Interim Report - Introduction - EASA

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
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