Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B
EASA.2009.OP.21
organisations): it is an option that NAAs can appoint one single person as the de-icing / antiicing
authority, whose responsibility is to coordinate oversight of this safety critical activity.
The impact would be easier and improved communication of issues between authorities, the
Agency, and operators. The success of any harmonised cooperative programmes and
initiatives will be greatly enhanced.
GM 1 AR.GEN.300 Continuing oversight OPS
1. Responsibility for the conduct of safe operations lies with the operator. Under these
provisions a positive move is made towards devolving upon the operator a share of the
responsibility for monitoring the safety of operations. The objective cannot be attained unless
operators are prepared to accept the implications of this policy including that of committing
the necessary resources to its implementation. Crucial to success of the policy is the content
of PartOR which requires the establishment of a management system by the operator.
2. The competent authority shall continue to assess the operator's compliance with the
applicable requirements, including the effectiveness of the management system. If the
management system is judged to have failed in its effectiveness, then this in itself is a breach
of the requirements which may, among others, call into question the validity of a certificate, if
applicable.
3. It is essential that the competent authority has the full capability to adequately assess the
continued competence of an operator by ensuring that the whole range of activities is
assessed by appropriately qualified personnel.
4. The safety manager, designated by the operator in accordance with PartOR, shall have
direct access to the accountable manager. The accountable manager is accountable to the
competent authority as well as to those who appoint him. It follows that the competent
authority cannot accept a situation in which the accountable manager is denied sufficient
funds, manpower or influence to rectify deficiencies identified by the management system.
This AMC clearly states the intention of performance-based regulation to devolve
responsibility for oversight away from the regulator and onto the operator; therefore, any
recommendation for NAA oversight of service providers is moving against the current
regulatory impetus, and may be met with resistance on this fact alone. The operators’
management systems do have to prove themselves capable though, and in this respect the
NAA can legitimately require more scrutiny and the submission of more evidence from
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