Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE EASA.2009.OP.21 Proposed Implementing Rules as contained within EASA NPAs 2008-22 and 2009-02 improve the situation slightly, however, there is great scope for improving these further: − AR.GEN.030(a) Mutual Exchange of Information – requires Authorities to share all necessary information taken as a result of oversight of persons and organizations exercising activities on the territory of a Member State. However, service providers are not included as they are not directly within the oversight of the Authorities unless such data is obtained as a result of the oversight of operators. − AR.GEN.040(a) Reporting – requires NAAs to notify the Agency of any safety significant occurrences in addition to those required in Directive 2003/42/EC. No explanation is given as to what is meant by “significant”, leaving the way clear for different interpretation. − AMC 2 AR.GEN.300.2 Continuing oversight OPS – how an operator oversees all ground-handling services is omitted from the list of areas the Authority should at least inspect and monitor. − AMC 2 to OR.GEN.200(a)(2) Management System – fulfils the requirements of ICAO SMS SARPs, with some additional parameters. However, it still does not categorically focus the operator onto the collection of reports of “unsafe acts” from contractor organisations. However, without this data, an operator will not be able to fulfil other elements of the Rule; i.e. to identify all the hazards associated with de-icing / antiicing, assess the associated risk and make interventions to improve safety performance in this area. The outcome of this Rule depends on the interpretation. − AMC 2 to OR.GEN.200(a)(4) Management System, Training and Communication on Safety – this requires the organisation to establish communication so that safety matters can be explained. This is limited to within the operators own organisation. − AMC to OR.GEN.200(a)(5) Management System, Occurrence Reporting – in contradiction to the title, this mirrors EU OPS 1.037 and only highlights the need to report Incidents and Accidents, therefore excluding “unsafe acts” and other valuable safety data. − AMC to OR.GEN.205 Contracting and purchasing – this re-introduces JAA AMC OPS 1.035 material on quality assurance of contracting organisations. It also clearly requires operators to specify in their contracts with service providers what safety services and safety related activities should be undertaken; thus providing a mechanism to include the collection, analysis and provision of specific safety data. airsight GmbH 23
INTERIM REPORT – OPTIONS FOR CHANGE EASA.2009.OP.21 The thrust behind all ICAO SARPs for SMS is clear: that it is the responsibility of all organisations across the aviation industry to identify hazards in all areas of operation, assess them for risk and take mitigating actions where necessary. That this should include the hazards encountered by de-icing / anti-icing operatives is unquestioned. The fact that such data is not being collected, analysed and/or shared is evident from our Study. There are several options available to ensure an improved situation in these respects, and they are detailed below. SAF1. Conduct an Industry-wide collaborative safety initiative: including data collection and analysis; awareness activities; and development of recommendations and, where possible, tools. Recommended. An Industry-wide Safety Initiative, involving all stakeholder groups including service providers, and having the primary aim of obtaining good quality safety data concerning de-icing / anti-icing operations. To achieve this, service providers would require support and guidance to establish effective reporting cultures. Such a Safety Initiative could be launched and facilitated in many ways, including by: SAF1.a. EASA alone. SAF1.b. EASA in partnership with Industry; perhaps through the ESSI. SAF1.c. EASA in conjunction with Member State NAAs. SAF1.d. Industry alone; perhaps through FSF, IATA, the airline Associations etc. SAF2. Reinterpret existing regulations for operators and aerodromes to motivate greater collection and analysis of relevant safety data. Recommended. Existing Rules for operators and aerodromes could be re-interpreted to ensure that the relevant safety data is collected. This would require EASA and NAA collaboration and cooperation. As no amendments to regulations would be required under this option, a great deal of explanatory material would be necessary. The appropriate Regulatory mechanisms include those listed above for SMS and Occurrence Reporting. Such reinterpretation may best be served by the use of AMC and GM produced by NAAs. SAF3. Amend proposed EASA regulations for authorities and operators to ensure effective collection and analysis of relevant safety data. airsight GmbH 24
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