International Aircraft Ground Deicing Service Providers Winter

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					  International Aircraft                       Federal Aviation
                                               Administration
     Ground Deicing
    Service Providers
    Winter 2008-2009
         Update


Presented to: FAA Aviation Safety Inspectors
By:   Mr. Jerry Ostronic and
      Mr. Cliff Fiscus, AFS-200
Date: July 17 and 22, 2008
   FAA Washington Headquarters Focal Points
          for Aircraft Ground Deicing

                           Mr. Jerry Ostronic
                                 AFS-200
                        Jerry.c.ostronic@faa.gov
                              202-267-8166

                             Mr. Cliff Fiscus
                                 AFS-200
                         Cliff.g.fiscus@faa.gov
                               202-267-8166

International Deicing                             Federal Aviation
July 17 and 22, 2008                              Administration     2
                        Purpose?

1. Explain what can be expected regarding the air
   carriers’ Standardized International Aircraft
   Ground Deicing Program, Winter 2008-2009.
2. Answer questions and discuss the air carriers’
   proposed Standardized International Aircraft
   Ground Deicing Program and procedures.
3. Answer questions and discuss any other
   issues relating to aircraft ground deicing,
   Winter 2008-2009.

International Deicing                 Federal Aviation
July 17 and 22, 2008                  Administration     3
                        Before we begin!


     For a better understanding it is necessary to
     provide a bit of background of where we are
     now, and where we are trying to move to
     with aircraft ground de/anti-icing.




International Deicing                      Federal Aviation
July 17 and 22, 2008                       Administration     4
Advisory Circular 120-60B, GROUND
DEICING AND ANTI-ICING PROGRAM
                         Dated 12/20/2004

            Primary guidance document for
            the development of an air carrier’s
            aircraft ground deicing program.
                   (compliance with 14 CFR 121.695)




International Deicing                       Federal Aviation
July 17 and 22, 2008                        Administration     5
                        Advisory Circular 120-60
• Originally written when:
       – Most air carriers accomplished aircraft de/anti-
         icing utilizing their own company equipment and
         personnel at most airports.
       – Much of the de/anti-icing was conducted by
         company aircraft mechanics with a high degree
         of knowledge of de/anti-icing fluids, aircraft
         systems, aerodynamics, aircraft sensitive areas,
         and the effects of contamination on the critical
         areas of the aircraft.


International Deicing                       Federal Aviation
July 17 and 22, 2008                        Administration     6
Today, that is often NOT the case!

• Depending on the air carrier, approximately
  70 - 80% of aircraft ground de/anti-icing is
  accomplished by third party contract
  service providers.




International Deicing              Federal Aviation
July 17 and 22, 2008               Administration     7
Also Today:
• The employee of the typical contract third
  party aircraft ground de/anti-icing service
  provider:
       – Has been with the company less than 2 years.
       – Is often his/her first exposure to aviation and
         airplanes.
       – Is usually minimally paid with little or no benefits.
       – Almost always does part time and seasonal work.



International Deicing                          Federal Aviation
July 17 and 22, 2008                           Administration     8
                        Currently AC 120-60B

• Simply does not address the realities of
  the present situation in the aircraft ground
  deicing environment and the contractual
  relationships that have evolved between
  the air carriers and the third party aircraft
  ground deicing service providers.




International Deicing                    Federal Aviation
July 17 and 22, 2008                     Administration     9
                   What is the FAA doing
                to address this disconnect?
• In cooperation with air carriers and third
  party aircraft ground deicing service
  providers, the FAA is in the process of
  addressing the realities of today's aircraft
  ground deicing environment through a
  major revision (total re-write) of AC 120-60B.




International Deicing                Federal Aviation
July 17 and 22, 2008                 Administration     10
If successful, the revised AC will:
1. Improve safety by increased standardization
   through the development of a detailed
   outline for a standardized aircraft ground
   deicing program for use domestically and
   internationally.
2. Provide an authorization process for third
   party aircraft ground deicing service
   providers independent of an air carrier’s
   14 CFR 121.629 approved ground deicing
   program.

International Deicing             Federal Aviation
July 17 and 22, 2008              Administration     11
If successful, the AC will (continued):

3. Improve FAA oversight through the third
   party service provider authorization process.

4. Make available and encourage the use of
   quality de/anti-icing fluids to a larger
   segment of the aviation industry. Primarily
   air carriers operating under 14 CFR 135 and
   91K.



