 3(1), definition of relevant equipment). The exemption therefore does not cover items that are already part of the aircraft approved design or already Part 21 approved. The instrument preserves the separate meaning of other MOS terms by adopting Part 133 MOS and Part 138 MOS definitions where applicable (s 3(2)-(3)).

“Relevant permission” is the mechanism that converts the theoretical exemption into authorised operational practice. It is a written permission, issued on behalf of CASA’s National Manager, Airworthiness & Engineering, that may include conditions (s 3(1), definition of relevant permission; s 8(3)). The application for a permission must be submitted by the operator’s head of flying operations and must identify the equipment, its source, service history, manufacturer working load limit, intended use, safety assessment and maintenance history (s 8(1)-(2)). The instrument expressly contemplates that CASA may attach conditions to the permission including, potentially, conditions concerning attachment items (s 8(3)).

Time limitation and transition are embedded concepts. The instrument starts the day after registration and is repealed at 30 June 2026 (s 2). The application must indicate whether the equipment is expected to be approved under Part 21, or replaced by Part 21 approved equipment, by not later than 30 June 2026 (s 8(2)(c) and Note 1). Thus the instrument is a temporary regulatory bridge where operators may continue using certain non‑Part 21 equipment for a defined transition period, subject to CASA oversight.

Safety and control concepts are expressed as conditions. The required controls include compatibility with other helicopter equipment and the hoist hook (s 9(2)-(5)), prohibition on modification after permission (s 9(6)-(7)), repair restrictions to manufacturer or authorised person (s 9(8)), strict adherence to manufacturer’s working load limit (s 9(9)), crew training and inspection requirements before and after flights (s 9(10)-(13)), ongoing inspections and compliance with manufacturer Instructions for Continuing Airworthiness (ICA) (s 9(14)-(15)), documented procedures and recordkeeping (s 9(16)), manufacturer labelling requirements (s 9(17)), and retirement and replacement conditions (s 9(18)-(19)). The pilot in command has an operational gatekeeping role: they must not commence a relevant operation unless satisfied that the conditions in sections 8 and 9 have been complied with (s 11).

Finally, administrative integration is required. The relevant operator must ensure their exposition or operations manual contains a copy of this instrument and the relevant permission, and must document procedures to ensure compliance (s 10). These concepts combine to make a permission‑based, time‑limited, safety‑conditioned exception to the default Part 21 rules for certain external load equipment used in SAR and medical transport rotorcraft operations.

The instrument affects several identifiable actors and shifts certain costs and responsibilities onto specified parties. Primary legal subjects are the relevant operator and the pilot in command of a relevant helicopter in a relevant operation, each of whom is expressly exempted only to the limited extent set out and each of whom is subject to the instrument’s conditions (s 4; s 5(1); s 6(1)). The “relevant operator” is the operator of the helicopter in a relevant operation and is the entity that must apply for CASA permission through its head of flying operations (s 3(1), definitions; s 8(1)). The “pilot in command” has responsibilities under s 11 to refuse commencement of an operation unless they are satisfied sections 8 and 9 have been complied with.

CASA, represented by the National Manager, Airworthiness & Engineering, and the delegated officer who executed the instrument, occupies the decision role for granting permissions and attaching conditions (s 3(1) definition of relevant permission; s 8(3)). The instrument identifies the head of flying operations of the operator as the applicant and the operator as the party who must ensure compliance with all conditions in section 9 (s 8(1); s 7). The instrument’s Note indicates applications should be emailed to airworthiness@casa.gov.au (s 8(1) Note).

Manufacturers and authorised repairers are second‑tier affected parties. The instrument requires that relevant equipment not be repaired by anyone other than the manufacturer unless that person has the manufacturer’s specific authorisation to carry out the repair (s 9(8)). Manufacturer‑provided information and ICA must be followed and recorded (s 9(14)-(15); s 9(16)-(17)). Attachment items suppliers are implicated by retirement and compatibility conditions that the permission may impose (s 9(4)-(5); s 9(19)).

