JAR-OPS 1 - DOC by wuyunyi

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									                                             OSG review of Comments to A-NPA OPS 32



The final text, as agreed by OSG is provided in the annex to this document.

Explanatory Note
No from         Proposal to change                Commenter reason to change or to reject            OSG conclusion
29    MOT       Question, no text proposal        §2.1: “....This is a compensating factor for the   The aeroplane may stay at FL 150 for a
      Austria                                     relief in JAR-OPS 1.770 which now allows to        certain time and then descend to FL 100,
                                                  stay for 10 minutes at FL 15 000 ....”             all this in less than 10 minutes !
                                                  Question: Where are these 10 minutes coming        Wide ranging discussion about the
                                                  from? I understand from the new proposed           merits of the changes. ENAC resolutely
                                                  1.760 that the relief of 10 minutes is the         opposed. ETF resolutely opposed
                                                  maximum from descending from FL 150 to FL
                                                                                                     Others pro or eclectic
                                                  100..? Not a relief to stay at 150 !




General
No from         Proposal to change                Commenter reason to change or to reject            OSG conclusion/
04    ECA       reject NPA-OPS 32 and upgrade           ICAO standards are minimum                  - ICAO standards regarding O2 are
                JAR standards to ICAO standards   requirements                                       applied neither by FAA nor JAA.
                                                        proposed changes merely commercially        - Second comment is not relevant.
                                                  driven                                         . - - The majority of the group except
                                                        current and future developments are not ENAC and ETF is of the opinion that
                                                  taken into account                             target levels of safety will be
                                                                                                 maintained owing to the compensatory
                                                        medical studies needed
                                                                                                 increase in requirements for a/c
                                                                                                 operating below FL250. OSG and then
                                                                                                 AEA, through FAA CAMI, have
                                                                                                 provided statistically based risk analysis.

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                                               OSG review of Comments to A-NPA OPS 32


                                                                                        LSST(M) view has been given in favour
                                                                                        except representatives of ENAC & LBA
                                                                                        Germany. The majority approved the
                                                                                        justification paper of B.Gardner (CAMI),
                                                                                        which includes Medical studies.


                                                                                        Much discussion on the length of time
                                                                                        for which O2 should be supplied.
                                                                                        .


05     Airbus   full support for NPA-OPS 32                                             acknowledged
                Shared view of AECMA, AEA and
                Airbus
09     LFV      Accept NPA                                                              acknowledged
       Sweden
14     IFALPA   reject NPA-OPS 32 and upgrade      Copy of comment 04, ECA, above       see comment 04 above
                JAR standards to ICAO standards
27     ERA      supports A-NPA-OPS 32 with one                                          acknowledged
                comment (same number)
                concerning Appendix 1 to JAR-
                OPS 1.770
33,    AEA      full support of A-NPA-OPS 32       see position paper                   acknowledged
34,
36



JAR-OPS 1.760 Title

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                                                     OSG review of Comments to A-NPA OPS 32


No from          Proposal to change                      Commenter reason to change or to reject           OSG conclusion
08    Martin Air First-aid oxygen and therapeutic        Title and intent proposed in 1.760(a) no longer  It was agreed that the phrase “first aid
      Holland    oxygen                                  correspond with definition of “first-aid oxygen” oxygen” is simpler to understand and
                                                         in JAR 1.1                                       that the definition in JAR 1.1 should be
                                                                                                          amended to reflect that.



JAR-OPS 1.760 (a)
No from          Proposal to change                      Commenter reason to change or to reject           OSG conclusion
23    ENAC,      refers to .... (The word “undiluted     Oxygen used for First Aid purposes must           Discussed at length. A new text was
      ENAC       oxygen” means that the breathing        contain 99.9 oxygen. A gas mixture containing     developed which removed the reference
                 gas contains at least 95% of            95% of oxygen is not worth for medical use, and   to 95% and which permitted the use of
                 oxygen)....                             in any case chemical composition of the           OBOGS. This was accepted by all except
                                                         remaining 5% should be specified.                 ENAC (opposed to any less than 99.9%
                                                                                                           and opposed to use of OBOGS) and ETF
                                                                                                           (reservation on use of OBOGS for first
                                                                                                           aid)
                                                                                                           NOTE: Today available portable bottles
                                                                                                           contain O2 only,[ above 99.9 % O2.]
35    AEA        .... unless it is equipped with a       The aim of the requirement is to provide a      Agreed see discussion above, comment
                 supply of undiluted oxygen              minimum level of protection. Apply the tracheal 23.
                                                         pressure criteria.
02    LBA Ger    Apply JAR-OPS 1 pre-amendment - 3% requested and additional 1% for                        - JAR OPS 1 Change 2 was deleted by
                 3 (change 2).The amount of oxygen therapeutic O2.                                         EQSC, OST and JAAC.
                 shall be ...... for at least 1% 3% of
                                                       - Supplemental O2 is not enough                     - Supplemental O2 is covered by JAR
                 the passengers carried, ...
                                                                                                           25.1443 and has proved adequate in the
                                                                                                           past. 3% was reduced by OST to 2%.
25    ENAC       The amount of oxygen shall be ......    The requirement is no more linked to              OSG is willing to consider this but the

