Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE
EASA.2009.OP.21
of weakness highlighted in “The Summary and Analysis of Safety Data”, the
recommendations made by stakeholders, and the ToRs to this Study, all previously
described within this document.
REGAO1. Require the approval of operators’ de-icing / anti-icing programmes against
minimum requirements defined within the regulations.
REGAO2. Develop an effective AMC in the form of an example of, or framework for, an
operator’s de-icing / anti-icing programme.
These three options, and a combination thereof, will need to be undertaken with
consideration given to the intended aims of harmonising programmes and raising standards.
ICAO recommends (Doc 9640) that the operator’s de-icing / anti-icing programme, or
procedures, is “approved” by the NAA; with special focus on responsibilities and training.
De-icing / anti-icing is not included as an item requiring Authority approval, merely
“acceptance” through a technical evaluation (Attachment F to Annex 6 Part 1). EASA no
longer differentiates between “approval” and “acceptance”, although the means of evaluation
may vary. Such an evaluation must consider whether the specific policies and procedures
would result in the desired outcome. For a satisfactory evaluation to be made, the facilities,
procedures and equipment available at each location would need to be considered.
EU OPS 1.345 and JAA ACJ OPS 1.345 do not require any approval by the NAA, but they
do provide adequate direction for an operator as to the requirements, however, not towards
the detail. With several informative and comprehensive reference documents highlighted as
sources for operators to develop their de-icing / anti-icing policies, procedures and
programmes, the outcomes will naturally vary and harmonisation of procedures is unlikely.
De-icing / anti-icing procedures are not an element of the OM that requires specific approval
(JAA IEM OPS 1.1040(b)), instead the operator only needs to ensure that the structure of the
OM is acceptable to the NAA (OPS 1.1045). The required contents of the OM contain little
guidance and focus mainly on fluid types. There is no presentation of an “acceptable” set of
procedures, nor a standard template for both procedures and training syllabus. Furthermore,
there is no direct requirement for an operator to establish coordination and communication
procedures between flight operations, flight crew, aerodromes and service providers,
adequate for all their destinations.
The proposed OPS.GEN.100 and associated AMC and GM does not improve the current
regulatory situation, (Attachment B). However, AMC under the Basic Regulation and as
described in NPA 2009-02A (paragraph 56 and Appendix II, paragraph 6) are part of a
commercial operator’s approval, and therefore have the same status as a regulation. Such
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