International Deicing             Federal Aviation
July 17 and 22, 2008              Administration     12
             Revising AC 120-60 is a major
                 undertaking and very
                   time consuming.
• Incorporating and merging the best of:
       – SAE standards and guidance material
       – Guidance material developed by the Association
         of European Airlines (AEA)
       – Transport Canada guidance material
       – Industry practices successfully in use today, and
       – Some out of the box thinking.

International Deicing                       Federal Aviation
July 17 and 22, 2008                        Administration     13
                        Why all this talk about
                        revising AC 120-60B?

• Short answer:
       – It may help in the understanding of why the air
         carriers have gotten together in the development
         of one Standardized International Aircraft
         Ground Deicing Program.




International Deicing                       Federal Aviation
July 17 and 22, 2008                        Administration     14
          Notice 8900.26, Outsourcing of
              (Third Party Provider)
             Aircraft Ground Deicing

• Restated regulatory requirements and
  current FAA national policy and guidance.
       – An air carrier aircraft may only be de/anti-iced
         under the air carrier’s own approved program
         or under another air carrier’s approved
         program.




International Deicing                       Federal Aviation
July 17 and 22, 2008                        Administration     15
                        Why Notice 8900.26?

• Resulted from follow up investigations to
  the disclosure of falsified employee training
  records by a major aircraft ground deicing
  service provider in the western US.




International Deicing                    Federal Aviation
July 17 and 22, 2008                     Administration     16
                            These follow up
                        investigations indicated:
• Some air carriers had been authorized to
  use the unapproved deicing programs of
  third party aircraft ground deicing service
  providers not in accordance with 14 CFR
  121.629, FAA national policy, and current
  guidance material.
       – FAA national policy division (AFS-200), Principal
         Inspectors, and the air carriers all shared in this
         breakdown in compliance.

International Deicing                         Federal Aviation
July 17 and 22, 2008                          Administration     17
  In addition to this practice not being
  in regulatory and policy compliance:
• In some cases the deicing was not being
  accomplished in accordance with the
  flightcrew’s expectations, and therefore
  potentially introducing safety concerns.
• This practice led to questionable oversight
  by the individual air carriers and FAA
  personnel, and
• Created an unclear chain of responsibility
  and authority between the air carrier and the
  service provider.

International Deicing              Federal Aviation
July 17 and 22, 2008               Administration     18
          Compliance with Notice 8900.26

• Within 90 days from time of discovery of
  noncompliance for domestic locations.
       – All domestic locations should be in
         compliance at this time
              • Which means all domestic de/anti-icing is
                being done under the air carriers approved
                program or under another air carriers approved
                program and so indicated in the air carrier’s
                approved aircraft ground deicing program.


International Deicing                          Federal Aviation
July 17 and 22, 2008                           Administration     19
                        Notice 8900.33


• Extended the compliance date for foreign
  locations to October 1, 2008.




International Deicing                    Federal Aviation
July 17 and 22, 2008                     Administration     20
Strict compliance has shown to be
more difficult at foreign locations.
• At some foreign locations only one aircraft
  ground deicing service provider is authorized
  to provide aircraft ground de/anti-icing by local
  governments for environmental concerns.
       – These service providers are providing de/anti-icing
         services to as many as 25 different air carriers.
              • Not desirable or practicable to expect these
                companies, or their employees, to know 25
                different ways of accomplishing the same basic
                task.

International Deicing                             Federal Aviation
July 17 and 22, 2008                              Administration     21
                        Air carriers considered a
                         “Host Airline” concept.
• After much discussion this concept was rejected by
  air carriers over liability concerns.
       – Under this concept a Host Airline is responsible for ground
         deicing service provided to a second air carrier by a aircraft
         ground deicing service provider under contract to the Host
         Airline in accordance with the air carrier’s approved deicing
         program.
              • An air carrier utilizing the deicing service of another air
                carrier’s approved aircraft deicing program as permitted
                by current FAA national policy.
              • Could have raised additional questions as to
                responsibility and authority.

International Deicing                                    Federal Aviation
July 17 and 22, 2008                                     Administration     22
                 Air Carriers considered one
                 standardized very specific
                    international program.
• Modeled after one US aircraft ground
  deicing service providers program.
       – Rejected by air carriers and foreign service
         providers as a non-workable program.
              • To specific to fit all the various locations, air
                carriers programs, and various service
                providers.


