Prevention of Future Deaths reports · 2025

Eric Swaffer, Izabela Lechowicz, Khun Vichai Srivaddhanaprabha, Nusara Suknamai and Kaveporn Punpare

Regulation 28 report to prevent future deaths, reference 2025-0266, written 30 May 2025. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report30 May 2025
Reference2025-0266
DeceasedEric Swaffer, Izabela Lechowicz, Khun Vichai Srivaddhanaprabha, Nusara Suknamai and Kaveporn Punpare
CoronerCatherine Mason
Coroner areaLeicester City and South Leicestershire
CategoryAccident at Work and Health and Safety related deaths · Other related deaths
Sourcejudiciary.uk record · original PDF
Responses published2

The report

Text extracted from the PDF text layer. Reproduced verbatim, including the scan's own layout.

HM Senior Coroner for Leicester City & South Leicestershire

INQUESTS INTO THE DEATHS ARISING FROM THE HELICOPTER CRASH

AT KING POWER STADIUM ON 27 OCTOBER 2018

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS

THIS REPORT IS BEING SENT TO:

1. European Union Aviation Safety Authority (EASA)

Postfach 10 12 53
50452 Cologne
Germany
(By email to:

2. The Civil Aviation Authority (The CAA)

Aviation House
Beehive Ringroad
Crawley
West Sussex
RH6 0YR
(By email to:

1

CORONER

)

)

I am Professor Catherine Mason, Senior Coroner for the coroner area of
Leicester City and South Leicestershire.

2

CORONER’S LEGAL POWERS

I make this report under:

(a) Paragraph 7 of Schedule 5 to the Coroners and Justice Act 2009

(https://www.legislation.gov.uk/ukpga/2009/25/schedule/5); and

(b) Regulations 28 and 29 of the Coroners (Investigations) Regulations 2013

(https://www.legislation.gov.uk/uksi/2013/1629/part/7/made).

3

INVESTIGATION AND INQUESTS

1

 On 6 November 2018, I commenced an investigation into the deaths of the five
people who lost
their lives in the helicopter crash at King Power Stadium,
Leicester, on 27 October 2018. The names of the five people were Eric Swaffer,
Izabela Lechowicz, Khun Vichai Srivaddhanaprabha, Nusara Suknamai and
Kaveporn Punpare.

The investigation concluded at the end of an inquests hearing on 28 January
2025. The conclusions at the end of the hearing were in summary as follows:

(a) The medical cause of death for each of the five people other than Izabela
Lechowicz was: 1a. Inhalation of the products of combustion, while the
medical cause of death for Ms Lechowicz was: 1a. Head and chest
injuries.

(b) The jury returned a short-form conclusion of death by accident for each
the

of
those who died, supplemented with a narrative setting out
circumstances of death (as set out in the next section of this report).

4

CIRCUMSTANCES OF THE DEATHS

The jury returned a supplementary narrative as to the circumstances of the
deaths, as follows:

“On the 27th October 2018, an Agusta Westland 169 helicopter, registration G-
It was piloted by Eric
VSKP, departed the King Power stadium in Leicester.
Swaffer
Vichai
passengers
Srivaddhanaprabha, Nusara Suknamai and Kaveporn Punpare. The destination
was Stansted Airport in the UK and the helicopter departed at 8.37pm British
Summer Time.

Lechowicz,

carrying

Izabela

and

After the helicopter reached the appropriate take-off decision point, the pilot
initiated a right turn. The helicopter spun out of control and crash landed at
8.38pm British Summer Time in the car park of
the King Power Stadium,
Leicester.

The helicopter hit a 0.5 metre high concrete step, rupturing the fuel tank, and
came to rest on its left side with no means of escape.
Izabela Lechowicz
sustained head and chest injuries on impact, which proved fatal. Leaking fuel
ignited, resulting in rapid spread of
fire. Vichai Srivaddhanaprabha, Eric
Swaffer, Nusara Suknamai and Kaveporn Punpare died due to inhalation of the
products of combustion.

The subsequent AAIB [Air Accidents Investigation Branch]
investigation
concluded that due to likely rolling contact fatigue, the tail rotor duplex bearing
seized, commencing a sequence of events leading to the crash of the helicopter.
This included rotation and detachment of the actuator control shaft, loss of yaw
control and uncontrollable spinning.
the tail rotor control system
became uncontrollable.

In effect,

It
The helicopter had all appropriate airworthiness and maintenance certificates.
was found that the pilot, Eric Swaffer, took all appropriate and available options
to him, to try and regain control of the helicopter.”

5

CORONER’S CONCERNS

During the course of the inquests, the evidence revealed matters giving rise to

2

 concerns.
action is taken.

In my opinion there is a risk that future deaths could occur unless
In the circumstances it is my statutory duty to report to you.

The matters of concern set out below all relate to the systems and procedures
for design and safety supervision of aircraft, specifically helicopters. They are
founded upon specialist
technical evidence given to the court during the
inquests. They take full account of action taken by EASA to date of which the
court is aware.

I should stress at the outset that the matters of concern set out below remain
valid irrespective of whether the AAIB’s causal explanation of the accident is
correct. Each one is based on a safety concern which exists even if the points
raised by EASA in response to that causal explanation have merit.

It should also be stressed that none of these matters of concern should be
interpreted as levelling implicit criticism at
the aircraft or component
manufacturers involved in this case. They are all concerned with achieving
safety improvements for the future.

Given the potentially catastrophic consequences of
failure of an individual
component or system in a helicopter, I hope that this report will be considered
carefully.

