Interim Report - Introduction - EASA

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INTERIM REPORT – DATA SUMMARY AND ANALYSIS <strong>EASA</strong>.2009.OP.21 exhaustive audits of de-icing / anti-icing operations. The main reasons for this are: firstly, the lack of the direct regulations to oversee (confirming the assumptions of the previous chapter), secondly, the lack of personnel responsible for de-icing / anti-icing at the Authorities, and thirdly, Quality Assurance of de-icing / anti-icing is considered to be within the responsibility of the aircraft operators. 2.3.4 National de-icing / anti-icing regulations directly applicable to aircraft operator The regulation of an aircraft operator’s de-icing / anti-icing operations is indirect, via the regulation of Air Operator Certificate (AOC) Holders (AOCH) and related requirements (EU OPS): airlines are required to establish procedures for de-icing / anti-icing (EU OPS 1.345) and to establish a Quality System (EU OPS 1.035). These regulatory requirements imposed upon airlines concerning de-icing / anti-icing are neither precise nor comprehensive, which introduces much scope for variation in the interpretation of these regulations. NAAs are therefore not required to draft additional direct regulations. Figure 26 shows the global answers provided by the aircraft operator on the NAAs’ requirements on de-icing / anti-icing (fluid types and application, as well as maintenance activities related to thickened fluids) 27 . The information provided by the study participants confirms that there are few national regulatory requirements on de-icing / anti-icing for aircraft operators. 27 Aircraft Operator Questionnaire 2 – Question 2.3: Does your National Authority impose/advise/provide/require in any of the following areas airsight GmbH - 39 -
INTERIM REPORT – DATA SUMMARY AND ANALYSIS <strong>EASA</strong>.2009.OP.21 Regulatory Requirements Acceptable Means of Compliance Recommendations and Guidance Aircraft manufacturer’s Requirements Don't know Qualification of maintenance personnel permitted to remove residues Training of maintenance personnel in the detection and removal of residues Methods for residue removal Methods for Inspecting Specified areas for inspecting Frequency of removing residues Frequency of inspections for residues No-spray/Sensitive zones Method and process of spraying Procedures to be avoided Whether to use 1 or 2 step procedure Which fluids to avoid Which fluids to use airsight GmbH - 40 - 0% 20% 40% 60% 80% 100% Figure 26: Imposition of National Authorities 2.3.5 National oversight of aircraft operator de-icing / anti-icing operations The oversight of aircraft operator de-icing / anti-icing operations are generally performed via the review and approval by the NAAs of each airline’s Operations Manual (OM), which shall include details of the winter operations plan and any relevant procedures for the flight crew. Figure 27 graphically illustrates the responses provided by aircraft operators on the methods for the approval of the winter operations programme for de-icing / anti-icing. 4% 8% 76% 12% Direct Indirect via Operations Manual No Approval required Don't know Figure 27: National Authority approval of winter operations plan/programme for deicing / anti-icing of aircraft on the ground The winter operations programmes (incl. flight crew training) are audited – as shown in Figure 28 – usually internally by the airline quality department (82%), and only in very few cases directly by the NAAs (9%).
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