Interim Report - Introduction - EASA

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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. airsight GmbH 51
INTERIM REPORT – OPTIONS FOR CHANGE EASA.2009.OP.21 The regulatory control would be established if EASA accepted that a shared audit from one of it’s “accepted” schemes would ease the obligation of participating operators to conduct their own audits. Whereas if an operator wished to use the services of a provider who sat “outside” of any scheme and did not possess an LoA, they would have to demonstrate to their competent Authority that they could meet the same standards through their own contract provisions and quality programme. REGLOA. EASA to investigate the possibility, and the potential for an LoA system of quality assurance of de-icing / anti-icing service providers. In support of the Option REGLOA, or instead of, it may be possible for the Industry to establish a voluntary system of accrediting service providers. Such a system could still be based on ensuring the standards of for example AEA Recommendations, through an audit scheme like the IATA DAQCP. For such a scheme to be successful, all airlines and all service providers would need to agree to participate. However, if a voluntary scheme was established, whereby service providers could opt to be “accredited” by Industry, then this could be used as the basis of lobbying for EASA “approval” of such schemes. VOL: Industry commence a system whereby service providers can opt to be accredited through a recognised audit scheme based on acceptable standards. airsight GmbH 52
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