The MATTERS OF CONCERN are as follows:

(1) Provision of system and flight-testing data by aircraft manufacturers to

suppliers

In the inquests, the AAIB investigation team explained that they had
recommended that EASA amend Certification Specification 29.602 to
require type design manufacturers to provide the results of all relevant
system and flight testing to any supplier who retains the sole expertise to
assess the performance and reliability of components identified as critical
parts within a specific system application, to verify that such components
can safely meet
to the
certification
This was AAIB safety
overall
of
recommendation SR-2023-018.

the in-serve operational demands, prior

system.

the

As
(AAIB Principal Inspector) explained in his evidence, in this
case the bearing manufacturer (SKF Aerospace) was the only party
which could fully assess the contact pressures that loads experienced
tests generated on the duplex bearing which ultimately
during flight
it would have been a desirable
failed. He further explained that
improvement
the aircraft
to the design and certification process if
manufacturer had been required to provide system and flight-testing data
it could have used its unique
to the bearing manufacturer, so that
expertise to identify risks arising from in-service use.

explained that EASA had responded to this recommendation
the relevant regulations required the
by saying that another part of
aircraft type certificate holder to be responsible for demonstration of
for showing that critical parts and systems met
compliance (i.e.
this was an inadequate
performance requirements). He said that
the safety
response, because it did not meet
recommendation by introducing the specific improvement proposed.

the intent of

3

 of SKF gave evidence in relation to this safety
recommendation. He said that the data his company would receive from
manufacturers if the recommendation were implemented would be useful
to SKF. He said that his company would not find it difficult to manage
being provided with data as required. He noted that data of this kind had
been made available in relation to the duplex bearing as a result of the
AAIB investigation.

In these circumstances, I am concerned by EASA’s rejection of the AAIB
safety recommendation, which would appear to propose a meaningful
improvement to requirements for aircraft design work.

(2) Requirements for Certification Specification to address rolling contact

fatigue failure

In the inquests, the AAIB investigation team explained that they had
recommended that EASA introduce further requirements to Certification
Specification 29 so as specifically to address premature rolling contact
fatigue failure as a failure mechanism across the full bearing operating
spectrum and service life of bearings used in safety-critical applications.
This was AAIB safety recommendation SR-2023-019.

explained in evidence that this safety recommendation was not
prescriptive.
It asked EASA to propose requirements which would
address risks of premature rolling contact fatigue in bearings, the form of
failure which the AAIB concluded had caused the catastrophic accident
in this case.

As
explained, EASA is undertaking work which looks at the
fatigue tolerance of principal structural elements and at the possibility of
changing acceptable means of compliance (AMC) for those items. As
part of this work, EASA is considering adding clarification and detail
which might meet the AAIB recommendation. This reflects the position
stated by EASA in its letter of 6 February 2024.

I am concerned that an issue raised by the AAIB to the effect that CS-29
and/or AMC may be improved to address risks of rolling contact fatigue
failure in critical part bearings has not been addressed by EASA by a
time over 18 months after the AAIB report on this crash was issued.

(3) Airworthiness status and control of life limits for non-structural critical

parts of aircraft designs already in service

In the inquests, the AAIB investigation team explained that they had
recommended that EASA should define the airworthiness status of life
limits on non-structural critical parts and how they should be controlled in
service. They said that they had recommended this in relation to aircraft
designs not yet in service (safety recommendation SR-2023-020) and in
relation to aircraft designs already in service (safety recommendation
SR-2023-021).

in his evidence pointed out that this recommendation did not
raise an issue of causal relevance to this particular accident, but that it
was nevertheless important to ensure greater clarity as regards the life
limits of non-structural critical parts.

4

 He said that new AMC introduced by Amendment 11 of Certification
Specification 29 had adequately addressed the recommendation in
relation to aircraft designs to be put into service in future, but that EASA
had decided not to make any changes which would secure the requisite
additional clarity in relation to designs already in service. As he put it
“those aircraft already in service will not benefit from the Amendment 11
changes to life control.”

In these circumstances, I am concerned that EASA has not implemented
the recommendation in relation to designs already in service. Although
said that EASA had explained that it considered that issues
with non-structural critical parts would be picked up as part of continued
airworthiness review, that does not strike me as a response which meets
the recommendation.

(4) Comprehensive programme for assessment of critical parts after removal

from service

In the inquests, the AAIB investigation team explained that they had
recommended that EASA amend CS 29.602 to require aircraft
manufacturers to implement a comprehensive programme for assessing
critical parts after removal from service. AAIB safety recommendation
SR-2023-022 addressed this topic for aircraft yet to be put into service,
while safety recommendation SR-2023-023 addressed the topic for
designs already in service.

As
explained this recommendation, it was “for EASA to require
a closed-loop system for critical components removed from helicopters
so that anything that is removed that is classified as a critical part has
to ensure
some form of… assessment programme carried out on it
that… it is progressing throughout its service life in the manner that was
expected at the design stage using the design assumptions.” He told the
court that such a system would have meant that, when duplex bearings
were removed from the AW-169 helicopter at the end of their service life,
at least a sample would have been reviewed by Leonardo and/or SKF to
verify design assumptions.

responded positively

I understand it, EASA has

to the
As
recommendation as regarding aircraft designs yet to be put into service.
It has published a notice of proposed amendment to CS 29 with a view to
implementing a Continued Integrity Verification Programme (CIVP). This
work is still ongoing. However, EASA has indicated to the AAIB that it
does not intend to make any regulatory change for in-service aircraft,
because existing procedures are sufficient.

to benefit

told the court that this response from EASA did not allow in-
service helicopters
He
acknowledged that there were some existing requirements which could
identify adverse trends or deficiencies in relation to critical parts (such as
the duplex bearing which failed in this case) but he stressed that they
were not prescriptive enough, given the safety issues underlying the
recommendations.

from the proposed CIVP.

the safety
recommendation with retrospective effect which the AAIB had made, and
which EASA was resisting, “would be very beneficial” (although he

of SKF told the court

that

5

 commented that his company was already acting in accordance with the
recommendation at least for some components).

