Interim Report - Introduction - EASA

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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 airsight GmbH 39
INTERIM REPORT – OPTIONS FOR CHANGE EASA.2009.OP.21 an AMC can be divided into the “essential” elements, and the “supporting information” elements. Overall, in addressing these three options, attention should be given to the following: REGAO2.a. providing operators with a clear framework for an acceptable de-icing / anti-icing policy, procedures, training programme, REGAO2.b. providing operators with clear guidelines for establishing and maintaining effective communication and coordination procedures, REGAO2.c. providing operators with template communication messages and meanings connected with all inspections, checks and operations; in particular review of the anti-icing code, and clarification of the “all clear” signal/message (refer to COMM), REGAO2.d. providing operators with a structured framework for the relevant section of the OM (A8), REGAO2.e. clarifying responsibilities for key decision-makers, REGAO2.f. requiring and defining the minimum elements required for an effective contract between operator and service provider, and REGAO2.g. requiring operators to seek approval for any deviations (in certain areas) from the published AMC. REGAO3. Require operators to appoint a subject-matter expert as per Option SME4. This contributes towards the need for improved internal and external communication and may help promote improved knowledge amongst the relevant employees and ensure an effective homogenous de-icing / anti-icing policy and programme. Combined with other SME options, this may also contribute towards a harmonisation of standards required of service providers. EU OPS 1.175 details the requirement for operators to appoint nominated post-holders in the areas of flight and ground operations, maintenance and crew training. No preference is given as to which Post-Holder should be responsible for de-icing / anti-icing. This will be detailed in their responsibilities published in the Operations Manual (OM). However, one of these Post-Holders is to be responsible for ensuring contracted organisations maintain proper standards. This particular nominated Post-Holder could be made responsible for appointing a suitably qualified and experienced subjectmatter expert to coordinate the operators de-icing / anti-icing programme. airsight GmbH 40
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Interim Report - Introduction - EASA

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