Civil Aviation Order 20.9 - Air service operations - Precautions in refuelling, engine and ground radar operations (02/12/2004)

The Order organises its rules around three operational regimes: (1) fuelling operations (location, fuel quality, personnel and procedural controls), (2) starting and ground engine operations (clearances, evacuation means, prohibited proximity to hazards), and (3) ground radar operation (power thresholds and exclusion zones). It embeds a technical annex (Appendix I) for fire safety of mechanical and electrical equipment within 15 metres of fuel tank fill points and vents.

Key definitional and operational concepts in the Order are:

• Pilot in command and operator duties: The pilot in command has primary responsibility to ensure fluids meet CASA‑approved specifications before flight (s 3.1). Operator obligations are repeatedly required for provision of safe procedures, staffing, equipment and documentation (for example s 4.2.2(l) requires the operator’s operations manual to set out responsibilities and procedures).

• CASA approval and manufacturer specifications: The Order gives CASA a gatekeeping and approval role for fluid specifications and for certain hangar fuelling procedures (s 3.1 and s 4.1.1.1(d)). It also recognises manufacturer manuals as approved specifications for some fluids (s 3.1, Note 1).

• Fuel integrity: The Order requires checking ground fuel stocks for undissolved water prior to operations (s 3.3), and mandates straining or filtering of all fuel before it enters aircraft tanks (s 3.4). Notes identify methods (water‑detecting paste, paper) and warn about detection limits for turbine fuels (s 3.3 notes).

• Bonding and static control: Before fuel tank access, aircraft and fuelling equipment must be bonded and bonds must be maintained; loss of bond requires immediate cessation of transfer (ss 4.3.4-4.3.4A).

• Spatial separation rules: The Order sets minimum distances between fuel tank filling points or vent outlets and sealed buildings, other aircraft, exposed public areas and unsealed buildings, with different distances depending on aircraft maximum take‑off weight (s 4.1.1). For engine operation, separate minimum separation distances apply and turbine engines have additional rear‑arc exclusion zones tied to engine type and power condition (s 5.1.4 and table).

• Passenger safety when fuelling with passengers present: The Order makes general prohibition for avgas with passengers on board (s 4.2.1) and detailed conditional permissibility for underwing fuelling and non‑underwing exceptions, including announcements, seatbelt instructions, crew ratios, emergency light arming, and interior signage (s 4.2.2-4.2.5). It defines cabin crew member and passenger zone for these provisions (s 4.7).

• Equipment and vehicle standards near fuelling points: Appendix I sets maintenance and design expectations, including flame arrestors for carburettor intakes, protected electrical wiring, isolation switches on fuelling vehicles, insulation and sheathing requirements for cables, hermetically sealed fuses, and compliance to SAA wiring rules and Australian Standard 1425 where specified.

• Radar safety: Threshold of 25 kW nominal peak power for applicability (s 6.1). Exclusion zones of 37 metres during rotating operation and 60 metres while stationary (ss 6.2.1-6.2.2), with permitted reduction when an approved attenuating device is used (s 6.2.3). Radar must not be operated while the fitted aircraft is being refuelled or defuelled (s 6.2.5).

Several cross‑cutting concepts establish procedural obligations: signage and placarding (s 4.4.1), fire control equipment proximity and type (ss 4.4.4-4.4.6), immediate suspension and reporting where spills create fire hazard (s 4.5.1), and crew training and emergency preparedness (ss 4.2.2(c) and 5.2). The Order repeatedly links operational permissions to documented procedures in the operator’s operations manual or maintenance manual (for example s 4.1.1.1(d) and s 4.2.2(l)), making the manual the locus of procedural detail.

The Order also introduces graded technical tolerances and exceptions: for instance an approved beam attenuating device allows a 75 per cent reduction of radar exclusion distances (s 6.2.3), and the aircraft flight manual can provide the basis for CASA satisfaction that an auxiliary power unit may operate during fuelling (s 4.3.1 Note). This structure embeds administrative discretion and documented authorisations into the compliance architecture.

Finally, the Order is framed as applicable to "all Australian aircraft operating on aerodromes in Australian territory" and "as far as practicable , all Australian aircraft operating outside Australian territory" (s 2.1), with specific cross‑references to other CAOs that modify applicability (s 2.2). That phrase "as far as practicable" is not defined in the text and therefore introduces an element of fact‑sensitive application for aircraft outside Australian territory.

The Order names specific actors and, through its duties and technical requirements, imposes obligations on a wider set of parties involved in aviation operations. The named and implied affected parties are:

• Pilots in command: The Order repeatedly places immediate obligations on the pilot in command. They must not fly unless specified fluids meet CASA‑approved specifications (s 3.1). They must ensure engines are shut down during fuelling unless CASA is satisfied otherwise and that all fuel and oil tank caps are securely refitted after fuelling (ss 4.3.1 and 4.3.7). During spills or fire hazards the pilot in command, or in their absence the operator, must ensure removal of passengers and shutdown of equipment (s 4.5.3).