International Deicing                               Federal Aviation
July 17 and 22, 2008                                Administration     23
  Consideration given to incorporating
   each service provider’s complete
     program into the air carrier’s
          approved program.
• Also rejected because:
       – Many foreign aircraft ground deicing service
         providers do not have written programs that
         could be incorporated into the air carrier’s
         programs.
       – Depending on the number of foreign locations
         serviced by the air carrier, the shear volume of
         the number of different programs would have
         been prohibitive both from the air carrier’s and
         the FAA’s perspective.

International Deicing                        Federal Aviation
July 17 and 22, 2008                         Administration     24
                        This brings us to today!

• The air carriers proposed Standardized
  International Aircraft Ground Deicing
  Program (SIAGDP)
       – Supported by the Air Transportation Association
         (ATA)
       – 14 CFR 121 air carrier POIs have or will be
         receiving revisions to their air carrier’s ground
         deicing program incorporating the SIAGDP for
         most foreign operations.


International Deicing                         Federal Aviation
July 17 and 22, 2008                          Administration     25
                        What is SIAGDP?
• SIAGDP is a comprehensive generic aircraft
  ground deicing program based on the
  guidelines developed by the Association of
  European Airlines (AEA) for aircraft ground
  de/anti-icing, and followed by many of the
  foreign deicing service providers.
       – The SIAGDP is more detailed and comprehensive
         than that specified in the current AC 120-60B, and
         that is currently in most air carrier’s core FAA
         approved aircraft ground deicing programs.

International Deicing                       Federal Aviation
July 17 and 22, 2008                        Administration     26
 Individual service provider’s specific
 compliance methods and procedures
           for each location.

• A service provider’s methods of compliance
  and specific procedures with the SIAGDP
  will be identified and evaluated through the
  initial and yearly audit reports.




International Deicing             Federal Aviation
July 17 and 22, 2008              Administration     27
   SIAGDP and the service provider’s
     specific audit reports provide
         program details for:
   •    Receiving of de/anti-icing fluids
   •    Storage of de/anti-icing fluids
   •    Safe handling of de/anti-icing fluids
   •    Appropriate application of de/anti-icing fluids
   •    Quality control of de/anti-icing fluids
   •    Non-fluid methods of de/anti-icing
   •    Training of aircraft ground de/anti-icing
        personnel.
International Deicing                      Federal Aviation
July 17 and 22, 2008                       Administration     28
                        SIAGDP Does Not!
• Include aircraft ground deicing program
  requirements for flightcrew or air carrier
  management personnel not directly involved with
  those elements identified in the previous slide.
       – These elements should already be addressed in the
         air carrier’s core approved aircraft ground deicing
         program and not changed by the SIAGDP.
       – Requirements or procedural differences affecting
         flightcrew or flightcrew ground interface must be
         provided to the flightcrew prior to de/anti-icing.
              • Airport chart advisory pages, flight release, FOM, etc.
              • Communication procedures, deicing starting position, etc.

International Deicing                                     Federal Aviation
July 17 and 22, 2008                                      Administration     29
The SIAGDP has five sections:

• Forward, Procedures, Training, Quality
  Control, and References.
• Should be placed in the air carrier’s manual
  system consistent with the air carrier’s
  current procedures as agreed between the
  air carrier and the principal inspectors.




International Deicing              Federal Aviation
July 17 and 22, 2008               Administration     30
Forward section:


• Explains the purpose of the program and its
  use and limitations.




International Deicing             Federal Aviation
July 17 and 22, 2008              Administration     31
Procedures section:

• Addresses:
       – Fluid receiving, handling, and storage
       – Fluid quality control checks
       – De/anti-icing procedures on and off the gate
       – Aircraft general critical areas and no spray
         zones
       – De/anti-icing equipment requirements
       – De/anti-icing coordination and communication.

International Deicing                        Federal Aviation
July 17 and 22, 2008                         Administration     32
Training section:

• Includes (for aircraft ground deicing
  personnel):
       – Scope of training
       – Curriculum
       – Testing
       – Qualification renewal
       – Quality control
       – Records and review plan
       – Aircraft specific training.

