International Aircraft Ground Deicing Service Providers Winter 2008-2009 Update

1. International Aircraft Ground Deicing Service Providers Winter 2008-2009 Update Mr. Jerry Ostronic and Mr. Cliff Fiscus, AFS-200

2. 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

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

4. 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.

5. Advisory Circular 120-60B, GROUNDDEICING AND ANTI-ICING PROGRAM Primary guidance document for the development of an air carrier’s aircraft ground deicing program. (compliance with 14 CFR 121.695) Dated 12/20/2004

6. 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.

7. 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.

8. 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.

9. 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.

10. 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.

11. If successful, the revised AC will: • Improve safety by increased standardization through the development of a detailed outline for a standardized aircraft ground deicing program for use domestically and internationally. • 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.

12. 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.

13. 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.

14. 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.

15. 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.

16. 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.

17. 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.

18. 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.

19. 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.

20. Notice 8900.33 • Extended the compliance date for foreign locations to October 1, 2008.

21. 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.

22. 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.

23. 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.

24. 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.

25. 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.

26. 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.

27. 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.

28. 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.

29. 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.

30. 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.

31. Forward section: • Explains the purpose of the program and its use and limitations.

32. 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.

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

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

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

36. 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.

37. 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.

38. 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.

39. 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.

40. 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.

41. 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.

42. Questions, and hopefully our answers, after the break!

43. 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

44. 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