Interim Report - Introduction - EASA
Interim Report - Introduction - EASA
Interim Report - Introduction - EASA
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INTERIM REPORT – OPTIONS FOR CHANGE<br />
<strong>EASA</strong>.2009.OP.21<br />
4.8 National authority requirements for oversight of operations<br />
Without a system of direct oversight of service providers it is possible that some NAAs rely<br />
on their relationships with operators to understand this dynamic and safety critical activity<br />
which takes place within their territory. In such cases, there is no relationship between the<br />
NAA and providers of de-icing / anti-icing services. The difficulty, encountered during this<br />
Study, in determining a responsible person within <strong>EASA</strong> Member State NAAs for de-icing /<br />
anti-icing service provision is evidence that this lack of working relationship, and possibly<br />
knowledge can exist. Option SME3, above, addresses this particular issue.<br />
The oversight of an operator’s de-icing / anti-icing programme relies on the NAA accepting<br />
the operator’s OM, and quality assurance programme. With the emphasis on compliance<br />
with operations regulations, the important element of how operators arrange contracts with<br />
service providers may be overlooked. How these contracts are arranged and constructed<br />
should be of interest to NAAs in determining the standards against which operators audit<br />
third-party contractors.<br />
<strong>EASA</strong>AR1. <strong>EASA</strong> to require all NAAs to establish and maintain a monitoring programme<br />
of de-icing / anti-icing service providers exercising activities on their territory.<br />
This requirement will exist in the new Authority Requirements, but may not be<br />
implemented fully by all States. AR.GEN.305 Monitoring of activities –<br />
requires NAAs to conduct oversight of non-certified bodies and personnel<br />
when they are conducting activities on their territory – such programmes and<br />
audit schedules shall be proportionate. A unified purpose for such<br />
programmes would encourage their development and use, and also provide<br />
useful feedback which could be compared between States.<br />
<strong>EASA</strong>AR2. <strong>EASA</strong> to develop guidance for NAAs in how to implement a monitoring<br />
programme of de-icing / anti-icing service providers in compliance with<br />
AR.GEN.305.<br />
<strong>EASA</strong>AR3. <strong>EASA</strong> to amend AMC2 AR.GEN.300 Continuing Oversight Ops – to include<br />
an operator’s arrangements for ground-handling.<br />
Ill-conceived contracts and arrangements made with de-icing / anti-icing<br />
providers can be a source of confusion, or worse. AMC 2 AR.GEN.300<br />
Continuing oversight OPS – specifies a list of items which an operator should<br />
at least be subject to inspections and monitoring by the Authority. Although<br />
not an exclusive list, the inclusion of an operator’s arrangements for ground-<br />
airsight GmbH 54
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