                                                                         3/ 12
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                                           OSG review of Comments to A-NPA OPS 32


      ENAC   for at least 1% 2% of the           depressurisation events, therefore the        only data available suggests that
             passengers carried, ...             probability for the use of F/A oxygen to be   additional supplemental oxygen is
                                                 considered in this requirement should be      almost never used. ENAC and ETF
                                                 higher.                                       disagreed.
35    AEA    The amount of oxygen shall be       The aim of the requirement is to provide a    Agreed see discussion above, comment
             calculated using an average flow    minimum level of protection                   23.
             rate of at least 3 litres/min
             (STPD)/min undiluted
             oxygen/person, or such equivalent
             lower oxygen concentration as will
             provide minimum tracheal oxygen
             partial pressure of 202 mmHg at 15
             l/min BTPS, and shall be sufficient
             for .....




                                                                 4/ 12
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                                                    OSG review of Comments to A-NPA OPS 32



11,    ETF         (a)(1) aeroplanes flying above FL      Flight times up to 18 hours are discussed on the   Partially accepted.
16                 250: Half of the flight duration, up   new age VLTA
                                                                                                             180 minutes or length of diversion
                   to three hours,
                                                                                                             whichever is greater seemed to be a
                                                                                                             consensus at this stage. See modified
                                                                                                             1.760(b)(2)
37     AEA         Refers to (a)(1) “flight duration”.    Request to define “flight duration”. a) flight     See comment above.
                   No text proposal                       duration until destination airport or b) flight
                                                          duration from critical point till an en-rout
                                                          alternate?
07     Martin Air Add (a)(3): Aeroplane certificated (a)( 1) and (a)(2) do not address all categories:       Agreed with the concept. The
       Holland    to fly above FL 250 but not flying   Aeroplanes certificated to fly above FL 250 but       requirement is “operational” related .
                  above FL 250. Or: (a) (1) aeroplanes not flying above FL 250.                              Text changed to “operating”
                  intended to be operated at pressure
                  altitudes above 25 000 ft (a)(2)
                  aero-planes not intended to be
                  operated at pressure altitudes
                  above 25 000 ft
07     Martin Air There shall be a sufficient number 1. This is not needed in the case of therapeutic        This is understood, nevertheless the
       Holland    of dispensing units ....with a means oxygen. 2. Following decompression, cabin             “decompression case” must also be
                  for cabin crew to use the supply.    crew are assumed not to need oxygen in                taken into account. A portable
                                                       addition to supplemental oxygen during the            dispensing unit is always available to
                                                       descent.                                              cabin crew members, for aeroplanes
                                                                                                             certified according to FAR/JAR 25.1447.
                                                                                                             Appendix text changed and note 6
                                                                                                             added to reflect this concern
32     MOT         Refers to: “.....with a means for      Clarification needed, the word “means” has         Text changed to reflect this concern. See
       Austria     cabin crew to use the supply. No       caused discussions in the past.                    comment 07 above.
                   text proposal

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                                                  OSG review of Comments to A-NPA OPS 32


32    MOT        Refers to: “.... Other dispensing       This seems to be a duplication. What is meant?    Text changed to remove this. See
      Austria    units carried to satisfy the                                                              comment 07.
                 requirements may be of a portable
                 type.” No text proposal.
18    CAA UK     Refers to the proposed change:          If first-aid oxygen is not portable can it be     Text changed to make this clear. See
                 There shall be a sufficient number      guaranteed to be available to all passengers      comment 07.
                 of dispensing units, ..., which may     regardless of their seats within the aeroplane?
                 must be of a portable type, ...: No
                 text proposal.