• Aircraft operators: The operator must ensure compliance across many areas, including not loading avgas with passengers on board (s 4.2.1), ensuring operations manuals set out responsibilities and procedures where fuelling with passengers may occur (s 4.2.2(l)), ensuring crew familiarity with nacelle fire extinguishing equipment (s 5.2), provision of fire extinguishers as specified (ss 4.4.4-4.4.6), and compliance with Appendix I for equipment under their control (Appendix I, para 1.2). Operators must also ensure that fuelling equipment is located to allow rapid movement of the aircraft if the equipment is not mobile (s 4.1.2).

• Ground servicing and fuelling personnel: The Order requires fuelling staff to check for undissolved water (s 3.3), filter or strain fuel (s 3.4), ensure bonding before removing caps (s 4.3.4), wear non‑sparking footwear and avoid carrying ignition sources (s 4.3.5), and use fire extinguishers and positioning as required (ss 4.4.4-4.4.6). They must refrain from maintenance or operating radar or certain electrical systems during fuelling (s 4.3.3).

• Cabin crew and flight crew: Where fuelling occurs with passengers under the precisely described conditions (s 4.2.2), cabin or flight crew members must be appointed to supervise passengers, maintain discipline and be prepared for immediate evacuation (s 4.2.2(c), (g)). Minimum crew‑to‑passenger ratios are specified: at least one crew member per 72 passengers or per passenger zone (s 4.2.2(e)) and one crew member at each exit for occupied passenger zones (s 4.2.2(f)). Crew must ensure aisles and exits remain unobstructed and supervise passengers (s 4.2.2(g)).

• Maintenance personnel and engineers: The Order restricts maintenance on electrical, electronic or radio systems except under kerosene fuel conditions with radar transmitter de‑activated (s 4.3.3). Maintenance manuals and aircraft maintenance manuals are called on to define sector areas for radar (s 6.2 Note), and Appendix I sets maintenance standards for vehicles and electrical systems working close to fuelling points.

• Airport operators and emergency services: The Order requires fuelling areas to be placarded 'No Smoking' and defines limits of fuelling areas (s 4.4.1). It requires notification of the Airport Fire Service when spills creating a fire hazard occur (s 4.5.1). Fire services and airport operators will therefore be involved in response and in ensuring that external areas remain clear during fuelling with passengers (s 4.2.2(h)).

• Equipment and vehicle owners/manufacturers: Appendix I contains design and maintenance requirements for vehicles and equipment used within 15 metres of fuel tank filling points, including requirements for flame arrestors, exhaust system designs, electrical insulation, battery ventilation and cable protection (Appendix I, paras 2.2.1-4.6). Owners and manufacturers are affected insofar as equipment must comply with the standards or obtain CASA approval where alternatives are proposed.

• Regulators (CASA): The Order explicitly assigns CASA the role of approving specifications, accepting manufacturer manuals as proxy approvals for some fluids (s 3.1 Note 1), and granting approvals for detailed hangar fuelling procedures (s 4.1.1.1(d)). CASA determines whether operation of an auxiliary power unit during fuelling is acceptable (s 4.3.1 Note).

• Passengers: The Order regulates passenger behaviour and risk exposure during fuelling: it forbids avgas loading with passengers on board (s 4.2.1), prohibits use of electrical equipment and smoking during certain fuelling with passengers (s 4.2.2(a)(iii)), and requires passengers to follow instructions and not fasten seatbelts during loading when fuelling with passengers is permitted (s 4.2.2(a)(ii)-(b)). It also creates evacuation procedures and crew supervision duties to protect passengers in the event of a problem (s 4.2.2(c), 4.5.3).

• Radar and avionics operators: Section 6 applies to any person in charge of radar equipment with nominal peak power in excess of 25 kW and requires spatial clearances and shielding for radar testing, maintenance and operation (ss 6.1-6.2.5). Those operating radar in maintenance settings must ensure beams do not scan specified objects within defined radii or, if stationary, meet larger distances (s 6.2.1-6.2.2).

Collectively, the Order shifts both procedural and capital responsibilities onto operators, fuel suppliers, ground equipment owners and flight crews. Those who own or control fuelling equipment and vehicles bear obligations under Appendix I to design, maintain and, in some cases, alter equipment to meet the technical requirements. CASA retains an approval role that can change the scope of allowed activity through approvals recorded in operations or maintenance manuals.

The Order is primarily a catalogue of duties. It specifies few discrete rights beyond conditional permissions to carry out certain operations when prescribed conditions are met.

Principal duties:

• Ensure fluid compliance: The pilot in command must ensure aviation fuel, engine lubricating oil, engine power augmentation fluid and hydraulic system fluid comply with CASA‑required or approved specifications and grades before flight (s 3.1). Manufacturer manuals may be treated as approved for augmentation and hydraulic fluids (s 3.1 Note 1). The pilot may assume that fluids delivered prior to their involvement comply, except those they delivered themselves (s 3.1 Note 2).