Recordkeeping and compliance obligations will fall on operations personnel and crewmembers: the instrument requires documented procedures, storage and cleaning records, maintenance records and use logs (s 9(16)). Crew members must be trained and familiar with inspection and deployment procedures (s 9(10)). The pilot in command is both a compliance enforcer and an actor whose operational discretion is constrained by a statutory precondition to commence flights (s 11).

Indirectly affected parties include insurers, auditors, and oversight entities that review operator expositions and operations manuals. The operator must ensure a copy of this instrument and the relevant permission appears in the exposition or operations manual (s 10). Administrative Review Tribunal is mentioned regarding reviewability of CASA decisions about permission (s 8(3) Note), which affects operators disputing CASA decisions.

Who pays: the instrument's structure places the compliance costs, recordkeeping, maintenance, training and eventual replacement or Part 21 approval acquisition costs on the relevant operator. The operator must apply for permissions, maintain records, perform additional inspections, obtain manufacturer authorisations for repairs, and either obtain Part 21 approval or replace equipment by 30 June 2026 (s 8(2)(c) and Note 1; s 9(14)-(19)).

Duties flow primarily to the relevant operator and the pilot in command, while CASA holds discretionary authority to grant and condition permissions.

Duties of the relevant operator:

• Obtain permission before use: The operator must ensure the head of flying operations applies for and receives a relevant permission before the equipment is used (s 8(1)). Applications must be signed and dated and include specified detail about the equipment and operations (s 8(2)(a)-(f)). The Note provides an email address for applications (s 8(1) Note).
• Maintain records and procedures: The operator must establish documented procedures and keep records about manufacture date, service entry date, each use, storage and cleaning, maintenance, and receipt and response to manufacturer safety alerts or revised ICA (s 9(16)(a)-(f)). The exposition or operations manual must contain a copy of this instrument, the permission, and procedures to ensure compliance (s 10).
• Meet safety and maintenance standards: The operator must ensure compatibility, meet helicopter flight manual requirements for carriage of an external person, avoid hook‑reversal or dynamic rollout through compatible design, adhere to manufacturer ICA and working load limits, perform specified inspections, and ensure repairs are by the manufacturer or authorised persons (s 9(2)-(5), (8)-(15)). Retirement and replacement must follow permission conditions (s 9(18)-(19)).
• Report and transition: The application must indicate whether the equipment will be Part 21 approved or replaced by 30 June 2026 and may be required as a condition of permission to report steps and timelines taken to obtain Part 21 approval or replacement (s 8(2)(c) and Note 1; s 8(2) Note 2).

Duties of the pilot in command:

• Pre‑flight gatekeeping: The pilot in command must not commence a relevant operation unless satisfied that the conditions in sections 8 and 9 have been complied with (s 11). This places an operational safety duty on the pilot to verify permissions, inspections, training and serviceability checks.
• Operational inspections and adherence: Crew members, including the pilot, must ensure pre‑use and post‑use inspections are performed and that deployment conforms to documented procedures (s 9(10)-(13), (16)).

CASA’s rights and discretions:

• Granting and conditioning permissions: CASA may grant a relevant permission with or without conditions and can make conditions related to attachment items (s 8(3)). The instrument identifies the National Manager as the office through which permissions are issued (s 3(1)).
• Reviewability: The instrument notes that the grant (or presumably refusal) of a permission is a reviewable decision for the Administrative Review Tribunal (s 8(3) Note), which gives operators a statutory review pathway.

Limits and qualifications:

• Scope of exemptions: The exemptions are narrow, applying only insofar as CASR provisions require Part 21 approval for the equipment (s 5(1); s 6(1)). The instrument does not exempt the operator or pilot from other CASR obligations, for example seatbelt or restraint requirements (s 5(2) Note; s 6(2) Note).
• Time‑limited nature: All duties and permissions operate in a regulatory window that ends 30 June 2026, after which the instrument is repealed and operators must have Part 21 approved or replaced equipment (s 2; s 8(2)(c) Note 1).

Rights of operators and pilots:

• Operate under exemption: Subject to CASA permission and compliance with conditions, operators and pilots may lawfully use relevant equipment that is not Part 21 approved during the instrument’s effective period (s 5-6).
• Seek review: Operators that are refused permission or subjected to conditions may seek review in the Administrative Review Tribunal (s 8(3) Note).

