Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B
EASA.2009.OP.21
explanation, or guidance material.
The impact would be clearer instructions for NAAs to take some notice of how effective
operators are at influencing the standards set by service providers.
AMC 3 AR.GEN.305 Monitoring of activities OPS
1. The competent authority should establish a schedule of inspections appropriate to each
operator's business. The planning of inspections should take into account the results of the
hazard identification and risk assessment conducted and maintained by the operator as part
of the operator’s management system. Inspectors should work in accordance with the
schedule provided to them.
Assuming that the operator’s SMS is effective and suitably resourced, this AMC could be
effective. However, unless NAAs are specifically looking to learn whether operators are
collecting adequate safety data from service providers with which to effectively identify all
hazards, the effects of this AMC will be less than desired. Similarly, to limit (in this respect)
inspections to only cover the results of an operator’s hazard identification and risk
assessment system, deters the NAA scope to inspections in response to valid safety data
attained from elsewhere.
It may help to define clearly that inspections programmes ought to take account of any
relevant safety data regardless of source (eg FAA, FSF, ERA, other operators etc). A
dedicated safety initiative would help to inform NAAs of the hazards that exist in the Industry.
This would have the effect of NAAs helping to cross-fertilise best-practices across operators.
AMC to AR.OPS.300 Certification procedure OPS
PROCEDURES FOR THE APPROVAL OF CARRIAGE OF DANGEROUS GOODS
The competent authority should verify that:
1. the applicant is in compliance with the applicable requirements and recognized standards;
2. the procedures specified in the procedures manual are sufficient for the safe transport of
dangerous goods;
3. operations personnel is properly trained; and
4. a reporting scheme is in place.
This is shown as an example, if de-icing / anti-icing was ever considered as requiring special
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