I am concerned that EASA does not intend making changes which would
from the proposed new CIVP
allow in-service helicopters to benefit
requirements.

(5) Guidance and minimum standards for the calculation of design load

spectrums for non-structural critical parts

In the inquests, the AAIB investigation team told the court that they had
recommended that EASA amend CS 29.602 so as to provide guidance
and set minimum standards for calculating design load spectrums for
non-structural critical parts (like the duplex bearing which failed in this
accident). Under this recommendation, the standards would have to
include highest individual operating loads and combination of dynamic
operating loads, as well as the longest duration of exposure for such
loads that could be experienced in operation.
This was safety
recommendation SR-2023-024.

it,

put

this recommendation represented an attempt

to
As
ensure that the design process took into account what the AAIB had
learned from this investigation.
He acknowledged that major
manufacturers would have procedures for considering design load
spectrums for parts such as the bearing which failed in this case.
However, his concern was to have a comprehensive and uniform set of
standards for such safety-critical parts.

According to the latest information provided by the AAIB, EASA has
issued a Certification Memorandum (CM)-RTS-003, which gives
guidance on demonstration of compliance with applicable CS-27 and
CS-29 requirements for hybrid bearings (i.e. bearings involving steel
races and ceramic balls). EASA claims that this adequately addresses
the findings from the accident.

The AAIB does not consider this an adequate response.
It points out
that there is no guidance or requirement to calculate loads for non-
structural critical parts (such as the tail rotor bearing), as distinct from a
principal structural element (such as the entire tail rotor).
It further notes
that Certification Memorandum (CM)-RTS-003 focusses on issues with
one type of bearing and does not address the broader issue raised by
this recommendation.

I am concerned that EASA has responded to this AAIB recommendation
by citing action it has taken which does not appear to meet the AAIB’s
concerns.

(6) Failure modes analysis at a system level

In the inquests, the AAIB investigation team explained that they had
recommended that EASA make amendments to requirements in CS-29
and to AMC in order to stress that, where potentially catastrophic failure
modes are identified, the wider system should be reviewed for practical
mitigation options, such as early warning systems and failure-tolerant
design, rather than relying solely on statistical analysis to address the
risk. This was safety recommendation SR-2023-025.

6

 explained that, in the present case, it may have been helpful to
consider failure modes in relation to the tail rotor bearing and actuator as
a single or conjoined system. He said that, if this had been done, “it may
have been possible to mitigate the catastrophic nature of the tail rotor
duplex bearing failure”.

He told the court that EASA’s initial response to the recommendation had
the points the AAIB had raised and had not
not covered any of
addressed the intent of the recommendation at all.

of

He said that, after
further engagement, EASA had given a more
comprehensive reply which stated that Amendment 11 to CS-29 and the
sufficiently
provision
the
recommendation. However,
said that even that reply had
quoted features of CS-29 which did not meet the requirements of the
recommendation. There remained no provision for failure analysis to be
conducted at a system level.

guidance material

addressed

In those circumstances, the AAIB assessed EASA’s response to the
recommendation as not being adequate.

I am concerned that
the AAIB’s apparently sensible suggestion of
requiring failure modes analysis to be conducted at a system level
continues to be rejected.

6

ACTION SHOULD BE TAKEN

In my opinion, action should be taken to prevent future deaths, and I believe that
each of EASA and the CAA have power to take such action.

to make regulatory changes and issue guidance as
EASA has power
recommended by the AAIB under
the various safety recommendations
referenced above. These would affect helicopters in use in the UK at present
and helicopters which may be in use in the UK in the future.

Meanwhile, as
of the CAA told the court, the CAA has power to set
certification specification requirements for helicopters which would affect the
ability of a particular design of aircraft to be used in the UK. Furthermore, the
CAA has a role in seeking to work with EASA and other international regulators
to secure appropriate action to improve safety.

7

YOUR RESPONSE

A response to this report should be provided within 56 days of the date of this
report, namely by 25th July 2025. As coroner, I am able to extend the period if
appropriate.

Your response should contain details of action taken or proposed to be taken,
setting out the timetable for action. Otherwise, you should explain why no action
is proposed.

8

COPIES AND PUBLICATION

I have sent a copy of my report to the Chief Coroner and to the following
Interested Persons in the inquest, namely (i) the families of those who died; (ii)

7

 King Power International Group; (iii) Starspeed Ltd; (iv) Leicester City FC; (v)
Sloane Helicopters Ltd; (vi) Gama Aviation plc; (vii) Leonardo SpA; (viii) SKF
Aerospace;
(xi) AIG Pacific
Insurance Pte Ltd; and (xii) the AAIB.

(x) Shell Aviation Ltd;

(ix) Microtecnica Srl;

I have also sent it to the Secretary of State for Transport (
as a person who may find it useful or of interest.