These duties and rights define an operational compliance regime where operators bear the practical burden of securing permission and maintaining documentation and safety controls, while CASA retains a gatekeeping role with the capacity to impose conditions and oversight.

The instrument itself does not create specific criminal offences or specify monetary penalties within its text. It operates by creating an exemption to specified CASR requirements (s 5(1); s 6(1)) and by imposing compliance conditions that, if not met, remove the operator’s protection of that exemption. The logical enforcement mechanism therefore is that non‑compliance with the instrument’s conditions means the operator and pilot are no longer operating under the statutory exemption and are instead subject to the full suite of CASR obligations and any enforcement mechanisms provided by the broader CASR framework. The instrument makes that legal consequence explicit by limiting the exemption only to the extent required and by reminding that other CASR obligations remain in force (s 5(2) Note; s 6(2) Note).

Practical enforcement levers that are implicit in the instrument’s structure and expressly stated include:

• CASA permissions: CASA’s authority to grant permissions with conditions (s 8(3)) gives it a direct regulatory lever. A permission can be withheld, granted with restrictive conditions, or revoked in accordance with CASA’s broader administrative powers under CASR (the instrument does not itself set revocation rules, but permissions are issued by CASA).
• Administrative reviewability: The instrument notes that the decision to grant or refuse a permission is reviewable by the Administrative Review Tribunal (s 8(3) Note). That creates an administrative law check on CASA’s exercise of discretion and provides a procedural enforcement pathway for operators seeking to challenge adverse decisions.
• Operational compliance requirements linked to civil liability and operational safety: The instrument requires documented procedures, maintenance to manufacturer ICA, inspections before and after flights, authorised repairs only, and crew training (s 9(10)-(15), (8), (16)). Failure to follow these conditions could be relied upon in administrative enforcement actions, regulatory audits, or civil proceedings, although the instrument does not itself specify enforcement sanctions.
• Manual and exposition obligations: The operator must include the instrument and the permission in its exposition or operations manual and maintain procedures for compliance (s 10). Non‑compliance with exposition or manual obligations under CASR may attract regulatory scrutiny or enforcement action under the wider CASR regime.

Who enforces: CASA is the decision‑maker and regulator that issues permissions and sets conditions (s 8(3)). The instrument identifies CASA’s National Manager, Airworthiness & Engineering as the official on whose behalf permissions are issued (s 3(1) definition). The pilot in command bears the operational enforcement role on each flight because they must not commence unless satisfied that sections 8 and 9 have been complied with (s 11).

What happens if conditions are breached: The instrument does not itself prescribe a penalty schedule. The practical consequence is loss of entitlement to rely on the exemption and exposure to the CASR requirements from which the exemption was carved out. The instrument’s Note warnings that it does not exempt from other CASR provisions (s 5(2) Note; s 6(2) Note) underscore that statutory enforcement under CASR would remain available to regulators.

Record of decisions and review: The instrument gives operators a route to challenge CASA decisions through the Administrative Review Tribunal (s 8(3) Note), which provides a procedural balance to CASA discretion. The instrument does not specify any other enforcement process, inspector powers, or penalty formulas.

In sum, enforcement operates by CASA’s permissions process, operator obligations in exposition and operations, pilot pre‑flight duties, the prospect of administrative review, and the fallback of full CASR compliance and any enforcement measures available under CASR if the conditions of the exemption are not met.

The instrument is explicitly framed as a limited deviation from particular CASR requirements. It operates by exempting relevant operators and pilots from specified CASR provisions only insofar as those provisions require relevant equipment to meet Part 21 approval and airworthiness requirements. The cross‑references are integral: the exemptions concern CASR regs 133.295 and 133.360(2) for medical transport operations (s 5(1)), and regs 138.375, 138.410(4)-(6) and 138.465(3)-(4) for SAR operations (s 6(1)). Those CASR provisions are connected in the instrument to particular parts of the Part 133 MOS and Part 138 MOS that require Part 21 approval for external load equipment (see s 5(1) Note and s 6(1) Note).

