Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B <strong>EASA</strong>.2009.OP.21 The management and organisation of an AOC holder (a) General An operator must have a sound and effective management structure in order to ensure the safe conduct of air operations. Nominated post holders must have managerial competency together with appropriate technical/operational qualifications in aviation. (b) Nominated post holders: 1. A description of the functions and the responsibilities of the nominated post holders, including their names, must be contained in the Operations Manual and the Authority must be given notice in writing of any intended or actual change in appointments or functions. 2. The operator must make arrangements to ensure continuity of supervision in the absence of nominated post holders. 3. A person nominated as a post holder by the holder of an AOC must not be nominated as a post holder by the holder of any other AOC, unless acceptable to the Authorities concerned. 4. Persons nominated as post holders must be contracted to work sufficient hours to fulfil the management functions associated with the scale and scope of the operation. (c) Adequacy and supervision of staff: 2. Ground Staff (i) The number of ground staff is dependent upon the nature and the scale of operations. Operations and ground handling departments, in particular, must be staffed by trained personnel who have a thorough understanding of their responsibilities within the organisation. (ii) An operator contracting other organisations to provide certain services retains responsibility for the maintenance of proper standards. In such circumstances, a nominated post holder must be given the task of ensuring that any contractor employed meets the required standards. This Regulation details the need for the operator to appoint a nominated post-holder whose responsibilities implicitly include ensuring that sub-contracted de-icing / anti-icing service providers meet the required standards. Which nominated post-holder is not specified (operators may choose either the flight or ground operations nominated post-holders). JAA ACJ OPS 1.175(i) does not insist on any requirements for knowledge or experience of deicing / anti-icing amongst its nominated post-holders. Furthermore, this Regulation only requires ground staff to have a thorough understanding of their responsibilities and not airsight GmbH - 10 -
INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B <strong>EASA</strong>.2009.OP.21 necessarily the technical complexities of sub-contracted services. Requiring operators to nominate one single person as their de-icing / anti-icing “coordinator/expert/post-holder” may improve communication between all departments, and also with the NAA. The results of our Study show that de-icing / anti-icing experience and knowledge within operators’ organisations are fragmented, and therefore one assumes the decision-making process on matters concerning de-icing / anti-icing is not efficient. Providing more detailed supporting information detailing the roles and responsibilities of nominated post-holders may also have the same effect. The act of nominating a focal-point, any necessary in-house training, and any subsequent establishment of new procedures can all be achieved within the existing management organisation; however, the benefits derived from improved coordination, communication and awareness could be substantial. OPS 1.175 (m) General rules for air operator certification The operator must arrange appropriate ground handling facilities to ensure the safe handling of its flights. This is more like an Essential Requirement, high level regulation, than an Implementing Rule. There is no expansion or explanation, however, accepting de-icing / anti-icing as a groundhandling operation, this Regulation would apply. In practice the de-icing / anti-icing facilities are often owned and managed by the aerodrome management, which is often separate from the de-icing / anti-icing service provision. Therefore, this requirement will need to be met by the operator through the quality system oversight of both aerodromes and service providers. The Regulation could be amended to state that the operator must ensure through the quality system etc, this is merely cosmetic, but it would be appropriate. Otherwise, far more detailed information could be given to explain to operators exactly what is required, both in the Rule and as supporting information. No great positive or negative impact to be made from these options. OPS 1.205 Competence of operations personnel airsight GmbH - 11 -
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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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