Interim Report - Introduction - EASA

Research Project EASA.2009/4 

Regulation of Ground de-Icing and Anti-Icing 

Services in the EASA Member States 

Interim Report

Disclaimer 

This study has been carried out for the European Aviation Safety Agency by an 

external organization and expresses the opinion of the organization undertaking 

the study. It is provided for information purposes only and the views expressed in 

the study have not been adopted, endorsed or in any way approved by the 

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other commitment binding in law upon the European Aviation Safety Agency. 

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Reproduction of this study, in whole or in part, is permitted under the condition 

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EASA.2009.OP 21 

Study on the regulation of ground de-icing and anti-icing 

services in the EASA Member States 

INTERIM REPORT 

INTRODUCTION 

airsight GmbH 

© airsight GmbH 

Gustav-Meyer-Allee 25 

13355 Berlin 

Germany 

Phone: +49 30 45803177 

Fax: +49 30 45803188 

www.airsight.de

INTERIM REPORT – INTRODUCTION 

EASA.2009.OP.21 

Table of Contents 

1 Introduction.....................................................................................................................1 

2 Structure of the Interim Report .....................................................................................3 

3 Aim of the Interim Report ..............................................................................................4 

3.1 Stakeholders Representatives’ Briefing................................................................4 

3.2 EASA Actions ..........................................................................................................4 

4 Contents of the Interim Report......................................................................................5 

4.1 Data Summary and Analysis ..................................................................................5 

4.2 Options for Change .................................................................................................5 

4.3 Options for Change – Attachments .......................................................................6 

4.3.1 Attachment A – Summary and Analysis of Available Safety Data ....................6 

4.3.2 Attachment B – References to Regulations and other Documents ..................6 

4.3.3 Attachment C – FAA Standardised International Aircraft Ground De-icing 

Programme .......................................................................................................6 

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1 Introduction 

The tender specifications for EASA 2009.OP 21 were issued following: recommendations to 

address safety issues associated with thickened fluid residues; in response to comments 

submitted to A-NPA 2007-11; and the development of an Agency Plan of six medium and 

long-term actions. The terms of reference for this Study constitute one of the medium-term 

elements of this Plan, as follows: 

Investigate and recommend the means by which the Aviation Authorities of Member 

States manage matters with respect to the certification of service providers, 

availability of fluids at aerodromes, etc. 

In order to support the Agency in developing a voluntary harmonised regulatory approach to 

providers of de-icing / anti-icing services, and to achieve a greater availability of fluids at 

aerodromes, the Agency demanded factual inputs and informed advice from a 

knowledgeable consultant. 

The Project consists of three work packages: 

Investigation of the problem area: 

A systematic study containing an overview over the regulatory approaches taken by 

the National Aviation Authorities (NAAs) in the EASA Member States towards de-icing 

and anti-icing service providers. Also to obtain an overview over the airports / 

aerodromes at which air operators with a fleet containing susceptible aircraft are 

unable to get the appropriate de-icing and anti-icing treatment. 

Recommendations for regulatory action by Member States and the role of EASA 

therein: 

Due to being neither the direct regulator nor rule maker for ground-handlers, EASA 

wanted to obtain appropriate recommendations as to the most effective ways in which 

the NAAs of the EASA Member States could regulate deicing / anti-icing services in a 

harmonised way, so that the safety of aircraft operations is maximised and a level 

commercial playing field remains ensured. Recommendations were to centre on how 

the availability of type I fluids and the quality of service provision can be improved at 

the aerodromes of the EASA Member States. 

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Pre-regulatory impact assessment (pre-RIA) on the recommendations: 

In order to assess the impact of the recommendations the Agency wanted the 

prospective consultant to undertake a Pre-Regulatory Impact Assessment in which to 

judge the safety, economic, social, and environmental impacts of each 

recommendation. In particular the Agency wished to obtain quantitative estimations of 

the average investment expenditure for equipment to provide adequate aircraft 

ground de-icing / anti-icing operations (at an aerodrome where this was not previously 

provided) including the corresponding depreciation costs and maintenance costs, and 

also the same for very small, small and larger aerodromes to upgrade facilities and 

equipment to providing fluid type I in addition to type II and IV. 

The Interim Report to EASA.2009.OP.21 marks the end of the second work package (above) 

and includes a complete summary of the Study conducted under the first work package 

(above). With reference to the submitted airsight GmbH Project Plan (submitted to EASA at 

the Kick-off Meeting, in Köln, on 13 April 2010) this Report fulfils Deliverable 4 and marks the 

end of Work Package 5. It represents the culmination of an investigation in to the status quo 

of de-icing / anti-icing service provision and operations throughout EASA Member States. 

Furthermore, it includes an analysis of the data collected and the presentation of various 

options which, if adopted, may lead to an improvement in standards of de-icing / anti-icing 

and a greater availability of de-icing fluids. As a Deliverable to the Agency from the 

contractors, the opinion, analyses, assumptions and recommendations made within this 

Report are made by airsight GmbH and do not constitute any commitment, nor infer support, 

by EASA for the Report’s contents. 

This paper briefly explains the content and structure of the Interim Report. 

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2 Structure of the Interim Report 

The Interim Report consists of 6 separate documents: 

- Introduction Paper 

- Data Summary and Analysis 

- Options for Change 

- Attachment A to Options for Change: Summary and Analysis of Available Safety Data 

- Attachment B to Options for Change: References from Regulations and Other 

Documents 

- Attachment C to Options for Change: Notes on FAA Standardised International 

Aircraft Ground De-icing Programme 

Also accompanying the Interim Report will be any raw data collected via questionnaires, 

interviews and other means. 

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3 Aim of the Interim Report 

The aim of the Interim Report is to present the Agency with options for the most effective 

ways in which NAAs could regulate de-icing / anti-icing services in a harmonised way, so that 

the safety of air operations is maximised, and a level commercial playing field remains 

ensured. These options centre on how the availability of type I fluids can be improved, and 

how the quality of service provision can be improved. Options are also presented centred on 

voluntary mechanisms with potential for achieving the same goals. 

3.1 Stakeholders Representatives’ Briefing 

The options developed are to be presented to stakeholder representatives, including EASA 

representatives, at a Briefing in Köln, 6 December 2010. The aim of this is to attain feedback 

from all relevant stakeholder groups on the viability of each option. This feedback can then 

be included in the subsequent Preliminary Regulatory Impact Assessment, where the safety, 

economic, social and environmental impact of options will be assessed. Thus allowing 

substantive recommendations to be made, backed-up with supporting evidence. 

The options included within this Report are numerous and detailed and, in effect, many of 

them could form a Work Programme for future development. It is not the intention to present 

each and every option at the Briefing, but rather to present the higher-level options that meet 

the criteria of the project; i.e. those options that address regulatory and voluntary 

mechanisms for improving standards and the availability of fluids. To create a short-list will 

involve a prioritisation of options and a de-facto list of recommendations; this short-list will be 

circulated to attendees around 10-days prior to the Briefing as part of an Information Paper. 

3.2 EASA Actions 

The Agency, as well as being the project sponsor, is also a stakeholder and will be able to 

provide valuable and relevant feedback on the options as they are presented in the Interim 

Report and also at the Briefing. It seems sensible for the Agency’s representatives to 

evaluate the options (both high-level and detailed) and provide early feedback on the 

creation of a short-list for presentation at the Briefing. The allotted 20-day response time 

expires after the planned Briefing; therefore a quicker turn-round would be necessary. 

To assist the Agency in this matter, the Study Team will commence immediate drafting of the 

Information Paper, including a proposed short-list of options to be presented, and this will be 

available for discussion directly following the planned teleconference on 12 November at 

10:30 German Local Time. 

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4 Contents of the Interim Report 

The 3 Attachments to the “Options for Change” section of the Report are supporting 

documents, frequently referred to in the main body of the Report. They are useful in that 

they provide background details to some of the analysis and opinions within the main Report; 

however, for expediency, the reader may wish to delay examining these documents. 

Attachment B (References) is not designed to be read from start to finish, anyway, and is 

completely a reference document to specific regulations excerpts (and other documents), 

and includes possible options that were not selected for the main Report. 

The two main documents: Data Summary and Analysis, and Options for Change, are best 

read in that order. The latter document’s discussions and conclusions are based on the data 

presented in the former. 

4.1 Data Summary and Analysis 

This document presents the statistics of responses to on-line questionnaires, interviews and 

other data sources, followed by analysis of each area within the Study. The analyses 

presented include: 

- type I fluid availability, defined by weather zones and Member States, 

- factors affecting the supply and use of different fluids, 

- varieties of market mechanisms for supplying de-icing / anti-icing services, 

- infrastructure ownership and use, 

- training standards and classifications, and 

- NAA oversight and responsibilities of the three main affected stakeholder groups: 

operators, aerodromes and service providers. 

4.2 Options for Change 

This document provides further analysis and opinion. It specifically leads the discussion to 

numerous options, aimed at a variety of stakeholder groups, to change the status quo. 

Utilisation is made of existing and available information of relevance, primarily the Agency’s 

previous work on de-icing / anti-icing matters through A-NPA 2007-11, wherein numerous 

recommendations that were made remain valid and still need to be considered. Included 

within the document are discussions on the following subjects: 

- an Industry-wide safety initiative aimed at collecting data, 

- the nomination of de-icing / anti-icing subject-matter experts, 

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- the various regulatory pathways to affect de-icing / anti-icing standards and 

availability of fluid, 

- the factors that promote and deter service providers attaining high standards, and 

- alternative regulatory models based on regulation of other activities. 

4.3 Options for Change – Attachments 

4.3.1 Attachment A – Summary and Analysis of Available Safety Data 

This is not a full Safety Study, however, in determining which options to propose, the areas 

of weakness within de-icing / anti-icing operations needed to be identified. Therefore, this 

brief and restricted meta-study allows the Study Team to draw conclusions as to which areas 

to focus any proposed regulatory changes. Fortunately, the conclusions drawn support 

anecdotal data collected during interviews and also openly discussed, for many years, at 

other forums (AEA, ERA, SAE). Furthermore, this paper highlights the lack of lower-level 

safety data which is collected, shared and analysed; specifically, self-reported human error 

by service provider operatives. 

4.3.2 Attachment B – References to Regulations and other Documents 

This document is an edited and improved version of that presented with the Inception Report 

in June 2010. It was used as a logical tool by the Study Team to ensure that all existing 

regulatory mechanisms were examined in detail, with the intention of creating options for 

future amendment, improvement and addition. It includes relevant excerpts from such 

documents as EU OPS, ICAO Annexes 6 and 14, Doc 9640, and also includes the Agency’s 

proposals for Authority Requirements, Operator Requirements and Implementing Rules 

Operations. Each excerpt is accompanied by a brief explanation of relevance, a variety of 

possible options and a brief impact statement. 

Although used as a development tool by the Team, it is included to assist the reader access 

the relevant regulatory excerpts easily and to view the logic applied by the Team in the 

analyses. 

4.3.3 Attachment C – FAA Standardised International Aircraft Ground 

De-icing Programme 

This document contains brief notes made from an FAA presentation on their proposed 

programme of regulatory reform for US Air Carriers’ approved de-icing / anti-icing 

programmes. Also included are some useful excerpts from the FAA SIAGDP document, to 

help the reader understand the intended emphasis of this programme. 

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DATA SUMMARY AND ANALYSIS 

airsight GmbH 



13355 Berlin 

Germany 

Phone: +49 30 45803177 

Fax: +49 30 45803188 

www.airsight.de

INTERIM REPORT – DATA SUMMARY AND ANALYSIS 



1 Off-Site Data collection..................................................................................................1 

1.1 Objectives ...............................................................................................................1 

1.2 Online questionnaires............................................................................................1 

1.3 Questionnaire respondents...................................................................................2 

2 Analysis of the collected data.......................................................................................3 

2.1 Type I Fluids availability at Member States aerodromes ....................................3 

2.1.1 General Overview .............................................................................................3 

2.1.2 Type I Fluids availability per Member State......................................................5 

2.1.3 Type I Fluids availability per Winter Zone.........................................................6 

2.1.4 Type I Fluids availability per Aerodrome Size and Affected Traffic...................7 

2.1.5 Impact on affected traffic of Type I Fluids unavailability ...................................8 

2.1.6 Responsibility for the decision of the types of fluids provided...........................9 

2.1.7 Factors influencing Type I Fluids availability ..................................................11 

2.1.7.1 Supporting factors...................................................................................11 

2.1.7.2 Limiting factors........................................................................................12 

2.1.7.3 Non-influencing factors ...........................................................................14 

2.1.8 Selection of Type II/III/IV thickened fluids.......................................................15 

2.1.9 Selection of fluid manufacturer .......................................................................15 

2.2 De-icing / anti-icing services provision at Member States aerodromes..........17 

2.2.1 De-icing / anti-icing market overview ..............................................................17 

2.2.1.1 Service providers ownership and control ................................................17 

2.2.1.2 Other services provided by service providers .........................................19 

2.2.1.3 Competition in the de-icing / anti-icing service market............................20 

2.2.1.4 Selection of the service providers by the aircraft operators ....................21 

2.2.2 De-icing / anti-icing infrastructure, facilities and equipment............................23 

2.2.2.1 Storage tanks..........................................................................................23 

2.2.2.2 De-icing / anti-icing locations ..................................................................23 

2.2.2.3 De-icing / anti-icing fluids recovery and treatment / recycling.................24 

2.2.2.4 De-icing / anti-icing units.........................................................................25 

2.2.3 De-icing / anti-icing fluids................................................................................26 

2.2.4 De-icing / anti-icing standards and quality assurance ....................................27 

2.2.4.1 De-icing / anti-icing standards.................................................................27 

2.2.4.2 De-icing / anti-icing quality assurance ....................................................28 

2.2.5 De-icing / anti-icing personnel and training.....................................................31 

2.2.5.1 Structure of personnel.............................................................................31 

2.2.5.2 Training ...................................................................................................31 

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2.2.5.2.1 Selection procedures...........................................................................31 

2.2.5.2.2 Levels of qualification ..........................................................................31 

2.2.5.2.3 Trainers’ qualifications.........................................................................32 

2.2.5.2.4 Training types......................................................................................33 

2.2.5.2.5 Training requirements and content......................................................34 

2.2.5.2.6 Training evaluation ..............................................................................35 

2.2.5.2.7 Training records ..................................................................................35 

2.2.5.3 Safety Management................................................................................35 

2.3 Responsibilities of the National Aviation Authorities (NAAs)..........................37 

2.3.1 Coordination of de-icing / anti-icing activities within the NAAs .......................37 

2.3.2 National de-icing / anti-icing regulations directly applicable to aerodromes and 

service providers ....................................................................................................................37 

2.3.3 Direct oversight of de-icing / anti-icing service providers by National Aviation 

Authorities 38 

2.3.4 National de-icing / anti-icing regulations directly applicable to aircraft operator 

39 

2.3.5 National oversight of aircraft operator de-icing / anti-icing operations............40 

2.4 Incidents related to de-icing / anti-icing services and fluids............................41 

Annex 1 – Supportive Material ............................................................................................42 

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Table of Figures 

Figure 1: Map of Type I Fluids availability at Member States’ aerodromes..............................4 

Figure 2: Type I Fluids availability per Member State ..............................................................5 

Figure 3: Type I Fluids availability per Winter Zone .................................................................6 

Figure 4: Type I Fluids availability per Aerodrome Size ...........................................................7 

Figure 5: Type I Fluids availability per aerodrome Affected Traffic Category (aircraft with no 

powered flight controls) ............................................................................................................7 

