“Global Safety Management: Revolution or Evolution?”

Operations and Licensing Part 2

Summaries, Conclusions, and Action Items 2

Major Discussion Points

• Overview of responsibilities of states, operators, and ICAO.

• ICAO has standard minimum content and layout of AOC and operations specifications (effective 2010).– Development of International AOC register—Annex 6, Doc

8335

• International Cooperation– Exchange of safety data through ICAO and bi-and multi-

laterally– Mutual recognition under Article 33– Reciprocal acceptance/validation under bilateral agreements– Cooperation between State of Operator and state of operations

Summaries, Conclusions, and Action Items 3

Major Discussion Points (cont)

• Operations Specifications remain necessary at some level, including conditions, limitations, technical permissions to assist surveillance.

• FAA is revising Part 129 to remove overlap between regulation and op specs.

• EASA will issue NPA for international operations around same time as NPA for ops. – Will include examination of existing safety information, which

could lead to an investigation.– Includes operator declaration of compliance with requirements

• Enforcement of non-compliance under laws of member state

Summaries, Conclusions, and Action Items 4

Reaction from the Floor

• Should have single universal ICAO-based op specs document in one language– This would not obviate right of contracting states to determine

compliance.

• Part 135 operators have similar issues• ICAO and EASA’s concept of self-declaration• Legislator concerns are behind requirements such

as part 129, SAFA, etc. Mutual confidence needs to be established bilaterally until universal compliance at ICAO level is established.

Summaries, Conclusions, and Action Items 5

Reaction from the Floor (cont)

• Grandfathering/reciprocal acceptance between EASA and FAA?

• Concern about proliferation of additional requirements within op specs

• Concern about proliferation of audits. – Suggestion for one audit document (eg IOSA) that

will satisfy FAA, EASA, Australia, etc.

Summaries, Conclusions, and Action Items 6

Reaction from the Floor (cont)

• ICAO requirement that flight time limitations be based on scientific principles

• How to prevent punishing the carrier if its authority doesn’t meet standards

Summaries, Conclusions, and Action Items 7

Reaction from the Floor (cont)

• Questions for EASA:– Any advance info on what EASA fees and charges

on carriers will look like

– Credit to third country operators that meet the intent of declaration requirement (part 2 annex 6) through national rules such as FAR 91.501.

Summaries, Conclusions, and Action Items 8

Outcomes/Additional Ideas

• EASA and FAA agreed to look at areas of reciprocal acceptance that can be addressed under the US-European Community safety agreement.

– Based on mutual confidence achieved through a documented assessment process that will take some time.