• Fuel quality checks and filtration: Ground fuel stocks must be checked for undissolved water before fuelling (s 3.3) using positive methods (notes), and fuel must be strained or filtered to remove free or suspended water and contaminants before entering tanks (s 3.4).

• Location and clearances during fuelling: Aircraft and ground fuelling equipment must be positioned so fuel tank filling points or vent outlets are outside specified radii of sealed buildings, other aircraft, exposed public areas and unsealed buildings; distances vary by type and weight (s 4.1.1). If fuelling equipment is not mobile, the aircraft must be positioned to allow rapid movement to safety and a means of ensuring rapid movement must be available (s 4.1.2).

• Hangar fuelling controls: Limited fuelling for maintenance in hangars is allowed only under specified conditions (no refuelling of gasoline or wide‑cut gasoline turbine fuel, no overwing fuelling, not in multi‑tenant hangars), and operators must obtain CASA approval for procedures documented in the maintenance manual, including maximum allowed volume (s 4.1.1.1).

• Passenger rules and crew responsibilities during fuelling with passengers: Avgas may not be loaded with passengers on board (s 4.2.1). Underwing fuelling with passengers is permitted only when fuel contains anti‑static additive (or meets ASTM D1655 and is loaded in the USA) and when a set of instructions, crew appointments, signage and emergency preparedness requirements are satisfied (s 4.2.2). For aircraft that cannot be underwing fuelled, refuelling with a passenger on board is only permitted for medical necessity with the cabin door open and loading equipment in position and compliance with the s 4.2.2 requirements (s 4.2.4).

• Engine shutdown, bonding and ignition source control: Engines, including APU, must be shut down for fuelling unless CASA is satisfied operation will not present a hazard and conditions are included in the operations manual (s 4.3.1). Before a fuel tank cap is removed, aircraft and fuelling equipment must be bonded; loss of bonding must stop fuel transfer until restored (s 4.3.4). Servicing personnel must wear non‑sparking footwear and not carry matches, lighters or similar items (s 4.3.5).

• Fire control and emergency response: Fuelling areas must be placarded 'No Smoking' with limits set at 15 metres or a sealed building (s 4.4.1). At least two approved fire extinguishers must be positioned within specified distances or carried on fuelling equipment, meeting type and capacity requirements or CASA approval (ss 4.4.4-4.4.6). Fuelling must be suspended and Airport Fire Service notified for spills likely to create a fire hazard (s 4.5.1). Fuelling must cease immediately where fuel vapour is detected inside the aircraft or where it is unsafe to continue (s 4.2.5).

• Starting and ground operation rules: Evacuation equipment for land aircraft or water transport for seaplanes must be available during engine start (ss 5.1.1-5.1.2). Aircraft engines must not be started if spill hazards exist within 15 metres (s 5.1.3). Minimum separation distances for engine start/operation are set, including turbine rear‑arc exclusion distances tied to engine type and power condition (s 5.1.4). Operators must ensure personnel starting engines are familiar with nacelle fire extinguishing equipment (s 5.2).

• Radar operation constraints: Any person in charge of radar equipment above 25 kW must ensure exclusion zones are clear before energising in rotating mode (37 metres) or when stationary (60 metres), and must not energise while aircraft is being refuelled or defuelled (ss 6.1-6.2.5). Approved attenuating devices may reduce distances by 75 per cent (s 6.2.3). Radar in hangars must be shielded if energised (s 6.2.4).

Rights or conditional permissions:

• Conditional operation of auxiliary power units: The Order permits APUs or engines to operate during fuelling where CASA is satisfied and a statement plus special conditions are in the operator’s operations manual (s 4.3.1; Note).

• Hangar fuelling for maintenance: Limited fuelling and defuelling in certain hangars is permitted but subject to specified conditions and CASA approval for procedures recorded in the maintenance manual (s 4.1.1.1).

• Fuelling with passengers in specified circumstances: The Order creates a conditional permission to load fuel while passengers are on board for underwing fuelling systems (s 4.2.2) and for aircraft that cannot be underwing fuelled for passengers who cannot leave due to medical condition (s 4.2.4), subject to enumerated safety and procedural requirements.

• Manufacturer and standards recognition: Manufacturer‑promulgated specifications for some fluids may be treated as CASA‑approved (s 3.1 Note 1), and compliance with Australian Standards or SAA Wiring Rules is required or recommended in Appendix I.

Duties are prescriptive and procedural rather than discretionary at the operator level; where discretion exists it is vested in CASA to approve or satisfy certain conditions. The Order does not itself articulate exemptions beyond the stated conditional permissions; instead it cross‑references other CAOs and CASA approvals. Rights to operate in ways otherwise restricted are kept contingent on meeting detailed procedural, documentation and equipment conditions.

