Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 can/cannot be used, via the aircraft manufacturer. It is currently normal that manufacturers indicate that airworthiness is compromised by contamination (eg ice, snow, slush etc) on aircraft surfaces, and it should already be made clear in the AFM whether certain amounts of certain contamination (eg frost) on certain surfaces is acceptable and in compliance with the CoA. No options or need to change this rule. 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. OPS 1.035 Quality system (a) An operator shall establish one quality system and designate one quality manager to monitor compliance with, and adequacy of, procedures required to ensure safe operational practices and airworthy aeroplanes. Compliance monitoring must include a feed-back system to the accountable manager (see also OPS 1.175 (h)) to ensure corrective action as necessary. (b) The quality system must include a quality assurance programme that contains procedures designed to verify that all operations are being conducted in accordance with all applicable requirements, standards and procedures. It is through this Rule that airlines are obliged to ensure that their own procedures are adequate to ensure airworthy aeroplanes. Furthermore, as well as meeting regulatory requirements, the airline must verify that all operations are being conducted in accordance with all applicable standards and procedures. There is no definition or explanation of what these standards and procedures may include. EU OPS has no supporting material, and no mention is made to contracted-out services. Whereas JAR OPS 1, Section 2 used to provide interpretive information (some excerpts below) especially AMC OPS 1.035. 5.1 dealing directly with sub-contractors: JAA AMC OPS 1.035 2.3 Purpose of the Quality System airsight GmbH - 6 -
INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 2.3.1 The Quality System should enable the operator to monitor compliance with JAR-OPS 1, the Operations Manual, the Operator's Maintenance Management Exposition, and any other standards specified by that operator, or the Authority, to ensure safe operations and airworthy aircraft. This gives the Regulatory Authority the power to specify standards of de-icing / antiicing, and one assumes to then allow, for example, AEA Recommendations as AMC? Similarly, if the airline (operator) should opt to follow the AEA Recommendations and make it a requirement, then a functional Quality System should assure that these standards are achieved and maintained. 2.4.4.c. The Quality Manager should have access to all parts of the operator’s and, as necessary, any sub-contractor’s organisation. 4.2.2.b. Typical subject areas for quality inspections are Ground De-icing/Anti-icing; It is not made clear here whether this applies to the airline’s own procedures or those of a sub-contractor. 5.1 Sub-Contractors 5.1.1.a. Operators may decide to sub-contract out certain activities to external agencies for the provision of services related to areas such as Ground De-icing/Antiicing; 5.1.2 The ultimate responsibility for the product or service provided by the subcontractor always remains with the operator. A written agreement should exist between the operator and the sub-contractor clearly defining the safety related services and quality to be provided. The sub-contractor’s safety related activities relevant to the agreement should be included in the operator’s Quality Assurance Programme. 5.1.3 The operator should ensure that the sub-contractor has the necessary authorisation / approval when required and commands the resources and competence to undertake the task. If the operator requires the sub-contractor to conduct activity which exceeds the sub-contractor’s authorisation/approval, the operator is responsible for ensuring that the sub-contractor’s quality assurance takes account of such additional requirements. Regardless of whether a service provider is authorised (licensed/certificated) and/or approved, the operator is still responsible for ensuring its procedures are followed and standards maintained. This is achieved through writing an effective agreement (contract), airsight GmbH - 7 -
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Research Project EASA.2009/4 Regula
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EASA.2009.OP 21 Study on the regula
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INTERIM REPORT - INTRODUCTION EASA.
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INTERIM REPORT - DATA SUMMARY AND A
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Interim Report - Introduction - EASA

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