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SIASA project This project is funded by the European Union and implemented by EASA. The EU ramp inspection programme Federico GRANDINI SAFA/TCO Coordination Officer SASO Workshop Mbabane (Swaziland), 2 December 2015

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SIASA project

This project is funded by the European Union and implemented by EASA.

The EU ramp inspection programme

Federico GRANDINISAFA/TCO Coordination Officer

SASO WorkshopMbabane (Swaziland), 2 December 2015

Background SAFA Programme

Concern ICAO Standards not fully applied

Continuous growth in air transport => same

trend in accidents?

ICAO and FAA actions

European initiative:

European Civil Aviation Conference - ECAC

Initial discussion 1994/1995

June 1996: adoption of SAFA programme by ECAC

DGCA meeting

2 December 2015 SASO Workshop, Mbabane 2

Principles SAFA Programme

Safety Assessment of Foreign Aircraft

Safetyinternal: crew and passengers

external: airspace and in vicinity of airports

Ramp inspections by Participating States

Foreign/Third Country Aircraft

Executed by ECAC Member States

2 December 2015 SASO Workshop, Mbabane 3

Search of aircraft (Chicago convention)

Right to perform inspections of aircraft while on landInspection of certificated and other required documents

Principle of avoidance of unreasonable delay

2 December 2015 SASO Workshop, Mbabane 4

Next

State obligations for foreign operators surveillance => Andrea Costantini

2 December 2015 SASO Workshop, Mbabane 5

2 December 2015 SASO Workshop, Mbabane 6

Principles SAFA Programme

Voluntary basis until April 2006

SAFA Directive (2004/36/CE)to be implemented by EU MS by 30/04/2006

Introducing legal obligation upon EU MS:to inspect third-country aircraft landing at their airports

to participate to the collection and exchange of information on the ramp inspections carried out

possibility to inspect aircraft from other UE MS

Not applicable to State aircraft

As of 01/01/2007 SAFA transferred to UE institutions (Commission and EASA) by means of Commission Regulation No 768/2006

Principles SAFA Programme

Linked to ICAO compliance with ICAO (regional) Standards

complementary to ICAO USOA Programme

Bottom-up approach

A single set of procedures for the performance of the ramp inspections

A single tool => centralised SAFA Database

A single syllabus for training and qualification of inspectors

Standardisation – ensuring long term data quality improvements

Prioritisation: a tool to make SAFA more effective

2 December 2015 SASO Workshop, Mbabane 7

Principles SAFA Programme

• …

ICAO

NAA

Operator(s)

AircraftMember States

EASA

European Commission

Analysis

Reports

2 December 2015 SASO Workshop, Mbabane 8

EASA

SAFA Programme under the SAFA Directive

DIRECTIVE 2004/36/CE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

Aircraft involved in commercial operation, non-commercial over 5700kg, helicopter

Possible application to non-commercial below 5700kg, and EU aircraft

Collect/exchange/protect safety information; ground aircraft when necessary

COMMISSION REGULATION (EC) No 768/2006

Management of SAFA transferred to EASA; reports in Database without delay

COMMISSION DIRECTIVE 2008/49/EC amending Annex II to Directive 2004/36/EC

Introducing core elements of SAFA procedures for ramp inspections

COMMISSION REGULATION (EC) 351/2008 implementing Directive 2004/36/ECPrioritisation of ramp inspections, introducing criteria

EASA GM On the Qualification of SAFA Inspectors (ED Decision 2008/001/S)

29/09/2008

SAFA Ramp Inspections Guidance Material Version 1.0 (ED Decision 2009/001/S)

22/07/2009

SAFA Ramp Inspections Guidance Material Version 2.0 (ED Decision 2012/001/S)

27/07/2012

2 December 2015 SASO Workshop, Mbabane 9

Ramp inspections under the Air Operations Regulation

REGULATION (EC) No 216/2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency (EASA Basic Regulation)

COMMISSION REGULATION (EU) No 965/2012 laying down technical requirements and administrative procedures related to air operations