),

I am also under a duty to send a copy of your response to the Chief Coroner
and all Interested Persons who in my opinion should receive it.
I may also send
a copy of your response to any other person who I believe may find it useful or
of interest.

The Chief Coroner may publish this report and/or any response to it in complete,
redacted or summary forms. She may send a copy of this report and/or any
response to any person who he believes may find it useful or of interest.

You may make representations to me, the coroner, at the time of your response,
about the release or the publication of your response.

9

30 May 2025

8

Responses

2 responses published against this report on judiciary.uk. A response is a body's written reply to the coroner's concerns; publication is at the discretion of the Chief Coroner's office, so an absent response does not mean nobody replied.

Response from Civil Aviation Authority (PDF)
Professor Catherine E Mason 
H.M. Senior Coroner for Leicester City & South Leicestershire 
H.M. Coroner’s Office 
Town Hall  
Town Hall Square 
Leicester 
LE1 9BG 

By email only:

25 July 2025 

IN  THE  MATTER  OF  AN  INQUEST  INTO  THE  DEATHS  ARISING  FROM  THE  HELICOPTER 
CRASH AT KING POWER STADIUM ON 27 OCTOBER 2018 

CIVIL  AVIATION  AUTHORITY  RESPONSE  TO  A  REPORT  ON  ACTION  TO  PREVENT  OTHER 
DEATHS PURSUANT TO PARAGRAPH 7 OF SCHEDULE 5 TO THE CORONERS AND JUSTICE 
ACT  2009  AND  REGULATIONS  28  AND  29  OF  THE  CORONERS  (INVESTIGATIONS) 
REGULATIONS 2013  

Introduction  

The UK Civil Aviation Authority wishes to express its sincere condolences to the families, friends, and 
loved ones of those who lost their lives in this tragic accident.  

The CAA has carefully considered the Regulation 28 Report and the matters of concern raised by the 
Senior Coroner.  

Response 

Following this tragic accident, the CAA analysed the Safety Recommendations (SRs) issued to EASA 
by the Air Accident Investigation Branch (AAIB) to understand the intent of the SRs and to consider 
what actions are within the CAA’s power to address within the UK. The CAA gave a detailed account 
of these actions to the Senior Coroner in the course of the inquest. 

The CAA: 

a.  has  adopted  updates  to  Acceptable  Means  of  Compliance  to  CS-27  and  CS-29  relating  to 

rolling contact fatigue in critical bearings classified as Principal Structural Elements;  

b.  has initiated rulemaking projects to update the UK regulatory framework to: 

Civil Aviation Authority 
Aviation House, Beehive Ring Road, Crawley West Sussex RH6 0YR    www.caa.co.uk 

 
 
 
 
 i. 

ii. 

clarify how the airworthiness status and life limits of critical parts should be defined and 
published to operators of the aircraft type; 

ensure the removal of defective critical parts from service and their return to the Type 
Certificate  Holder  (TCH)  of  the  aircraft  for  analysis,  to  better  understand  the 
performance of critical parts in service; 

iii. 

extend the scope of existing required safety assessments of the rotor and rotor drive 
system to minimise the hazard severity resulting from component failure; 

c. 

is developing a Certification Memorandum (“CM”) which will clarify that applicable data from 
the supplier of critical bearings (including installation and operating limitations, bearing design 
specification, and applicable best practice) should be recorded and assessed by the TCH of 
the aircraft prior to certification. This CM will apply to all critical bearings, including both metallic 
and hybrid designs. The CAA will share this CM with EASA for discussion; 

d.  will  consider  EASA’s  final  proposals  in  relation  to  the  Continued  Integrity  Verification 
Programme (CIVP) once they are issued and will reflect those provisions in the equivalent UK 
regulatory provisions if appropriate to do so; 

e.  will  continue  its  work to ensure that  industry  can  better  identify  critical  parts  and  notify  any 
failure  to  meet  their  design  life  to  the  CAA  through  the  Mandatory  Occurrence  Reporting 
(MOR) system; and 

f.  will continue to explore an internationally harmonised approach to the treatment of critical parts 
by  maintenance  organisations  to  ensure  such  parts  are  properly  identified,  controlled, 
managed, stored and released to service throughout the global aviation industry.  

The CAA also continues to work with its international counterparts, including EASA, as advised to the 
Senior  Coroner  during  the  inquest,  to consider what  actions  might  be  taken to  address  the  Senior 
Coroner’s concerns and ensure ongoing high safety standards for helicopters. The CAA and EASA 
met to discuss these issues on 2 July 2025, and a further meeting is planned for the autumn at which 
these  discussions  will  continue.  The  CAA  will  also  raise  these  issues  with  other  international 
counterparts, such as the FAA, as appropriate. 

As the Senior Coroner has noted, divergence of regulatory standards is generally undesirable in the 
context  of  civil  aviation.  For  this  reason,  the  CAA  will  continue  this  process  of  international 
engagement  with  the  aim  of  achieving  an  internationally  harmonised  approach  to  the  question  of 
critical bearing design and certification, and the identification, handling, maintenance and analysis of 
critical parts. If international harmonisation cannot be achieved in due course, the CAA will consider 
whether it would be appropriate nonetheless to exercise its own powers to amend UK certification 
specifications or other regulatory provisions unilaterally.   

