Interim Report - Introduction - EASA

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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 airsight GmbH - 26 -
INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 applied to all service providers. Both the first two options would incur effort on the part of the NAAs; the amount of effort will depend on the mandatory elements and detail required for approval. There is no guarantee for harmonisation using the full approval method unless NAAs/EASA define carefully each element and the standards required. The third option would result in less effort from NAAs and more likelihood of harmonisation amongst operators. Flight preparations – Weather Conditions 4.3.5.4 A flight to be planned or expected to operate in suspected or known ground icing conditions shall not take off unless the aeroplane has been inspected for icing and, if necessary, has been given appropriate de-icing/anti-icing treatment. Accumulation of ice or other naturally occurring contaminants shall be removed so that the aeroplane is kept in an airworthy condition prior to take-off. Note.— Guidance material is given in the Manual of Aircraft Ground De-icing/Anti-icing Operations (Doc 9640). OPS 1.345 Ice and other contaminants — ground procedures (a) An operator shall establish procedures to be followed when ground de-icing and anti-icing and related inspections of the aeroplane(s) are necessary. (b) A commander shall not commence take-off unless the external surfaces are clear of any deposit which might adversely affect the performance and/or controllability of the aeroplane except as permitted in the Aeroplane Flight Manual. This SARP is covered by OPS 1.345, which inherently (but not clearly) covers also post deicing / anti-icing inspections and pre-take-off contamination checks, which the SARP does not. An option would be to expand on this SARP and include in NAA/EASA regulations a clear requirement for both pre and post-de-icing / anti-icing checks/inspections, as well as other checks/inspections whenever doubt exists concerning the state of the external surfaces. This could be expanded upon by requiring the operator’s de-icing / anti-icing procedures to specifically include details of check/inspection procedures together with the coordination and communication processes to cater for all variations of location, equipment and contract that the operator currently is exposed to. airsight GmbH - 27 -
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