=> Scope widened to cover all aircraft subject to EASA’s Basic Regulation used by either TCO (SAFA) or EU operators (SACA), both commercial and non-commercial

Part-ARO AMC-GM - Issue 3 (Annex to ED Decision 2014/025/R)

=> To complement ED Decision 2012-16-R as regards ramp inspections procedure and approval of third party ramp inspection training organisations

INSPECTION INSTRUCTIONS ON THE CATEGORISATION OF RAMP INSPECTION (SAFA/SACA) FINDINGS – INST.RI.01/002 (updated 18/11/2015)

2 December 2015 SASO Workshop, Mbabane 10

Stakeholders

EASA Operators:

NAAs: regular oversight

EASA standardisation:

performance indicator (state level);

targeted scrutiny (on specific operators);

area specific

Non-EASA operators

EASA: continuous oversight of TCO

EC (Safety List)

2 December 2015 SASO Workshop, Mbabane 11

Regulation 965/2012

Article 3 – Oversight capabilities

[…]

5. Personnel authorised by the competent authority to carry out certification and/oroversight tasks shall be empowered to perform at least the following tasks:

[…]

(e) perform audits, investigations, assessments, inspections, including ramp inspectionsand unannounced inspections;

(f) take or initiate enforcement measures as appropriate.

6. The tasks under paragraph 5 shall be carried out in compliance with the legal provisionsof the relevant Member State.

Article 4 – Ramp inspections

Ramp inspections of aircraft of operators under the safety oversight of another MemberState or of a third country shall be carried out in accordance with Subpart RAMP of AnnexII.

2 December 2015 SASO Workshop, Mbabane 12

Regulation 965/2012 - Annex I

Definitions for terms used in Annexes II to V

[…]

For the purpose of this Regulation, the following definitions shall apply:

(95) ‘prioritisation of ramp inspections’ means the dedication of an appropriate portion ofthe total number of ramp inspections conducted by or on behalf of a competent authorityon an annual basis as provided in Part-ARO;

[…]

(97) ‘ramp inspection’ means the inspection of aircraft, of flight and cabin crewqualifications and of flight documentation in order to verify the compliance with theapplicable requirements;

2 December 2015 SASO Workshop, Mbabane 13

Oversight and safety priorities

2 December 2015 SASO Workshop, Mbabane 14

Oversight programme and cooperative oversight

2 December 2015 SASO Workshop, Mbabane 15

Regulation 965/2012 - Annex II

SUBPART RAMP

RAMP INSPECTIONS OF AIRCRAFT OF OPERATORS UNDER THE REGULATORY OVERSIGHTOF ANOTHER STATE

ARO.RAMP.005 Scope

This Subpart establishes the requirements to be followed by the competent authority orthe Agency when exercising its tasks and responsibilities regarding the performance oframp inspections of aircraft used by third country operators or used by operators underthe regulatory oversight of another Member State when landed at aerodromes located inthe territory subject to the provisions of the Treaty.

2 December 2015 SASO Workshop, Mbabane 16

Implementing Rules to EASA’s Basic Regulation –Ramp Inspections

Part ARO-Subpart RAMP – new elements:

RI Programme based on calculation methodology and on

safety risk

Mandatory inspections on EU operators (SACA)

Use of EU standards for EU operators (SACA)

Quantitative prioritisation: minimum annual proportion for

each Member State

Whenever no EU requirements exist, ICAO standards continue to be used (e.g. Certificate of Registration => ICAO Annex 7)

2 December 2015 SASO Workshop, Mbabane 17

SAFA Stakeholders

2 December 2015 SASO Workshop, Mbabane 18

SAFA States (28 EU + 17 non-EU + 2 candidates)

Ramp Inspections SAFA/SACA

Collection of safety data

European Commission

- Policy

- EU Air Safety List

EUROCONTROL

Support by means of:

- Alarming function

- Traffic Data

EASA

- Overall coordination

- SAFA Database

- DATA Analysis

- Procedures/Training syllabi

-Standardisation

19

EASA

(28+3+1)

EU

(28)

Switzerland IcelandNorway

FYROM

Turkey

Georgia

Israel (*)

Monaco

Ukraine

UAE

Singapore

Armenia

Moldova

Montenegro

Canada (*)

Albania

Bosnia & Herzegovina

Serbia

Morocco

Cyprus

Finland

Greece

Italy

Netherlands

Slovenia

United Kingdom

Belgium

Denmark

Germany

Ireland

Malta

Slovak Rep.

