3 Things to Consider When Flying to an EASA Member State

The August 14, 2016 Part-NCC adoption and the November 26, 2016 deadline for EASA Third Country Operators (TCO) Guidelines have come and gone. It’s been our experience that there is still much confusion or, at the very least some lack of clarity, as to which operators will be required to comply with Part-NCC and/or Part-TCO.

1. Part 135 operators
Get up to speed on InFO 16018, European Aviation Safety Agency (EASA) Third Country Operators (TCO) Authorization

If you’re a Part 135 or other non-EASA member commercial operator doing business in Europe, and landing at any EASA airport, then you definitely must fulfill the requirements found at https://www.easa.europa.eu/easa-and-you/air-operations/tco-third-country-operators. You can also get more information and apply online at the same web address. TCO requires that operators have a GOM, which must include SMS and dangerous goods procedures, among others. For commercial operators merely overflying the EU, compliance is not required.

2. Part 91 or other non-EASA member private operators
Read up on EASA NCC (Regulation (EU) No 965/2012, Annex VI)

For Part 91 or other non-EASA private operators, some of this summer’s Part-NCC requirements may apply if you are subject to the new EASA Part NCC guidelines. For instance, if you have a base in an EASA member country or operational control resides there in some form, you should take measures to comply with Part-NCC. It’s important to be aware that the EASA authorities are conducting ramp checks more frequently to make sure anyone who needs to follow these guidelines are doing so.

In principle, it may be a good idea to take this opportunity to formalize your operation by developing an FOM/GOM, IOM (International Procedures Manual), and an SMS program, and making sure you have an MEL specific to your aircraft rather than simply operating with an MMEL approved for MEL use. These are the fundamental elements that will be looked for and you should be able to demonstrate that you have them in place.

3. Managed aircraft – or private flights operated by commercial operators

Operational control is increasingly being scrutinized, particularly in cases where commercial operators are conducting private flights. The SAO authorizations that are carried on those flights may or may not satisfy the inspectors in EASA member countries. It may be a good idea to take this opportunity to formalize your documentation by developing an FOM/GOM, IOM, SMS program and MEL specific to your aircraft. Developing these does not preclude anyone from continuing to operate under a management company. Management companies continue to provide valuable services, but being able to provide such documentation to inspectors could avoid embarrassing delays.

The important thing to take away is to make sure you’re on top of whether or not you need to do anything additional to continue operating in compliance with these new EASA regulations to ensure your trips run smoothly.

Lithium Batteries Onboard? 5 Ways to Manage the Potential Risk of Cabin Fires

As recent news stories have shown us, the desire for smaller and more powerful devices has led to an increased threat of Personal Electronic Devices (PEDs) combusting as manufacturers try to meet user demands.

Lithium Batteries Onboard?

The FAA has already banned the Samsung Note 7 from all commercial flights, but what about your flight department? At the moment, the FAA has not banned these devices on private or commercial/charter flights, so it’s up to you to set your own policies and to make sure your passengers are aware of them.

Here are five ways to mitigate the risk on your own aircraft:

1. Complete a Safety Risk Assessment (SRA)

We recommend that everyone familiarize themselves with SRAs; FAA SAFO 16001 contains a helpful list of things operators should consider. An SRA may vary with different aircraft depending on how they are equipped (e.g., fire fighting equipment) and the type of flights generally taken (e.g., long extended overwater operations vs. terminal/domestic operations). Completing an SRA will allow you to gain valuable information by taking stock of where you should be focusing, as well as inviting participation from everyone in the operation on mitigating this serious and real risk.

2. Establish procedures for the transportation of electronic devices

As with anything in your operation, your SRA findings should lead to the development of clear procedures, such as:

  • Not leaving devices in direct sunlight for extended periods of time
  • Not leaving devices in the aircraft unattended while charging
  • Monitoring device temperature and discontinuing use if warmer than normal
  • Asking passengers if they are carrying devices known to be at higher risk

3. Include onboard fire procedures in passenger briefings

While in flight, the first people to notice a PED that could become a fire hazard may be your passengers, so it is important that they are briefed and instructed on what to do, as they are your first line of defense. Include procedures for handling such situations in the pre-recorded passenger briefing, oral briefing, and/or printed materials to help reduce response time.

Such procedures may include:

  • Notifying flight or cabin crew
  • Locating and using fire extinguishers and fire containment devices
  • Using towels to cover nose and mouth to filter smoke
  • Moving away from any fire
  • Ensuring therapeutic oxygen is moved away from a fire

4. Make in-flight fires part of your recurrent training

Given the pervasiveness of PEDs and the corresponding increased risks of PED-related fires, in-flight fires should be emphasized in recurrent training for both pilots and flight attendants. Part of this training could include familiarization with regulatory guidelines, procedures, and industry best practices.

FAA AC 120-80A is a valuable source of information for handling in-flight fires, as it covers topics such as the use of halon and water fire extinguishers. The AC also includes procedures for after the fire is extinguished such as dousing the device with water or other nonalcoholic / nonflammable liquid to help cool the device.

5. Equip your fleet with fire containment devices

A fire containment device can be excellent supplementary support for PEDs that have not yet caught fire but may pose a fire risk, as well as for PEDs that have already caught fire and where initial steps to extinguish the fire have failed.

Containment bags and boxes are made out of high temperature resistant materials and are specifically built to contain not only the fire, but smoke and toxic fumes as well. Some may even contain fire suppression systems within the containment device. Note that some kits come with a glove or other means of handling or scooping the PED into the container. If yours does not, consider adding a thermal glove to your kit.

Batteries are a real risk in PEDs, and while the industry has long had procedures for battery fires for onboard aircraft equipment, it is clear that those should be extended to PEDs and other battery-operated devices brought on board the aircraft during a trip, since they have become such a common part of daily life.