Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE
EASA.2009.OP.21
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operator with an insight into potential accident pre-cursors and
areas of high risk. It may be made clear that this data should be
sought not only from the operator’s own personnel and employees,
but also from those personnel working for service providers
conducting contracted-out safety critical functions.
SAF3.f. AMC to OR.GEN.205 Contracting and purchasing – clarification
can be provided to this AMC such that SMS activities, including
reporting of “unsafe acts”, are included in the written agreement
between operator and service provider, as well as details of the
safety services to be provided. The written agreement referred to
could be subject to oversight and monitoring as required under
AMC 2 AR.GEN.300.2, mentioned above in Option SAF3.b.
SAF4. To conduct an Industry-wide review of, and lobby for amendment to, Directive
2003/42/EC on Occurrence Reporting; in order to align the Directive with
ICAO SMS requirements. Thereby encouraging States to meet the needs of
the Directive and encouraging a harmonised interpretation.
SAF4.a. NAAs to ensure that the intent of the Directive is enforced: the
need for all personnel to report occurrences (Clause 7); and the
need to share this information (Clause 8).
SAF4.b. Lobby to amend, or expand, the definition of “occurrence” to
include specifically: human, procedural and system errors
considered by the reporter to increase risk.
SAF4.c. Lobby to expand the Scope of the Directive (Article 3), to include
specifically de-icing / anti-icing activities, by including examples in
the Appendix to Annex I.
SAF4.d. NAAs to take up their responsibilities to ensure de-icing / anti-icing
operatives comply with mandatory occurrence reporting (Article 4,
1.g) and they shall (rather than may) encourage voluntary reporting
(Article 9).
SAF4.e. NAAs to interpret the Directive from the point of view of de-icing /
anti-icing operations and issue relevant awareness and guidance
material.