Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE
EASA.2009.OP.21
− AEA Recommendations; this is the predominant reference document for operators. It
is designed, published and updated regularly by operators, with input from aircraft
manufacturers. Because operators rely on this document, service providers also use
this as a reference, together with ICAO , ISO and SAE documents. However, as an
AMC, or set of Technical Instructions the AEA Recommendations is too broad and not
specific enough.
− ISO 11075/6/7/8 are used by service providers who may wish to benefit from ISO
9001 accreditation, however, operators prefer to use the documents mentioned above
to these ISO documents. It is worth investigating whether a service provider
accredited for Quality Management under ISO, specifically against the relevant deicing
/ anti-icing standards, has a safer operation than those who are not. If a benefit
can be identified and the Industry agrees that the ISO accreditation results in a
worthwhile standard and quality of service, then operators may be “required” to obtain
their services only from ISO accredited organisations. This concept would be
structured in a similar way to Option REGLOA shown below, but more investigation is
required.
Identifying, or creating an acceptable source reference set of technical instructions for the
safe de-icing / anti-icing of aircraft on the ground may allow EASA to regulate de-icing / antiicing
in a manner similar to the carriage of dangerous goods. Operators de-icing / anti-icing
programmes may be approved against these instructions, or not.
TECIN1. EASA develops a set of Technical Instructions against which operators deicing
/ anti-icing programmes shall be approved.
This Option should be considered alongside Option REGAO1. Operations
other than the carriage of dangerous goods which also require special
operations approval (OPS.SPA) include: operations in RVSM airspace;
operations in airspace with specified navigation performance; and, low
visibility operations. Not so easy to draw parallels with de-icing / anti-icing
here; the regulation of these operations does involve a lot of technical
instruction within the regulations themselves, and therefore a precedent has
been set for detailed direction for operators within the regulatory framework.
The format of applying for a special operational approval is quite straightforward.
Applicants provide the competent authority with the documentation
required by the applicable subpart as well as a description of the intended
operation. Applicants then need to demonstrate that:
- they comply with the requirements of the applicable section;
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