Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE EASA.2009.OP.21 4.7 FAA SIAGDP Attachment C provides some description of the proposed FAA Standardised International Aircraft Ground De/Anti-icing Programme (SIAGDP). This programme is relevant to this Study because as stated in FAA Notice N 8900.26 Dec 2007 Policies, procedures, and requirements are currently under development to authorize an aircraft ground deicing service provider to be issued a letter of authorization (LOA) to provide aircraft ground deicing services under an industry standardized aircraft ground deicing program. This FAA SIAGDP also involves a detailed overhaul of FAA AC 120-60B the document against which carriers have their de-icing / anti-icing programmes approved by the FAA. A mechanism that does not exist in EASA Member States. Naturally, to avoid duplication and confliction, any proposed changes to the method of regulation and oversight of operators’ deicing / anti-icing requirements ought to be shared with the FAA (and TC) in order to promote a harmonised system of regulation between the two continents. LIASFAA. EASA should take this opportunity to liaise closely with the FAA, and TC, with the aim of harmonising future de-icing / anti-icing regulations and thereby avoiding differing requirements, giving rise to ambiguity and confusion. airsight GmbH 53
INTERIM REPORT – OPTIONS FOR CHANGE EASA.2009.OP.21 4.8 National authority requirements for oversight of operations Without a system of direct oversight of service providers it is possible that some NAAs rely on their relationships with operators to understand this dynamic and safety critical activity which takes place within their territory. In such cases, there is no relationship between the NAA and providers of de-icing / anti-icing services. The difficulty, encountered during this Study, in determining a responsible person within EASA Member State NAAs for de-icing / anti-icing service provision is evidence that this lack of working relationship, and possibly knowledge can exist. Option SME3, above, addresses this particular issue. The oversight of an operator’s de-icing / anti-icing programme relies on the NAA accepting the operator’s OM, and quality assurance programme. With the emphasis on compliance with operations regulations, the important element of how operators arrange contracts with service providers may be overlooked. How these contracts are arranged and constructed should be of interest to NAAs in determining the standards against which operators audit third-party contractors. EASAAR1. EASA to require all NAAs to establish and maintain a monitoring programme of de-icing / anti-icing service providers exercising activities on their territory. This requirement will exist in the new Authority Requirements, but may not be implemented fully by all States. AR.GEN.305 Monitoring of activities – requires NAAs to conduct oversight of non-certified bodies and personnel when they are conducting activities on their territory – such programmes and audit schedules shall be proportionate. A unified purpose for such programmes would encourage their development and use, and also provide useful feedback which could be compared between States. EASAAR2. EASA to develop guidance for NAAs in how to implement a monitoring programme of de-icing / anti-icing service providers in compliance with AR.GEN.305. EASAAR3. EASA to amend AMC2 AR.GEN.300 Continuing Oversight Ops – to include an operator’s arrangements for ground-handling. Ill-conceived contracts and arrangements made with de-icing / anti-icing providers can be a source of confusion, or worse. AMC 2 AR.GEN.300 Continuing oversight OPS – specifies a list of items which an operator should at least be subject to inspections and monitoring by the Authority. Although not an exclusive list, the inclusion of an operator’s arrangements for ground- airsight GmbH 54
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Interim Report - Introduction - EASA

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