The text of Civil Aviation Order 20.9 itself does not contain express penalty provisions or a detailed enforcement mechanism. The Order is an instrument “made under subregulation 235(7) of the Civil Aviation Regulations 1988” (header), and that placement indicates the Order functions within the regulatory architecture administered by the Civil Aviation Safety Authority (CASA). That context implies enforcement and sanctioning powers lie in the Civil Aviation Regulations and the administrative powers of CASA rather than in the Order text; however, the Order compilation provided does not set out the Civil Aviation Regulations, enforcement procedures, administrative penalties, or criminal sanctions.

What the Order does specify that is relevant to enforcement and compliance oversight:

• CASA approvals and satisfactions: The Order repeatedly makes compliance conditional on CASA approval or satisfaction (for example s 3.1, s 4.1.1.1(d), s 4.3.1 Note). Those approval mechanisms create recordable permissions which CASA can grant or withhold and which could be reviewed in administrative processes.

• Documented procedures in manuals: The Order requires operators to include procedures and responsibilities in the operator’s operations manual and maintenance manual (for example s 4.2.2(l) and s 4.1.1.1(d)). Requiring documented procedures creates an audit trail that regulators can inspect and enforce.

• Objective technical requirements and equipment standards: The Order sets measurable technical requirements , distances, extinguisher types, bonding, filtration, cable insulation specifications , that create objective compliance criteria for inspectors. Appendix I refers to Australian Standards and SAA Wiring Rules, which provide external standards enforcement reference points.

• Cross‑references to other Orders/sections: Section 2.2 excludes aircraft being refuelled in accordance with CAO 20.10 and CAO 20.10.1 except where those sections specify otherwise, indicating that enforcement and applicable obligations may vary by activity and may be governed by other CAOs. Enforcement therefore may involve interpreting overlapping instruments.

Because the Order does not enumerate fines, licence suspensions, or other sanctions, practitioners must look to the Civil Aviation Regulations 1988 and CASA’s regulatory enforcement policies for the concrete penalty framework and the processes applying where the Order’s duties are breached. The header citation to subregulation 235(7) indicates the Order is made under the Regulations, and enforcement consequences for non‑compliance would typically be grounded in the statutory/regulatory provisions establishing CASA’s powers, offences and penalties.

Implementation and compliance oversight risks:

• Administrative discretion: CASA’s approvals (for hangar fuelling procedures, fluid specifications, allowances for APUs) create potential variability between operators and airports and place importance on CASA’s administrative processes and timelines.

• Auditability: The Order’s reliance on operations and maintenance manuals as the primary repository of procedural approvals and constraints (s 4.2.2(l); s 4.1.1.1(d)) makes the quality and accessibility of those manuals important for enforcement actions and audits.

• Multiple overlapping standards: Appendix I requires compliance with SAA Wiring Rules, Australian Standard 1425 and other standards, which may require cross‑discipline inspectors or external technical verification. Where equipment is acceptable "on application to CASA" (s 4.4.6, Appendix I), enforcement may require review of CASA approvals or variations.

• Absence of penalties in text: Because the Order itself gives no penalties, enforcement action will depend on the statutory regime. Practitioners should therefore identify the applicable offences and administrative remedies in the Civil Aviation Regulations 1988 and CASA instruments when advising clients on consequences of non‑compliance.

In short, enforcement is not specified inside CAO 20.9; compliance and enforcement will be effected within the broader CASA/Regulations framework, and the Order creates objective standards, CASA approval gateways and documentary duties that enable enforcement through that framework rather than by setting out sanctions itself.

The Order is expressly made under subregulation 235(7) of the Civil Aviation Regulations 1988 and therefore forms part of the Civil Aviation Orders framework governed by those Regulations and administered by CASA (header). The Order also cross‑references other Civil Aviation Orders and external technical standards, creating a networked regulatory regime.

Specific cross‑references and interactions in the text:

• Cross‑references to CAO 20.10 and CAO 20.10.1: Section 2.2 excludes aircraft that are being refuelled in accordance with section 20.10 (except as noted) and section 20.10.1 (except as noted). Those cross‑references mean that certain refuelling activities may be governed by different CAOs and that practitioners must check the text of CAO 20.10 and 20.10.1 for exception rules, scope, or additional requirements. The Order as compiled does not include those CAOs, so full application requires consulting those instruments.

• CASA approvals and manufacturer documents: Section 3.1 recognises CASA‑required or approved specifications and allows manufacturer manuals to be treated as approved for engine power augmentation fluid and hydraulic fluid (s 3.1 Note 1). That creates an interaction between CASA administrative approvals and private manufacturer documentation.

• Australian standards and SAA Wiring Rules: Appendix I requires certain equipment to comply with SAA Wiring Rules and Australian Standard 1425 (Appendix I, paras 2.2.1 and 4.1). Those references import technical standards developed outside the Civil Aviation Orders and create technical compliance obligations that may be enforced through CASA audits or through referenced material in other regulatory instruments.

• Relationship to airport and fire safety regimes: The Order requires notification of Airport Fire Service and the positioning of fire extinguishers (ss 4.5.1; 4.4.4-4.4.6). Those provisions will intersect with local airport operating procedures, fire code obligations and, possibly, state or territory emergency service rules. The Order does not displace those regimes but overlays aviation‑specific distances and requirements.