Sweden

Romania

Austria

Czech Rep.

France

Hungary

Luxembourg

Poland

Portugal

Spain

Estonia

Latvia

Lithuania

Bulgaria

Croatia

Member/Participating/Candidate States

(Lichtenstein)

SAFA Participating (45)

and Candidate (2*)

States

2 December 2015 SASO Workshop, Mbabane

2 December 2015

Member/Participating/Candidate States

2 December 2015 SASO Workshop, Mbabane 21

Criteria for new members

Good safety records

“Green light” from Commission

Important Hubs

Members of ICF

Interest expressed

Technical capability

Next

Basic elements to set up a ramp inspection system organisation => Andrea Costantini

2 December 2015 SASO Workshop, Mbabane 22

23

Inspection privileges: the competent authority should determine what the inspector can be entitled to inspect, taking into account: background knowledge working experience interrelation of the inspection item with other disciplines

Eligibility criteria: ICAO English Proficiency Level 4 or equivalent education and experience over the previous 5 years in the areas of

either aircraft operations or maintenance, personnel licensing, commercial pilot/flight engineer, cabin crew, maintenance staff, or trained and experienced in transport of Dangerous Goods, or with post-secondary aeronautical education (min. 3 years)

Senior ramp inspectors: Qualified ramp inspectors since at least 3 years Minimum of 72 inspections in previous 36 months Recency requirement of 24 inspections in any 12-month period

Qualification of ramp inspectorsARO.RAMP.115 and relevant AMC/GM

2 December 2015 SASO Workshop, Mbabane

24

Initial training: Initial theoretical training (min. 3 days) Practical training in non-operational environment (min. 1 day) On-the-job (OJT) training in two phases (over a max. period of 6 months):

Observing inspector (min. 6 inspections) Inspector under supervision (min. 6 inspections)

Qualification by means of a formal statement listing the inspecting privileges

Recent experience requirements: 12 inspections in 12-month period If recency is lost: requalification by inspections under supervision of

senior insp. If more than 12 months without inspecting: OJT and recurrent training

Recurrent training (at least once every 3 years): New regulatory and procedural developments, new operational

practices, review of EU processes (2111/2005, TCO), data analysis, standardisation and harmonisation issues

Training and qualification of ramp inspectors

2 December 2015 SASO Workshop, Mbabane

25

Listed in the formal qualification statement Determined by: background knowledge working experience interrelation of the inspection item with other disciplines

May be enlarged if basic knowledge enhanced by additionaltheoretical and/or practical trainings

Inspecting privileges

2 December 2015 SASO Workshop, Mbabane

Next

Inspectors’ training => Andrea Costantini

2 December 2015 SASO Workshop, Mbabane 26

Conduct of a ramp inspection

Ramp inspections should be performed by at least two inspectors

Inspections performed by solo inspectors should be limited to exceptional cases, such as last minute unavailability of a team member, very short time to prepare a spot inspection, etc.

