Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE
EASA.2009.OP.21
evidence that their required residue management programme was effective, then they should
require operators to always use Type I in a two-step procedure.
FLUID1. Aircraft manufacturers instructions for continuing airworthiness to effectively
“ban” the use of thickened fluid.
FLUID2. Aircraft manufacturers to provide evidence that their proposed residue
management procedures are effective; otherwise, to require operators to
always use a two-step procedure with Type I in the first step.
If NAAs, or EASA, consider that de-icing with a thickened fluid produces an unwarranted
increase in risk, or that current mitigation measures are unreliable, then operators could be
mandated to always use a two-step process, and not allow thickened fluids to be used in the
de-icing phase. In effect, the regulator could re-define de-icing fluids as being only Type I,
Type I/water mix, or hot water. Again, any evidence that one-step de-icing / anti-icing does
not increase risks due to residues, provided a suitable inspection and cleaning programme is
followed, could be used to counter this concept.
FLUID3. EASA redefines de-icing fluid as being only Type I, Type I/water mix, and hot
water.
It may be possible to influence the availability of Type I fluid through NAA regulation of
aerodromes; several possibilities exist.
If a State determines that de-icing / anti-icing fluid is part of the aerodrome centralised
infrastructure/facilities (Options GHDAD2 and REGAD5 above), then it may be possible to
require that all fluid types are available to fulfil the infrastructure/facilities requirements; this
responsibility to provide all fluid types may be passed to service providers as necessary and
supported by Directive 96/97/EC on ground-handling. ICAO Doc 9640 recommends that all
de-icing / anti-icing services and fluids be planned for by the aerodrome, regardless of
whether they are used or not. This recommendation could be enforced as a requirement,
however, a safety case would need to support the enforcement.
FLUID4. NAAs mandate that all appropriate aerodromes should always offer Type I
fluids and a two-step de-icing / anti-icing procedure.
An alternative to the above strategy would be to mandate the availability of Type I fluid and
the two-step procedure whenever any “user operator” makes a formal request, based on
their own safety case, or desired procedures. Of course, this option would also necessarily
have to include Type III.
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