Relationship with Part 21 of CASR and MOS documents:

• The instrument does not change Part 21 or the MOS documents themselves. Instead it creates a temporary operational pathway that relaxes, for the period of the exemption, the requirement that relevant equipment be Part 21 approved before use in the defined operations (s 5(1); s 6(1)). The instrument expressly states that Part 21 of CASR “relevantly concerns certification and airworthiness requirements for parts” (s 5(1) Note; s 6(1) Note).
• The instrument incorporates the Part 133 MOS and Part 138 MOS meanings and documents as in force from time to time for definitions and interpretation (s 3(2)-(3)). This tethering means that other MOS obligations remain applicable to the extent not displaced by the narrow exemption.

Interaction with safety obligations and continued applicability:

• The instrument’s Notes emphasise that the exemption does not relieve operators of other CASR obligations, including requirements to wear seatbelts, harnesses or restraints (s 5(2) Note; s 6(2) Note). That preserves the operation of the remainder of CASR and MOS requirements.
• The safety and maintenance requirements in section 9 reference manufacturer ICA and owner’s manuals (s 9(11), (14)-(15)), tying the exemption to existing manufacturer obligations and continuing airworthiness processes rather than creating an alternative regulatory standard.

Administrative law overlay:

• CASA permissions are an administrative act issued under the instrument, and the instrument notes that such permission is a reviewable decision for the Administrative Review Tribunal (s 8(3) Note). This provides a statutory review mechanism for operators dissatisfied with CASA’s exercise of discretion.

Temporal interaction:

• The exemption is expressly time‑limited, ending 30 June 2026 (s 2). Applications must indicate whether the equipment will be Part 21 approved or replaced by that date (s 8(2)(c) and Note 1), creating a transition obligation that aligns operational practice with Part 21 rules at or before expiry.

Repair, modification and manufacturer authorisation:

• The instrument places limits on repairs and modifications that interact directly with Part 21 concepts: relevant equipment must not be modified after CASA grants permission (s 9(6)-(7)) and must not be repaired by anyone other than the manufacturer unless there is specific manufacturer authorisation (s 9(8)). Those restraints dovetail with the regulatory logic of Part 21 control over design and airworthiness approvals.

Consequential legal exposure:

• Because the exemption is narrow, any conduct outside the exemption’s limits immediately reactivates the underlying CASR obligations and any associated enforcement or liability. The instrument therefore functions as a temporary and conditional legal carve‑out that must be managed within the broader CASR legal regime.

In short, the instrument sits as a temporary, conditional overlay to CASR and MOS obligations. It modifies the legal effect of specific CASR provisions for the limited purpose and period stated, but it does not rewrite Part 21, nor does it displace other CASR or MOS requirements. Administrative law review and manufacturer ICA remain materially significant in that legal relationship.

The instrument provides its own creation and temporal parameters but does not record previous amendments. The document as supplied states the instrument name, the delegate who made it, and the date of signature: it was made by Steven James Campbell, Executive Manager, National Operations & Standards, a CASA delegate, and signed on 20 December 2024 (instrument header and signature block). Section 1 gives the instrument name. Section 2 establishes commencement and repeal: the instrument commences the day after registration and is repealed at the end of 30 June 2026.

No amendments or earlier versions are referenced inside the instrument text. The instrument expressly provides that all documents mentioned, applied, adopted or incorporated in this instrument are such documents “as are in force from time to time, as applicable” (s 3(3)). That clause means that while the instrument itself has no recorded amendment history, incorporated external documents such as the Part 133 MOS and Part 138 MOS may change independently and be read into this instrument as they stand at any given time.

Key timeline points embedded in the instrument:

• Commencement: the instrument commences the day after registration (s 2(a)).
• Repeal: the instrument is set to be repealed at the end of 30 June 2026 (s 2(b)). This creates an explicit sunset clause.
• Transition expectation: the instrument requires applicants to indicate if and when the relevant equipment is expected to be Part 21 approved or replaced no later than 30 June 2026 (s 8(2)(c)). Note 1 under s 8(2) reiterates that relevant equipment must be approved under Part 21 or replaced by not later than the end of 30 June 2026, or earlier if a CASA permission so requires.

