Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE
EASA.2009.OP.21
4.6 Alternative models for regulating de-icing / anti-icing through
operations regulations
Like de-icing / anti-icing, other activities exist which
− need to be fulfilled by operators
− rely on third-party contracted organisations and persons
− can be classified as safety critical
These activities include:
− loading (OPS 1.625)
− the carriage of dangerous goods (OPS 1.1145), and
− maintaining the integrity of navigation data (OPS 1.873).
In each case, a different framework of regulations and guidance material has been
developed to meet the needs of each activity. However, certain aspects of how these
activities are regulated (or not) may provide an insight into potential amendments to de-icing
/ anti-icing regulation.
Loading
This particular alternative model does not lead to a radical alternative proposal for regulation,
but it does highlight the importance given to communication; and the options proposed stand
on their own as valid, and would fit within Options REGAO and REGAO3 above.
Unlicensed personnel, employed by non-certified organisations, working under contract to
the airline and sometimes sub-contracted through another body (aerodrome, groundhandling
agent) are weighing cargo, loading aircraft and completing load documentation.
The captain is responsible for ensuring that the aircraft is loaded correctly and within
performance limitations. He/she does this by determining whether the mass and balance
documentation is acceptable.
The mass and balance documentation must enable the commander to determine that
the load and its distribution is such that the mass and balance limits of the aeroplane
are not exceeded.
Incorrect weighing, loading, and/or calculations and form-filling may result in an incident or
accident. The parallels with de-icing / anti-icing are significant.
For a captain to determine whether de-icing has been successful he/she is relying on the
passing of a message, not usually paperwork, but often verbal or visual. The verbal
message can be delivered in person, or via VHF; sometimes this message is passed via a
airsight GmbH 44