Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE
EASA.2009.OP.21
this itself satisfies their responsibility for assuring that the data is accurate. EASA issues the
LoA to appropriate suppliers who meet the criteria; this is accomplished in accordance with
EASA Opinion 01/2005. Operators can still obtain databases from suppliers who do not hold
a LoA, but they then have to demonstrate to the Authority that their procedures are adequate
to assure the same standards. In both cases, the operator’s Quality System still needs to be
employed. One of the aims of the LoA is to ease the obligation on operators to perform what
would be nearly impossible and unimplementable controls and processes.
The option of EASA issuing LoAs to service providers of de-icing / anti-icing would introduce
different challenges. First there are only a few air navigation database suppliers, therefore
the Agency’s commitment of resources is limited. Secondly, if EASA did audit every de-icing
/ anti-icing service provider, this is only a process that operator’s are obliged to do anyway;
therefore, the duplication would be wasted effort, and to against whose standard would the
Agency be conducting audits – each individual operator’s? The benefit of using an LoA
process is that standard “conditions and guidance” can be established against which audits
and inspections can take place.
In EASA Opinion 01/2005, the Agency has the view that the best solution would certainly be
that the industry organizes itself to verify the quality of the navigation data provided by the
suppliers and used by the aircraft operators. Such an option, similar to that developed by
IATA for the operational safety audit of its member airlines (IOSA). This view points towards
a possible hybrid system of regulation and oversight. The IATA DAQCP provides a model
where member airlines agree a common standard audit checklist (based on AEA
Recommendations), and accept the audit results of shared audits within the pool of
members. The auditors are provided by the pool members and are trained in accordance
with the DAQCP’s own accepted standards. In effect, any service provider passing a
DAQCP audit is issued with an Industry seal of approval, much like IOSA, whilst not
removing the ultimate responsibility from the operator. It could be conceivable that any
organisation (like IATA) wishing to establish a de-icing / anti-icing quality control pool can be
“approved” or “accepted” by EASA and issued with their own LoA (perhaps LoA1); this would
then permit the pool’s own qualified auditors to issue, on behalf of the Agency, LoAs
(perhaps LoA2) to service providers who meet the necessary standards. Currently, the
DAQCP is established from the perspective of their own airline membership, and this limits
the number of destinations and service providers included in the scheme. An improvement
to the scheme would be to allow service provider membership where they either paid for the
privilege of being audited and thereby “accepted”, or they paid a fee and contributed to the
pool of auditors.
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