While this process of international discussion is ongoing, the CAA will continue to have a range of 
powers available to ensure high standards of safety in helicopters operating in the UK, and will use 
these powers if necessary and appropriate to do so. These powers include: 

a.  powers to issue Airworthiness Directives, requiring action to be taken to ensure an aircraft 

remains safe to operate; 

Civil Aviation Authority 
Aviation House, Beehive Ring Road, Crawley West Sussex RH6 0YR    www.caa.co.uk 

 
 
 
 b.  powers to validate new aircraft types being brought onto the UK register, and to require 
additional assurances or actions to enable the CAA to be satisfied that the aircraft is safe 
to operate in the UK;  

c.  powers to ground aircraft if an unsafe condition is found to exist. 

The  CAA  considers  that  these  actions  address  the  Senior  Coroner’s  concerns  as  they  may  apply 
within the UK. The CAA remains committed to maintaining high standards of aircraft safety within the 
UK and contributing to similarly high standards globally. The CAA will continue to engage with EASA 
and other international counterparts, and to assess the UK’s regulatory framework, to address the 
lessons from this tragic accident.  

The Civil Aviation Authority 

Civil Aviation Authority 
Aviation House, Beehive Ring Road, Crawley West Sussex RH6 0YR    www.caa.co.uk
Response from European Union Aviation Safety Authority (PDF)
Acting Resources and Support Director
Resources and Support Directorate

Cologne, as per the e-signature

Professor Catherine E. Mason LL.B (Hons)
His Majesty’s Senior Coroner
Leicester City & South Leicestershire

Town Hall
Town Square
Leicester
LE1 9BG

Sent by e-mail only

Subject:

Attachment:

Inquest into the Deaths arising from the Helicopter Crash at King Power Stadium on
27 October 2018 – Regulation 28 Report to prevent future deaths

Annex recalling the EASA replies to AAIB safety recommendations 2023-018, 2023-019, 2023-021, 2023-
023, 2023-024 and 2023-025

Dear Prof. Mason,

We would like to express our sincere appreciation for the investigation into the helicopter crash at King
Power  Stadium  on 27 October  2018.  We  acknowledge  the significant effort and dedication that has
gone  into this inquest, and we are grateful for providing the European Union Aviation Safety Agency
(EASA) with the opportunity to respond to the concerns formulated in the Prevention of Future Death
Report arising from this tragic event.

As you are aware, EASA assisted the Air Accidents Investigation Branch (AAIB) of the UK in the safety
investigation into this accident in accordance with the provisions of Regulation (EU) No 996/2010. As
mentioned in our previous submissions, there has been some topics  on which we could not reach a
common understanding, and that included the root cause of the accident (cf. ‘Appendix K of the AAIB
Final  Report).  Nevertheless,  we  understand  the  importance  of  these  safety  recommendations  and
have approached them with the utmost seriousness and consideration. Our decision regarding these
recommendations were  not  taken lightly. They have been  carefully  produced according  to a formal
internal  procedure  that  involved  various  subject  matter  experts  from  within  the  Agency,  as  well  as
management review.

In the context of aircraft certification, it is crucial to ensure harmonization of certification requirements
applied  by  aviation  authorities  around  the  world,  with  the  primary  objective  of  ensuring  aviation
safety.  EASA  is  committed  to  working  closely  with  other  regulatory  bodies,  including  the  UK  Civil
Aviation Authority (CAA), to achieve this goal. In fact, we have been in contact with the UK CAA and are
aware  that  they  are  exploring  certain  concepts  related  to  some  of  the  safety  recommendations
proposed by the AAIB. We are open to engaging in consultation with UK CAA to assess the merits of
these proposals and to discuss potential ways forward.

However, at this point, EASA maintains its position as already communicated in response to the AAIB's
safety recommendations. For the sake of convenience, the latest responses to those recommendation
that are reconfirmed in  point 5 of the PFD as  ‘Coroner’s Concerns’ are recalled in the annex to  this
letter. We believe that our positions, as outlined in the annex, address the safety recommendations

TE.GEN.00101-010

An agency of the European Union

Postal address: Postfach 10 12 53, 50452 Cologne, Germany
Visiting address: Konrad-Adenauer-Ufer 3, 50668 Cologne, Germany
ISO 9001 Certified

Tel.: 
E-mail: 
Web: www.easa.europa.eu

Page 1 of 8

 
 raised by the investigation. At the same time, EASA is working on other improvements to the rotorcraft
certification process to address lessons learned beyond AAIB’s safety recommendations. The Agency is
committed  to  ensuring  that  any  regulatory  changes  are  proportionate,  effective,  and  aligned  with
international best practices.

Once again, we would like to express our gratitude for the opportunity to respond to the Coroner's PFD
report. We remain committed to working with all stakeholders to identify areas for improvement and to
implement measures that enhance aviation safety.

We trust that this letter clarifies EASA’s position in this matter and we thank you for your attention.

Yours sincerely,

(electronically signed)

TE.GEN.00101-010

An agency of the European Union

Postal address: Postfach 10 12 53, 50452 Cologne, Germany
Visiting address: Konrad-Adenauer-Ufer 3, 50668 Cologne, Germany
ISO 9001 Certified

Tel.: +49 221 89990 3000
E-mail: arthur.beckand@easa.europa.eu
Web: www.easa.europa.eu

Page 2 of 8

 Annex recalling the EASA replies to AAIB safety recommendations 2023-018, 2023-019, 2023-021,
2023-023, 2023-024 and 2023-025

AAIB reference 2023-018: “It is recommended that the European Union Aviation Safety Agency amend
Certification Specification 29.602 to require type design manufacturers to provide  the results of all
relevant  system  and  flight  testing  to  any  supplier  who  retains  the  sole  expertise  to  assess  the
performance  and  reliability  of  components  identified  as  critical  parts  within  a  specific  system
application, to verify that such components can safely meet the in-service operational demands, prior
to the certification of the overall system.” [EASA reference: UNKG-2023-001]
Final EASA reply sent on 06/02/2024:

“Pursuant  to  point  21.A.20  of  Annex  I  (Part  21)  to  Regulation  (EU)  No  748/2012,  the  applicant  for
aircraft type certification is responsible for the demonstration of compliance with the type certification
basis (that includes certification specifications), and to record justifications of compliance within the
compliance documents as referred to in the certification programme. This implies ensuring that parts
and systems reach minimum performance and reliability targets.