Figure 6: Impact on affected traffic of Type I Fluids unavailability (based on number of 

affected traffic movements at aerodromes not providing Type I fluids and number of snow 

days).........................................................................................................................................8 

Figure 7: Risk factor based on percentage of aerodromes not providing Type I Fluids and on 

the number of snow days .........................................................................................................9 

Figure 8: Influence of the Airport Users’ Committee over which fluid types are made available 

to airlines................................................................................................................................10 

Figure 9: Supporting Factors which influenced the decision to provide Type I fluid and two 

step de-icing / anti-icing..........................................................................................................11 

Figure 10: Limiting factors which influence the decision not to provide Type I fluid and two 

step de-icing / anti-icing..........................................................................................................12 

Figure 11: De-icing / anti-icing service provision....................................................................17 

Figure 12: Other aviation services provided at the stations ...................................................19 

Figure 13: Percentage of Annual Turnover generated by de-icing / anti-icing services .........19 

Figure 14: Factors when considering the choice of a de-icing / anti-icing service provider ...21 

Figure 15: Location of the de-icing / anti-icing operations......................................................24 

Figure 16: De-icing / anti-icing fluids recovery .......................................................................25 

Figure 17: Applicable standards and procedures for service provider operations .................27 

Figure 18: Standards required by airlines for de-icing / anti-icing operations ........................28 

Figure 19: Organisation conducting audits of the de-icing / anti-icing service providers........29 

Figure 20: Number of audits conducted per annum on service providers..............................30 

Figure 21: Levels of qualification............................................................................................32 

Figure 22: Training instructor or organisation.........................................................................32 

Figure 23: Refresher training duration....................................................................................33 

Figure 24: Training requirements & standards applying to de-icing / anti-icing personnel.....34 

Figure 25: Responsibility for the examinations and awards the qualifications .......................35 

Figure 26: Imposition of National Authorities..........................................................................40 

Figure 27: National Authority approval of winter operations plan/programme for de-icing / 

anti-icing of aircraft on the ground..........................................................................................40 

Figure 28: Conduction of aircraft operator de-icing / anti-icing winter operations programme 

audits......................................................................................................................................41 

Figure 29: Map of Type I Fluids availability at Member States’ aerodromes (zoom to Central 

Europe)...................................................................................................................................43 

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Figure 30: Map of Type I Fluids availability at Member States’ aerodromes (zoom to 

Germany) ...............................................................................................................................44 

Figure 31: Map of Type I Fluids availability at Member States’ aerodromes (zoom to Poland) 

...............................................................................................................................................45 


Scandinavia)...........................................................................................................................46 

Figure 33: Map of Type I Fluids availability at Member States’ aerodromes (zoom to United 

Kingdom) ................................................................................................................................47 

Figure 34: Map of Type I Fluids availability at Member States’ aerodromes (zoom to Portugal, 

Spain and France)..................................................................................................................48 

Figure 35: Map of Type I Fluids availability at Member States’ aerodromes (zoom to Italy, 

Switzerland and Austria) ........................................................................................................49 

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INTERIM REPORT – Data Summary and Analysis 


1 Off-Site Data collection 

1.1 Objectives 

The initial objective of the off-site data collection was to collect a large amount of data from 

all stakeholders, in order to get an overview of the current situation with regard to de-icing / 

anti-icing services, and to provide the required quantitative information for the Impact 

Assessment. 

1.2 Online questionnaires 

To fulfil the previous objectives, the following questionnaires have been developed, and 

made available online between 07 th July 2010 and 15 th October 2010 to the stakeholders: 

− NAAs Questionnaires 

o Questionnaire 1: General Data 

o Questionnaire 2: Oversight of Aerodromes 

o Questionnaire 3: Oversight of Service Providers 

o Questionnaire 4: Oversight of Air Operators 

o Questionnaire 5: Oversight of Continuing Airworthiness 

− Aerodromes Questionnaire 

− Service Providers Questionnaire 

− Air Operators Questionnaires 

o Questionnaire 1: Regulations and Operations 

o Questionnaire 2: Maintenance 

Please refer to the Inception Report for more details on the development methodology and 

content of the questionnaires. The initial invitations to the online questionnaires, supported 

by an accreditation letter issued by EASA Rulemaking Director, were sent per email to the 

stakeholders either directly (to existing airsight contacts to aerodromes, service providers’ 

individual stations, aircraft operators, as well as to the directors of the Member States’ 

national authorities) or indirectly (aircraft operators via associations such as ERA, AEA, 

service providers’ individual stations via their headquarters or aerodromes etc.). 

Individual reminders containing the initial invitation were sent to the stakeholders during the 

summer, and further actions (email reminders, phone calls etc.) were conducted throughout 

the summer to achieve a highest possible number of respondents. 

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1.3 Questionnaire respondents 

As of 15 th October 2010, completed questionnaires have been received, as follows: 

− 37 questionnaires from the Aerodromes 

− 69 questionnaires from the Service Providers 

− 30 questionnaires from the Air Operators (Questionnaire 1 - Regulations and 

Operations) 

− 25 questionnaires from the Air Operators (Questionnaire 2 - Maintenance, including 

Quality Assurance) 

− 13 questionnaires from the National Aviation Authorities 

Thus, the overall participation of the stakeholders is considered to be most satisfactory. 

The different response ratios of the stakeholders may, in themselves, be interpreted as a 

potential finding of the study. 

− The high level of participation of the service providers can be explained by the fact that 

they are the most involved in the field of de-icing / anti-icing, and will be potentially the 

most affected stakeholder group by the impact of this present study. The identification 

of a responsible person for this study and the provision of detailed quantitative figures 

was straightforward, possibly because service providers are used to being frequently 

audited by the aircraft operator. 

− The medium level of participation of the aerodromes (37 answers for over 150 

aerodromes directly contacted) is related to their current level of involvement in deicing 

/ anti-icing services. Most aerodromes do not provide directly for de-icing / antiicing, 

and therefore do not feel responsible for third-party providers. Such aerodromes, 

within the study, simply forwarded the relevant questionnaires to their service 

providers (this further also explains the high participation of the service providers). 

− The medium, and partially incomplete, involvement of the NAAs in the study is 

probably due to the difficulties of the authority to identify a central focal point 

responsible for the field of de-icing / anti-icing. In most cases, no such dedicated 

persons exist within the NAAs. 

− The medium level of participation of the aircraft operators is due to similar reasons as 

mentioned above for the NAAs. De-icing / anti-icing related matters are dealt with by 

several distinct departments (air operations, quality assurance, maintenance etc.), and 

the identification of a focal point was difficult. 

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2 Analysis of the collected data 

2.1 Type I Fluids availability at Member States aerodromes 

2.1.1 General Overview 

The following analysis focuses on the availability of Type I fluids 1 at European Aerodromes. 

The information on Type I fluids has been provided by the questionnaire respondents 

(aerodromes and service providers) consolidated with IATA DAQCP data. In total, data on 

Type I fluid availability has been determined from the sample of 168 aerodromes involved in 

this study. 

Type I fluids are currently available at 91 aerodromes (54.17 % of the 168 studied 

aerodromes). 

The following map (Figure 1) shows graphically the collected data and defined weather 

zones; the red dots represent those aerodromes not providing Type I fluids, and blue dots 

the aerodromes which are providing Type I fluids. The figures contained in the Annex of this 

document presents several magnifications of selected area of this map. 

In order to classify aerodrome stakeholders to make informative comparisons of data, six 

weather zones were established. The criteria used for these five classifications are based on 

the average number of “snow days” (Table 1) experienced per annum as measured over the 

past 5 years. 

1 SAE AMS 1424 Type I Qualified Fluids 

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Zone Snow Days 

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fewer than 5 

5 to 9 

10 to 19 

20 to 39 

40 to 70 

more than 70 

Table 1: Average Number of Snow Days per annum 

which define selected Weather Zones 

Figure 1: Map of Type I Fluids availability at Member States’ aerodromes



2.1.2 Type I Fluids availability per Member State 

As shown in the previous map and in the Figure 2 below, fluids availability is very 

heterogeneous among the Member States. While in addition to thickened fluids 2 , Type I fluids 

are greatly available in the Nordic countries (Finland, Sweden, Norway, Denmark and the 

Baltic States), other Member States tend to rely mainly on thickened fluids (Belgium, United 

Kingdom, Romania, The Netherlands, Austria, Poland, Bulgaria, Greece, Ireland, Italy and 

Iceland). 

Denmark 

Estonia 

Finland 

Hungary 

Latvia 

Lithuania 

Slovak Republic 

Slovenia 

Sw eden 

Sw itzerland 

Norw ay 

Spain 

France 

Czech Republic 

Germany 

Belgium 

United Kingdom 

Romania 

The Netherlands 

Austria 

Poland 

Bulgaria 

Greece 

Ireland 

Italy 

Luxemburg 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 


Type I Fluids Availability (in percent) 

Figure 2: Type I Fluids availability per Member State 3 

2 SAE AMS 1428 Type II, III, IV Qualified Fluids 

3 Based on the data collected in 2010 during the study – possibly not representative of a country 

situation



2.1.3 Type I Fluids availability per Winter Zone 

The proportion of aerodromes providing Type I fluids per Winter Zone, displayed in Figure 3, 

further explains the current utilisation of de-icing and anti-icing fluids. Italy, Spain, and South 

of France, situated in Zones 1 and 2 (less than 10 snow days per year) have a different 

approach on the fluids provision at their aerodromes. While aerodromes in Spain and South 

of France mainly conduct “de-icing only” operations with Type I fluids, Italy mainly conduct 

de-icing / anti-icing operations mainly with thickened fluids only. The aerodromes within Zone 

3 are for most part in the UK – a country with a low Type I fluids availability ratio. 

Zone 4 and 5 aerodromes (situated in e.g. Germany, Austria, the Benelux, Poland, Romania, 

Bulgaria etc.) have a Type I availability ratio close to the overall average. It can be observed 

that, the ‘New’ Member States, such as Poland, Romania and Bulgaria, have a low Type I 

availability ratio. This may be explained by the fact that these aerodromes had already 

invested in de-icing / anti-icing infrastructure, facilities and equipment prior to the safety 

issues with thickened fluids being raised. 

Zone 6 aerodromes, mainly located in Nordic countries, make great utilisation of Type I 

fluids, mainly for use as a de-icer instead of using thickened fluids for that purpose. 

Zone 6 (more than 70 

snow days) 

Zone 5 (between 40 and 

70 snow days) 


40 snow days) 


20 snow days) 


10 snow days) 

Zone 1 (less than 5 

snow days) 

93.10% 

54.76% 

52.63% 

38.46% 

18.18% 

57.89% 


Type I Available Type I Not Available 

0 5 10 15 20 25 30 35 40 45 

Number of aerodromes 

Figure 3: Type I Fluids availability per Winter Zone



2.1.4 Type I Fluids availability per Aerodrome Size and Affected Traffic 

A further analysis of the provided information reveals two important facts, namely that Type I 

fluids availability is, generally, not correlated to: 

− the aerodrome size (as displayed in Figure 4) 

− the percentage of potentially affected traffic (aircraft with no powered flight controls – 

which are more affected by thickened fluid residue issues) (as displayed in Figure 5) 

Large (More than 1 Million PAX) 

Medium (0.5 to 1 Million PAX) 

Small (0.1 to 0.5 Million PAX) 

Very Small (less than 0.1 Million 

PAX) 

Category 4 (more than 50% of 

affected traffic) 

Category 3 (betw een 30% and 

50% of affected traffic) 

Category 2 (betw een 15% and 

30% of affected traffic) 

Category 1 (less than 15% of 

affected traffic) 

50.86% 

47.83% 

66.67% 

100.00% 


0 20 40 60 80 100 120 140 


Figure 4: Type I Fluids availability per Aerodrome Size 4 

60.00% 

51.11% 

53.13% 

51.06% 


0 10 20 30 40 50 60 70 


Figure 5: Type I Fluids availability per aerodrome Affected Traffic Category (aircraft 

with no powered flight controls) 

4 

Please consider that the high number of Nordic Countries “Small Aerodromes” (generally providing 

Type I fluids) which participated to the study increases the proportion of small aerodromes providing 

TypeI fluids. 

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2.1.5 Impact on affected traffic of Type I Fluids unavailability 

The Figure 6 displays a qualitative “risk factor”, based on the total number of affected aircraft 

traffic at aerodromes not providing Type I fluids and the weather zone (number of 

movements of affected traffic at aerodromes not providing type I – multiplied by the weather 

zone number, e.g. 1 for “Zone 1”). However, a different weighting of the parameters may 

have led to slightly different results, according to this key indicator; the most affected 

countries by potential safety issues related to the non-availability of Type I fluids are United 

Kingdom, Poland, Italy, Austria, Germany and Romania. 


Poland 

Italy 

Aus tria 

Germany 

Romania 

Bulgaria 

Ireland 


France 

Spain 

Greece 

Luxemburg 

Norway 


Iceland 


Risk factor based on total affected traffic 

Figure 6: Impact on affected traffic of Type I Fluids unavailability (based on number of 

affected traffic movements at aerodromes not providing Type I fluids and number of 

snow days) 

The Figure 7 displays a similar qualitative “risk factor” as the previous one, but based only on 

the number of aerodromes not providing Type I fluids and the number of snow days. In this 

case, the risk factor does not take the traffic volumes into account.



Poland 


Germany 

Aus tria 

Romania 


Italy 

Bulgaria 

Iceland 

Ireland 

France 


Luxemburg 

Norway 

Greece 

Spain 

Risk factor based on number of aerodromes not providing Type I Fluids and snow days 

Figure 7: Risk factor based on percentage of aerodromes not providing Type I Fluids 

and on the number of snow days 

2.1.6 Responsibility for the decision of the types of fluids provided 

The selection of the types of fluid to be provided, and to a greater extent the decision for 

upgrading an aerodrome’s de-icing / anti-icing infrastructure, facilities and the equipment to 

be provided, may require significant investment from the stakeholders, namely the 

aerodrome itself, the service provider(s) and, indirectly, the airlines (higher cost for service). 

According to the respondents and interviewees, no national aviation safety regulations 

directly affect the selection of the types of fluid provided at an aerodrome (please refer to 

Chapter 2.3.2 for more details). 

Therefore, the selection of the types of fluid and related investment is generally based on a 

consensus of the stakeholders’ interests. Therefore, active airline requests, as well as the 

management and organisation of the de-icing / anti-icing services and the ownership of the 

storage facilities, are the main influencing factors for the responsibility of the decision. 

As a general rule, the higher the number of stakeholders and required investment, the more 

difficult is the decision process. In cases where the aerodrome itself is providing de-icing / 

anti-icing services, or the sole service provider is under the partial or full management of the 

airsight GmbH - 9 -



aerodrome, the decision for additional investment could be straightforward. Whereas, in 

cases where multiple independent service providers are required to invest in new equipment 

and possibly new storage facilities, the decision may be more complex. 

Almost all airports have set-up an Airport Users' Committee (mandatory for aerodromes 

within the scope of Council Directive 96/67/EC). However, the inclusion of de-icing / anti-icing 

service provision related matters within such committees is very limited, especially at small 

and medium aerodromes. The AUC is more likely to discuss surface snow removal plans, 

taxi traffic patterns and traffic flow rates during winter operations. According to Figure 8, at 

58% of the aerodromes the Airport Users' Committee has no influence; only 17% of the 

aerodrome respondents mentioned that such committees have a large influence 5 . This is 

mainly due to the complexity of the subject as well as the lack of representation of the 

airlines. As a result, airlines informally express their interest indirectly to the monopoly 

service provider or to the aerodrome if several service providers are present. The 

discussions on the required de-icing / anti-icing investments and resulting costs to the 

airlines take place more in dedicated working groups. 

