Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 conducting quality inspections and audits, attaining feedback, and then assuring remedial action is undertaken to rectify any deviations. There are options for EASA to propose amendments to EU OPS such that clear direction concerning sub-contracted services is addressed. However, the Agency has already indicated (NPA 2009 – 02a) that it supports the use of the existing JAR OPS 1 section 2 material, as issued through JAA TGL 44, until such time as it releases its own operations regulations and supplementary material. This issue is addressed through the proposed AMC to OR.GEN.205. Amending EU OPS would be a wasted effort due to its projected short life expectancy. Any effort would be better focused on ensuring EASA Part Ops met any desired requirements to improve performance. Therefore any recommendations to change EU OPS also need to consider the proposed EASA OPS regulations. OPS 1.037 Accident prevention and flight safety programme (a) An operator shall establish and maintain an accident prevention and flight safety programme, which may be integrated with the quality system, including: 1. programmes to achieve and maintain risk awareness by all persons involved in operations; and 2. an occurrence reporting scheme to enable the collation and assessment of relevant incident and accident reports in order to identify adverse trends or to address deficiencies in the interests of flight safety. The scheme shall protect the identity of the reporter and include the possibility that reports may be submitted anonymously; and 3. evaluation of relevant information relating to accidents and incidents and the promulgation of related information, but not the attribution of blame; and 4. a flight data monitoring programme for those aeroplanes in excess of 27 000 kg MCTOM. Flight data monitoring (FDM) is the pro-active use of digital flight data from routine operations to improve aviation safety. The flight data monitoring programme shall be non-punitive and contain adequate safeguards to protect the source(s) of the data; and 5. the appointment of a person accountable for managing the programme. (b) Proposals for corrective action resulting from the accident prevention and flight safety programme shall be the responsibility of the person accountable for managing the airsight GmbH - 8 -
INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 programme. (c) The effectiveness of changes resulting from proposals for corrective action identified by the accident and flight safety programme shall be monitored by the quality manager. This Regulation is very much “interpreted” to be aimed at the operator, and personnel employed by the operator, and it is not clear that it extends to sub-contracted service providers and their personnel. Also this regulation has an emphasis on accident and incident reports, and not on safety data per se (of the type associated with Human Factors that might be appropriate to de-icing / anti-icing operatives). The supplementary information contained within JAA ACJ OPS 1.037(a)(2) does not expand on this emphasis and does not improve interpretation of the Regulation. Amending this Regulation to address the need for operators to collect safety data from subcontracted service providers and their personnel would make it clear that this is required (and beneficial). The inclusion of ICAO SMS Standards within Part Ops may achieve this task. Providing expanded and more explicit explanatory, and/or supplementary material may help operators interpret and follow the requirements. A broadening of operators’ safety focus, the integration of sub-contracted service providers, and the provision of more explanatory material within operators’ SMS’s will have a positive impact on safety. OPS 1.175 (i) General rules for air operator certification The operator must have nominated post holders, acceptable to the Authority, who are responsible for the management and supervision of the following areas: 1. flight operations; 2. the maintenance system; 3. crew training; and 4. ground operations. Appendix 2 to OPS 1.175 airsight GmbH - 9 -
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Research Project EASA.2009/4 Regula
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INTERIM REPORT - INTRODUCTION EASA.
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Interim Report - Introduction - EASA

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