Therefore, the applicant is responsible for providing any information such as, but not limited to, test
results to its suppliers to ensure a final airworthy design.

This  principle  is  not  specific  to  certain  products  and  should  not  be  repeated  in  each  Certification
Specification where a supplier could be affected.

The  European  Union  Aviation  Safety  Agency  (EASA)  considers  that  the  above-mentioned  regulatory
framework,  including  Certification  Specifications,  is  adequate  and  does  not  envisage  creating  new
prescriptive requirements.”

AAIB  reference  2023-019:  “It  is  recommended  that  the  European  Union  Aviation  Safety  Agency
introduce additional requirements to Certification Specification 29 to specifically address premature
rolling contact fatigue failure across the full operating spectrum and service life of bearings used in
safety critical applications.” [EASA reference: UNKG-2023-002]

Interim reply sent on 06/02/2024:

“Point  CS  29.571  (Fatigue Tolerance  Evaluation of  Metallic  Structure)  paragraph  (d)  of  Certification
Specification  for  Large  Rotorcraft  (CS-29)  specifies  the  following  with  regard  to  Principle  Structure
Elements (PSE):

“Each PSE must be identified. Structure to be considered must include the rotors, rotor drive systems
between the engines and rotor hubs, controls, fuselage, fixed and movable control surfaces, engine and
transmission mountings, landing gear, and their related primary attachments.”

The European Union Aviation Safety Agency (EASA) considers that this includes critical components
within the rotor control mechanism, such as the tail rotor duplex bearing of the AW169.

TE.GEN.00101-010

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Page 3 of 8

 Acceptable Means of Compliance AMC1 29.571 (introduced with Amendment 11 of CS-29) addresses
Rolling  Contact  Fatigue  (RCF)  which  should  be  included,  when  applicable,  in  the  fatigue  tolerance
evaluation  of  Principle  Structure  Elements  (PSE).  This  AMC  describes  possible  steps  to  be  taken  to
minimise the risk of crack initiation due to RCF on PSEs (and in particular for integrated bearing races). A
fail-safe  approach  is  recommended  wherever  possible,  such  that  cracking  of  the  affected  structural
element(s)  is  detected  prior  to  its  residual  strength  capability  falling  below  the  required  levels
prescribed  in  CS  29.571(f).  In  addition  to  following  a  fail-safe  approach,  inspection  and  retirement
times may be needed in order to ensure that the assumptions supporting the fail-safety and detection
of failure remain valid throughout the operational life of the component.

EASA  is  however  reviewing the opportunity  to  clarify  the scope of application of AMC1  29.571,  and
similarly  of  AMC1  27.571,  to  ensure  that  critical  bearings  are  always  considered.  A  proposed
amendment of CS-27 and CS-29 is planned to be included in the next Notice of Proposed Amendment
under  rulemaking  task  RMT.0128  ‘Regular  update  of  the  Certification  Specifications  for  Very  Light
Rotorcraft (CS-VLR), Small Rotorcraft (CS-27), and Large Rotorcraft (CS-29)’.”

AAIB reference 2023-021: “It is recommended that the European Union Aviation Safety Agency define
the airworthiness status of life limits and how they should be controlled for existing non-structural
critical parts approved to Certification Specification 29.602 requirements, already in service.” [EASA

reference: UNKG-2023-004]

Final reply sent on 22/03/2024:

“In  accordance  with  point  21.A.7  of  Annex  I  (Part  21)  to  Regulation  (EU)  No  748/2012,  the  Type
Certificate Holder (TCH) must provide Instructions for Continued Airworthiness (ICA) for critical parts,
either  structural  or  non-structural,  and,  in  case  of  large  rotorcraft,  the  preparation  of  ICA  must  be
performed in compliance with the Certification Specification (CS) 29.1529.

The ICA applicable to critical parts may be included within the Airworthiness Limitation Section (ALS)
of the ICA and/or in other appropriate Sections.

Retirement Times or Operational Time Limits provided in the ICA are necessary for the safe operation of
the aircraft and they have to be implemented in the Aircraft Maintenance Programme (AMP) to obtain
approval by the Competent Authority [ref. point M.A.302(d)(2) of Annex I (Part M) to Regulation (EU) No
1321/2014]. This requirement is applicable to both ALS and other Sections of the ICA.

In addition, point 21.A.3A of Annex I (Part 21) to Regulation (EU) No 748/2012 contains the necessary
provisions for ensuring the collection, investigation and analysis of occurrence reports to identify the
necessary mitigations in terms of changes to the design and/or to the ICA to prevent or minimize the
possibility of such occurrences in the future, as necessary. This includes, as per point 21.A.3A(a)(1), the
identification  of  adverse  trends  or  deficiencies  that  cause  or  might  cause  adverse  effects  on  the
continuing airworthiness of the product. The ‘analysis’ is not limited to those occurrences that require
the involvement of the European Union Aviation Safety Agency (EASA) under point 21.A.3A(e).