17% 

8% 

17% 


0% 

58% 

No Influence 

Slight influence 

Moderate influence 

Large Influence 

Total influence 

Figure 8: Influence of the Airport Users’ Committee over which fluid types are made 

available to airlines 

5 

Service Provider Questionnaire – Question 2.2: With regard to the role of aerodrome management, 

does your National Authority imposes Regulatory Requirements on Availability of Type I Fluid



2.1.7 Factors influencing Type I Fluids availability 

2.1.7.1 Supporting factors 

No Influence Slight influence Moderate influence Large Influence Total influence 

Broader awareness of Safety issues related to Type II/IV Residues 

Majority airline demand 

Airline demand (some or the majority) 

Some airline demand 

Suitable de/anti-icing Truck capacity and capability 

Sufficient environmental protection 

Adequate fluid storage infrastructure and facilities 

Lack of time pressure for throughput 

Adequate Space/Area to conduct 2-step de/anti-icing 

Economic factors 


0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Figure 9: Supporting Factors which influenced the decision to provide Type I fluid and 

two step de-icing / anti-icing 

The principal factor supporting the utilisation of a Type I fluid, not assessed in the 

questionnaires, is its capability as a de-icer to break the bonding of snow and ice. 

Consequently, countries with severe winter conditions make an intense use of such fluids 

within a two step de-icing / anti-icing. 

According to those aerodromes and service providers who have introduced the two-step 

procedure with Type I fluid used in the first step, the second contributory factor was the 

broader awareness of safety issues related to Type II/IV Residues: over 70% of the 

respondents stated that it had a large or total influence in providing Type I fluids. Some 

aerodromes, immediately or soon after the publication of the first safety advices related to 

thickened fluid residues consequently changed their operations – though, according to the 

opinion of the stakeholders, there was no scientific evidence that two-step procedures would 

completely eradicate the residue issues. 

The third influential factor, and related to the second factor, is the active – or anticipated – 

demand from the airlines to provide Type I fluids and a two-step procedure. Airlines, by 

reducing the number of thickened fluids applications lowers both the risk of incidents related 

to residues (safety factor) as well as their maintenance cost for cleaning residues (economic 

factor). By responding directly to existing airline requests, or projecting new airlines’ 

requirements, aerodromes potentially increase current client satisfaction and attract more 

airlines: an interviewed airline mentioned that the non-availability of Type I fluid would 

decrease by 25% the probability to operate at an aerodrome.



According to the interviewed aerodromes and service providers, the total cost of fluids for 

providing one-step or two-step de-icing / anti-icing procedures is similar. This is because, 

while the cost of neat Type I fluid is higher than thickened fluids, it is more efficient as a deicing 

fluid, and is also frequently used in a more diluted form than thickened fluids; therefore 

the cost is about the same. Consequently, there is no additional increased cost of fluids for 

the airline, besides the initial investment for upgrading the infrastructure, facilities and 

equipment. 

Numerous arguments have been provided by the stakeholders through interviews regarding 

the operational benefits of providing a two step de-icing / anti-icing procedure with Type I 

fluids (applied heated) for de-icing and thickened fluids (applied cold) for anti-icing, namely: 

− The ease of storage, mixing and testing Type I fluid and its low risk of degradation 

when compared to thickened fluids. 

− The ease of using (in a second step) “cold” thickened fluids. First, it avoids 

unnecessary heating of fluid in vehicle tanks, or repeated heating of fluids which may 

degrade fluids. Secondly, the use of cold thickened fluids ensures a more accurate 

HoT; the heating of thickened fluids reduces their viscosity, thereby decreasing the 

fluid’s ability to absorb the quantity of precipitation as assumed in HoT tables. 

2.1.7.2 Limiting factors 


Airline preference for Type II/IV fluids 


Not enough airline demand 

No airline demand 

Inadequate de/anti-icing truck capability/capacity 

Inadequate environmental protection 

Insufficient time / Operational throughput demands 

Insufficient De/Anti-icing personnel 

Inadequate Fluid storage infrastructure and facilities 

Environmental Regulatory restriction 

Restricted Location and/or availability of de/anti-icing areas 


0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Figure 10: Limiting factors which influence the decision not to provide Type I fluid and 

two step de-icing / anti-icing 

According to the service providers, the main limiting factor to providing Type I fluid and twostep 

de-icing / anti-icing is the “airline preferences for thickened fluids”, directly resulting in 

too little or no airline demand for changing fluids and methods. For approximately 40% of the



service providers, their given reason for not providing Type I fluids and two-step de-icing / 

anti-icing is that there is not enough airline demand. 

There is probably a series of reasons for such a lack of (communicated) active requests from 

the airlines to the service providers. The main reasons could be, for instance: 

− Many airlines are not affected by safety issues caused by anti-icing fluid residues. 

− Many airlines now have adequate maintenance programmes for the inspection and the 

cleaning of residues. 

− The real or perceived higher cost associated to Type I fluids and two step de-icing / 

anti-icing. 

− The longer HoT of thickened fluids may represent a benefit in operations for the pilots. 

− Pilots informal comments to their service providers, possibly in contradiction with their 

company policy, prefer a quick-and-easy one-step de-icing / anti-icing. 

− Airlines possibly do not communicate appropriately their requests for Type I fluids and 

two-step de-icing / anti-icing, or their requests are ignored (50% of the interviewed 

airlines stated they would actively make such requests to the service providers). 

− The lack of airline awareness of the current availability of Type I fluids at the stations 

at which they operate from. 

Besides the lack of airline demand for Type I fluids and two step de-icing / anti-icing, other 

main limiting factors, from the point of view of the service providers, are of an economic 

nature: the provision of Type I fluids and two step de-icing / anti-icing at aerodromes where it 

is not yet provided can sometimes require a significant initial investment. This investment 

represents a major long-term financial commitment from the owners of the facilities and 

equipment (the aerodrome and/or the service provider(s)), and the rate of return – in most 

cases not quantifiable – is uncertain. De-icing / anti-icing vehicles are the major equipment 

expenditure; these vehicles typically have a lifespan of 10 to 15 years, which reflects their 

depreciation rates. Although they can still retain a high value after seven years, the secondhand 

market cannot be relied upon to secure a return of investment. 

Such investment is hindered by several market conditions: 

− Most aerodromes and service providers have a limited financial capacity: de-icing / 

anti-icing is often performed at a loss at small and medium aerodromes or at 

aerodromes with modest winter operations (e.g. Southern Europe). 

− In addition to the previous point, the predicted level of future earnings for de-icing / 

anti-icing service provision is very low. This is because traffic figures and the severity 

airsight GmbH - 13 -



of winter operations are highly volatile: thus, the number of de-icing / anti-icing 

operations per year can vary in Central Europe by up to 50% (e.g. EFM Ground 

Handling published in their annual report (4 778 operations during the winter season in 

2006-2007, versus 7 309 operations 2007-2008 – an increase of 53%). 

− Service providers generally have short-term contracts with the airlines (renegotiated in 

some cases on an annual basis), as well as with the aerodromes (license terms of 

seven years for aerodromes within the scope of Council Directive 96/67/EC) – 

considering that equipment and facilities is used on average between 10 to 15 years. 

Together, these factors contribute to defensive strategies and the minimising of 

investment. 

− In keeping with providing a better quality of service, the provision of Type I fluids could 

represent a competitive advantage towards local competitors; however, even if 

competition exists when several service providers are operating at an aerodrome, the 

same fluids are usually provided to and by all of them (generally storage facilities are 

shared). 

− It must be noted that the service providers who responded to the questionnaire 

probably underestimated the limitation imposed by their current equipment (only 

around 25% of the respondents mentioned that “inadequate de-icing / anti-icing truck 

capability/capacity to provide Type I fluid” would be a limiting factor). 

− Several interviewed representatives of the aerodromes or service providers identified 

the provision of Type I fluid as a necessity, but could not convince the final decisionmakers 

to adopt the proposed improvement. Some interviewees mentioned that 

regulatory actions at a National or European level could provide the necessary 

leverage regarding the provision of fluids. 

− From an operational standpoint, operating with a single type of fluid (mainly Type II) 

offers the advantage of simplicity: aerodromes and service providers can purchase (in 

most cases pre-mixed) and store a single fluid type, used for both de-icing and antiicing. 

Furthermore, according to the interviewees, Type II fluids would particularly well 

suit the oceanic or moderate continental climates. 

2.1.7.3 Non-influencing factors 

Several factors have little or no influence on the decision to provide Type I fluids and twostep 

de-icing / anti-icing. Such non-influencing factors are, amongst others: 

− Aviation regulations on fluid availability: No national regulations require the 

utilisation of specific fluid types. Operational Directives on the use of thickened fluids 




published by e.g. the Federal Office of Civil Aviation (FOCA) and the French 

Directorate General of Civil Aviation (DGAC) in 2001 only contain recommendations of 

a non-binding nature on the types of fluids and procedures. 

− Environmental regulations: According to the respondents, Environmental 

regulations have no influence on the provision of Type I fluids. . Nevertheless, prior to 

the utilisation of any new chemical substance, some aerodromes (e.g. in some States 

in Germany) have to get approval from the responsible environmental authorities. 

− Operational throughput (capacity issues): Availability of space (areas) to conduct 

de-icing / anti-icing operations, together with manpower related issues: A change in 

the de-icing / anti-icing procedures would not greatly affect throughput, space 

required (except when additional trucks are required in addition to the existing ones), 

nor manpower requirements, and therefore does not represent a major limiting factor. 

In addition, the informal recommendations made by some IATA DAQCP auditors to the 

service providers regarding the provision of Type I fluid have usually no impact/response 

(possibly because non-availability of Type I fluids is not an audit finding). 

2.1.8 Selection of Type II/III/IV thickened fluids 

Thickened Type II, III and IV fluids may be used in conjunction with Type I fluids in a two-step 

procedure, when anti-icing is required. The utilisation of these fluids mainly depends of the 

holdover time to be achieved and the service provider’s preferences. 

According to the information provided by the stakeholders, Type II and IV fluids are used at 

an almost equal number of aerodromes (in 44 service providers offering a two step 

procedure, in addition to Type I fluids, 23 service providers are using Type II fluids, and 21 

service providers Type IV fluids). Type III fluids are not used at the aerodromes analysed; 

and it is believed that only one aerodrome currently supplies Type III at the request of one 

operator. Operators of regional aircraft may be more inclined to request Type III if more deicing 

/ anti-icing areas were located closer to departure runways. Figure 15 below shows 

that 74% of de-icing / anti-icing operations take place at the gate, and only 17% close to 

departure runways. 

2.1.9 Selection of fluid manufacturer 

The main criteria for the selection of the brand of fluid are of a commercial, environmental 

and technical nature. 

Commercial aspects include mainly the price of fluids, delivery time and service quality. 

According to the service providers, the requirements on the delivery-time are the main 




limitation in the choice of the fluid manufacturer. Service quality, namely the support provided 

to answer questions on fluid utilisation (and possibly conduct laboratory tests) in a timely 

manner is also an important factor. 

As all de-icing / anti-icing fluids used in Europe comply with strict SAE technical qualification 

standards, the physical and chemical characteristics of the fluids used at European 

aerodromes are probably of secondary importance in the selection of the fluid brand and 

were not assessed in the questionnaires and interviews. 




2.2 De-icing / anti-icing services provision at Member States 

aerodromes 

2.2.1 De-icing / anti-icing market overview 

2.2.1.1 Service providers ownership and control 

The ownership and control of the service providers may have an influence on de-icing / antiicing 

operations. In general, the current global market situation is very eclectic and in 

constant flux. 

Firstly, in order to simplify matters, it is possible to distinguish between “non-independent 

service providers” (aerodrome operator handling), “independent service providers” (thirdparty 

handling), and “self-handling” by the airlines. 

− Non-independent service providers are operated directly by the aerodrome. The 

aerodrome is then providing de-icing / anti-icing services and has full control and 

responsibility over the services provided. Non-independent stations are for instance 

operating at Paris-Charles de Gaulle and Ljubljana Airport. 

− Independent service providers are owned by commercial entities, separate from the 

aerodrome operator. 

− Self-handling airlines, in this current definition, are also potentially providing services 

to third party operators or code-sharing partners. 

The results of a manual assignment of the audited DAQCP service providers (more reliable 

in this case than the questionnaire data) to the above categories are illustrated in the 

following Figure. 

13% 

58% 


29% 

Non-independent service provider 

Independent service provider 

Self-handling airlines 

Figure 11: De-icing / anti-icing service provision



The ownership and control of the independent service providers is a complex subject, and 

beyond the scope of this study. In general, an independent service provider may be owned 

by a single, as well as multiple, shareholders, such as: 

− an aerodrome operator (e.g. Portground GmbH in Dresden and Leipzig, Tallinn Airport 

GH Ltd) 

− an airline (e.g. SAS Ground Services) 

− a major ground handling company (Servisair, WISAG Aviation Service Holding, Swiss 

Port) 

− a state-owned company (RTG Ground Handling Oy in Finland) 

As the provision of de-icing / anti-icing services is viewed by aerodromes as either essential 

for their operations, or as simply good for business, aerodrome operators often directly 

provide de-icing / anti-icing services, or have total or partial control over their independent 

service providers. 

Due to the frequent lack of commercial viability of the de-icing / anti-icing service business, 

de-icing / anti-icing may have to be performed directly by the aerodrome (acting as a nonindependent 

service provider) or be indirectly subsidised by other ground handling activities. 

When services are provided by an independent service provider, owned by the aerodrome, 

the responsibilities for de-icing / anti-icing overlap in some cases between the aerodrome 

operator and the independent service provider: for instance, the aerodrome operator may 

share resources (e.g. workforce) with the service provider. In such scenarios, there is 

possibly a cross subsidisation of the de-icing / anti-icing activities from other sources of 

revenue, leading to possible conflict of interests and thereby hindering competition. 

However, according to the majority of stakeholders, the involvement of the aerodrome in deicing 

/ anti-icing may benefit the airlines. 

The provision of de-icing / anti-icing services, although listed as a ground handling service in 

Council Directive 96/67/EC, is defined as an operational requirement (ICAO Annex 6/EU 

OPS) essential to maintain and ensure airworthiness. Therefore, it should be best considered 

as a safety critical function rather than a commercial activity. 




2.2.1.2 Other services provided by service providers 

With a few exceptions (EFM at Munich Airport and N*Ice at Frankfurt Main Airport), all 

service providers provide other ground handling services besides de-icing / anti-icing. Figure 

12 lists the other services provided by the service providers 6 . 

Ramp handling services 

Baggage handling services 

Passenger handling services 

Ground administration and supervision services 

Freight and mail handling services 

Aircraft services 

Surface transport services 

Flight operations and crew administration services 

Catering services 

Aircraft maintenance services 

Fuel and oil handling services 

None 


4% 

7% 

7% 

11% 

29% 

39% 

46% 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Figure 12: Other aviation services provided at the stations 

According to the estimation of the respondents 7 (Figure 13), the contribution to annual 

turnover by de-icing / anti-icing services is generally below 20%. 

Number of responses 

14 

12 

10 

8 

6 

4 

2 

0 

12 

Less than 

10% 

6 

8 

1 

3 

55% 

57% 

0 

2 

80% 

79% 

10 - 20% 20 - 40% 40 - 60% 60 - 80% 80 - 90% More than 

90% 

Figure 13: Percentage of Annual Turnover generated by de-icing / anti-icing services 

6 

Service Provider Questionnaire – Question 1.10: What other aviation handling services are provided 

by your company at this location/station? 