• Interaction with aircraft manuals and maintenance documentation: Several provisions make operator permissions contingent on material recorded in operations or maintenance manuals (s 4.1.1.1(d); s 4.2.2(l); s 4.3.1 Note). This ties compliance to the content of those documents, which themselves may be required under other Civil Aviation Orders or Regulations.

• International standards: Section 4.2.2 includes a condition that underwing fuelling with passengers is permissible where fuel is "loaded in the USA and meets the ASTM D 1655 standard" (s 4.2.2). This explicitly incorporates an international technical standard as a basis for permissibility in specified circumstances, creating a cross‑jurisdictional point of reference.

• Overlap with occupational health and safety law: Many of the Order’s safety controls (no smoking signs, placement of extinguishers, protection of pedestrians from trailing cables) will overlap with workplace health and safety obligations under state and territory laws. The Order’s requirements do not replace those laws; operators need to satisfy both aviation requirements and applicable OH&S obligations.

• Enforcement and offences under Civil Aviation Regulations 1988: Because the Order was made under the Civil Aviation Regulations, contravention of an applicable Civil Aviation Order can be relevant to enforcement action under the Regulations. The Order’s text does not specify offences, but regulatory enforcement would be tied to the powers and offences set out in the Regulations and CASA’s compliance framework.

• Technical approvals and alternative equipment: The Order provides that some fire extinguisher types and other equipment may be approved by CASA on application (s 4.4.6, Appendix I). This enables a process by which equipment complying with alternative standards can be accepted, thereby creating an administrative interface between operators’ choices and CASA’s approval processes.

Practitioners should therefore treat CAO 20.9 as one node in a network of aviation instruments, technical standards and local laws. Advising operators or pilots requires cross‑checking CAO 20.9 against CAO 20.10/20.10.1, the Civil Aviation Regulations 1988 for enforcement provisions, applicable CASA manuals or approvals, Australian Standards and SAA Wiring Rules, and local airport and OH&S regimes.

The compilation includes a table of orders and a table of amendments that identify instruments and dates affecting CAO 20.9. The instrument was originally notified as CAO 2004 No. R10 on 8 December 2004 (see header and Notes Table) and has been subsequently amended. The compilation prepared on 11 November 2011 incorporates amendments up to CAO 20.9 Amendment Instrument 2011 (No. 2).

The Table of Orders records:

• CAO 2004 No. R10 , notified 8 December 2004, commencement 8 December 2004 (s 2).
• CAO 20.9 2005 No. 1 , FRLI 6 January 2006, commencement 7 January 2006 (s 2).
• CAO 20.9 2010 No. 1 , FRLI 2 March 2010, commencement 3 March 2010 (s 2).
• CAO 20.9 2011 No. 1 , FRLI 15 July 2011, commencement 16 July 2011 (s 2).
• CAO 20.9 2011 No. 2 , FRLI 9 November 2011, commencement 10 November 2011 (s 2).

The Table of Amendments indicates specific provisions affected and how they were changed:

• Section 20.9 as a whole was repealed and substituted by the 2004 instrument (rs. 2004 No. R10).
• Subsection 3 was substituted by CAO 20.9 2011 No. 2 (shown as "subs. 3 , am. CAO 20.9 2011 No. 2").
• Subsection 4 was amended by CAO 20.9 2005 No. 1, CAO 20.9 2010 No. 1 and CAO 20.9 2011 No. 1 (shown as "subs. 4 , am. CAO 20.9 2005 No. 1; CAO 20.9 2010 No. 1; CAO 20.9 2011 No. 1").

The compilation’s Notes section and tabular extract provide the formal amendment citations and commencement dates. The text also indicates specific insertions and substitutions made over time (for example the insertion of definitions and the addition of Appendix I requirements reflected in the current text). The table of amendments indicates a programme of iterative amendment to the CAO between 2005 and 2011, including most recently in 2011 No. 2 which replaced subsection 3.

The instrument itself does not provide a policy memorandum or explanatory notes beyond in‑text Notes that explain technical rationale (for example, the need for positive water detection methods (s 3.3 Notes) and recommendations on diesel engines for fuelling vehicles in Appendix I para 2). To trace policy intent beyond these in‑text notes, practitioners should consult the separate instrument files and Gazette notices referenced in the Table of Orders and the legislative history on FRLI.

Because the compilation covers amendments up to November 2011, any changes after that date are not reflected here. Users must check the Federal Register of Legislation or CASA’s current CAO compilations to identify subsequent amendments or consolidations.

The compilation of CAO 20.9 provided contains no referenced judicial decisions or litigation history. The document lists statutory and administrative amendment instruments and internal explanatory notes but does not cite any cases or court decisions. The Order itself does not reference judicial interpretation or administrative review outcomes.