Administrative notes and procedural detail:

• The instrument includes a procedural note indicating that applications should be emailed to airworthiness@casa.gov.au (s 8(1) Note). It also notes that CASA may impose conditions that require reporting steps and timetables for acquiring Part 21 approval or replacement equipment (s 8(2) Note 2).
• The instrument records that permissions issued will be written and may include conditions, and that such decisions are reviewable (s 8(3) Note).

Because the instrument itself does not set out any later amendments, any change to its terms would require a separate instrument or formal amendment by CASA and would be reflected in subsequent instrument texts. As it stands, the amendment history consists solely of its making on 20 December 2024 and its pre‑set repeal date of 30 June 2026.

The instrument contains no record of judicial or tribunal determinations applying or construing it. The only adjudicative mechanism expressly mentioned in the instrument is administrative review: the instrument states that CASA’s grant of a relevant permission would be a reviewable decision for the Administrative Review Tribunal (s 8(3) Note). That is an internal statutory reference to reviewability rather than a case citation.

Consequences and practical litigation pathways implied by the instrument:

• Administrative review: Operators or applicants dissatisfied with CASA’s decision to grant, refuse, or condition a permission have a procedural route to challenge that decision by lodging an application with the Administrative Review Tribunal, as the instrument itself notes (s 8(3) Note). The instrument does not specify grounds of review, remedies, or timeframes; those would be governed by the relevant administrative law and Tribunal rules.
• Regulatory enforcement and civil exposure: The instrument does not itself record any litigation outcomes or precedent. However, failure to comply with the instrument’s conditions would result in exposure to the underlying CASR requirements from which the exemption is carved out (s 5(2) Note; s 6(2) Note). Any regulatory enforcement, civil liability, or common law proceedings arising from such failure would proceed under the normal legal framework outside the instrument. The instrument does not catalogue or limit such proceedings.

Absence of cases in the text:

• The instrument does not name any judicial authority, case law, or prior administrative decisions. Accordingly, there is no internal litigation history to summarise beyond the statement about Administrative Review Tribunal reviewability.

Practical implication for operators and advisers:

• Because the instrument creates a new permission pathway, disputes about the scope, conditions or revocation of permissions are most likely to be resolved in administrative review forums rather than being litigated as questions of statutory interpretation of CASR, at least initially. The instrument gives operators a statutory review route (s 8(3) Note) but provides no substantive litigation guidance.

In sum, there is no recorded litigation history in the instrument. Administrative Review Tribunal review is the only adjudicative process mentioned, and operators should treat CASA permissions as administrative decisions that may be subject to Tribunal review under applicable administrative law procedures.

This instrument contains several operational and legal traps for the unwary. They arise from the narrow scope of the exemption, the pre‑use permission requirement, strict conditions on modification and repair, the time‑limited transition to Part 21 approval, and record and labelling obligations. Below are concrete items to flag, each grounded in a specific provision.

1. Exemption is narrowly limited to Part 21 requirement only. The instrument exempts operators only “to the extent” that CASR provisions require equipment to meet, or be approved under, Part 21 (s 5(1); s 6(1)). It does not exempt operators from other CASR requirements. The instrument’s Notes explicitly warn that other CASR obligations such as seatbelts, harness or restraint rules still apply (s 5(2) Note; s 6(2) Note). Practically, reliance on the exemption does not create a general carve‑out from safety rules.

2. Permission must be obtained before first use. The relevant operator must ensure relevant equipment is not used unless and until the operator’s head of flying operations has applied for and received a relevant permission (s 8(1)). Using equipment before permission is both a breach of the instrument and a factual exposure to full CASR obligations and potential enforcement.

3. Application detail is strict. The application must include detailed information: identification of equipment, source, date first placed in service, manufacturer’s working load limit, intended operations and justification, expected pathway to Part 21 approval or replacement by 30 June 2026, safety assessments, evidence of prior safety reliability, and maintenance history including dates and who carried out maintenance (s 8(2)(a)-(f)). Incomplete or vague applications risk refusal or restrictive conditions.

4. Time‑limited transition and mandatory finish date. The instrument requires that relevant equipment be approved under Part 21 or replaced by not later than 30 June 2026 (s 8(2)(c) Note 1). If operators intend to continue using the equipment beyond that date, a Part 21 path must be in place. The instrument may also permit CASA to require earlier retirement as a condition of permission (s 9(18)-(19)).