7 

Service Provider Questionnaire – Question 1.11: What percentage of your Annual Turn-Over is 

generated by De/Anti-icing services at this station? 

84%



2.2.1.3 Competition in the de-icing / anti-icing service market 

Any increase in competition between local service providers may be viewed as potentially 

leading to an increase in quality of service and reduced prices. However, in practice, this 

theoretical market-mechanism has little influence on price and quality of de-icing / anti-icing 

services. 

As shown in Table 2, the number of service providers available per aerodrome, and therefore 

the competition – is in most cases extremely limited. 

Number of service providers 

1 2 3 more than 3 

Very Small (less than 0.1 Million PAX) 11 (84.6%) 2 (15.4%) 0 (0%) 0 (0%) 

Small (0.1 to 0.5 Million PAX) 39 (92.9%) 3 (7.1%) 0 (0%) 0 (0%) 

Medium (0.5 to 1 Million PAX) 24 (100%) 0 (0%) 0 (0%) 0 (0%) 

Large (More than 1 Million PAX) 26 (74.3%) 9 (25.7%) 0 (0%) 0 (0%) 

Very Large (More than 2 Million PAX) 36 (43.9%) 27 (32.9%) 13 (15.9%) 6 (7.3%) 

All aerodromes 136 (69.4%) 41 (20.9%) 13 (6.6%) 6 (3.1%) 

Table 2: Number of service providers available per aerodrome 

At 69.4% of the analysed aerodromes, a single service provider is in a monopoly position. 

Except for very large aerodromes (more than 2 Million PAX and therefore within the scope of 

Council Directive 96/67/EC), the majority of aerodromes have a single provider, and none 

have more than two. Of the remaining 30.6% of aerodromes, there is more than one service 

provider. 

The main factor limiting the number of service providers at aerodromes appears to be the 

lack of profitability of de-icing / anti-icing. The total amount of de-icing / anti-icing operations 

at an aerodrome (further dependent on the airport traffic and weather conditions) enables, 

only in a few cases, multiple service providers to operate at an aerodrome. Based on the 

above figures, it is possible to suppose that – independent of the winter conditions and 

further barriers to entry – there is no place for two simultaneous actors at an aerodrome in 

Central Europe with less than one million passengers per annum. The investment required 

for a projected small (and unpredictable) number de-icing / anti-icing operations is too great. 

A more detailed analysis of the results further reveals major national differences in the 

competition between service providers. For instance, while more than half of the aerodromes 

in the United Kingdom have multiple service providers, almost all German aerodromes have 

a monopoly service provider, under the ownership of the aerodrome. 

Though Council Directive 96/67/EC may facilitate market access for new entrants, its 

interpretation and implementation at national level has led to varying results, and significant 

“unwritten” barriers to entry still exist. For example, it would make little business sense for a 




ground handler to enter into competition with the current monopoly service provider owned 

by the aerodrome. 

2.2.1.4 Selection of the service providers by the aircraft operators 

The main factors and their importance for the selection of a service provider by an aircraft 

operator 8 are shown in Figure 14. 

Standard of Service 

Availability of desired fluids 

and procedures 

Results of available audits 



Other 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Figure 14: Factors when considering the choice of a de-icing / anti-icing service 

provider 

Unsurprisingly, these factors are: 

− The standard of service provided 

− The availability of desired fluids and procedures 

− The results of available audits 

− Economic factors (less than 20% of the respondents mentioned that it would have no 

or a slight influence) 

As most services provided are offered as very standardised, and de-icing / anti-icing is 

mainly perceived as a commodity by the airlines, it is possible to assume that the main 

selection criteria are driven by economics. 

8 

Service Provider Questionnaire – Question 3.10: Service Provision: Where you have a choice: 

Indicate the weighting you give to the following factors when considering your choice of a de/anti-icing 

Service provider. 




In cases where multiple service providers operate at an aerodrome (as previously 

mentioned, on average at 30.6% of the aerodromes), other economic or commercial aspects 

may, however, limit the choice available to operators. For example: 

− An aircraft operator usually chooses a single provider at an aerodrome for all its 

ground handling services. As de-icing / anti-icing services only represent a minor 

portion of the contract volumes, the importance given to the previously mentioned 

factors for the selection of a service provider, in a de-icing / anti-icing context, will be 

minimal. 

− An aircraft operator may have a contract with a single service provider to provide 

ground handling at different stations. Consequently, this may also reduce the 

importance given to the standard of de-icing / anti-icing service at each single station. 

− Any affiliation between service providers and aircraft operators may further reduce the 

number of alternative service providers for the airlines, as their obligations may 

preclude the purchase of services from competitors. 




2.2.2 De-icing / anti-icing infrastructure, facilities and equipment 

2.2.2.1 Storage tanks 

According to the aerodrome respondents, at 85% of the aerodromes, storage tanks are 

owned and managed by the commercial entity providing de-icing / anti-icing services. At the 

remaining 15%, the storage tanks are owned by the aerodromes or shared between the 

service provider(s) and the aerodrome. 

By owning the storage facilities, service providers (aerodromes or third parties) have 

potentially more control over the fluids they provide. When the storage tanks are part of the 

shared infrastructure – owned by the aerodrome – the service providers can only purchase 

the fluid types supplied by the aerodrome (e.g. Paris-Orly Airport). 

The ownership of the storage tanks is a further limiting factor to competition. For example, 

when storage is owned by an already established independent service provider, and the 

aerodrome operator (especially when owning the monopoly service provider) does not permit 

the construction/use of separate storage facilities, a new entrant would have to purchase 

fluids– and at the price set – by its competitor. 

While at large aerodromes it is usual to have fixed storage facilities, aerodromes with low deicing 

/ anti-icing activity, such as small and medium ones in France, are making a great use 

of portable, self-contained cubitainers provided by the fluid manufacturers (e.g. pre-mixed 

Type II fluids cubitainers). 

As well as an aerodrome charging a service provider for their accommodation facilities, they 

may also charge a rent for the space required by the service providers for their storage 

facilities and/or cubitainers. 

2.2.2.2 De-icing / anti-icing locations 

As shown in Figure 15, at 74% of the aerodromes, de-icing / anti-icing operations are 

performed at the ramp/gate 9 . 

9 Service Provider Questionnaire – Question 1.13: Facilities & Infrastructure, 

description/quantity/capacity: Where are De/Anti-icing operations conducted? 




Gate 

Remote/Centralized 

Position 

Taxiw ay close to 

departure runw ay 

17% 

23% 


74% 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Figure 15: Location of the de-icing / anti-icing operations 

Though not specifically addressed by the questionnaires, it would appear that only a minority 

of aerodromes are equipped with de-icing pads. The main reasons for this are the cost of 

such infrastructure, and its limited suitability when several service providers are operating at 

an aerodrome, and the consequent potential for traffic bottlenecks. In this respect the impact 

of having competing service providers may increase the risk of HoTs being exceeded, due to 

operations being conducted on the ramp. 

2.2.2.3 De-icing / anti-icing fluids recovery and treatment / recycling 

According to the responses provided by the aerodromes 10 (Figure 16), 41% of the 

aerodromes do not recover de-icing / anti-icing fluids. The other 59% of the aerodromes 

recover fluids, either by glycol recovery vehicles, by the fixed infrastructure at de-icing areas, 

or by other means. 

10 Service Provider Questionnaire – Question 1.10: Facilities & Infrastructure, 

description/quantity/capacity: How are de/anti-icing fluids recovered at your aerodrome?



18% 

12% 

29% 


41% 

None 

Fixed infrastructure at deicing 

area 

Vacuum trucks 

Other 

Figure 16: De-icing / anti-icing fluids recovery 

The treatment of the collected fluids differs widely, and is not further analysed within this 

document. 

2.2.2.4 De-icing / anti-icing units 

Service providers usually buy or lease (or lease buy-back) their de-icing / anti-icing vehicles. 

It represents generally their most important investment. De-icing / anti-icing trucks are in 

almost all cases owned (or leased) by the entity providing de-icing / anti-icing services. 

Trucks are in useful operation between 10-15 years on average. 

The number of units at an aerodrome mainly depends on the maximum planned throughput. 

While an aerodrome such as Frankfurt-Main Airport has around 40 units, smaller aerodromes 

(e.g. about one million passengers per annum) with a similar climate may only have 3 units 

(2 in operation, and 1 spare unit). 

The sizes, brands, options (e.g. forced air, on-board proportional mix-capability, etc.) and 

related characteristics (price, maintenance, manoeuvrability, fluid consumption) of the deicing 

/ anti-icing units depend on the requirements and preferences of the service providers. 

Service providers operating with a single type of fluid (e.g. Type II) have, in most cases, 

trucks not yet equipped to perform a two-step de-icing / anti-icing with both type I for de-icing 

and thickened fluids for anti-icing. While most manufacturers offer the option to upgrade deicing 

units, in some cases (usually for older vehicles) it can be an expensive conversion. 

Another option, considered by some, is to provide two-step de-icing / anti-icing in the short 

term (provided fluids are made available), using dedicated trucks for de-icing and others 

dedicated to anti-icing. However, such procedures are more complicated in practice 

(coordination effort), and involve more trucks on the apron – which may have an impact on 

safety.



Therefore, the costs associated with upgrading vehicles/systems to provide two-step 

procedures can vary considerable between little to great and is dependent on their current 

equipment. 

2.2.3 De-icing / anti-icing fluids 

An analysis of the utilisation of non-thickened and thickened fluids is provided in Chapter 2.1. 




2.2.4 De-icing / anti-icing standards and quality assurance 

2.2.4.1 De-icing / anti-icing standards 

Based on the answers of the respondents 11 , as shown in Figure 17, 96% of the service 

providers plan to conduct their operations in accordance with AEA recommendations. 

Service providers further adapt these recommendations to their own requirements (67%), or 

to each airline’s requirements (43%) as well as the aerodrome management requirements 

(24%). 

AEA 

Your own Company 

SAE 

Every individual Airline customer 

Aerodrome Management 

Your main Airline customer(s) 

Airline Alliance 

Airport Users' Committee 

Other 

0% 

7% 

7% 

24% 


28% 

43% 

48% 

67% 

96% 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Figure 17: Applicable standards and procedures for service provider operations 

The aircraft operators’ requirements on de-icing / anti-icing operations are fortunately also 

based on AEA recommendations 12 , as shown in Figure 18, with the aircraft manufacturer’s 

requirements providing a large influence. 

11 Service Provider Questionnaire – Question 4.2: Under whose Standards/Procedures are your 

De/Anti-icing operations conducted? 

12 Aircraft Operator Questionnaire 2 – Question 2.3: To what Standards are your De/Anti-icing 

applications undertaken?



AEA 

Your ow n airline's 

Aircraft Manufacturer's 

IATA De/Anti-Icing Quality Control Pool 

SAE 

National Authority's 

Aerodromes' 

Ow ner "mother" airline's 

Service Providers' 

Aerodrome User Councils' 

Airline Alliances's/Partner's 


4% 

4% 

7% 

11% 

11% 

15% 

30% 

44% 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 

Figure 18: Standards required by airlines for de-icing / anti-icing operations 

AEA recommendations are very comprehensive, frequently updated, and freely available 

over the internet. It must be noted, however, that no reference is made by the service 

providers to ICAO Manuals and national specifications (choice: “Other”). However, most 

stakeholders understand that procedures developed from the AEA Recommendations will 

automatically ensure compliance with ICAO Annex 6, Doc 9640 and EU OPS. 

Interviews further revealed that service providers spend a large amount of effort in 

considering each airline’s specific requirements. These requirements are provided to the 

service providers at the beginning of each season in the form of an airline winter operations 

manual (according to the aircraft operator respondents, 86% of them have specific 

requirements 13 ). As the manual structure and the requirements may differ for each airline, 

their implementation in operations is a challenging task. 

Numerous service providers interviewed pointed out this last issue, and called for a 

harmonisation of the airline requirements. 

2.2.4.2 De-icing / anti-icing quality assurance 

Quality assurance is accomplished via internal and external audits. As shown in Figure 19, 

70% of the service providers stated that internal audits were accomplished 14 . 

13 Aircraft Operator Questionnaire – Question 1.8: Do you provide documentation to Service Providers 

detailing your own specific requirements? 

14 Service Provider Questionnaire – Question 6.3: Who conducts audits on your Operations? 

70% 

74% 

85%



Fluid manufacturers 

Governmental Environmental Agencies 

Airport User's Committee 

National Authority 

Other Service Providers 

Airline Alliance 

Aerodrome 

Your ow n Company (HQ) 

Individual Airline customers 

IATA DAQCP 

11% 

13% 


0% 

2% 

2% 

6% 

9% 

70% 

81% 

83% 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Figure 19: Organisation conducting audits of the de-icing / anti-icing service providers 

Based on the same data, external audits are conducted systematically by the airlines, 

indirectly through IATA DAQCP (“pool-audit”, 83%) or directly by individual airlines (81%). 

The involvement of the aerodrome and the national authorities remains minimal. 

IATA DAQCP audits are conducted on an annual basis. These audits, conducted worldwide 

by a pool of selected auditors, are very comprehensive and standardised. The audit 

questionnaires are aligned with AEA recommendations, and their results (including potential 

non-resolved findings) are published to DAQCP members. 

Individual airlines also conduct their own audits, either because they are not members of 

DAQCP, or possibly to follow national regulations (e.g. FAA) or internal quality management 

requirements. 

It is of interest that European airline members of the DAQCP often conduct their own 

independent audits (e.g. Air Berlin). According to the service providers, these audits are in 

most cases “pro-forma” (possibly specific to ensure the implementation of an airline specific 

requirements), and less comprehensive than DAQCP audits. 

The number of audits conducted on a service provider per year depends on the number of 

airlines serviced. Figure 20 shows the number of yearly audits conducted on service 

providers 15 . While the number of audits remains reasonable for most service providers 

operating at small and medium aerodromes, some operators at large international 

aerodromes are audited by more than 20 airlines per season (e.g. Frankfurt Main and Zurich 

Airport). 

15 Service Provider Questionnaire – Question 6.1: How many audits are conducted by other 

organisations on your de/anti-icing operation?



Number of responses received from service providers 

25 

20 

15 

10 

5 

0 

Less than 3 3 to 5 6 to 9 10 to 19 More than 20 

Figure 20: Number of audits conducted per annum on service providers 

Meeting the demands of many audits can be expensive and time-consuming, as well as 

confusing. During interviews, these latter service providers (who are subjected to frequent 

auditing activity as mentioned above) expressed interest in the harmonisation of airline audits 

to avoid duplication and simplify matters. 




2.2.5 De-icing / anti-icing personnel and training 

2.2.5.1 Structure of personnel 

As de-icing / anti-icing is a seasonal and irregular activity, almost all personnel involved 

share other tasks (e.g. ramp and baggage handling) 16 . Except for the Head of Operations or 

supervisors of large dedicated service providers, no employee is engaged in working full time 

on de-icing / anti-icing activities. 

The proportion of time spent on de-icing / anti-icing activities, and the total number of 

procedures carried out per employee, also depends on the aerodrome traffic and the winter 

conditions. 

As for ground handling in general, de-icing / anti-icing personnel turnover is very high: 

between 5% and 30% of the personnel are new and inexperienced recruits, the average 

being 24% (based on the answer provided by the questionnaire respondents 17 and 

interviewees). Qualitatively, the higher levels of employee turnover are at service providers 

operating near larger urban populations. 

The above facts pose a major challenge for training and personnel management. 