Distribution of the tasks between ramp inspectors involved should be duly taken into account, especially in the case of limited inspection time and/or size and complexity of the aircraft

When circumstances prevent inspection of all checklist items, inspectors should try to inspect those elements which are likely to be more safety critical depending on the particularities of the inspected flight –also taking into account previous inspection results

2 December 2015 SASO Workshop, Mbabane 27

•Inspector’s documents

Follow-up actions

Findings

Categorise Findings

SAFA Ramp Checks

SAFA Process

•Instructions inRI procedure

•SAFA Checklist

2 December 2015 SASO Workshop, Mbabane 28

General Information

Inspection (53 items)

A. Flight Deck (24)

B. Safety/Cabin (14)

C. Aircraft Condition (11)

D. Cargo (3)

E. General (1)

Findings, actions and remarks

Checklist/POI

2 December 2015 SASO Workshop, Mbabane 29

Detailed guidance for each inspection item

What and how to inspect

Reference to relevant standards as part of the pre-

described findings

Chicago Convention

The Annexes

Doc. 7030 Regional Supplementary Procedures

Manufacturers standards

Inspection instructions

2 December 2015 SASO Workshop, Mbabane 30

Reference to Inspection Instructions/PDFs

a) Inspection instructions on the categorisation of findings identified during SAFA inspections

b) Inspection instructions on the categorisation of findings identified during SACA inspections

Doc # INST.RI.01/002, approved 18 November 2015

The current PDFs cover only commercial transport => we are investigating whether a similar approach is needed also for complex non-commercial ops

2 December 2015 SASO Workshop, Mbabane 31

INSPECTION INSTRUCTIONS ON THE CATEGORISATION OF RAMP INSPECTION (SAFA/SACA) FINDINGS

AMC1 ARO.RAMP 125&130 => ramp inspectors should follow the inspection instructionson the categorisation of findings established by EASA for SAFA and SACA ramp inspections

Overall objective => to ensure that ramp inspections are performed in a standardisedmanner in all member states by providing :

1. detailed inspection instructions, and

2. a common reporting taxonomy.

The finding should be categorised according to the list of PDFs, which provide:

1. description

2. categorisation, and

3. reference to the applicable standard.

The list of PDFs is as complete as possible => however it cannot cover all possibledeviations that may occur.

The inspector should always privilege the use of PDF while reporting findings.

In those cases where there is no appropriate PDF, the inspector should file a UDF, basedupon his proficiency and the impact on safety to make a sound judgement into whichcategory the finding needs to be placed.

2 December 2015 SASO Workshop, Mbabane 32

Inspection instructions (App.1)

2 December 2015 SASO Workshop, Mbabane 33

•Inspector’s documents

•Instructions inRI procedure

•SAFA Checklist

•Pre-describedfindings

Follow-up actions

Findings

Categorise Findings

SAFA Ramp Checks

SAFA Process

2 December 2015 SASO Workshop, Mbabane 34

Deviation from ICAO Annexes or manufacturer’s

standards

Ramp Inspection procedure introduced some 600

“pre-described findings” (PDF)

If no suitable PDF is available, the inspector may

create its own “User Described Finding” (UDF)

No PDFs available yet for Annex 6 – Part II & Part III

operations

SAFA finding

2 December 2015 SASO Workshop, Mbabane 35

Advantages:

Harmonisation and Standardisation

Common & clear descriptions

No language difficulties

Standardised categorisation

Linked to a (ICAO) standard

Clearer, less invalid findings

Pre-Described Findings

2 December 2015 SASO Workshop, Mbabane 36

Three categories:

cat. 1, minor influence on safety

cat. 2, significant influence on safety

cat. 3, major influence on safety

Pre-determined for PDF

In case of UDF, inspector selects category after

comparison with similar findings

SAFA Finding Categories

2 December 2015 SASO Workshop, Mbabane 37

Pre-described findings

2 December 2015 SASO Workshop, Mbabane 38

Pre-described findings

2 December 2015 SASO Workshop, Mbabane 39

Pre-described findings

2 December 2015 SASO Workshop, Mbabane 40

SAFA vs. SACA PDF

Independent portable lights

Different requirements (night ops only vs. all ops), different PDFs

SAFA

SACA

2 December 2015 SASO Workshop, Mbabane 41

Deficiencies under the control of the operator

Clear wording : no finding should be raised as long as the defect is properly reported

2 December 2015 SASO Workshop, Mbabane 42

Significant technical defects

New wording for cases where there are no clear dispatch limits: limits on defects included in manufacturer’s data, which are to be used during scheduled maintenance, should not be used to raise findings => however, if defect is beyond dispatch limits specified by the manufacturer, cat. 3 finding

2 December 2015 SASO Workshop, Mbabane 43

Dispatch limits

• Inspectors should identify safety related issues, and address those to the crew/operator for their action.