5. No post‑permission modification or configuration change. Once CASA grants a permission, the relevant equipment must not be modified or have its configuration changed from the version that was the subject of the permission (s 9(6)-(7)). Any alterations may invalidate the permission and expose the operator to CASR requirements and enforcement.

6. Repair limits: manufacturer authorisation required. Repairs must be performed by the manufacturer or by a person specifically authorised by the manufacturer (s 9(8)). Unauthorised repairs may breach the instrument and any subsequent permission.

7. Strict adherence to working load limits and compatibility requirements. The manufacturer’s working load limit must not be exceeded in a relevant operation (s 9(9)). Equipment must be compatible with helicopter fittings, hoist hooks, attachment points and must not cause hook reversal or dynamic rollout (s 9(2)-(5)). These technical constraints may require engineering input before CASA will grant permission.

8. Recordkeeping and labelling obligations. Operators must document manufacture date, date placed in service, each occasion of use, storage and cleaning, maintenance and responses to ICA updates or safety alerts (s 9(16)). Manufacturer labelling, including serial numbers, part numbers, service life limits and authorised payload/person numbers, must be present or recorded (s 9(17)). Poor recordkeeping undermines the operator’s ability to satisfy s 11 obligations and CASA scrutiny.

9. Retirement obligations may be permission‑specific. Relevant equipment and attachment items “must be retired and replaced in accordance with any conditions in the relevant permission” (s 9(18)-(19)). Retirement schedules imposed by CASA may be earlier than manufacturer recommendations.

10. Pilot in command’s practical blocking power. The pilot must be satisfied that sections 8 and 9 have been complied with before commencing a relevant operation (s 11). This gives the pilot operational authority to refuse deployment where documentation or inspections are incomplete.

11. Administrative review but no guaranteed outcome. While CASA decisions are reviewable by the Administrative Review Tribunal (s 8(3) Note), review may take time and the Tribunal’s processes may not provide immediate operational relief. Operators should not assume that reviewability equals rapid availability of permission.

12. Attachment items can be conditioned. CASA may attach conditions not only to the equipment but to attachment items; these may include retirement and compatibility requirements (s 8(3); s 9(4)-(5); s 9(19)). Misunderstanding attachment item requirements risks creating a single‑point failure.

13. No explicit enforcement penalties in the instrument. The instrument does not state specific penalties for non‑compliance; the practical consequence is exposure to full CASR obligations and any enforcement action under CASR. Operators should not interpret the absence of penalties as lack of regulatory exposure.

14. Incorporation of external documents “as in force from time to time”. Because the instrument adopts MOS definitions as they are “in force from time to time” (s 3(3)), changes to the MOS documents after the permission is granted could affect interpretation and operating obligations.

These gotchas converge on a single practical point: the exemption is delicate and procedural. Operators that rely on it must plan the administrative application, technical compatibility and engineering checks, authorised repair pathways, recordkeeping systems and an exit or Part 21 approval plan well before 30 June 2026.

Compliance requires an operator to build administrative, technical and operational steps into existing safety management systems and the exposition or operations manual. The instrument specifies concrete actions and documents required. Below is a stepwise compliance blueprint, tied to the relevant provisions.

1. Pre‑use administrative step: apply for CASA permission (s 8(1)).

• The operator’s head of flying operations must prepare and sign an application addressed to CASA (s 8(1)); note the application email airworthiness@casa.gov.au (s 8(1) Note).
• The application must include detailed identification and description of the relevant equipment, including source, date first placed in service, purpose, and the manufacturer’s applicable working load limit (s 8(2)(a)).
• Include the intended kinds of operations, explanation of necessity and appropriateness (s 8(2)(b)).
• State if and when the equipment is expected to be Part 21 approved, or replaced by Part 21 approved equipment, no later than 30 June 2026 (s 8(2)(c)) and be prepared to provide a timetable if CASA conditions require it (s 8(2) Note 2).
• Provide evidence of safety assessment, prior use reliability in Australia, and maintenance history including inspection dates and who carried out maintenance (s 8(2)(d)-(f)).

