Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE EASA.2009.OP.21 Most of these messages are essential for safe coordination, and as such would benefit from international standardisation and use, as well as continuously open channels of instant communication during de-icing / anti-icing. The adherence to special instructions, the Code and the results of the post treatment check effectively (like the mass and balance documents) allow the captain to establish whether the aircraft is airworthy, and whether it remains in that condition. Therefore, the communication from the service provider should be from a suitably qualified person, who ought to be willing to “sign-off” his/her work, by communicating their name (perhaps as part of the “aircraft clean” or Code messages). Furthermore, this person should be present at the operation, in charge of the operation and able to conduct the post treatment check. The Code and “aircraft clean” elements should also be recorded. If, for contractual reasons the post treatment check is conducted by another organisation, then this element of the communication should also be delivered by the qualified person, who is present and also provides his/her identity. COMM. Standardise communication elements and their meaning. COMM1. Clarify that the anti-icing Code only provides those information elements within it and does not infer anything else. COMM2. Require a separate “aircraft clean/aircraft not clean” message following the post treatment check. COMM3. Require a separate “equipment and personnel clear of aircraft” message. COMM4. Require continuous verbal contact between de-icing / anti-icing crew chief and flight deck. COMM5. Require critical messages (aircraft clean) to be delivered by qualified person who is present at the operation. COMM6. Require this qualified person to provide his/her name/number with either the Code, or the post treatment check results. COMM7. Require operators to include these elements in their contracts with service providers. Dangerous Goods This is another area where unlicensed personnel working for non-certified organisations are responsible for activities, which if not carried out to the required standards will introduce hazards and therefore introduce risk into aircraft operations. Unlike de-icing / anti-icing, the regulators have found a way of ensuring that all operators and their handling agents comply with the same set of standards. airsight GmbH 47
INTERIM REPORT – OPTIONS FOR CHANGE EASA.2009.OP.21 EU OPS 1.1145 and OPS.GEN.030 refer. These rules require operators and their handling agents to comply with ICAO Doc 9284-AN/905 (Technical Instructions for the Transport of Dangerous Goods). This document is accepted globally, and updated regularly with contributions from many NAAs and Industry organisations. Operators are approved to transport dangerous goods by their Authority; this may, or may not be applied to operators to approve their operations when de-icing / anti-icing is required. An EASA ruling in the future OR.OPS could be considered whereby the Agency requires an operator to comply with the applicable provisions contained in the latest edition of Technical Instructions for the safe de-icing / anti-icing of aircraft on the ground. Specific references can then be made to ensure that the de-icing / anti-icing service provider follows certain checklists and procedures in accordance with these Instructions, and that any personnel involved (whether employees of the operator or not) should also apply the standards within the Instructions. The ultimate result would be that operators draft their de-icing / anti-icing programmes and associated contracts from a single source document. There are various options available for the source of these Technical Instructions: − ICAO Doc 9640. Useful as a basis for a regulation, and indeed this is the case existing today. Although reference to an ICAO document is a direct parallel with the regulation of dangerous goods, it is not very useful as a source of technical instructions, checklists and templates. − EASA AMC to OPS.GEN.100 can be developed into a suitable set of Technical Instructions, with which operators would be obliged to comply unless they sought approval for an alternative means of compliance. Such an AMC could be used to direct operators towards standardised means of coordination, communication, training, training etc, and the template used for the AMC could be designed to assist operators construct their programmes, OM entries and contracts. Options REGAO2 and REGAO3 refer. − SAE ARP 4737 Aircraft de-icing / anti-icing methods is a technical manual; useful for training, designing procedures and also developing an operator’s de-icing / anti-icing policy and programme. However, as an AMC, or set of Technical Instructions it is too broad and not specific enough. However, referring to SAE Recommended Procedures may be considered similar to other references made within regulations to EUROCAE and RTCA documents. One benefit of using SAE is that both Industry and Authorities participate in their update – which is also regular. Another benefit of using SAE is that a family of documents is available covering application, fluids and their handling, equipment and training; these are referred to from within ARP 4737. airsight GmbH 48
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