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Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B<br />

<strong>EASA</strong>.2009.OP.21<br />

Personnel include all persons involved in the transport of dangerous goods, whether<br />

they are employees of the operator or not.<br />

This is included as a potential mechanism to be copied for de-icing / anti-icing, although<br />

ICAO Doc 9640 is inadequate as a source of Implementing Rules. The AMC demonstrates<br />

the ability for <strong>EASA</strong> to determine “what” a third-party unregulated body “should” do.<br />

It may be possible to find a way, legally, for the Agency to refer to a document produced by<br />

Industry as an accepted set of standards and procedures, this would ensure operators are<br />

harmonised with their de-icing / anti-icing programmes. References to EUROCAE or RTCA<br />

documents provide workable examples.<br />

Another option would be for the Agency to develop its own reference document; and this may<br />

be better placed as AMC to Part Ops.<br />

Finding a solution where Industry best-practices can be adopted universally as the sole<br />

standard will greatly enhance harmonisation in this field.<br />

Finding a mechanism to directly affect unregulated service providers, and their personnel, via<br />

the operator’s procedures, policies and contracts will also encourage greater harmonisation.<br />

OPS.GEN.100 Ice and other contaminants<br />

(a) At the commencement of a flight the external surfaces of the aircraft shall be clear of any<br />

deposit which might adversely affect its performance or controllability.<br />

(b) The operator shall apply ground de-icing/anti-icing processes whenever determined<br />

necessary, on the basis of inspections and weather conditions.<br />

AMC2 OPS.GEN.100<br />

GM1 OPS.GEN.100<br />

GM2 OPS.GEN.100<br />

GM3 OPS.GEN.100<br />

Comments made on this Rule and associated material are contained in an<br />

Attachment/Appendix XX to this <strong>Interim</strong> <strong>Report</strong>.<br />

There are many options to amend and improve this material, including:<br />

- offering more detailed guidance to assist operators create their procedures, such that<br />

airsight GmbH - 33 -

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