Accordingly, there is no litigation history recorded within the provided text. Where a practitioner requires information about any litigation that has addressed the interpretation or enforcement of CAO 20.9, they must undertake a jurisdictional case law search in Australian federal and state courts, administrative tribunals and the Administrative Appeals Tribunal, and review decisions of CASA where available. The Order’s reliance on CASA approval processes and cross‑references to the Civil Aviation Regulations suggests that enforcement disputes would typically involve administrative law grounds (procedural fairness, reasonableness of approvals) or regulatory offence proceedings under the Regulations, but the compilation contains no direct evidence of such cases.

Where risk allocation or disputed operational interpretations are anticipated,such as the meaning of "as far as practicable" (s 2.1(b)), the sufficiency of an operator’s procedures in their operations or maintenance manual, or the acceptability of alternative equipment under Appendix I,these issues are plausibly fertile ground for administrative review or litigation. However, such an assertion is conditional and must be verified against actual reported decisions, none of which are contained in this compilation.

Practitioners should therefore not rely on the CAO 20.9 compilation as evidence of any judicial construction; to advise on settled legal interpretation they should search case law databases and CASA decisions for any matters where CAO 20.9 was in issue.

This Order contains multiple detail‑rich provisions with scope for practical missteps. Key "gotchas",areas where compliance may be unintentionally missed or where interpretation can materially affect operations,are:

• Applicability outside Australian territory: Section 2.1(b) applies the Order to Australian aircraft operating outside Australian territory "as far as practicable." That phrase is fact‑sensitive and not defined in the instrument. Operators conducting international operations must determine, on a flight‑by‑flight basis, whether fuller compliance is practicable given host state regulatory regimes. Reliance on this clause without documenting the practicability assessment in manuals or records risks non‑compliance in inspections or enforcement interactions (s 2.1(b)).

• Cross‑referenced CAOs: Section 2.2 carves out aircraft being refuelled in accordance with CAO 20.10 and CAO 20.10.1, except where those sections narrow the carve‑out. Failure to consult those other CAOs may lead an operator to apply the wrong set of rules; the compilation does not include those texts, so practitioners must check them to determine which provisions apply to particular fuelling activities (s 2.2).

• Manufacturer‑approved specifications and CASA approval: Section 3.1 permits manufacturer manuals to be treated as CASA‑approved for some fluids (Note 1), but other fluids and grades require CASA approval. Operators who rely on manufacturer specification must ensure the manual is current and that CASA acceptance is documented where the Order contemplates CASA approval (s 3.1). The distinction between fluids the pilot may assume comply and those required to be CASA‑approved can be a compliance trap if suppliers’ specifications change.

• Precision of clearance distances and measurement reference points: Multiple distance measures (metres and feet interchange) and different measurement reference points (fuel tank filling points or vent outlets) can cause misinterpretation. For example, positioning around sealed vs unsealed buildings has different distances for heavier vs lighter aircraft (s 4.1.1(d)-(e)). Engine rear‑arc distances depend on engine type and power condition with a 15‑degree arc either side of the exhaust axis (s 5.1.4). Operators must have clear procedures and diagrams in manuals showing measurement points; failing to do so may result in inconsistent practice.

• Bonding and static dissipation timing: Section 4.3.4 requires bonding before opening fuel caps and immediate cessation if bonding is lost. The Note warns to allow dissipation of static before reconnecting bonding wire. Practical missteps include reconnecting bonding too early or not confirming adequate touch‑down for static dissipation, which could produce hazards.

• Fuelling with passengers , complex conditional regime: The Order creates several conditions for underwing fuelling with passengers (s 4.2.2) and for non‑underwing exceptions for medically immobile passengers (s 4.2.4). These conditions require pre‑loading announcements, seatbelt instructions, disarming/arming of lights and signs, crew ratios, and external area clearance. Missing any element (for example failing to ensure "fasten seat belt" signs are turned off and "no smoking" signs turned on, s 4.2.2(d)) can render the conditional permission inapplicable and expose the operator to a breach.

• Definitions embedded in notes and other CAOs: Some operative concepts (for example "underwing fuelling system" definition appears in a Note beneath s 4.2.2) are not in a separate definitions section. Also, the passenger zone definition is in s 4.7. Operators must capture those embedded definitions when drafting manuals and checklists.

• Appendix I references to external technical standards: Appendix I requires compliance with SAA Wiring Rules and Australian Standard 1425 and prescribes specialised equipment protection (Appendix I, paras 4.1, 2.2.1). Operators who lack familiarity with those documents may design non‑compliant installations inadvertently. The appendix also permits alternative equipment by CASA approval, which requires procedural interaction that may take time.

• Radar beam attenuation and static antenna testing: Radar exclusion distances can be reduced by 75 per cent if an approved beam attenuating device is used (s 6.2.3). If operators assume attenuation without documented CASA approval, non‑compliance arises. Also, energising radar while aircraft is in a hangar is allowed only with suitable microwave energy absorbing shields (s 6.2.4), a requirement that can be overlooked during maintenance.

