EASA Fuel Tank Safety Training Seminar

1. EASA Fuel Tank Safety Training Seminar Presentation on behalf of IACA Steve Sells Airworthiness Manager Thomas Cook Airlines UK Ltd IACA Presentation 23 Nov 2007

2. EASA Fuel Tank Safety Training SeminarIACAInternational Air Carrier Association • Founded in 1971 • 37 Airlines • Over 750 Aircraft • 50000 + Employees • 100 million + Passengers annually • 650 Destinations IACA Presentation 23 Nov 2007

3. EASA Fuel Tank Safety Training Seminar • Industry Concerns • Confusion over Training Requirements in Agency Decisions 2007-001-R, 2007-002-R, 2007-003-R • This seminar is evidence that there is concern over the implementation of these requirements – these concerns are shared by many Operators and Part 145 Organisations • Operators are concerned as to what the Level 1 and 2 should include – the requirement in the AMC for “having access to aircraft… where typical examples of FTS issues can be shown” is a problem – we are trying to keep people away from Fuel Systems! IACA Presentation 23 Nov 2007

4. EASA Fuel Tank Safety Training Seminar • No indication given as to if training, and continuation training, needs to be assessed • Should separate authorisations be given for Part 66 staff? • Concern re lack of consistency of training that will be given. • Lack of Support from Manufacturers particularly in respect of training material IACA Presentation 23 Nov 2007

5. EASA Fuel Tank Safety Training Seminar • Confusion as to recording requirements for CDCCL Tasks – Operators can manage these for Planned/Scheduled Tasks, but are having problems with this for Unscheduled Tasks – For example, one manufacturer has a CDCCL task that requires the air gap between an FQI probe and the Aircraft structure to be maintained. Is it the intention that individual records are required to be maintained for each probe? • Many IACA members have aircraft that transfer on short term seasonal leases. As these requirements are not harmonised with the FAA, and other Authorities, this will result in confusion and potential errors. IACA Presentation 23 Nov 2007

6. EASA Fuel Tank Safety Training Seminar • Many of the IACA members do have not their own Base Maintenance facilities and contract with third party MROs • Concern that not all Part 145 organisations, both inside and outside Member States, fully understand the requirements. This would include both Airframe/Engine Overhaul Agencies as well as smaller Component Overhaul companies. We would encourage the Agency and NAAs to have open dialogue with these organisations and work together to ensure consistency. • Do all Part 145 organisations have to provide training, or only with respect to their scope of approval? IACA Presentation 23 Nov 2007

7. EASA Fuel Tank Safety Training Seminar • We would further encourage the Agency to consider facilitating Industry Workshops to ensure that the results from meetings such as todays, are shared and to enable organisations to raise queries IACA Presentation 23 Nov 2007

8. EASA Fuel Tank Safety Training Seminar • Lack of coordination with the Airworthiness Directives that have been issued in respect of Fuel AWLs • Lack of coordination with the forthcoming regulation changes in respect of EWIS ( NPA 2007-01) which also imposes a heavy training workload • We would encourage the Agency to coordinate these issues with Industry to ensure that training efforts are not duplicated IACA Presentation 23 Nov 2007

9. EASA Fuel Tank Safety Training Seminar • Thank you for the opportunity to participate in todays seminar IACA Presentation 23 Nov 2007

10. IACA Presentation 23 Nov 2007