Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE
EASA.2009.OP.21
Forthcoming ARs, ORs, and Implementing Rules for Operators (eventually
aerodromes) may be amended to include specific references to de-icing / antiicing
operations and service providers to achieve the aim of collecting suitable
safety data. Furthermore, explanatory material can be produced to help NAAs
and organisations to interpret the meaning, and which clearly highlight the
need to collect data of “unsafe acts” from service providers. For example:
SAF3.a. AR.GEN.30.(a) Exchange of Information & AR.GEN.40.(a)
Reporting – interpretation of these requirements may include
guidance for Authorities to include the exchange of safety data
including “unsafe acts” arising through operators’ contracted out
service providers, and that this data is not restricted to incidents
and accidents.
SAF3.b. AMC 2 AR.GEN.300.2 Continuing Oversight Ops – this AMC can
be amended to include oversight and monitoring (as required) of
the mechanism through which operators ensure service providers
maintain an appropriate safety culture (professional attitude)
through collection of safety data – specifically self-reporting of
“unsafe acts”. This may be achieved through the inspection of
those elements of a basic contract with service providers
(excluding commercial clauses) that are relevant to safety.
SAF3.c. AMC 2 to OR.GEN.200(a)(2) Management System – can be
expanded to include the need for operators to include service
providers within their SMS as a source of safety data, such that
hazards encountered by service providers can be identified and
the associated risks to operations assessed by the operator. A
programme for achieving this may be required.
SAF3.d. AMC 2 to OR.GEN.200(a)(4) Management System, Training and
Communication on Safety – this AMC might be amended to
include the need for operators to explain safety matters to service
providers, and give support where necessary, in particular why
certain safety data should be collected and analysed.
SAF3.e. AMC to OR.GEN.200(a)(5) Management System, Occurrence
Reporting – this AMC can be expanded to include the objective of
collecting and analysing valuable data such as that obtained
through the self-reporting of unsafe acts, thereby providing an
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