TE.GEN.00101-010

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Page 4 of 8

 Taking  into  account  the  information  above,  the  EASA  considers  that  the  necessary  regulatory
framework  is  already  in  place and,  therefore,  EASA  does  not  intend  to re-define  or  re-evaluate the
airworthiness status of ICA for critical parts, either structural or non-structural, already in service.”

AAIB reference 2023-023: “It is recommended that the European Union Aviation Safety Agency require
manufacturers to retrospectively implement a comprehensive post removal from service assessment
programme for critical parts, approved to Certification Specification 29.602 requirements, already in
service. The findings from this should be used to ensure that the reliability and life assumptions in the
certification risk analysis for the critical part or the system in which it operates remain valid.” [EASA
reference: UNKG-2023-006]
Final reply sent on 22/03/2024:

“Point 21.A.3A of Annex I (Part 21) to Regulation (EU) No 748/2012 defines the obligations applicable to
the Type Certificate Holders (TCHs) to establish and maintain a system for collecting, investigating and
analysing occurrence reports. This includes, as per point 21.A.3A(a)(1), identification of adverse trends
or deficiencies that might cause adverse effects on the continuing airworthiness of the product.

In  addition,  acceptable  means  of compliance  AMC1  21.A.3A(a)  clarifies  that,  for parts  whose failure
could lead to  an  unsafe  condition  (and critical parts  are  candidates  as  they  could have  catastrophic
effect  upon  the  rotorcraft),  the  ‘analysis’  function  of  the  system  should  ensure  that  reports  and
information sent, or available, to the Design Approval Holder (DAH) are fully investigated so that the
exact nature of any event and its effect on continuing airworthiness is understood. This may then result
in  changes  to  the  design  and/or  to  the  Instructions  for  Continued  Airworthiness  (ICA),  and/or  in
establishing a mitigation plan to prevent or minimize the possibility of such occurrences in the future, as
necessary.  The  ‘analysis’  is  not  limited  to  those  occurrences  that  require  the  involvement  of  the
European Union Aviation Safety Agency (EASA) under point 21.A.3A(e).

EASA  considers  that  obligations  outlined  in  21.A.3A  already  indicate  that  the  TCH  shall  collect,
investigate and analyse reports and information [including the early rejection of parts from service as
mentioned in guidance material GM1 21.A.3A(a) and 21.A.3A(b) Reporting system] that might question
the  certification  assumptions  for  critical  parts  and  when  necessary,  define  design  changes  and
implement mitigation plans.

Therefore, EASA considers that the necessary regulatory framework is already in place to address the
intent  of  this  Safety  Recommendation  (SR)  and,  therefore,  there  is  no  need  to  retrospectively
implement  a  comprehensive  post  removal  from  service  assessment  programme  for  critical  parts
already in service.”

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Page 5 of 8

 AAIB reference 2023-024: “It is recommended that the European Union Aviation Safety Agency amend
Certification Specification 29.602 to provide guidance and set minimum standards for the calculation
of design load spectrums for non-structural critical parts. They must encompass, with an appropriate
and  defined  safety  margin,  the  highest  individual  operating  load  and  combination  of  dynamic
operating  loads,  and  the  longest  duration  of  exposure  to  such  loads  that  can  be  experienced  in
operation.” [EASA reference: UNKG-2023-007]
Final reply sent on 24/03/2025:

“The  accident  investigation  report  mentions  a  non-conservative  loads  calculation  at  the  time  of
certification as a root cause of the bearing failure.

The  European  Union  Aviation  Safety  Agency  (EASA)  does  not  share  this  single  factor  conclusion,
considering that other possible detrimental factors may also have contributed to the bearing failure.

The  methodology  for  loads  calculation  as  used  by Leonardo  is  not  novel  or  unusual  and  does  not
require complete reconsideration by means of new, prescriptive certification specifications.

However, as lessons learned from this accident, EASA considers that future approvals of hybrid bearing
with ceramic balls will deserve more attention as regards to the failure mechanics and the sensitivity of
the    bearing    to    its    working    conditions    (including    abnormal    conditions    originated    by    e.g.
manufacturing  defects,  degraded  lubrication,  improper  maintenance,  etc..)  in  order  to  better  cope
with a wider range of scenarios.

Consequently,  EASA  issued  Certification  Memorandum  (CM)-RTS-003  titled  ‘Hybrid  Bearings’  on  13
Dec 2024 to provide specific guidance related to the demonstration of compliance with applicable CS- 27
and CS-29 certification specifications for hybrid bearings (combination of steel races with ceramic ball
is  available  on  EASA’s  website  at: https://www.easa.europa.eu/en/document-
bearings).  This 
library/product-certification-consultations/hybrid-bearings

EASA  considers  that  this  action  adequately  addresses  findings  from  this  accident  by  highlighting
relevant  aspects  to  be  addressed  during  the  certification  process  of  rotorcraft  featuring  hybrid
bearings.”

