Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B
EASA.2009.OP.21
icing/anti-icing programme or procedures.
The de-icing/anti-icing programme shall:
− clearly define areas of responsibility for the operator
− cover all locations within the operator’s route network including de-icing/anti-icing
accomplished by subcontract..
All persons involved in ground de-icing/anti-icing activities shall be trained and
qualified in the procedures, communications and limitations of their area of
responsibility.
This SARP is complied with in OPS 1.1045 (OM), however, ICAO recommends (Doc 9640)
that the operator’s de-icing / anti-icing programme, or procedures, is “approved” by the NAA.
There is special focus on responsibilities and training. Attachment F to Annex 6 Part 1 (AOC
& Validation) does not include de-icing / anti-icing as an item that needs Authority “approval”
(para 3.3); it refers only to the contents of the OM as requiring “acceptance” through a
technical evaluation.
4.3.2 The State’s technical evaluation should, in addition to ensuring that all required
contents are addressed, consider if the specific policies and procedures would result
in the desired outcome.
It can be deduced that an Authority’s technical evaluation must consider whether the
operator’s policy and procedures would work at all of the operator’s destinations where deicing
/ anti-icing is expected. Therefore this evaluation is dependant on the facilities,
procedures and equipment available at each location; making the evaluation dependant on
aerodrome management and/or service providers.
It is an option for NAAs/EASA to amend their regulations to conform with Annex 6 as
interpreted by Doc 9640, and use an approval process for operator’s de-icing / anti-icing
programmes, or procedures.
Also, another option would be to limit the approval to particular elements of the programme,
in particular the training syllabus and methods, and responsibilities of all those involved. This
could be extended to the contents of contracts with service providers.
An alternative would be for NAAs/EASA to specify (through means of an AMC) the contents
of an operator’s de-icing / anti-icing programme, and the standards to be achieved; then any
operator wishing to deviate from this would need an approval.
The problem remains as to whether the operator’s policy and procedures/programme is
applicable and viable to all of the operator’s destinations. One solution would be for a
universal audit programme to be used by all operators, acceptable to NAAs/EASA, and
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