2.2.5.2 Training 

2.2.5.2.1 Selection procedures 

According to the interviewees, though no formal procedure is defined for the selection of deicing 

/ anti-icing personnel, great care is given in the initial staff capability. 

2.2.5.2.2 Levels of qualification 

Figure 21 displays the levels of qualifications (defined by AEA) of the de-icing / anti-icing 

personnel achieved through training by the service providers. 

16 Service Provider Questionnaire – Question 1.8 How many of your permanent Staff is employed for 

De/Anti-icing (Dedicated 100% to De/Anti-icing / Sharing other tasks) 

17 

Service Provider Questionnaire – Question 1.9 On average for each season, how many Temporary / 

Seasonal Staff are typically employed for De/Anti-icing, and what are their experience levels? 

(Experienced recruits / Inexperienced recruits) 




De-Icing Operator 

Pre & Post de/anti-icing inspector 

De/Anti-Icing Supervisor 

De/Anti-icing Coordinator 

De/Anti-icing Instructor 

Fluid Quality Inspector 

De/Anti-icing Examiner 

Head of de/anti-icing Training 

Other 


0% 

29% 

27% 

35% 

42% 

45% 

65% 

71% 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Figure 21: Levels of qualification 

According to the respondents, service providers train their personnel as de-icing operators 

(98% of the service providers), pre & post de-icing / anti-icing inspectors (71%), supervisors 

(65%), coordinators (45%), instructors (42%) and fluid quality inspectors (35%). 18 

2.2.5.2.3 Trainers’ qualifications 

The training of the de-icing personnel (mainly de-icing operators), shown in Figure 22, is 

conducted at the majority of service providers at their premises by an internal instructor 

(86%), or by an external instructor, usually working as an instructor for another service 

provider (20%) or an airline (17%). 

Internal instructor(s) 

External training organisation 

Airline(s) 

Aerodrome 


0% 

2% 

17% 

20% 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Figure 22: Training instructor or organisation 

The involvement of the airlines in training is especially interesting. For instance, Lufthansa 

proposes training modules for current and future instructors (“train the trainer”). 

The NAAs, as well as the aerodromes, are not involved in training. 

18 Service Provider Questionnaire - Question 5.3: What positions are personnel trained for? 

85% 

98%



2.2.5.2.4 Training types 

Two main types of training are generally provided: initial (for new or inexperienced recruits) 

and refresher/recurrent training (for experienced recruits). Both types of training are normally 

provided annually. 

However, as the number of new recruits does not always justify a dedicated initial training 

course, training sessions for both experienced operators and inexperienced recruits are 

usually combined. 

The duration of the refresher training (possibly similar to the initial training course duration, 

but not specifically addressed by the questionnaires), displayed in Figure 23, is on average 

of one and half days, with most opting for one day. 

100% 

80% 

60% 

40% 

20% 

0% 

0% 

Less than half a 

day 

19% 

49% 


28% 

4% 0% 

Half a day 1 day 2 days 3 days 4 days 

Figure 23: Refresher training duration 

Whilst AEA does not provide recommendations on the duration of refresher training, it 

recommends 14 hours for the theoretical part of initial training and 21 hours for the practical 

element. These times are reflected in the City & Guilds training course developed by flybe, 

where “raw” recruits can take 5 days to qualify. However, in practice, initial training times are 

frequently adjusted to suit the capabilities and experiences of the recruits.



2.2.5.2.5 Training requirements and content 

According to the respondents 19 (Figure 24), training courses are mainly based on AEA 

recommendations (91%), service providers own requirements – usually based on AEA – 

(80%), and airlines specific standards (59%). 

AEA 

Your ow n Company 

Airlines 

SAE 

Aerodrome's 


9% 

44% 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Figure 24: Training requirements & standards applying to de-icing / anti-icing 

personnel 

Therefore, theoretical (classroom) training contains most AEA elements, including the effects 

of Type II/IV residues on aircraft systems and aerodynamics. 20 

Practical training, a key element, is more complex to conduct than classroom training: 

Training is conducted prior the winter season; therefore, practical operation in real conditions 

is, in most cases, not possible immediately after theoretical training. While personnel may be 

able to become familiar with manoeuvring de/icing units soon after the classroom course, 

due to the lack of available aircraft and the cost of fluids, practical training on real aircraft 

requiring de-icing / anti-icing is difficult; it is usually involves simulation by means of the 

spraying of water. Therefore, operatives are trained during live operations under the 

supervision of an instructor or experienced operatives (“On the Job Training” – OJT). Some 

general uncertainties remain about the content and duration of such training (number and 

type of aircraft de-iced under supervision), as well as the qualifications of the supervisors and 

possible evaluation procedure. 

19 Service Provider Questionnaire - Question 5.2: Indicate which Training Requirements & Standards 

you apply to your de/anti-icing personnel 

20 Service Provider Questionnaire - Question 5.8: Indicate which Training Requirements & Standards 

you apply to your de/anti-icing personnel 

59% 

80% 

91%



Training simulators and other devices are now available (at a cost) to support training 

courses. While these may greatly assist with building confidence and addressing operational 

hazards, they will unlikely rule-out the need for OJT. 

2.2.5.2.6 Training evaluation 

As recommended by AEA, personnel must successfully complete a final written examination 

at the end of training. The examination is conducted as shown in Figure 25 by the instructor 

(internal or external staff). As was already noted for the conduct of training, NAAs and the 

aerodromes are not involved in this process, either. 

Internal examiner(s) 

External training organisation 

Airline(s) 

Aerodrome 

Other 



0% 

0% 

2% 

6% 

24% 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Figure 25: Responsibility for the examinations and awards the qualifications 

2.2.5.2.7 Training records 

After the successful completion of the written examination (led by the instructors), the recruits 

receive a certificate – issued internally by the service provider itself or externally by the 

training organisation – to operate. 

The training records are systematically maintained by all service providers 21 , as these are 

required and are checked during audits. 

Some service providers issue individual identity certificates/licences to be carried by 

operatives and produced on request. 

2.2.5.3 Safety Management 

Service providers may have their own safety management system, or integrate their 

reporting scheme with the reporting systems of the aerodrome and aircraft operators to share 

occurrence information. 

21 Service Provider Questionnaire - Question 5.10: Does your Company maintain Training Records? 

87%



According to the 85% of the aerodromes 22 and 65% of the aircraft operators 23 , service 

providers’ occurrence reports are included in their SMS reporting scheme. These figures 

have to be taken carefully, as it does not mean that the reporting system is functioning in 

practice, and no information was provided to the categories of occurrence potentially 

reported. For further discussion on this matter see OPTIONS FOR CHANGE – 

ATTACHMENT A: Summary and Analysis of Available Safety Data (Safety Data Section). 

22 Service Provider Questionnaire - Question 2.10: Does the Aerodrome include De/Anti-icing Service 

Providers within the SMS occurrence reporting scheme? 

23 Aircraft Operator Questionnaire - Question 1.9: Do you include De/Anti-icing Service Providers in 

your Occurrence Reporting Scheme/SMS? 




2.3 Responsibilities of the National Aviation Authorities (NAAs) 

2.3.1 Coordination of de-icing / anti-icing activities within the NAAs 

De-icing / anti-icing activities generally involve several departments of the Authorities, 

namely: Safety Regulation, Certification, Aerodrome, Flight Operations, Airworthiness, and 

Personnel Licensing department. 

According to representatives of the NAAs, responsibilities in this field are divided between 

the one or many of the above mentioned departments; 3 out of 10 NAAs stated that the 

Aerodrome department held responsibility, while the remainder mentioned divided 

responsibilities – involving principally the Aerodrome, Safety Regulations, Airworthiness (incl. 

maintenance) and Flight Operations departments. 

NAAs normally have no principal coordinator in the field of de-icing / anti-icing (exceptions: 

France and Switzerland). 

2.3.2 National de-icing / anti-icing regulations directly applicable to 

aerodromes and service providers 

The answers provided by the stakeholders (aerodromes, service providers, aircraft operators 

and national aviation authorities) through the questionnaires on the regulations of de-icing / 

anti-icing services have to be taken with great caution. Therefore, no quantitative figures 

based on the answers are provided in this chapter. 

A cross-analysis of the responses provided by stakeholders operating at the same 

aerodrome or within the same Member State reveals many discrepancies and contradictions. 

For instance, in the United Kingdom, 5 service providers stated in the questionnaires that the 

UKCAA would regulate their operations and 5 other providers stated that it would not 24 . The 

UKCAA itself advised that contractual arrangements between airlines and their service 

providers are not regulated. 

Firstly, the questionnaires and interviews were aimed to collect information on binding 

regulations published by national authorities specific to de-icing / anti-icing which are directly 

applicable to service providers or aerodromes. However, the respondents have very different 

definitions or perceptions of the scope, applicability, nature or status of “regulations” – which 

makes comparison of answers difficult. Although only a minority of the aerodromes and 

24 Service Provider Questionnaire – Question 4.1: What influence does your National Aviation Authority 

have over your operations? 




service providers declared that their de-icing / anti-icing activities are regulated, this minority 

probably overestimated the extent of the regulations: 

− For instance, ICAO manuals or AEA recommendations, which are not binding 

regulations, are in some cases perceived as binding regulations by the service 

providers or aerodromes. 

− Similarly, some respondents (e.g. NAAs of Hungary, Czech Republic and Italy), 

referring to the fact that de-icing / anti-icing is a ground handling activity, answered in 

the questionnaire that de-icing / anti-icing is regulated by the national implementation 

of the Council Directive 96/97/EC – or by the Code of Civil Aviation. While these 

answers are semantically correct, these national ground handling regulations do not 

cover specifically or in great details de-icing / anti-icing services. 

− Additionally, many NAAs, aerodromes and service providers consider (correctly) that 

de-icing / anti-icing services are regulated, but with reference to indirect regulation 

through air operations regulations (EU-OPS). 

Therefore, in general, no specific, direct, binding National Aviation regulations are applicable 

directly to de-icing / anti-icing service providers. 

A regulatory document applicable to service providers and containing some detailed 

requirements on de-icing / anti-icing operations was provided by Finland 25 . This document, is 

however non-exhaustive and contains a few requirements in addition to those derived from 

Directive 96/97/EC. It makes reference to the “ICAO Manual of Aircraft Ground de-icing / 

anti-icing Operations” (ICAO Doc. 9640- AN/940), and therefore does not contain detailed 

binding specifications. 

2.3.3 Direct oversight of de-icing / anti-icing service providers by 

National Aviation Authorities 

According to the responses provided by the service providers, NAAs perform very little 

oversight of de-icing / anti-icing service providers: only three of 54 service providers (less 

than 6%) stated that their NAAs conducted audits on their operations 26 . 

NAAs may conduct audits of the aerodrome de-icing / anti-icing infrastructure (against ICAO 

Annex 14 requirements) and approve or license ground handlers, but they do not conduct 

25 GEN M1-3, 12.6.2002: Ground Handling at Airports (Chapter 4.2.2: De-icing and anti-icing); 

www.ilmailuhallinto.fi/files/lth/imt-gen-m/ger1_03.pdf - last accessed 27.10.2010. 

26 Service Provider Questionnaire – Question 6.3: Who conducts audits on your Operations? 




exhaustive audits of de-icing / anti-icing operations. The main reasons for this are: firstly, the 

lack of the direct regulations to oversee (confirming the assumptions of the previous 

chapter), secondly, the lack of personnel responsible for de-icing / anti-icing at the 

Authorities, and thirdly, Quality Assurance of de-icing / anti-icing is considered to be within 

the responsibility of the aircraft operators. 

2.3.4 National de-icing / anti-icing regulations directly applicable to 

aircraft operator 

The regulation of an aircraft operator’s de-icing / anti-icing operations is indirect, via the 

regulation of Air Operator Certificate (AOC) Holders (AOCH) and related requirements (EU 

OPS): airlines are required to establish procedures for de-icing / anti-icing (EU OPS 1.345) 

and to establish a Quality System (EU OPS 1.035). 

These regulatory requirements imposed upon airlines concerning de-icing / anti-icing are 

neither precise nor comprehensive, which introduces much scope for variation in the 

interpretation of these regulations. 

NAAs are therefore not required to draft additional direct regulations. 

Figure 26 shows the global answers provided by the aircraft operator on the NAAs’ 

requirements on de-icing / anti-icing (fluid types and application, as well as maintenance 

activities related to thickened fluids) 27 . The information provided by the study participants 

confirms that there are few national regulatory requirements on de-icing / anti-icing for 

aircraft operators. 

27 Aircraft Operator Questionnaire 2 – Question 2.3: Does your National Authority 

impose/advise/provide/require in any of the following areas 




Regulatory Requirements Acceptable Means of Compliance Recommendations and Guidance Aircraft manufacturer’s Requirements Don't know 

Qualification of maintenance personnel permitted to remove residues 

Training of maintenance personnel in the detection and removal of residues 

Methods for residue removal 

Methods for Inspecting 

Specified areas for inspecting 

Frequency of removing residues 

Frequency of inspections for residues 

No-spray/Sensitive zones 

Method and process of spraying 

Procedures to be avoided 

Whether to use 1 or 2 step procedure 

Which fluids to avoid 

Which fluids to use 


0% 20% 40% 60% 80% 100% 

Figure 26: Imposition of National Authorities 

2.3.5 National oversight of aircraft operator de-icing / anti-icing 

operations 

The oversight of aircraft operator de-icing / anti-icing operations are generally performed via 

the review and approval by the NAAs of each airline’s Operations Manual (OM), which shall 

include details of the winter operations plan and any relevant procedures for the flight crew. 

Figure 27 graphically illustrates the responses provided by aircraft operators on the methods 

for the approval of the winter operations programme for de-icing / anti-icing. 

4% 8% 

76% 

12% 

Direct 

Indirect via Operations 

Manual 

No Approval required 

Don't know 

Figure 27: National Authority approval of winter operations plan/programme for deicing 

/ anti-icing of aircraft on the ground 

The winter operations programmes (incl. flight crew training) are audited – as shown in 

Figure 28 – usually internally by the airline quality department (82%), and only in very few 

cases directly by the NAAs (9%).



Alliance, Partner or Ow ner 

"mother" airline 


Your ow n airline QA 

department 


9% 

18% 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Figure 28: Conduction of aircraft operator de-icing / anti-icing winter operations 

programme audits 

2.4 Incidents related to de-icing / anti-icing services and fluids 

The analysis of recent incidents related to de-icing / anti-icing services and fluids is detailed 

in the attachment “Summary and Analysis of Available Safety Data “ to the “Options for 

Changes” Document. 

82%



Annex 1 – Supportive Material 

Answers from aerodromes Answers from service providers 

Assumption Global Assumption 

De-/anti-icing operations 

are regulated 


are not regulated 

Table 3: Assumptions on the regulatory situation based on aerodrome 28 and service 

provider 29 answers 

28 Aerodrome Questionnaire – Question 2.2: With regard to the role of aerodrome management: Does 

your National Authority impose for de/anti-icing operations 

29 Service Provider Questionnaire – Question 4.1: What influence does your National Aviation 

Authority have over your operations? 