TE.GEN.00101-010

An agency of the European Union

Postal address: Postfach 10 12 53, 50452 Cologne, Germany
Visiting address: Konrad-Adenauer-Ufer 3, 50668 Cologne, Germany
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Page 6 of 8

 AAIB reference 2023-025: “It is recommended that the European Union Aviation Safety Agency amend
the relevant requirements of Certification Specification 29 and their Acceptable Means of Compliance
(AMC) to emphasise that where potentially catastrophic failure modes are identified, rather than rely
solely on statistical analysis to address the risk, the wider system should also be reviewed for practical
mitigation options, such as early warning systems and failure tolerant design, in order to mitigate the
severity of the outcome as well as the likelihood of occurrence.” [EASA reference: UNKG-2023-008]
Final reply sent on 19/07/2024:

“The European Union Aviation Safety Agency (EASA) considers that practical mitigation options such as
early warning systems and failure tolerant designs are relevant means to achieve adequate safety levels
in rotorcraft designs.

According to CS-29 Amdt 11 (Certification Specifications, Acceptable Means of Compliance (AMC) and
Guidance Material for Large Rotorcraft), CS 29.571 (Fatigue tolerance evaluation of metallic structure)
and AMC1 29.571 (dealing with rolling contact fatigue (RCF)) address the need to take into account the
impact  of  RCF  and  minimise  the  risk  of  crack  initiation  resulting  from  RCF  on  Principal  Structural
Elements  (PSEs).  In  addition,  AMC1  29.571  states  that  ‘as  it  is  difficult  to  totally  preclude  cracking
initiated  by  RCF,  a  fail-safe  approach  is  recommended  wherever  possible,  such  that  cracking  of  the
affected  structural  element(s)  is  detected  prior  to  its  residual  strength  capability  falling  below  the
required levels prescribed in CS 29.571(f)’. Hence AMC1 29.571 clearly introduces the notion of fail- safe
designs and of means of detection to fulfil the objective of preventing failure as a result of RCF. This
regulatory material was relatively new at the date of publication of the accident investigation report
and it appeared, in EASA’s view, not to have been considered.

Nevertheless, additional CS-29 provisions help to meet the intent of this safety recommendation:

(1)

The design assessments specified by CS 29.547(b) (Strength requirements - Main and tail rotor
structure)  and  CS  29.917(b)  (Powerplant  –   Rotor  Drive  System  -  Design)  require  the
identification of all failures in rotors and rotor drive systems that will prevent continued safe
flight or safe landing, as well as the means to minimise the likelihood of their occurrence. As
per Federal Aviation Administration (FAA) Advisory Circular (AC) 29-2C Change 7 (recognised as
AMC to CS-29) sections 29.547 and 29.917, ‘a design assessment […] should be carried out in
order to substantiate that the system is of a safe design and that compensating provisions are
made  available  to  prevent  failures  classified  as  hazardous  and  catastrophic[…]’.  The  listed
compensating provisions include design features (such as redundancies and safety factors) and
the  use  of  safety  devices  or  vibration  health  monitoring  systems,  which  cover  the  means
proposed by the AAIB in this safety recommendation. Other compensating provisions such as
inspections or checks, as well as preventive maintenance are also listed.

(2)

Since  some  years  EASA  has  recognised  the  need  to  clearly  identify  those  continuing
airworthiness tasks which are listed as compensating provisions in the aforementioned design
assessments  and  are  also  considered  key  to  ensuring  that  the  hazardous  and  catastrophic
failures  of  the design  are either  adequately mitigated or their probability  of  occurrence  has
been adequately minimised. EASA considers that these continuing airworthiness tasks should
be:

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Postal address: Postfach 10 12 53, 50452 Cologne, Germany
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Page 7 of 8

 (i)

(ii)

considered  as  candidates  for  Certification  Maintenance  Requirements  (CMRs)  in
accordance  with  AMC  25-19  of  CS-25  (Certification  Specifications  and  Acceptable
Means of Compliance for Large Aeroplanes). EASA currently addresses the application
of  the  CS-25  CMR  concept  to  support  the  demonstration  of  compliance  with  large
rotorcraft   certification   specifications   requiring   safety   assessment   and   design
assessment, including CS 29.547(b) and CS 29.917(b), through a Means of Compliance
Certification Review Item. Therein applicants are requested to detail the criteria and
methods to demonstrate the adequacy of these CMRs.
evaluated  for  the  need  of  dedicated  certification  testing  to  demonstrate  adequate
performance  and  suitable  intervals.  EASA  is  currently  considering  the  possibility  of
introducing  new  AMC  to  CS  29.927(a)  (Additional  tests)  to  address  this  aspect.  This
would  clarify  the  need  to  support  inspection  intervals  and  retirement  times  with
appropriate directly applicable data.

In conclusion, while the relevance of a full assessment of the design and a detailed evaluation of
the  failure  scenarios  is  agreed  and  already  present  in  CS-29,  EASA  considers  that mandating
design  measures  to  systematically  mitigate  the  outcome  of  catastrophic  failures  could  be
counterproductive. This could lead to impractical and overly complex solutions, that negatively
impact the reliability of rotors and rotor drive systems.

Based on the above, EASA considers that the necessary elements are in place to ensure that
hazardous  and    catastrophic  failures  are  adequately  addressed  during   certification,   by
adequately  mitigating  such  failures  and/or minimising  their  probability  of  occurrence,  thus,
ensuring adequate safety levels.”

Electronically signed on 14/07/2025 09:19 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121

An agency of the European Union

Page 8 of 8

Postal address: Postfach 10 12 53, 50452 Cologne, Germany
Visiting address: Konrad-Adenauer-Ufer 3, 50668 Cologne, Germany
ISO 9001 Certified

Tel.: +49 221 89990 3000
E-mail: arthur.beckand@easa.europa.eu
Web: www.easa.europa.eu

TE.GEN.00101-010

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