Update – CAA and EASA regulations and standards

Published:  02 March, 2015

During the AFOA conference (Dublin January 20-21, 2015) a regulatory update was provided by Neil Gray (Principal RFFS Inspector – Civil Aviation Authority). CAA priorities for 2015 include a transition process that sees in-scope aerodromes moving from compliance with the requirements of CAP168, to compliance with Commission Regulation (EU) 139/2014 (EU Rules).

At the time of the conference, eight of the 50 in-scope aerodromes had successfully completed the process. CAA is also going through a process of transformation to become a performance-based regulator, with better regulation principles (proportionality, accountability, consistency, transparency, targeting).

Guidance for Aerodrome Rescue and Firefighting Service (RFFS) task and resource analysis (TRA) has been reviewed and updated in the form of CAA Information Notice 141/2014. CAA have also worked with the Chief Fire Officers Association (CFOA) to ensure that aerodrome operators and their local authority fire and rescue service partners fully understand the conclusions of the TRA process, and the associated risks. CFOA provided guidance to Chief Fire Officers through its Directorate Programme.

Following the tragic crash involving a Super Puma helicopter on its approach to Sumburgh Airport in August 2013, Air Accident Investigation Branch (AAIB) made some safety recommendations within their report regarding the provision of rescue resources, and the associated risks, for such incidents. Whilst the focus of the safety recommendations was the accident near to Sumburgh Airport, CAA has taken a wider view and, with the support of the aerodrome operator, has conducted a difficult environs survey with the aim of providing guidance to all aerodrome operators on the planning for emergency response to such areas.

The implementation of Commission Regulation (EU) 139/2014 has introduced some potential changes to the requiremenst for RFFS training. The EU rules do not specifically require RFFS personnel to hold a certifcate of competence as required by CAP168, and no provision is made for the accreditation of RFFS training providers by CAA. Working with the Airport Operators Association (AOA) RFFS working group, it has been agreed that the current framework for the training and assessment of RFFS personel, including the occupational standards contained in CAP699, are well embedded and understood, and can be seen as a means of compliance with the EU rules. A working group will be established to review and update CAP699 and consider alternative arrangemenst for the accreditation of training and training providers.

Following the update provided by CAA, Graeme Day, who has represented Airports Council International (ACI) on the EASA RMT, delivered a presentation. In May 2014 EASA established and nominated the membership of a Rule Making Group for task RMT.0589 Rescue and Firefighting Services at Aerodromes. The RMT Group comprised members from Competent Authorities and aerodromes and was formed to review the RFFS Remission Factor, Cargo Operations and Medical and Fitness Standards for RFFS personnel. The RMT Group met four times in 2014 to discuss these matters and drafted Acceptable Means of Compliance (AMC) and Guidance Material (GM) covering the Remission Factor and Cargo Aircraft Operations.

Supported by three doctors the Group has also written an Implementing Rule (IR), AMC and GM covering Fire Fighter Medical and Fitness standards.

A Notice of Proposed Amendment (NPA) and Regulatory Impact Assessment(RIA) covering the Remission Factor and Cargo Operations will be published  by EASA by the end of March 2015. The NPA and associated Comment Response Document will enable all concerned to make comment regarding the content of the draft AMC and GM. An NPA and RIA covering Medical and Fitness Standards will initially be considered by the European Commission for publication at a later date.  

Key elements of the NPA covering the Remission Factor and cargo Aircraft Operations include:

• Worked examples.

• Clarification of the term 'unforeseen circumstances'.

• Inclusion of RFFS vehicles in EASA’s reference to maintenance programmes.

• Reference to Q3 when making Critical Area Concept calculations.

• Reference to performance Level C foam when considering media substitution.

• The level of RFFS provision for all cargo aircraft will be aligned to ICAO requirements.

• The provision of medical/ambulance services by RFFS personnel and the use of Nominated Diversion Aerodromes are out of scope for EASA, and the imminent publication of the EASA NPA covering the Remission Factor and Cargo Aircraft Operations represents a crucial opportunity for all concerned to make comment and influence the outcome of the EASA opinion regarding these topics.

• The consultation period will run through Q2 of 2015 and EASA and the RMT Group membership urge everyone to take the time to take part in the consultation when it is published.   

  • Operation Florian

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