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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 />

across states.<br />

This paragraph also adequately highlights the multitude of stakeholders involved.<br />

1.6 The only known method for positively ascertaining that an aeroplane is clean prior to<br />

take-off is by close inspection.<br />

1.7 It is essential for all personnel to recognize that final assurance for a safe take-off rests in<br />

a thorough pre-take-off inspection or check.<br />

2.4 Numerous techniques for complying with the Clean Aircraft Concept have been<br />

developed. Proper and adequate deicing, followed by an application of appropriate anti-icing<br />

fluid, provides the best protection against contamination. A visual or physical check of critical<br />

aeroplane surfaces to confirm that the treatment has been effective and that the aeroplane is<br />

in compliance with the Clean Aircraft Concept must be carried out.<br />

The message can not be clearer: whoever conducts these checks and inspections is the last<br />

link in the chain before the person responsible (the aircraft captain) can decide whether the<br />

aircraft is airworthy or not. Yet there is no regulated method of ensuring that these checks<br />

and inspections are conducted by appropriately trained and qualified personnel to an<br />

acceptable standard. NAAs have no direct control over how this is achieved, as they<br />

delegate all responsibility to the operator. Even if operators are diligent, they have to (in<br />

practice) delegate responsibility to a multitude of different service providers and/or other third<br />

parties; each with varying capabilities, experience and possibly procedures.<br />

If NAAs/<strong>EASA</strong> take these paragraphs as critical and understand the inevitability of human<br />

error occurring amongst the cadre of inspectors and checkers, then regulatory action must<br />

be considered as a potential risk mitigation measure.<br />

To do nothing does not address the known facts highlighted simply and clearly in these three<br />

paragraphs and the history of accidents related to winter operations as indicated in the<br />

forward.<br />

5.4 At the completion of aeroplane de-icing/anti-icing, the pilot-in-command will be provided<br />

with the following information:<br />

a) fluid type;<br />

b) fluid/water ratio (Type II, III or IV only);<br />

c) start time of the final anti-icing application; and<br />

airsight GmbH - 57 -

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