Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 EC/EASA Reg 2042/2003 Amendment 4, 5 March 2010 EASA - PART M/PART 145 & AMC TO PART M Applicability: Direct Requirements enforced by Member States on entities. CA of aircraft registered in Member State, or operated by entity overseen by a Member State. Options: Consideration could be given to including de-icing / anti-icing as a maintenance task, instead of an operational task. Impact: The financial and political impacts would be great in terms of reorganising the Industry, which in itself will introduce risks. Other impacts would need to be investigated. Article 2 Definitions (d) ‘continuing airworthiness’ means all of the processes ensuring that, at any time in its operating life, the aircraft complies with the airworthiness requirements in force and is in a condition for safe operation (h) ‘maintenance’ means any one or combination of overhaul, repair, inspection, replacement, modification or defect rectification of an aircraft or component, with the exception of pre-flight inspection; Article 3 2. Organisations and personnel involved in the continuing airworthiness of aircraft and components, including maintenance, shall comply with the provisions of Annex I and where appropriate those specified in Articles 4 and 5 (Organisation approvals and certifying staff respectively). AMC M.A.201 (h) Responsibilities * 2. The performance of ground de-icing and anti-icing activities does not require a maintenance organisation approval. Nevertheless, inspections required to detect and when necessary eliminate de-icing and/or anti-icing fluid residues is considered airsight GmbH - 82 -
INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 maintenance. Such inspections may only be carried out by suitably authorised personnel. De-icing / anti-icing could fit within the above definitions: cleaning ice off the airframe and maintaining a clean wing during snow is the process of ensuring a condition for safe operation and therefore can be interpreted as continuing airworthiness; and, applying thick fluid on the wings could be interpreted as a temporary maintenance modification. De-icing / anti-icing could be declared a maintenance task, in the same manner that cleaning of residues has been declared as a maintenance task. De-icing / anti-icing operatives would need to hold appropriate licenses/certificates, and their employer organisations approved. The impact would be great: some service providers would go out of business, some airlines would need to employ more staff, NAAs would need to conduct more approval/licensing/certifying tasks etc. M.A.201 Responsibilities (d) The pilot-in-command or, in the case of commercial air transport, the operator shall be responsible for the satisfactory accomplishment of the pre-flight inspection. This inspection must be carried out by the pilot or another qualified person but need not be carried out by an approved maintenance organisation or by Part-66 certifying staff. From EU OPS we know that the person who conducts the contamination check must be trained and qualified, as is repeated here, however, in both documents no standard is specified. A qualifying standard could be defined for personnel who conduct de-icing / anti-icing checks and inspections. A definition would be helpful. AMC M.A.201 (h)1 Responsibilities (*) 7. The operator’s management controls associated with sub-contracted continuing airworthiness management tasks should be reflected in the associated written contract and be in accordance with the operator’s policy and procedures defined in his continuing airworthiness management exposition. When such tasks are sub-contracted the operator’s airsight GmbH - 83 -
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