JAR-OPS 1.760 (b)
No comments


JAR-OPS 1.760 (c)
No from          Proposal to change                      Commenter reason to change or to reject           OSG conclusion
06    Martin Air Delete subpara (c)                      Has become redundant as proposed (a)(1) and       Noted.
      Holland                                            (a)(2) stipulate the amount of oxygen.
                 Proposed New subpara (c): The           Introduce a supply requirement which is solely .
                 amount of first-aid/therapeutic         based on discriminants which are relevant to
                                                                                                          Comment rejected, but a new text has
                 oxygen required for a particular        the therapeutic needs. I.e. normal cabin
                                                                                                          been proposed. See above.
                 operation shall be determined on        pressure altitude, flight duration and passenger
                 the basis of flight duration, cabin     demographics.
                 pressure altitude and passenger
                 demographics. An amount of
                 oxygen shall be available for at
                 least 1% of the passengers for at
                 least 50% of the flight duration for
                 flights up to 6 hours, and at least 3

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                                                    OSG review of Comments to A-NPA OPS 32


                 hours for longer flights, except
                 that:
                       an appropriate reduction is
                 allowed for flights where the
                 normal cabin pressure altitude is
                 not expected to exceed 5.000 ft
                 [figure subject to medical advice];
                 and
                       an appropriate surplus shall
                 be added when it is known that
                 passengers are carried that fall in a
                 category known to be more prone
                 to hypoxia and therefore requiring
                 therapeutic oxygen.



ACJ OPS 1.760 (a)&(c)
No from          Proposal to change                      reason to change or to reject                  conclusion/final text
03     LBA Ger   Question compliance with JAR 25.                                                       Certification will be dealt with by means
                                                                                                        of a special condition, which is an usual
                                                                                                        way of dealing with new systems.
                                                                                                        Reservation by ETF and opposition by
                                                                                                        ENAC
                                                                                                        Justification is done through reply to
                                                                                                        comment 23.
10,    ETF       Reject introduction of OBOGS            Further studies of the therapeutic effect of   Noted
15                                                       OBOGS on passengers in need of oxygen are
                                                         required.


                                                                          7/ 12
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                                               OSG review of Comments to A-NPA OPS 32


24     ENAC     Reject introduction of OBOGS       OBOGS flow is not equivalent to the mass flow      Refer to comment 23 and 10, 15 above.
       ENAC                                        of first-aid oxygen bottles (undiluted oxygen)
                                                   Is in contrast with JAR 25.1443(d)
                                                   Is not defined or accepted for civil purposes
28     DGAC     Disagreement with proposed text    Requirements are only needed on the supply         Refers to supplemental oxygen but
       France                                      but not on the source of oxygen.                   principle is accepted and reflected in
                                                                                                      changed text.
                                                   These requirements are more demanding than
                                                   in JAR 25.1443(c). It should be discussed with
                                                   certification group members.



JAR-OPS 1.770 and Appendix 1 to JAR-OPS 1.770, General
No from         Proposal to change                 Commenter reason to change or to reject            OSG conclusion
12,    ETF      reject changes                     more information and analysis of actual            Noted. The outcome of the event
17                                                 decompression as well as scientific studies is     described by the commenter, prompted
                                                   required                                           UK CAA to recommend procedural
                                                                                                      changes only.
                                                                                                      Procedural issue worthy of study. UK
                                                                                                      CAA’s report has been sent to OPSG.
19     CAA UK   reject changes                     Proposed changes based on operational              Comment not completely understood
                                                   requirements. No justification on safety grounds   asJAR-OPS 1 requires 14 000 ft at the
                                                   to support the change to 15 000 ft. Reassurance    moment. Refer to NPA.. The proposal is
                                                   required that the change from 13.000 ft as         based on data presented by AEA and
                                                   specified by ICAO SARPS to the proposed 15         CAMI.
                                                   000 ft is based on a justifiable safety case.
                                                                                                      ETF and ENAC agree with UK CAA’s
                                                                                                      comment.
26     ENAC     reject changes                     see original comment                               Refer to comments 23, 10, 15, 11 above.


