Interim Report - Introduction - EASA

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
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