Assumption De-/anti-icing operations 

are regulated 



are not regulated 

Austria 0 1 Not regulated 0 2 Not regulated Not regulated 

Belgium 1 0 Regulated 0 1 Not regulated Not regulated 

Bulgaria 0 0 No answer 0 0 No answer No answer 

Cyprus 0 0 No answer 0 0 No answer No answer 

Czech Republic 0 0 No answer 0 0 No answer No answer 

Denmark 0 1 Not regulated 0 0 No answer Not regulated 

Estonia 0 0 No answer 0 0 No answer No answer 

Finland 1 0 Regulated 3 8 Not regulated Not regulated 

France 1 2 Not regulated 0 3 Not regulated Not regulated 

Germany 0 0 No answer 0 6 Not regulated Not regulated 

Greece 0 0 No answer 0 0 No answer No answer 

Hungary 0 0 No answer 0 1 Not regulated Not regulated 

Iceland 0 0 No answer 0 0 No answer No answer 

Ireland 0 0 No answer 0 0 No answer No answer 

Italy 1 0 Regulated 0 0 No answer Regulated 

Latvia 0 1 Not regulated 0 0 No answer Not regulated 

Lithuania 0 0 No answer 0 0 No answer No answer 

Luxemburg 0 0 No answer 0 0 No answer No answer 

Malta 0 0 No answer 0 0 No answer No answer 

Norway 0 1 Not regulated 1 1 Not regulated Not regulated 

Poland 0 1 Not regulated 0 2 Not regulated Not regulated 

Portugal 0 0 No answer 0 0 No answer No answer 

Romania 0 0 No answer 0 0 No answer No answer 

Slovak Republic 0 0 No answer 0 0 No answer No answer 

Slovenia 0 0 No answer 0 0 No answer No answer 

Spain 1 0 Regulated 1 1 Not regulated Not regulated 

Sweden 1 0 Regulated 3 0 Regulated Regulated 

Switzerland 0 1 Not regulated 0 1 Not regulated Not regulated 

The Netherlands 0 0 No answer 0 1 Not regulated Not regulated 

United Kingdom 1 2 Not regulated 5 5 Not regulated Not regulated




Central Europe) 





Germany) 





Poland) 





Scandinavia) 





United Kingdom) 





Portugal, Spain and France) 





Italy, Switzerland and Austria) 




ICAO 

Code 

Country Aerodrome 

BIKF Iceland Keflavik International Airport 

EBBR Belgium Brussels International Airport Company (BIAC) 

EDDL Germany Flughafen Düsseldorf GmbH 

EDDG Germany Flughafen Münster / Osnabrück International Airport 

EDDM Germany Flughafen München GmbH 

EDDN Germany FNG Flughafen Nürnberg GmbH 

EDDP Germany Flughafen Leipzig/Halle GmbH 

EDDR Germany Flughafen Saarbrücken GmbH 

EDLW Germany Flughafen Dortmund GmbH 

EFHK Finland Finavia Helsinki-Vantaa International Airport 

EGBB Great Britain Birmingham International Airport Ltd 

EGCC Great Britain Manchester Airport 

EGLL Great Britain BAA plc. Heathrow Airport 

EGPH Great Britain Edinburgh Airport Ltd 

EGPK Great Britain Glasgow Prestwick Airport 

EGTE Great Britain Exeter International Airport Ltd 

EIDW Ireland Dublin Airport Authority plc 

EKBI Denmark Billund Lufthavn A/S 

ENGM Norway Oslo Lufthavn AS 

ENGN Norway SAS 

EPKK Poland The John Paul II International Airport Kraków - Balice Ltd. 

EPWA Poland 

Warsaw-Okecie International Airport Polish Airports State 

Enterprise 

ESSA Sweden Stockholm Arlanda Airport 

EVRA Latvia Riga International Airport 

LEBL Spain Aeropuerto Internacional de Barcelona 

LEMD Spain Madrid Barajas Airport 

LFBP France Aéroport de Pau - Pyrénées 

LFBT France Aéroport International Tarbes-Lourdes-Pyrénées 

LFJL France Aéroport de Metz-Nancy-Lorraine 

LFLC France Aéroport de Clermont-Ferrand-Auvergne International 

LFLY France Aéroport Lyon-Bron 

LFMT France Montpellier Méditerranée Airport 

LFPG France Aéroports de Paris 

LFRB France Chambre de Commerce et d'Industrie de Brest 

LIPX Italy Aeroporto Verona-Villafranca SpA di Gestione Valerio Catullo 

LIRF Italy Rome "Leonardo da Vinci" Fiumicino Airport 

LOWG Austria Flughafen Graz Betriebs GmbH 

LOWW Austria Flughafen Wien AG 

LOWS Austria Salzburger Flughafen GmbH 

LSGG Switzerland Geneva International Airport 

LWSK Macedonia 

PEAS Public Enterprise for Airport Services "Macedonia" - 

Skopje 

Table 4: List of Study Participants - Aerodromes 




ICAO 

Code 

Country Company 

EBBR Belgium Aviapartner 

EBLG Belgium Flightcare Belgium S.A./N.V. 

EDDF Germany N*ICE Aircraft Services & Support GmbH 

EDDG Germany FMO Airport Services GmbH 

EDDH Germany STARS Special Transport and Ramp Services GmbH & Co. KG 

EDDM Germany Aircraft De-icing Engineering 

EDDM Germany 

EFM - Gesellschaft für Enteisen und Flugzeugschleppen am 

Flughafen München mbH 

EDDP Germany PortGround GmbH 

EDDC Germany PortGround GmbH 

EDDV Germany Flughafen Hannover-Langenhagen GmbH 

EFHK Finland Northport Oy - Helsinki Vantaa 

EFIV Finland RTG Ground Handling Oy 

EFJO Finland RTG Ground Handling Oy 

EFKK Finland RTG Ground Handling Oy 

EFKI Finland RTG Ground Handling Oy 

EFKT Finland RTG Ground Handling Oy 

EFKS Finland RTG Ground Handling Oy 

EFOU Finland RTG Ground Handling Oy 

EFRO Finland RTG Ground Handling Oy 

EFVA Finland RTG Ground Handling Oy 

EGBB Finland Servisair 

EGBB Finland Airline Services Ltd 

EGCC Great Britain Servisair 

EGCC Great Britain Airline Services Ltd 

EGCN Great Britain Servisair 

EGFF Great Britain Servisair 

EGGD Great Britain Airline Services Ltd 

EGGD Great Britain Servisair 

EGGP Great Britain Servisair 

EGGW Great Britain Airline Services Ltd 

EGJJ Great Britain Know Ice 

EGKK Great Britain Airline Services 

EGLL Great Britain ASIG 

EGNT Great Britain Servisair 

EGNT Great Britain Airline Services Limited 

EGNV Great Britain Servisair 

EGNX England Servisair 

EGPD Scotland Servisair 

EGPF Scotland Airline Services Ltd 

EGPF Scotland Servisair 

EGPH Scotland Airline Services Ltd 

EGPK Scotland Prestwick Handling 

EGTE Great Britain flybe 

EHEH Netherlands Viggo 

EINN Ireland Servisair 

EKFE Finland RTG Ground Handling Oy 

ENGM Norway Nordic Aero AB 




ENGM Norway SAS Ground Service 

ENVA Norway Røros Flyservice 

EPKK Poland KRK Airport Services Sp. Zo.o. 

EPPO Poland POZ Airport Services Sp. Z o.o. 

EPWA Poland Flebl 

EPWA Poland Warsaw Airport Services Ltd 

ESGG Sweden Nordic Aero AB 

ESGG Sweden SAS Ground Service AB 

ESKN Sweden Stockholm Skavsta Airport 

ESSA Sweden Nordic Aero AB 

EVRA Latvia airBaltic Corporation AS 

LEMD Spain IBERIA Airport Services 

LEPA Spain Acciona Airport Services 

LFBP France CCI PAU AIRPORT 

LFJL France GIGAL 

LFPO France WFS 

LFRB France CCI BREST 

LHBP Hungary Malév Hungarian Airlines - Ground Handlings 

LOWS Austria Salzburger Flughafen GmbH 

LOWW Austria Vienna Airport Handling 

LSGG Switzerland TAG Aviation SA 

LSZH Switzerland Swissport Zurich 

EDDT Germany GlobeGround Berlin GmbH 

EDDB Germany GlobeGround Berlin GmbH 

Table 5: List of Study Participants - Service Providers 




Country National Aviation Authority (NAA) 

Austria BM für Verkehr, Innovation und Technologie als Oberste Zivilluftfahrtbehörde 

Czech Republic Civil Aviation Authority of the Czech Republic 

Denmark CAA Denmark 

Estonia Estonian Civil Aviation Administration 

Germany Bundesministerium für Verkehr, Bau und Stadtentwicklung 

Great Britain Civil Aviation Authority 

Greece Hellenic Civil Aviation Authority - Greece 

Hungary National Transport Authority Ungarn 

Iceland Icelandic Civil Aviation Administration 

Italy Italian Civil Aviation Authority (ENAC) 

Latvia Civil Aviation Agency of Latvia 

Lithuania Civil Aviation Administration Lithuania 

Netherlands CAA The Netherlands 

Norway Luftfartstilsynet - Civil Aviation Authority Norway 

Spain Ministerio de Fomento 

Switzerland Bundesamt für Zivilluftfahrt der Schweiz 

Table 6: List of Study Participants - National Aviation Authorities 

Country of Contact Aircraft Operators 

Austria Austrian Airlines 

Austria Tyrolean Airways 

Belgium TNT Airways 

Finland Finnair PLC 

France BRITAIR 

France Air France 

France REGIONAL 

Germany Contact Air 

Germany Eurowings 

Germany Lufthansa CityLine 

Great Britain British Airways PLC 

Great Britain Blue Islands 

Ireland CityJet 

Ireland Aer Arann 

Italy Neos 

Luxembourg Luxair SA 

Latvia airBaltic Corporation AS 

Netherlands KLM – Royal Dutch Airlines 

Netherlands Transavia 

Norway Widerøe Flyveselskap 

Poland EuroLOT 

Romania TAROM 

Sweden Ryanair 

Sweden SAS 

Switzerland Swiss Interantional Air Lines 

Ukraine CJSC AeroSvit Airlines 

Table 7: List of Study Participants - Aircarft Operators 






OPTIONS FOR CHANGE 

airsight GmbH 



13355 Berlin 

Germany 

Phone: +49 30 45803177 

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INTERIM REPORT – OPTIONS FOR CHANGE 


Attachments 

Attachment A: Summary and Analysis of Available Safety Data 

Attachment B: References from Regulations and other Documents 

Attachment C: FAA Standardised International Aircraft Ground De-icing / Anti-icing 

Programme (SIAGDP) 

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2 Data sources considered for this study.......................................................................3 

3 Summary of existing recommendations and options.................................................5 

3.1 Summary of relevant recommendations made by UK AAIB and German BFU 

(presented in A-NPA 2007-11) .............................................................................5 

3.2 Summary of options and impact assessments presented in A-NPA-2007-11 ..7 

3.3 Summary of results of CRD for A-NPA 2007-11...................................................9 

3.4 Summary of recommendations made from Study participants .......................11 

3.5 Summary of recommendations made by interviewees.....................................13 

3.6 Summary of relevant recommendations from AEA Training Manual ..............15 

3.7 Key themes from summaries...............................................................................17 

4 Options for change.......................................................................................................19 

4.1 The First and Most Important Recommendation ...............................................20 

4.2 Options to improve the collection and analysis of safety data........................21 

4.3 Options to improve communication and coordination – de-icing / anti-icing 

subject-matter experts .......................................................................................28 

4.4 Pathways to regulation ........................................................................................31 

4.5 Options concerning raising standards of de-icing / anti-icing.........................33 

4.6 Alternative models for regulating de-icing / anti-icing through operations 

regulations ..........................................................................................................44 

4.7 FAA SIAGDP .........................................................................................................53 

4.8 National authority requirements for oversight of operations...........................54 

4.9 Regulating de-icing / anti-icing through regulation of aerodromes ................57 

4.10 Availability of de-icing / anti-icing fluid types....................................................62 

4.11 Additional options ................................................................................................65 

5 Information paper and briefing 6 December 2010 Presentation of options to 

stakeholder representatives.......................................................................................66 

APPENDIX 1: List of Options .............................................................................................67 

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In this document, the Study Team presents various options for consideration by the Agency, 

and stakeholders, aimed at meeting the Terms of Reference for the Study 

EASA.2009.OP.21; namely options for improving the availability of fluids at EASA member 

state aerodromes and options for the certification of de-icing / anti-icing service providers by 

national authorities. However, because of the known difficulties in achieving either of these 

two outcomes, the options for change presented here have been developed to meet the 

underlying motivations for the Study, and in doing so, may also address the outcomes 

already mentioned. A full explanation of the underlying motivations is given in this paper. 

The options presented in this paper have been chosen, based on factual inputs and informed 

advice. In the selection of options, consideration was given to: 

− existing work conducted by the Agency in this field, 

− existing work conducted by the Industry, 

− data collected and analysed as required by the Study ToRs, and 

− informed opinion of the Study Team based on input from stakeholders and the Team 

members’ experiences. 

Options omitted from this paper are those concerning: 

− the management of fluid residues, and 

− the certification of fluids. 

The reason for the primary omission is that the Agency has undertaken work already to 

address this issue. However, the Study Team has considered whether the effects of 

operator, maintenance organisation, and aircraft manufacturer actions, since 2005 have 

been beneficial in reducing, or managing, the effects of fluid residues. This point is important 

because the impetus behind this Study is to help reduce the level of risk by reducing the 

occasions of residue build-up. The latter omission is justified due to any potential solution 

likely to be of a long-term nature. 

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Presentation of Options 

For this Interim Report, the Study Team, at this stage, has a preference for the presentation 

of “options” rather than recommendations: however, there are some exceptions (see below). 

The Study Team believes that the end result for EASA will be an improvement. The meaning 

of this is threefold: 

1. Options can be presented to Stakeholders’ Representatives without pre-attached 

value; therefore feedback can be objective and balanced. 

2. Objective feedback provides valuable material for a Regulatory Impact Assessment 

(RIA). 

3. Options are the preferred method of presentation within an RIA, and this Study’s Final 

Report will contain a pre-RIA. 

This decision does not preclude the Study Team forming and presenting the Agency with its 

choice of recommended options; however, this might be more effective if delayed until after 

the results of the Stakeholders Representatives’ Briefing (SRB), where stakeholders 

(including Agency experts) will have the opportunity to present their objective feedback on 

the options directly to the Study Team. 

Exceptions 

Some options, such as the need for a safety initiative and nominated subject-matter experts, 

have been recommended by the Study Team. These are high-level concepts; the specific 

mechanisms for implementation are still presented as options. Other options are “not 

recommended” by the Study Team. These are generally where the solutions are long-term 

(certification of fluids, direct regulation of service providers), and not necessarily because the 

idea is impractical. 

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2 Data sources considered for this study 

Questionnaires 

As described in the Data Summary and Analysis section of this Report, the Study Team has 

attempted, by means of questionnaires, to ascertain the status quo of a broad range of 

factors concerning de-icing / anti-icing, and involving the main involved stakeholder groups. 

This data was not the only source from which the Study Team developed its options. 

EASA 

The Recommendations made by the AAIB and BFU, and the options proposed and 

dismissed in A-NPA 2007-11 (summarised below) are all in concord with the Terms of 

Reference for this Study (2009.OP.21); in that they request the contractor to make 

appropriate recommendations as to the most effective ways in which the NAAs of the EASA 

Member States could regulate de-icing / anti-icing services in a harmonised way, so that the 

safety of aircraft operations is maximised and a level commercial playing field remains 

ensured. These recommendations should centre on how the following areas can be 

improved at the aerodromes of the EASA Member States: 

− availability of type 1 fluids, and 

− quality of service provision. 

Interviews 

During the data collection phase of this project, participants and interviewees were requested 

to provide their own recommendations, and these have been summarised and included 

below. 

