Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE
EASA.2009.OP.21
4.10 Availability of de-icing / anti-icing fluid types
The Study did not reveal any mechanism currently in use by any NAA which can act as an
example of how to influence the availability of fluids at aerodromes within the Member
States. However, existing regulations may provide some possibility for Authority influence
over the types of fluid supplied at aerodromes within their territory. In considering whether a
need exists for compulsory provision of Type I fluid in all, or just some, aerodromes, regard
must be given towards the existing risks associated with residues from thickened fluids. That
is, since the raising of awareness of the issues associated with residues, and the subsequent
introduction of residue maintenance programmes, has the risk been reduced significantly?
Furthermore, if Type I fluids were made compulsory, consideration should be given to
whether operators would choose to use Type I fluids more than they currently do. Failing
any regulation to demand operators always use Type I fluid for de-icing, there is no
guarantee that there would be any increased uptake.
There are several options that can be considered, which may increase the availability, and/or
the use of, Type I fluids.
If the conditions required for an individual aircraft to maintain its Certificate of Airworthiness
included limitations on the use of certain de-icing / anti-icing fluids, then operators would be
obliged to adhere to these limitations (EU OPS 1.005 (c)). By means of the instructions for
continuing airworthiness, manufacturers could influence operators’ use of Type I fluid by:
− insisting that Type I, Type I/water mix, and hot water are the only viable de-icing fluids
acceptable, or
− defining a limit to the number of one-step de-icing / anti-icing procedures that can be
undertaken before critical areas are cleaned.
For any amendment to the TC, or issue of an STC, evidence would be required as to the
necessity. Such evidence could be forthcoming from either the manufacturer following
appropriate testing (for all fluids and combinations of fluids), or from operational data
indicating loss of airworthiness, due to thickened fluid residues, in certain circumstances.
EASA has already taken action by requesting specific information from Type Certificate
Holders [14 April 2009 PBL/ein/C(1.1) 2009(D)61465] concerning any recommended
procedures and limitations for each aircraft type. Aircraft manufacturers have already issued
Operational Notices concerning maintenance procedures for preventing and managing fluid
residues. Any regulation in this respect would need to consider the evidential affects of
thickened fluid application to each different aircraft type and the associated variation in
impact. An alternative approach could be that unless an aircraft manufacturer could provide
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