Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 The operator should ensure that the subcontractor complies with the operator’s quality and training/qualification requirements together with the special requirements in respect of: a. De-icing and/or anti-icing methods and procedures; b. Fluids to be used, including precautions for storage and preparation for use; c. Specific aeroplane requirements (e.g. no-spray areas, propeller/engine de-icing, APU operation etc.); d. Checking and communications procedures. Ostensibly this Rule together with the associated supporting material and one of the better reference documents (AEA Recommendations) should be enough for an operator to establish suitable and safe procedures appropriate to all personnel involved and covering all aspects of de-icing / anti-icing operations, including contingency procedures. However, there is no link to an “acceptable” set of procedures, nor a standard template for both procedures and training syllabus. Furthermore, there is no direct requirement for an operator to establish coordination and communication procedures between flight operations, flight crew, aerodromes and service providers, adequate for all their destinations. 1. It is an option to review the supporting material and re-present it in more easily digestible chunks; this would also allow for a division of what is definitely required and what is recommended as well as the expected (or demanded) minimum standards acceptable. This is partially proposed in AMC.2.OPS.GEN.100. 2. A template for operators’ procedures could be included. 3. Another option would be for each operator’s de-icing / anti-icing procedures to be accepted/approved by the Authority: option 2 would also then be required. 4. A strong connection can be made here towards OPS 1.175, 1.205 and 1.210 to emphasise that procedures are required for ground staff and also to highlight the nominated post-holder’s responsibilities. 5. A requirement can be added to ensure that operators develop and use adequate coordination and communication procedures that are effective at all their destinations where de-icing / anti-icing is undertaken. 6. A connection can also be made to OPS 1.037 to emphasise the need for operators to improve the collection (and analysis) of occurrence and human factors reports from deicing / anti-icing service providers; and this element may need to be included in any contracts. airsight GmbH - 14 -
INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 1. The impact would be a clarification and perhaps a move towards more standardisation; the process would allow for further progress in other areas of de-icing / anti-icing if it involved industry expertise. 2. This is easily included in option 1, and it would further increase the move towards standardisation (from the operators’ point of view). 3. Likely to incur more work for both operators and NAAs, and also some cost in NAA manpower. This will further motivate operators to standardise their procedures and also NAAs to demand this. 4. As this is reinforcing already existing Rules there should be no effort required, but it may ensure better coordination and communication between flight operations, ground staff, flight crew, aerodromes, and service providers. 5. Creating more procedures and training will require time and effort, however, it should ensure better coordination and communication between flight operations, ground staff, flight crew, aerodromes, and service providers. 6. This would be of great benefit, as currently very little safety data is collected and analysed on the occurrences that de-icing / anti-icing operatives encounter. OPS1.420 Occurrence Reporting This Rule covers the need for the operator’s employees to file occurrence reports, but does not cover the need to encourage sub-contractors to file reports. No mention is made of human factors reporting. Reinforcement of OPS 1.037 could be made here by requiring operators to establish the procedures by which third-parties can file occurrence reports, and the need for the operator to promote this. Little effort required; the clause can be inserted when contracts are renewed, but before then voluntary schemes may develop alongside safety awareness programmes. These programmes can be delivered at the same time as operator specific requirements for de-icing / anti-icing are delivered. The result should be: directly – an increase in safety data available for analysis; and indirectly – greater safety awareness and improved culture amongst service providers. airsight GmbH - 15 -
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Interim Report - Introduction - EASA

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