• Inspectors should not insist on any action normally addressed by the regular AMP of the operator, especially so when this endangers the departure time of the operator.

• The AMP (in its wider sense) already covers to restore any mishaps of the A/C during its service life.

• Time permitting (in between arrival-departure), any corrective actions are possible, even encouraged

• Delaying an operator for a non-safety related issue is not only frustrating the operator, it also could result in unwanted human factor issues with possible negative effects on the flight preparation

2 December 2015 SASO Workshop, Mbabane 44

•Inspector’s documents

•Instructions inRI procedure

•SAFA Checklist

•CD 2008/49

•+ RI procedure

•Pre-describedfindings

Follow-up actions

Findings

Categorise Findings

SAFA Ramp Checks

SAFA Process

2 December 2015 SASO Workshop, Mbabane 45

Class 1

Information to the PIC

at every inspection

Proof of inspection

Class 2

Class 1 actions, and in addition:

Written communication to operator (request for

corrective actions)

Written communication to the Authority

(informative, possibly asking for involvement)

Follow-up actions

2 December 2015 SASO Workshop, Mbabane 46

Class 3

Class 1 and 2 actions, and in addition:

Aircraft may only depart after:

Restrictions have been imposed (3a)

Corrective actions have been taken (3b)

If no appropriate actions are taken:

Aircraft may be grounded (3c)

Full or partial ban may be imposed (3d)

Follow-up actions (Cont’d)

2 December 2015 SASO Workshop, Mbabane 47

Next

Basic planning => Andrea Costantini

2 December 2015 SASO Workshop, Mbabane 48

Data quality

Data quality improvement:

At NAA leveluse of moderators (quality control)

At Agency levelQuality review (general inspection data and findings)

Short term quality improvement by corrections

Long term improvement by increased standardisation and harmonisation

2 December 2015 SASO Workshop, Mbabane 49

SAFA Regular Analysis

Ratio: (SAFA/Safety) Performance Index

Weighting scheme: cat.1=0.25; cat.2=1; cat.3=2

Calculated for each airframe, then:Aggregated for operators

Aggregated for states

Period Considered: 12 months

Data Analysis Tool:Operator Ratio

Time period considered: 12 months

Weighting factor (cat. 3, cat. 2, cat. 1)

Trend

Comparison with indicators for previous 12 months periods (T-4 months, T-8 months, T-12 months)

++ (sharply increasing), + (increasing), 0 (stable), - (decreasing), --(sharply decreasing)

2 December 2015 SASO Workshop, Mbabane

SASO Workshop, Mbabane

Trend calculation

Operator Ratio 4

T-8 T-4

<Short trend >

< Long trend >

T

Operator Ratio 1

T-24 T-20 T-16 T-12

Operator Ratio 2

Operator Ratio 3

SAFA Analysis

2 December 2015

52

SAFA Analysis

Analysis every ~4 months

Preceded by a quality review

Attachment 2: Operators list sorted on ratio

Approximate 600+ operators

Min. 3 inspections during previous 12 month

Automated, numerical analysis

Meant to structure the population

Not a direct safety level ranking list!

2 December 2015 SASO Workshop, Mbabane

SASO Workshop, Mbabane

Data Analysis

Operator Number of Inspections

No. of aircraft inspected

Number of Findings

(cat.1-cat.2-cat.3)

Ratio Trend

ABC Airways

26 4 117

(61-39-17)

9.71

++

DEF Airlines

22 5 103

(59-32-12)

4.18 +

XYZ Air 31 8 74

(49-21-4)

1.16 -

Operator list sorted on ratio

2 December 2015

54

SAFA Analysis

In-depth analysis Manual analysis by EASA and 6 experts from Member States

Considered operators determined by:previous analysis, or

a SAFA ratio of more than 2

having more than 6 inspections (with exceptions)

