Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 d) confirmation that the aeroplane is in compliance with the clean aircraft concept. This basic information will assist the pilot-in-command in estimating an appropriate holdover time from the range provided in the operator’s table. There is no reference as to who passes this information, however, it can be clearly inferred that it is the intention for this information message (anti-icing code) to include confirmation that the “clean wing concept” applies, and that the person who confirms this is the person conducting the post treatment check, as per para 2.4 above. In fact this should apply to any external check – either the aircraft is “clean” or not. It will be helpful to require (clearly and directly) all operators to ensure that whoever they use to conduct external checks is both trained and qualified to do so and that only such a person can pass the final element of the anti-icing code. This may reduce some uncertainty by ensuring operators cover this aspect clearly in their contracts, and where a service provider will not (for whatever reason) provide this confirmation, that a suitable third-party is used. CHECKS AFTER THE APPLICATION OF DE-ICING/ANTI-ICING FLUIDS 6.3 A check to ensure compliance with the Clean Aircraft Concept is made immediately following the application of deicing/anti-icing fluids and is carried out by a qualified person in accordance with the approved operator plan and procedures. 6.4 The pre-take-off check, which is the responsibility of the pilot-in-command, ensures that the critical surfaces of the aeroplane are free of ice, snow, slush or frost just prior to take-off. This check shall be accomplished as close to the time of take-off as possible and is normally made from within the aeroplane by visually checking the wings or other surfaces. 6.5 The pre-take-off check procedures are a critical part of the ground operation and become the only means by which the pilot-in-command can ensure that the aeroplane is in compliance with the Clean Aircraft Concept prior to take-off. If stipulated by the regulatory authority, aeroplane manufacturer, or operational specification or if requested by the pilot-incommand, an external check of aeroplane critical surfaces shall be conducted by qualified ground personnel. 6.6 The pilot-in-command has the responsibility to continually monitor the weather and aeroplane condition to ensure compliance with the Clean Aircraft Concept. If this requirement cannot be satisfied by either an internal or external check of aeroplane critical surfaces, then another de-icing/anti-icing of the aeroplane must be accomplished. Special equipment or airsight GmbH - 58 -
INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 procedures may be required to carry out this check at night or under severe weather conditions. It is clear that any external check should be conducted by a qualified person. As these checks should be in accordance with the operator’s plan and procedures, the operator shall stipulate, or agree to, the training and qualification standard required. Reinforcement can be made of the need for external checks to be conducted by a trained and qualified person, and a clear connection made with the final element of the anti-icing code. This may reduce some uncertainty by ensuring operators cover this aspect clearly in their contracts, and where a service provider will not (for whatever reason) provide this confirmation, that a suitable third-party is used. Authority’s Responsibilities 7.1 The regulatory authority ensures that every operator shall have an approved deicing/anti-icing programme or procedures. The programme shall require that operators comply with the Clean Aircraft Concept. 7.3 The de-icing/anti-icing programme shall clearly define areas of responsibility for the operator. All persons involved in ground de-icing/anti-icing activities shall be trained and qualified in the procedures, communications and limitations of their area of responsibility. The de-icing/anti-icing programme shall cover all locations within the operator’s route network including de-icing/anti-icing accomplished by subcontract. In Europe, NAAs do not approve operators’ de-icing / anti-icing plans, policies, procedures or programmes. “Ensuring that every operator shall have an approved programme or procedures” may be interpreted differently if the NAA offered AMC. NAAs/EASA can be encouraged to agree (create) an AMC, in support of robust rules, which operators can adopt and gain tacit approval, or request specific approval for variations/deviations. A coordinated development programme would be needed, however, there is sufficient expertise and knowledge readily available that this should be relatively simple. The largest problem would be acquiring subject-matter-experts appointed by each NAA to participate. The positive impact would be greater harmonisation of operators procedures and/or programmes, which may impact positively on standards of service provision. airsight GmbH - 59 -
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Interim Report - Introduction - EASA

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