AEA 

When considering the documents “AEA Recommendations” and “AEA Training Manual”, the 

latter offered more general recommendations for improving overall standards, rather than the 

more specific technical practices recommended in the former. 

Safety 

Attachment A to this Study (Summary and Analysis of Available Safety Data) makes some 

conclusions regarding the regularly occurring underlying factors that may contribute to 

reduced risk, and these have been taken into account when drafting the options for change. 

In the absence of adequate quantity and quality of specific human error safety data 

concerning de-icing / anti-icing, the sections that follow provide, from valid sources, an 

overview of desired options and recommendations, which give a broad overview of the 

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issues which exist and which might need addressing. They are valuable in helping the Study 

Team to formulate their own options for change and also support some of the conclusions 

reached previously by the Industry and EASA. 

Applicability 

This Study concerns the de-icing / anti-icing of aircraft on the ground, and is not extended to 

de-icing / anti-icing of aerodrome surfaces or aircraft in-flight. 

The Study was directed at de-icing / anti-icing operations and oversight of fixed-wing 

Commercial Air Transport, within EASA Member Sates. 

Concerning the argument as to which aircraft are “at risk” from the effects of residues, the 

Agency’s general policy concerning any actions is to not limit them to only aeroplanes with 

non-powered flight controls but also include hydraulically controlled aeroplanes (CRD A NPA 

2007-11). Therefore, in addressing the quality of service provision, options will apply to all 

operators of commercial air transport and all aircraft types; as well as all aerodromes and 

service providers, regardless of the aircraft they provide for. 

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3 Summary of existing recommendations and options 

3.1 Summary of relevant recommendations made by UK AAIB and 

German BFU (presented in A-NPA 2007-11) 

1. Type I Fluid Availability 

a. Operators of aircraft with non-powered flight controls are strongly encouraged to 

use Type I de-icing / anti-icing fluids, in preference to ‘thickened’ fluids, for deicing. 

b. Type I de-icing fluids are made available on airports regularly used by aircraft with 

non-powered flying controls and not just Types II/IV. 

c. De-icing / anti-icing service providers apply Type I and not only Types II/IV on 

airports regularly used by aircraft with non-powered flying controls. 

2. Fluid Residue Management 

a. Operators of aircraft with non-powered flying controls that are vulnerable to the 

effects of freezing of re-hydrated de-icing fluid residues, establish engineering 

procedures for the inspection and removal of such residues from critical control 

surfaces. 

b. Where the use of ‘thickened’ de-icing / anti-icing fluids is unavoidable, operators 

of aircraft with non-powered flight controls, invoke controlled maintenance 

procedures for the frequent inspection for accumulations of fluid residues and 

their removal. 

c. Manufacturers of non-powered flying controlled aircraft develop reliable 

procedures for their aircraft types to ensure the identification and removal of rehydrated 

de-icing fluid residues. 

3. Approved Organisations and Personnel 

a. Consideration be given to establishing regulations such that de-icing / anti-icing 

training and operations are accomplished by certified and approved companies 

under the supervision of authorities. 

4. Fluid Certification 

a. Fluid manufacturers be encouraged to develop fluids, with suitable ‘holdover’ 

times, that incorporate gelling agents that are not re-hydratable (sic). 

b. Certification requirements and criteria be established with respect to all aircraft 

de-icing / anti-icing fluids, including mandatory limits or evidence of unrestricted 

suitability of fluids for aircraft with non-powered flying controls. 

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c. The expected drying and re-hydration properties of thickened de-icing fluids be 

described and defined by standardisation in such detail as to eliminate significant 

quality variations among the products of different manufacturers. 

Current Status of these Recommendations 

Addressed so far: 

1a – EASA SIN 2008-29 

2a, 2b – EASA SIN 2008-29 and NPA 2009-09 

2c – EASA letter to aircraft manufacturers PBL/ein/C(1.1)2009(D)61465 dated 14 

April 2009 

For long-term consideration: 

4a, 4b, & 4c. 

For consideration within this Study (see below): 

1b, 1c, & 3a. 

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3.2 Summary of options and impact assessments presented in A- 

NPA-2007-11 

In A-NPA 2007-11 options for action and associated impact assessments were presented. 

This is important to understand, because in some areas the Agency may maintain the same 

opinion, whilst in others it may need to change opinion based on the results of this Study. 

The purpose of A-NPA-2007-11 was to consult stakeholders on the appropriate measures to 

be taken in order to address potential safety hazards associated with the residues of fluids 

used for the ground de-icing / anti-icing of aircraft. It was the intention to use the outcome of 

the consultation to define an EASA action plan to address this issue and more particularly 

the recommendations from accident investigators shown above. 

A summary of the relevant details are shown below: 

Operations Option Proposed - Option 1: 

Do nothing. The major objectives are already described in current Regulation (EC) 

1899/2006 (EU OPS). Detailed provisions contained in JAR-OPS 1 are currently transposed 

into implementing rules and associated material for the envisaged amendment to Regulation 

(EC) No 1592/2002, replacing EU OPS once it becomes applicable. Therefore there is no 

need for additional wording. 

Operations Option Dismissed - Option 2: 

Additional rulemaking could address: 

− the assessment, oversight and management of de-icing / anti-icing service providers 

− the content, practices, procedures etc to be embodied in the operators’ processes with 

respect to selection, use and monitoring of types of fluid used, including the availability 

of de-icing / anti-icing fluids for aircraft with non-powered flight controls 

− the content, practices, processes etc. to be embodied in the operators maintenance 

programme 

− the training requirements for crew regarding fluid types, their properties, use and 

limitations such that the adequacy and appropriateness of the provided service can be 

assessed. 

Service Providers Option Proposed – Option 2 

Encourage the development of industry standards and industry monitoring programmes. 

Although this option does not lead to a regulatory solution, it may be considered that industry 

standards and monitoring programmes may bring an appropriate increase in safety. 

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Service Providers Options Dismissed – Options 1 & 3 

− Do nothing. It may be considered that licensing/regulating the de-icing / anti-icing 

service providers will not improve safety. 

− Regulatory approval of service providers: it may be considered that regulatory 

approval of service providers is necessary to achieve an acceptable level of safety. 

Aerodromes Option Dismissed – Option 1 

Do nothing. 

Aerodromes Option Proposed – Option 2 

Rulemaking. Some mechanism is required to ensure that the range of de-icing / anti-icing 

fluids is made available at all appropriate locations. 

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3.3 Summary of results of CRD for A-NPA 2007-11 

Responses to Options for Operations: Stakeholders tended to be dissatisfied with the 

chosen option to do nothing. The Agency invited them to comment on the transposition of 

EU OPS 1.345, 1.346 and associated AMCs into the forthcoming Implementing Rules 

Operations (NPA 2009-02). NB: the Comment-Response Document to this NPA is currently 

under review (as of Oct 2010). 

Responses to Options for Service Providers: A majority of the commentators preferred 

option 3 (regulatory approval of the service providers) to the Agency’s proposed option 2 

(encouragement of industry standards and monitoring programs) as a way forward with 

respect to service providers that perform de-icing / anti-icing services. Option 2 was 

considered as the status quo and that only the certification of service providers would make a 

significant difference. 

Responses to Options for Aerodromes: Because of the heterogeneous models for 

provision of de-icing / anti-icing across different states, weather zones and business models, 

there was no clear consensus concerning the Agency’s preferred option of rulemaking to 

ensure a range of fluids is available. However, the economic cost resulting from imposing a 

range of fluid types to be available at aerodromes were highlighted. NB: no aerodrome 

responded to the A-NPA. 

Conclusion 

Most commentators to A-NPA 2007-11 would wish that: 

a. An appropriate range of fluids is maintained and offered at each aerodrome receiving 

commercial air transport aircraft; 

b. De-icing / Anti-icing service providers be approved, and; 

c. Fluids are certified. 

However, whilst the Agency concurs with these comments, both fluids and aerodromes (at 

the time) were outside of the Agency’s remit, and therefore these would remain long-term 

goals. 

The Agency did however initiate actions to address the inspection for, and cleaning of, deicing 

/ anti-icing fluid residues; and, the remaining areas were included in a six-point plan for 

the medium to long-term. One of these areas formed the basis for this Study, whilst one 

other area will also be partially addressed by convenience during this Study; these are: 

− Investigate and recommend the means by which Aviation Authorities of Member 

States manage matters in regard to the certification of service providers, availability of 

fluids at aerodromes, etc (midterm), and 

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− Make, as far as possible, provisions in the implementing rules on the safety of 

aerodromes with a view to make the operations of de-icing / anti-icing service 

providers safer and ensure the availability of fluids (midterm). 

These two tasks, above, support the remaining unaddressed recommendations made by the 

AAIB and BFU as mentioned above (1b, 1c & 3a), which will be considered by this Study: 

− To make Type I fluids available at airports regularly used by aircraft with non-powered 

flying controls. 

− To ensure Type I fluids are applied at airports regularly used by aircraft with nonpowered 

flying controls. 

− Consideration should be given to establishing regulations such that de-icing / anti-icing 

training and operations are accomplished by certified and approved companies under 

the supervision of authorities. 

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3.4 Summary of recommendations made from Study participants 

The recommendations shown here in this section are taken from written comments made by 

respondents to on-line questionnaires, where an opportunity was given to add additional 

points of view. The headings refer to the relevant stakeholder group for whom each 

questionnaire was designed. The fact that comments on some areas of activity or other 

recommendations for change are omitted, does not imply that the respondents do not have 

further comments of points of view concerning other recommendations. The inclusion of 

these comments here does not imply agreement: they are included to maintain a record, but 

also to show that the Options presented later in this Report do address many of these 

recommendation. 

Operators 

− Airlines can nominate “experts” for better communication with service providers; these 

experts will still need convincing that Type I fluids are useful, e.g. especially when 

regular weather patterns require a high number of de-icing procedures only. 

− Operators can assist service providers and aerodromes with necessary “upgrade” 

investment by signing long-term contracts. NB: this is also one benefit of monopoly 

providers – in both cases service providers know they have long-term income and can 

budget accordingly. 

Service Providers 

− Regulation is recommended for de-icing / anti-icing: 

o procedures and operations, 

o training programmes, 

o personnel and trainer licensing, 

o standard of equipment, and 

o availability of fluids. 

− Service providers should participate in proactive SMS/reporting schemes, which 

should be linked to the NAA for analysis. 

− NAAs/EASA can clarify which fluid and treatment combinations are the “best” rather 

than just state the alternatives as per AEA/SAE. 

− Make the two-step procedure mandatory. 

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Aerodromes 

− Transfer to aerodromes the requirement to provide de-icing / anti-icing services, and 

allow the opportunity to sub-contract. There was also a small minority of strict 

opposition to aerodromes taking any responsibility for de-icing / anti-icing. 

− Consider the role of the aerodrome under Annex 14 SARPs to provide and maintain 

facilities and facilitate operational flow/throughput etc. 

− Require aerodromes to contact all operators and request what types of fluid and 

service they require; use the aerodrome to insist that service providers meet the 

operators’ needs; and include types of fluid and service available in the AIP. 

− Require the aerodrome to audit third-party contractors against its own SMS 

requirements. 

− NAAs/EASA to require aerodromes to collect safety and service information annually 

and submit it for analysis. 

− Consider the same regulatory arrangement for de-icing / anti-icing as exists for other 

operational areas e.g. “assistance to passengers with reduced mobility” and the 

aerodrome’s responsibilities therein. 

− Landing/take-off fees can be adjusted to cover the costs of annual de-icing / anti-icing. 

− A regulatory solution for de-icing / anti-icing can be extended to other unregulated and 

safety critical services, such as aircraft loading. 

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3.5 Summary of recommendations made by interviewees 

Some interviews were conducted with representative stakeholders from each of the main 

groups. These interviews were conducted face-to-face; by telephone and also via e-mail. The 

recommendations shown here represent a summary of those recorded. Their inclusion does 

not imply support: they are included as a record, and also to show that the Options presented 

in this Report do address many of these recommendations. 

Operators 

− Operators to have a nominated de-icing / anti-icing expert: this person to be sole 

conduit for communication with service providers, aerodromes and NAAs. 

− Improve the knowledge of pilots on this matter. 

− At the Airport User’s Committee level, operators can influence how money used for 

improving infrastructure is raised and invested. 

− Flight crew should not know the precise breakdown of costs/prices of de-icing / antiicing 

services and fluid for each location. 

Aerodromes 

− Aerodromes to convene AUC meetings dedicated to de-icing / anti-icing “operations” 

separate from those held to discuss traffic flow. 

− Aerodromes can mandate the supply of Type I fluid through its contracts with service 

providers (when granting a license to operate). 


− Training for de-icing / anti-icing operatives should be based on the practical: too much 

technical information is used, and this is often unclear and contradictory. 

− Service provider operatives should not know the price/costs their company charges for 

de-icing / anti-icing services and fluid. 

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Authorities 

− EASA to facilitate a standing working group to assist the Agency and stakeholders 

clarify harmonised understanding of regulations and recommendations. 

− EASA to provide a minimum set of “hard rules”; too many are difficult to apply in all 

circumstances. 

− EASA to prescribe the contents of Operations Manuals to prevent variation and 

promote higher standards. 

− EASA to clarify what is meant by the passing of the anti-icing code. 

− EASA to insist that aircraft manufacturers provide their requirements and 

recommendations for residue management in a standardised format. 

− Ensure that agreed standards are globally accepted (helps when foreign operators 

audit EU service providers and also when EU operators audit service providers 

overseas). 

− EASA to support and facilitate the pooling of audits using industry experts as auditors. 

− Allow monopoly service providers owned/managed by the aerodrome; this will 

encourage adequate levels of investment. 

− Define responsibilities based on “location of fluid”: the fluid manufacturer is 

responsible until delivery and acceptance; then before the fluid is sprayed it is the 

responsibility of the service provider; whilst the fluid is “on the wing” it is the 

responsibility of the operator; and, when it drips to the ground it becomes the 

responsibility of the aerodrome. 

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3.6 Summary of relevant recommendations from AEA Training 

Manual 

These excerpts are not exhaustive, but are chosen to highlight some of the broader 

recommendations which support the options presented in this paper. For a full 

understanding of all the recommendations made by AEA the reader should refer to both the 

AEA Recommendations and Training Manual documents. 

Safety 

The main deficiencies of de-icing / anti-icing operations (1.1) were found to contain errors in: 

− inspection or the determination for the need of de-icing / anti-icing, 

− the de-icing / anti-icing procedure itself and 

− negligence/misinterpretation of holdover time. 

The factors leading to these errors are: 

− poor training, 

− miscommunication, 

− improper de-icing / anti-icing, 

− fluid degradation, 

− misinterpretation of tables and manuals etc. 

Operators 

− Everyone involved in each step of the de-icing / anti-icing process must be trained, 

qualified and aware of their responsibilities and duties (1.2). 

− Operators should have suitable ground handling agreements in place with de-icing / 

anti-icing providers, at each airfield, which detail the rules and procedures. 

− Flight Crew training should cover all relevant aspects of the ground process. 

− Post-holder Training is responsible (2.1.3.8) for de-icing / anti-icing training for flight 

crews, and qualification to be renewed annually with a theoretical part including an 

examination. 

− Proper communication with the service provider is important; there cannot be any 

doubt of the procedure, fluid used, areas covered etc. when communicating and 

verifying the process (7.4). 

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Aerodromes 



− The infrastructure must enable and support de-icing operations. 

− When planning to collect waste glycol, the whole chain must be considered (from ramp 

to runway) and not only the place of de-icing / anti-icing (10.1). 

− The de-icing / anti-icing coordinator (12.2.3) is responsible for controlling the 

movement of de-icing / anti-icing vehicles on the ramp and remote areas. 