• Fire extinguisher types and capacities: The Order prescribes combinations and capacities (ss 4.4.6 and notes). In particular, the acceptable combinations and the possibility of CASA‑approved alternatives on application mean that defaulting to a non‑approved set could fail an inspection. Also, if extinguishers are carried on fuelling equipment the mounting and placement requirements (quick release brackets, availability from either side, location away from vehicle tanks) must be observed (s 4.4.5).

• Disjunction between operational practice and operations/maintenance manuals: Several permissions and allowed exceptions are conditional on written procedures in the operator’s operations manual or maintenance manual (ss 4.1.1.1(d), 4.2.2(l), 4.3.1 Note). Operators who have not updated manuals to reflect current practice may be non‑compliant even when physical safety controls are in place.

• No explicit penalties in the Order: The lack of expressed penalties within CAO 20.9 can create a false expectation that breaches are not sanctionable. Enforcement is situated in the wider CASA regulatory regime; failing to consult the Civil Aviation Regulations for offence provisions is a practical trap.

These gotchas are not exhaustive but highlight areas where ambiguity, cross‑referencing, operational complexity or technical specification can create compliance failure risk. Operators should translate each prescriptive requirement into checklists, diagrams and manual entries with documentary evidence of CASA approvals where required.

Compliance requires a layered approach: technical conformity, documented procedures, staff training, record‑keeping and coordination with CASA and airport services. Below is a practical compliance checklist mapped to the Order’s provisions, suitable for incorporation into operations and maintenance manuals.

1. Document scope and applicability

   • Record the CAO 20.9 obligations in the operator’s operations manual and maintenance manual where the Order requires documentary procedures (s 4.2.2(l); s 4.1.1.1(d); s 4.3.1 Note).
   • For international flights, document the practicability assessment for applying the Order outside Australian territory (s 2.1(b)).

2. Fuel and fluid compliance (s 3.1; s 3.3-3.4)

   • Maintain records of CASA‑approved fluid specifications and, where manufacturer manuals are relied on for augmentation/hydraulic fluids, retain copies and dates of manual revisions (s 3.1, Note 1).
   • Implement mandatory pre‑fuelling checks of ground fuel stocks for undissolved water using positive detection methods (water‑detecting paste or paper) and document checks (s 3.3 and Notes).
   • Ensure fuel is strained/filtered before entering tanks; specify filter type and maintenance intervals and retain filter change logs (s 3.4).
   • Record any assumptions about fuels already in aircraft, and procedures for fluids the pilot has caused to be delivered (s 3.1 Note 2).

3. Fuelling location, equipment placement and hangar fuelling (ss 4.1.1; 4.1.1.1; 4.1.2)

   • Produce apron diagrams identifying fuel tank filling points and vent outlets, marking distances to sealed and unsealed buildings, other aircraft and exposed public areas in accordance with the distance table (s 4.1.1).
   • For non‑mobile fuelling equipment, document and test rapid aircraft movement protocols (s 4.1.2).
   • If hangar fuelling for maintenance is required, prepare detailed procedures, define maximum volume, and apply to CASA for approval; include finalised, CASA‑approved procedures in the maintenance manual (s 4.1.1.1).

4. Fuelling with passengers (ss 4.2.1-4.2.5)

   • Prohibit avgas loading with passengers on board (s 4.2.1).
   • For underwing fuelling with passengers, verify fuel additive requirements (anti‑static additive or ASTM D1655 when loaded in USA) before approving crew procedures (s 4.2.2).
   • Draft scripts and signage for announcements to passengers, including seatbelt and no‑smoking instructions, and ensure systems to switch "fasten seat belt" and "no smoking" signs as required and to arm emergency lighting (s 4.2.2(a)-(d)).
   • Establish crew assignment rules (minimum ratios and positions at exits) and immediate evacuation preparedness, and include them in pre‑fuelling briefings and checklists (s 4.2.2(c), (e), (f), (g)).
   • For exceptions involving medically immobile passengers, document medical evidence required and ensure cabin door and passenger equipment positioning meet the listed criteria (s 4.2.4).
   • Incorporate an immediate stop rule for fuel loading if vapour is detected or safety is compromised (s 4.2.5).

5. Engine and APU operation during fuelling (s 4.3.1)

   • Default to shutting down all engines/APUs during fuelling.
   • Where continued operation might be required, obtain CASA satisfaction/approval and record any special conditions and statements in the operator’s operations manual per the Order (s 4.3.1).

6. Bonding and ignition control (ss 4.3.4, 4.3.4A, 4.3.5)

   • Implement bonding procedures with clear step‑by‑step instructions, pre‑fuelling bonding checks, and stop procedures if the bond is lost. Train personnel in static dissipation timing before reconnection (ss 4.3.4 and Note).
   • Require non‑sparking footwear for servicing personnel and enforce a no‑matches/lighters policy (s 4.3.5).