                                                                   8/ 12
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                                                OSG review of Comments to A-NPA OPS 32


      ENAC                                                                                              Noted that FAA requirements may be
                                                                                                        more demanding in certain cases. But
                                                                                                        this proposal is more demanding for
                                                                                                        aircraft not operating above FL250.
                                                                                                        Actual application of FAA rules should
                                                                                                        be looked at, e.g. exemption for the
                                                                                                        carrying of Oxygen



JAR-OPS 1.770 (a)
No comments

JAR-OPS 1.770 (b) (1)
No comments

JAR-OPS 1.770 (b) (2)
No from          Proposal to change                    reason to change or to reject                    conclusion/final text
22    CAA UK     Cabin crew members, additional        As written, an operator could have an aeroplane Change would be a certification issue.
                 crew members and passengers, for      to fly above 25 000 ft but which he intends to fly Also this is the ICAO and previous JAR
                 aeroplanes intended certified to be   below 25 000 ft and therefore need not comply      OPS text.
                 operated at pressure altitudes        with this requirement.
                 above 25 000 ft



JAR-OPS 1.770 (b) (3)
No from          Proposal to change                    reason to change or to reject                    conclusion/final text
20    CAA UK     no text proposal                      JAR-OPS 1.770(b)(3)(ii) and (iii) take no account Noted but regulated by JAR OPS 1.
                                                       of the oxygen requirement for the initial descent 100% of passengers are supplied with )2
                                                       phase - 4 min to 13 000 or 3,5 min to 15 000 ft.  above FL 150.


                                                                        9/ 12
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                                                  OSG review of Comments to A-NPA OPS 32


21    CAA UK    (iii), Proposal of different text: For   The proposed text could be interpretated as      Agree to use UK CAA ‘s text proposal.
                aeroplanes able to descend safely        “may be reduced to the entire flight time, not
                within 3 minutes and 30 seconds,         exceeding 10 minutes.”
                at all points along the route to be
                flown, to a cabin pressure altitude
                of 15 000 ft, and then able to
                descend safely within 10 minutes
                to a cabin pressure altitude of 10
                000 ft, oxygen must be provided to
                cabin crew members and at least
                10% of the passengers, for the
                entire time between 15 000 ft and
                10 000 ft cabin pressure altitudes.
30    MOT       no text proposal                         Quick Donning Masks; FL 150 itself is not        Text changed to “not above”
      Austria                                            covered




                                                                         10/ 12
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                                               OSG review of Comments to A-NPA OPS 32



Appendix 1 to JAR-OPS 1.770
No from         Proposal to change                     reason to change or to reject    conclusion/final text
01    LBA Ger   Proposed to keep current rule text.    Disgaree with the whole NPA.     Justification provided by AEA and
                                                                                        CAMI reports (not accepted by ENAC or
                                                                                        ETF).
                                                                                        Difference in fuel consumption at levels
                                                                                        between FL150 and FL130 is
                                                                                        insignificant.
                                                                                        ICAO Manual of Aviation Medicine is
                                                                                        not a requirement.
                                                                                        UK CAA’s proposal to clarify the text
                                                                                        has been accepted. See comment 21
                                                                                        “ and para (b) (2) (iv) above“ added to
                                                                                        para (b) (3) (i) to clarify
                                                                                        OSG (except ENAC and ETF) believes
                                                                                        that this NPA gives an equivalent safety
                                                                                        level to current regulation and notes that
                                                                                        ICAO audit of FAA regulations found
                                                                                        more deviations than European
                                                                                        authorities
27    ERA       1.     Entire flight time remaining                                     Editorial accepted
                where cabin pressure altitude
                exceeds 13 000 ft, or, entire flight
                time remaining minus 30 minutes
                where cabin pressure altitude is
                between 10 000 and 13 000 ft, but in
                no case less than ....


                                                                       11/ 12
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                                                OSG review of Comments to A-NPA OPS 32


                same changes in 2., 3. and 4.
38    AEA       When the cabin pressure exceeds ... To prevent misinterpretation of what is meant           Editorial accepted
                ft, the entire flight at these altitudes by "entire flight time"
                ... (for all items 1. - 4.)
38    AEA       When the cabin pressure exceeds ...     If the entire flight time is more than 30 minutes   Editorial accepted
                ft but does not exceed ... ft, the      it makes no difference for the determination of
                entire flight time after the first 30   the minimum requirement whether the excess
                minutes minus 30 minutes at these       time is considered at the beginning of the flight
                altitudes ... (for all items 1. - 4.)   between these levels or after the 30 minutes.
31    MOT       No text proposal                        If we give the relief to enhance altitude to FL     Noted for OST/NPA.
      Austria                                           150 with only 10% passengers covered, as a
                                                        compromise/proposal - the whole flight time
                                                        and not after 30 minutes, Oxygen should be
                                                        available.
                                                        Request that an independent medical                 5 Medical doctors are OSG members.
                                                        specialist/doctor has to give his expertise on
                                                        risks on such relief, taking into account that      [4 for NAA, one for IP.]. The medical
                                                        more and more elderly and unhealthy people          expertise is therefore ensured.
                                                        are travelling by air.




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