International Deicing                  Federal Aviation
July 17 and 22, 2008                   Administration     33
Quality Control section:

• Contains:
       – Quality control program general guidelines
       – Quality training statement
       – De/anti-icing International Vendor Audit Checklist.




International Deicing                        Federal Aviation
July 17 and 22, 2008                         Administration     34
Reference section:

• Includes reference material for:
       – Aerodynamics
       – Weather
       – Health and Safety
       – De/anti-icing fluids background information
       – Other reference documents.




International Deicing                       Federal Aviation
July 17 and 22, 2008                        Administration     35
SIAGDP should also include:

• Completed individual aircraft ground
  de/anti-icing service provider’s audit report
  forms.
       – One for each service provider for each location
       – Initial and yearly

• Station specific flightcrew requirements and
  procedures if different from air carrier’s
  core program and procedures.


International Deicing                       Federal Aviation   36
July 17 and 22, 2008                        Administration          36
         More about the Service Provider
            Audit and Audit Report.
• Audit checklist/form/report modeled after AEA
  aircraft ground deicing provider audit form.
• Very comprehensive.
• Audits are to be conducted by knowledgeable
  individuals under the oversight and coordination
  of ATA.
• Single audit sanctioned by an ATA auditor may
  be shared by all SIAGDP participants.


International Deicing                 Federal Aviation
July 17 and 22, 2008                  Administration     37
             Approval process for SIAGDP
• Approved by POI and incorporated into
  applicable sections of the air carrier’s manual
  system as part of the air carrier’s approved
  aircraft deicing program per CFR 121.629.
• Approval of an individual service provider at a
  specific location by incorporating satisfactory
  completed audit report into the applicable
  section of the air carrier’s manual system.
       – Audit must be repeated yearly and therefore
         audit report form should not be more than 12
         months old.

International Deicing                      Federal Aviation
July 17 and 22, 2008                       Administration     38
                        POI’s responsibility for
                         approval of SIAGDP

• Although proposed SIAGDP has been
  reviewed at the national level by Mr. Fiscus
  and myself, as well as other members of the
  headquarters team, the individual air carrier
  approval authority remains with the POI
  assigned to the air carrier.




International Deicing                       Federal Aviation
July 17 and 22, 2008                        Administration     39
                        Our thoughts of SIAGDP
• Although not perfect, and short of what we hope
  to accomplish with the revision of AC 120-60B:
       – Meets regulatory requirement and policy guidelines
       – Provides for a higher level of air carrier and FAA
         oversight than exists today
       – Enhances safety through standardization of the
         foreign aircraft ground deicing service providers and
         air carriers
       – Places the responsibility and authority more directly
         with the air carrier, the certificated entity
       – Is more specific and comprehensive than most air
         carrier’s approved core deicing programs.

International Deicing                            Federal Aviation
July 17 and 22, 2008                             Administration     40
Our thoughts of SIAGDP (continued)

       – Has been acceptable to most foreign aircraft
         ground deicing service providers
       – Is a big step toward a universally acceptable
         standardized aircraft ground deicing program,
         which is the goal of the revision to AC 120-60B
       – Only program presented that has been agreeable
         to both the FAA national policy office and the air
         carriers in general, that can be implemented in
         time for the upcoming Winter Season 2008-2009.



International Deicing                        Federal Aviation
July 17 and 22, 2008                         Administration     41
           Questions, and hopefully our
             answers, after the break!




International Deicing             Federal Aviation
July 17 and 22, 2008              Administration     42
             This ATN presentation will be
                    rebroadcasted:
                        Tuesday, July 22, 2008
                         3:00 – 5:00 p.m. EDT

                   Conference dial-in number:
               712-432-1699, Access code: 359843

Available on “Video-to-You”on July 23, 2008 at:
http://www.academy.faa.gov/intranet/vod/default.asp


International Deicing                        Federal Aviation
July 17 and 22, 2008                         Administration     43
   FAA Washington Headquarters Focal Points
          for Aircraft Ground Deicing

                           Mr. Jerry Ostronic
                                 AFS-200
                        Jerry.c.ostronic@faa.gov
                              202-267-8166

                             Mr. Cliff Fiscus
                                 AFS-200
                         Cliff.g.fiscus@faa.gov
                               202-267-8166

International Deicing                             Federal Aviation
July 17 and 22, 2008                              Administration     44