Levels of advice to member states and/or Commission:(1) Safety concern Focused Inspections

(2) Significant concern EASA letter to request corrective actions

(3) Major safety concern EASA TCO escalation/ Commission investigations under 2111/2005

(0) Sustained improvement stop Focused inspections

2 December 2015 SASO Workshop, Mbabane

List for the prioritisation of inspections

ARO.RAMP.105 Prioritisation criteriaEASA to maintain list of operators/aircraft identified as presenting a potential risk for the prioritisation of ramp inspections

List based on (amongst other aspects):EASA SAFA/SACA analysis

EU Air Safety listAir Safety Committee opinions

operational restrictions (Annex B)/Certified by States with other operators on SL

TCO that operates in the EU for the first time or whose TCO authorisation is limited or reinstated after suspension or revocation

Monitoring tool in SAFA database

Increased number of inspections should confirm either:safety deficiencies, or

normal / improved safety performance

2 December 2015 SASO Workshop, Mbabane 55

Integration with other processes

2 December 2015 SASO Workshop, Mbabane 56

Immediate threats = rectified on the ramp

Systemic risks

EASA: the Standardisation of EASA states

EASA/COM: requests to competent NAAs

EC: opening investigations under the Safety List

EASA TCO

Indicator for data driven processes:

Continuous Monitoring Approach (CMA) for EASA standardisation

Oversight of TCO

Regulatory feedback

2 December 2015 SASO Workshop, Mbabane 57

EASA’s contribution to the EU Safety List

Regulation (EC) No 2111/2005 (‘Air Safety List Regulation’): List of air operators subject to an operating ban within the European Union

Updated twice/year by EC (DG MOVE), assisted by EU Air Safety Committee

Purpose: restrict or ban unsafe operators from flights to Europe and inform the travelling public

EASA provides technical expertise, analysis and information:Participation in technical meetings (air operators and civil aviation authorities)

Participation in EU Aviation Safety Assessment Visits to third countries

Analysis of technical information and confidential safety reports

Analysis of audit reports of the International Civil Aviation Organisation (ICAO)

Coordination of the SAFA ramp inspection programme and providing data analysis and recommendations

Provision of information from EASA’s Third Country Operator Authorisation scheme

Used for Exchange of information

Web based application for exchange of information

Storage of Ramp Inspection Reports

Access for each Participating State

inclusion of reports

retrieve data

Access for guest States and for operator

inclusion of follow-up information

retrieve data

Stored information is confidential

EASA does not own the data!

SAFA Centralised database

2 December 2015 SASO Workshop, Mbabane 58

Access granted to Guest NAAs and to operators:

registered Guest NAAs have access limited to the reports of the operators for which they have regulatory oversight responsibilities

operators’ access is limited to their own reports

Guest NAAs and operators are able to retrieve their relevant reports and add information on follow-up actions taken

TCOs access can be obtained via the relevant Guest NAA in 2 steps:

the Guest NAA will give a first approval to the operator user

SAFA administrator will approve the access

An operator will be able to register only if there is a registered coordinator for its responsible NAA

Namely, if the State of operator has not yet registered for SAFA, the operator will not be able to obtain access

SAFA Database

2 December 2015 SASO Workshop, Mbabane 59

Please take into account that you must provide a corporate e-mail address which is managed by your organisation

generic e-mail providers, e.g. gmail, hotmail or yahoo, cannot be accepted

The registration will have to be approved before access is granted

During the registration process, a confidentiality statement must be accepted

The application will send periodically re-activation links to the e-mail address provided; if the user fails re-activating the account, the account will automatically be blocked

Access to non-SAFA NAAs and to operators

2 December 2015 SASO Workshop, Mbabane 60

Confidentiality statement

2 December 2015 SASO Workshop, Mbabane 61

Questions?

2 December 2015 SASO Workshop, Mbabane 62

SIASA project

This project is funded by the European Union and implemented by EASA.

Thank you.

[email protected]