Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B <strong>EASA</strong>.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 airsight GmbH - 52 -
INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B <strong>EASA</strong>.2009.OP.21 operators. Supporting such proposals is an option for improvement; as is encouraging the provision of guidance for NAAs specifically on how operators can/should improve their oversight of deicing / anti-icing service providers. Time will tell whether the adoption and implementation of performance-based regulation will make an impact on operators’ oversight of service providers; however, if applied in a spirit of positive safety culture, and support provided to service providers to change their culture, the impact on safety should be positive. AMC 2 AR.GEN.300 Continuing oversight OPS OPERATIONS INSPECTIONS AND MONITORING PROCEDURES 2. Inspection and monitoring, on a scale and frequency appropriate to the operation, should include at least: - infrastructure - manuals - training - crew - records - maintenance - equipment - release of flight/despatch - dangerous goods - operator's management system. It would be easy for an NAA to omit inspecting how operators oversee contracted-out services as they are not specifically mentioned. Specifically how operators attempt to meet their own requirements through the contracts they hold; how they communicate and collect safety data with service providers; and what influence they have over the service providers training etc. The caveat ‘should include at least’ is a week point in this AMC. An option would be to append a suitable option such as “ground handling”, together with an airsight GmbH - 53 -
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INTERIM REPORT - INTRODUCTION EASA.
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