7. Fire safety equipment and placarding (ss 4.4.1-4.4.6)

   • Placard fuelling areas 'No Smoking' with boundaries identified as sealed building or at least 15 metres (s 4.4.1).
   • Provide at least two approved fire extinguishers within the specified distances or on fuelling equipment, equipped and mounted as required. Record types, capacities and maintenance logs (ss 4.4.4-4.4.6).
   • If using alternative extinguisher types or capacities, seek CASA approval and retain approval documentation (s 4.4.6).

8. Spill response and Airport Fire Service coordination (ss 4.5.1-4.5.3)

   • Create and train staff in spill and fire hazard response procedures requiring suspension of fuelling operations, notification of Airport Fire Service, passenger removal, shutdown of mobile power units and suspension of maintenance until hazard removal (ss 4.5.1-4.5.3).
   • Maintain incident logs and reporting records for spill events.

9. Engine start procedures and separation measures (ss 5.1.1-5.1.4; 5.2-5.3)

   • Ensure rapid evacuation equipment is available during engine start (s 5.1.1-5.1.2).
   • Implement start‑up exclusion zones that match the Order’s distances and turbine engine rear‑arc specifications, and include diagrams in operations manual (s 5.1.4).
   • Train all personnel who may start engines on nacelle fire extinguishing equipment and maintain evidence of training (s 5.2).
   • Control passenger embarkation/disembarkation and freight loading relative to engine operation and include protective instructions for passengers and loading personnel (s 5.3).

10. Radar testing and maintenance controls (ss 6.1-6.2.5)

    • Identify radar installations with nominal peak power output above 25 kW and mark corresponding exclusion zones of 37 metres for rotating antennas and 60 metres for stationary beams; place checks on operation while aircraft are being refuelled (ss 6.1-6.2.2; 6.2.5).
    • If attenuation is to be used reducing distances by 75 per cent, obtain CASA approval for the beam attenuating device and document the approval (s 6.2.3).
    • Use microwave energy absorbing shields if radar is to be energized in a hangar and document shielding specifications (s 6.2.4).

11. Equipment and vehicle compliance (Appendix I)

    • Ensure vehicles and plant within 15 metres satisfy design and maintenance expectations: flame arrestors for carburettor intakes, secure fuel tank mounting, engine exhaust separation, mechanical protection of wiring, and battery coverings (Appendix I, paras 2.1-2.2.2).
    • Fit fuelling vehicles with isolation switches, mechanically protected cab rear wiring, insulating boots on exposed terminals, and fitting of generators/motors/switches to prevent hazardous sparks (Appendix I, para 3).
    • For fixed or portable electrical equipment, implement SAA Wiring Rules Class 1 Division 2 compliance (or corresponding label controls) and for below ground installations meet Class 1 Division 1 standards (Appendix I, paras 4.1-4.2).
    • Ensure cable insulation is 250‑volt grade and fuel/oil resistant sheath, and protect trailing cables with troughing or barricades (Appendix I, para 4.3).
    • Maintain hermetically sealed fuses, covered batteries with ventilation, secured connections and protective measures against breakdown (Appendix I, paras 4.4-4.6).

12. Recordkeeping, audits and CASA interactions

    • Keep versions of the operator’s operations manual and maintenance manual reflecting approved procedures required by the Order, and retain CASA approval letters/statements for any deviations or special conditions (ss 4.1.1.1(d); 4.2.2(l); 4.3.1 Note).
    • Maintain inspection logs for fuel checks, filtration records, bonding checks, fire extinguisher maintenance, cable and electrical equipment inspections and training attendance records.
    • When proposing alternative equipment, seek CASA approval in writing and retain the approval documentation.

13. Training and briefings

    • Train fuelling personnel on water detection methods, filtration, bonding, safe footwear requirements and emergency procedures (s 3.3; s 3.4; s 4.3.4; s 4.3.5).
    • Train cabin and flight crew in responsibilities when fuelling with passengers per the Order’s requirements and run regular evacuation drills reflecting those contingencies (s 4.2.2(c), (g)).
    • Ensure engineering staff understand radar exclusion zones, shielding requirements and that radar must not be operated in refuelled aircraft (s 6.2.1-6.2.5).

14. Internal compliance reviews and legal checks

    • Conduct periodic compliance audits against CAO 20.9 checklist items and cross‑check against CAO 20.10/20.10.1 where the Order defers application (s 2.2).
    • Coordinate compliance with airport fire services and local OH&S obligations to cover overlapping responsibilities (ss 4.5.1; 4.4.1).

15. Incident and non‑conformance handling

    • Maintain immediate stop protocols where vapour is detected or other unsafe conditions emerge and document investigation, remedial action and notification to CASA when required (ss 4.2.5; 4.5.1-4.5.3).
    • Preserve evidence and records in case of regulatory inquiry.

By mapping each technical requirement to a documented procedure, training programme, equipment specification and inspection record, operators create a defensible compliance posture. When seeking CASA approvals or alternative equipment acceptance, retain the written approvals and make them readily available for inspectors. Finally, because the Order situates some permissions on CASA satisfaction, build formal processes for application, approval tracking and manual updating to ensure field practice matches authorised conditions.