2. Secure a written relevant permission from CASA (s 8(3)).

• Await CASA’s decision. CASA may grant permission with conditions, which could include requirements on attachment items or reporting obligations (s 8(3)). Treat the permission as the controlling instrument for permitted configuration and retirement schedules (s 9(18)-(19)).

3. Ensure equipment compatibility and configuration alignment (s 9(2)-(5), (6)-(7)).

• Confirm physical compatibility with the helicopter, other external load equipment, and hoist hooks; address risks of hook reversal and dynamic rollout (s 9(2)-(5)).
• Do not modify equipment or change configuration after CASA grants permission without prior CASA approval (s 9(6)-(7)).

4. Implement inspection and maintenance regimes aligned with manufacturer ICA (s 9(11)-(15)).

• Perform Place‑In‑Service inspections per manufacturer Owner’s Manual before first flight where equipment will be used (s 9(11)).
• Inspect equipment prior to each flight in which it will or may be used to determine serviceability and absence of dangerous projections or sharp edges (s 9(12)).
• Inspect after any flight where equipment was used to verify continued serviceability (s 9(13)).
• Maintain the equipment at intervals set out in manufacturer ICA and comply with any safety alerts or revised ICA (s 9(14)-(15)).

5. Establish documented procedures and records (s 9(16)).

• Document procedures for recording date of manufacture, date placed in service, each occasion of use, storage and cleaning methods, maintenance timing and details, and receipt and response to safety alerts and ICA revisions (s 9(16)(a)-(f)).
• Ensure records are accessible to demonstrate compliance during CASA inspections or administrative review.

6. Apply labelling and identify lifecycle limits (s 9(17)-(19)).

• Record or display manufacturer information: name, part number, serial number, date of manufacture, service life‑limit date, authorised payload and authorised number of persons (s 9(17)(a)-(g)).
• Plan for retirement and replacement of metal or wear‑subject equipment and attachment items in accordance with permission conditions (s 9(18)-(19)).

7. Control repairs and alterations (s 9(6)-(8)).

• Do not permit repairs by unauthorised personnel. Obtain written manufacturer authorisation where needed (s 9(8)).
• Treat any change to configuration as requiring prior CASA re‑approval or an amendment to the permission.

8. Ensure crew training and deployment familiarity (s 9(10)).

• Train and certify crew members to inspect, deploy and use the equipment; ensure demonstrable familiarity with deployment procedures, pre‑use checks and emergency responses (s 9(10)(a)-(b)).

9. Meet operational safety controls and weight limits (s 9(3), (9)).

• Do not exceed the manufacturer’s working load limit in operations (s 9(9)).
• Ensure carriage of persons as external loads meets helicopter flight manual requirements (s 9(3)).

10. Update exposition and operations manual (s 10).

• Insert a copy of the instrument and the relevant permission into the operator’s exposition or operations manual, and include procedures to ensure ongoing compliance (s 10(a)-(b)(b)). Document how compliance will be monitored and who is responsibility for records.

11. Pilot pre‑flight assurance (s 11).

• Ensure pilots are briefed and have authority to refuse a mission if documentation, inspections or training are incomplete. The pilot in command must be satisfied that sections 8 and 9 have been complied with before commencing any relevant operation (s 11).

12. Monitor transition to Part 21 or replacement (s 8(2)(c) Note 1).

• Begin the process early for Part 21 approval or replacement equipment acquisition and be prepared to report steps taken and timetables if a permission’s condition requires it (s 8(2) Note 2). Remember the deadline is 30 June 2026 (s 2; s 8(2)(c) Note 1).

13. Prepare for administrative scrutiny and review.

• Maintain a clear audit trail to support any Administrative Review Tribunal challenge if CASA imposes restrictive conditions or refuses permission (s 8(3) Note).

14. Integrate into safety management systems.

• Treat the permission regime as a formal change to operations requiring risk assessments in the safety management system, with clear delegation of responsibilities between head of flying operations, maintenance personnel, crewing staff and pilots.

Following these steps maps directly onto the instrument’s express requirements and reduces risk of an unlawful operation or breach of the exemption. Operators should ensure the head of flying operations and the pilot in command are aligned on documentation and technical checks, and should commence Part 21 or replacement planning well ahead of the 30 June 2026 sunset.