− De-icing / anti-icing providers should have suitable ground handling agreements in 

place, with each operator, at each airfield, which detail the rules and procedures. 

− Thickened fluids (6.1.5) are, in general, not heated when used as anti-icing fluids 

because the viscosity will lower if heated. HoTs are determined using certain 

viscosities. They are also applied undiluted if longer HoTs are needed (7.3.2.2). 

− Type-I fluid should be used for de-icing to minimise the possibility of residue problems. 

− One-step de-icing / anti-icing is generally performed with a heated un-thickened fluid 

(7.2.1.1). 

− Proper communication with flight crew and other ground crews is important; there 

cannot be any doubt of the procedure, fluid used, holdover time, areas covered etc. 

when communicating and verifying the process (7.4). 

− The service provider should provide a coordinator(s) (12.2.1/2) for supervising 

operations, communications and resolving misunderstandings. 

− The coordinator is to verify and communicate the required procedures, taking into 

account variations between operators’ requirements (12.2.3). 

− Two-step de-icing / anti-icing is performed whenever the contamination demands a deicing 

process separately (7.2.1.1). 

Authorities 



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3.7 Key themes from summaries 

There are some key themes that recur through all the data collected, including the summary 

of safety data in Attachment A. These key themes highlight areas of weakness which need 

to be considered when developing options for change and making subsequent 

recommendations for action. The themes that have been highlighted in this Study are as 

follows: 

− lack of Human Factors safety data from service providers especially 

− lack of operator knowledge (pilots and management) 

− lack of operatives’ knowledge (service providers) 

− inconsistent demands for service/procedures/fluid from operators 

− inconsistent development and contents of contracts 

− inconsistent development of procedures 

− uncertainty of post-holder responsibilities 

− uncertainty of identifying the responsible post-holder (NAAs, operators) 

− uncertainty of responsibilities – operations versus airworthiness 

− uncertainty of ultimate responsibility 

− uncertainty of level of oversight 

− inconsistency in developing procedures, programmes, policies, contracts 

− varying interpretations and misconceptions of requirements, standards and 

procedures (e.g. meaning of anti-icing code, all-clear etc) 

− inconsistent auditing standards 

− no guaranteed external approval of operators’ procedures, policies and programmes 

− uncertainty of the role played by the aerodrome (when not a provider) 

− inconsistent levels of investment in facilities and equipment 

From these recurring themes a short list of general actions can be derived that would 

address these concerns, for example: 

− collect and analyse more safety data in order to reduce risk and comply with 

performance-based regulation of safety; 

− improve key stakeholders’ knowledge through better awareness and training 

programmes; 

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− clearly define key stakeholders’ and individual’s responsibilities; 

− enhance the consistent application of procedures and harmonised standards through 

more practical and specific guidance material for operators; 

− introduce a level of oversight from the Authority; 

− increase the involvement by aerodromes by defining a set of specific responsibilities; 

− encourage more investment where necessary. 

It is intended that the options developed in this Study and included below in this Report, if 

adopted as actions, would facilitate the achievement of the above goals, and satisfy all those 

existing recommendations introduced above in the Information Summaries. 

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4 Options for change 

The sections below detail options for how many of these issues introduced above may be 

addressed through regulatory and voluntary means in such a way as to also support the 

primary aims of this Study: 

− improving the availability of fluids at aerodromes within EASA member states, and 

− improving the standards of de-icing / anti-icing service provision. 

Where references are made below to existing or proposed Regulations, Directives, Rules, 

AMC, Guidance material and Recommendations, Attachment B contains the relevant 

extracts together with comments on the possible options. In particular, where references are 

made to “proposed” EASA rules, such as Authority Requirements, Operator’s Requirements 

and Implementing Rules for Operations, the versions used in this Report (and shown in 

Attachment B) are taken from EASA NPAs 2008-22 and 2009-02. Whilst some of the 

associated Comment-Response Documents have been recently published, the versions 

used here remain the originals from the NPAs. This provides a consistent approach and 

allows the Agency to consider the results of this Study alongside those of other respondents. 

All options are given a coded, self-explanatory reference and number; a list of all options is 

included at Appendix 1 to this paper. 

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4.1 The First and Most Important Recommendation 

The only known method for positively ascertaining that 

an aeroplane is clean prior to take-off is by close inspection. 

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ICAO Doc9640 

One may add to this quote, a close inspection performed by a trained, qualified and wellmotivated 

person. Ultimately, whatever has occurred before a post de-icing / anti-icing 

treatment check, this check is the last safety defence before shifting all responsibility onto the 

shoulders of the aircraft captain. For a captain to fulfil his/her responsibilities in ascertaining 

that the aircraft is in an airworthy state at take-off, this check needs to be 100% accurate 

100% of the time! The post treatment inspector must be able to accurately decide whether 

unwanted contamination is present on the aircraft or not, and then communicate this 

accurately to the captain. The close inspection necessary to achieve this must always 

include visual, and where necessary tactile. 

REC1. It is recommended that all those involved in de-icing / anti-icing operations on 

the ground, and all those who have an interest in ensuring the standards of 

these operations are the highest possible, do whatever they can to make the 

task of the post treatment inspector as easy as possible. 

This Recommendation requires focus on the purpose of de-icing / anti-icing, first and 

foremost, as a safety critical function aimed at ensuring an aircraft maintains its 

airworthiness, rather than as a commercial activity. If stakeholders maintain their focus on 

this Recommendation whilst reading this document and give it consideration whenever they 

feel a resistance to support change, then their feedback will be more effective in helping to 

raise standards of de-icing / anti-icing operations.



4.2 Options to improve the collection and analysis of safety data 

With reference to the known safety data, as shown in Attachment A, and the Heinrich 

occurrence triangle in Figure 1, it is clear that little is known concerning the “unsafe acts” 

connected with de-icing / anti-icing. This conclusion can be reached because despite there 

being a regular rate of related accidents, there does not appear to be any data originating 

from employees of de-icing / anti-icing service providers concerning their personal errors, 

slips and oversights, or the hazards and threats they face on a daily basis. Yet based on the 

number of accidents, we can only assume that many unsafe acts occur on a regular basis. 

The fact is, we just do not know. 

Figure 1: Heinrich Occurrence Triangle (source FAA) 

Therefore, the collection of this safety data from de-icing / anti-icing operatives is essential in 

assisting organisations and regulatory bodies highlight those areas of greatest risk and to 

direct their risk mitigation measures and resources appropriately. As de-icing / anti-icing 

service providers are unregulated, the necessary change in reporting culture will require 

either a voluntary programme of education, promotion, and participation; or, regulated bodies 

such as operators and/or aerodromes, to demand such a change within their contracts with 

service providers. Each of these activities will, in all likelihood, require support in the form of 

expertise, facilitation, education and promotion material. Such support can be made 

available from within the industry and/or from regulatory bodies. Such a task may be even 

more challenging, and take longer, than was the case during the changes in the safety 

culture within maintenance organisations some time ago. However, under the Human 

Factors banner, many maintenance organisations nowadays enjoy a high reporting rate 

amongst employees and this data is shared for the benefit of the whole industry. Difficulty in 

implementation should not be a deterrent to attempts at changing the status quo concerning 

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self-reporting of de-icing / anti-icing operatives and the analysis and sharing of that data by 

their employers. 

Regulatory requirements already exist for Safety Data to be collected and analysed, 

however, there is no clear impetus to require operators to collect the type of “low-level” data 

that is so valuable in reducing risk; furthermore, there is no clarity concerning the collection 

of such data from third-party contractors. References to existing relevant regulations and 

their limitations are listed below: 

− Directive 2003/42/EC Occurrence Reporting – Both Article 4 1(g) and Annex 1 D (iv) 

clearly mention and infer, de-icing / anti-icing personnel within the scope of the 

Directive (Article 3); the scope of the Directive also clearly includes “unsafe acts” 

(Article 2). However, interpretation of this Directive is within the remit of Member 

States, and since its publication there has been no amendment to JAR OPS 1.037 or 

EU OPS 1.037 providing guidance for authorities in this matter. 

− EU OPS 1.037 Accident Prevention and Flight Safety Programme – the emphasis is 

on Incident and Accident data, and not on “unsafe acts”, and no reference is made to 

contracted organisations. 

− EU OPS 1.035 Quality System – omits reference to contracted organisations; this was 

once contained in JAA AMC OPS 1.035. 

− ICAO Annexes 6 & 14 SMS Requirements – this SARP is extant and it clearly requires 

that National Authorities shall require both aerodromes and operators to identify safety 

hazards, take remedial action and aim to make improvements to safety performance. 

This adequately covers all areas of operation on an aerodrome and also those 

connected with continuing airworthiness and flight operations. However, without 

guidance from the Authority specifically mentioning de-icing / anti-icing operations, it is 

unlikely that additional effort will be invested. In the event, EU OPS was not amended 

to accommodate the ICAO SARP, and OPS 1.037 continues as the focus for 

operators’ safety programmes. 

− Annex Va to the Basic Regulation – Essential Requirements for Aerodromes – is clear 

that aerodrome management should: have access to relevant data (B1(a)); take some 

responsibility in ensuring risks are mitigated against (B1(e)); and, that relationships are 

established with relevant organisations, including service providers, such that the ERs 

can be fulfilled (B1(f)). Furthermore, safety data from these organisations collected 

through the aerodrome’s occurrence reporting scheme shall be analysed (B2(b)). It is 

noted that paragraph B1(f) was identified in A-NPA-2007-11 as a potential mechanism 

for the regulation of service providers indirectly through the aerodrome. 

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Proposed Implementing Rules as contained within EASA NPAs 2008-22 and 2009-02 

improve the situation slightly, however, there is great scope for improving these further: 

− AR.GEN.030(a) Mutual Exchange of Information – requires Authorities to share all 

necessary information taken as a result of oversight of persons and organizations 

exercising activities on the territory of a Member State. However, service providers 

are not included as they are not directly within the oversight of the Authorities unless 

such data is obtained as a result of the oversight of operators. 

− AR.GEN.040(a) Reporting – requires NAAs to notify the Agency of any safety 

significant occurrences in addition to those required in Directive 2003/42/EC. No 

explanation is given as to what is meant by “significant”, leaving the way clear for 

different interpretation. 

− AMC 2 AR.GEN.300.2 Continuing oversight OPS – how an operator oversees all 

ground-handling services is omitted from the list of areas the Authority should at least 

inspect and monitor. 

− AMC 2 to OR.GEN.200(a)(2) Management System – fulfils the requirements of ICAO 

SMS SARPs, with some additional parameters. However, it still does not categorically 

focus the operator onto the collection of reports of “unsafe acts” from contractor 

organisations. However, without this data, an operator will not be able to fulfil other 

elements of the Rule; i.e. to identify all the hazards associated with de-icing / antiicing, 

assess the associated risk and make interventions to improve safety 

performance in this area. The outcome of this Rule depends on the interpretation. 

− AMC 2 to OR.GEN.200(a)(4) Management System, Training and Communication on 

Safety – this requires the organisation to establish communication so that safety 

matters can be explained. This is limited to within the operators own organisation. 

− AMC to OR.GEN.200(a)(5) Management System, Occurrence Reporting – in 

contradiction to the title, this mirrors EU OPS 1.037 and only highlights the need to 

report Incidents and Accidents, therefore excluding “unsafe acts” and other valuable 

safety data. 

− AMC to OR.GEN.205 Contracting and purchasing – this re-introduces JAA AMC OPS 

1.035 material on quality assurance of contracting organisations. It also clearly 

requires operators to specify in their contracts with service providers what safety 

services and safety related activities should be undertaken; thus providing a 

mechanism to include the collection, analysis and provision of specific safety data. 

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The thrust behind all ICAO SARPs for SMS is clear: that it is the responsibility of all 

organisations across the aviation industry to identify hazards in all areas of operation, 

assess them for risk and take mitigating actions where necessary. That this should 

include the hazards encountered by de-icing / anti-icing operatives is unquestioned. 

The fact that such data is not being collected, analysed and/or shared is evident from 

our Study. 

There are several options available to ensure an improved situation in these respects, and 

they are detailed below. 

SAF1. Conduct an Industry-wide collaborative safety initiative: including data 

collection and analysis; awareness activities; and development of 

recommendations and, where possible, tools. Recommended. 

An Industry-wide Safety Initiative, involving all stakeholder groups including 

service providers, and having the primary aim of obtaining good quality safety 

data concerning de-icing / anti-icing operations. To achieve this, service 

providers would require support and guidance to establish effective reporting 

cultures. Such a Safety Initiative could be launched and facilitated in many 

ways, including by: 

SAF1.a. EASA alone. 

SAF1.b. EASA in partnership with Industry; perhaps through the ESSI. 

SAF1.c. EASA in conjunction with Member State NAAs. 

SAF1.d. Industry alone; perhaps through FSF, IATA, the airline 

Associations etc. 

SAF2. Reinterpret existing regulations for operators and aerodromes to motivate 

greater collection and analysis of relevant safety data. Recommended. 

Existing Rules for operators and aerodromes could be re-interpreted to ensure 

that the relevant safety data is collected. This would require EASA and NAA 

collaboration and cooperation. As no amendments to regulations would be 

required under this option, a great deal of explanatory material would be 

necessary. The appropriate Regulatory mechanisms include those listed 

above for SMS and Occurrence Reporting. Such reinterpretation may best be 

served by the use of AMC and GM produced by NAAs. 

SAF3. Amend proposed EASA regulations for authorities and operators to ensure 

effective collection and analysis of relevant safety data. 

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Forthcoming ARs, ORs, and Implementing Rules for Operators (eventually 

aerodromes) may be amended to include specific references to de-icing / antiicing 

operations and service providers to achieve the aim of collecting suitable 

safety data. Furthermore, explanatory material can be produced to help NAAs 

and organisations to interpret the meaning, and which clearly highlight the 

need to collect data of “unsafe acts” from service providers. For example: 

SAF3.a. AR.GEN.30.(a) Exchange of Information & AR.GEN.40.(a) 

Reporting – interpretation of these requirements may include 

guidance for Authorities to include the exchange of safety data 

including “unsafe acts” arising through operators’ contracted out 

service providers, and that this data is not restricted to incidents 

and accidents. 

SAF3.b. AMC 2 AR.GEN.300.2 Continuing Oversight Ops – this AMC can 

be amended to include oversight and monitoring (as required) of 

the mechanism through which operators ensure service providers 

maintain an appropriate safety culture (professional attitude) 

through collection of safety data – specifically self-reporting of 

“unsafe acts”. This may be achieved through the inspection of 

those elements of a basic contract with service providers 

(excluding commercial clauses) that are relevant to safety. 

SAF3.c. AMC 2 to OR.GEN.200(a)(2) Management System – can be 

expanded to include the need for operators to include service 

providers within their SMS as a source of safety data, such that 

hazards encountered by service providers can be identified and 

the associated risks to operations assessed by the operator. A 

programme for achieving this may be required. 

SAF3.d. AMC 2 to OR.GEN.200(a)(4) Management System, Training and 

Communication on Safety – this AMC might be amended to 

include the need for operators to explain safety matters to service 

providers, and give support where necessary, in particular why 

certain safety data should be collected and analysed. 

SAF3.e. AMC to OR.GEN.200(a)(5) Management System, Occurrence 

Reporting – this AMC can be expanded to include the objective of 

collecting and analysing valuable data such as that obtained 

through the self-reporting of unsafe acts, thereby providing an 

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operator with an insight into potential accident pre-cursors and 

areas of high risk. It may be made clear that this data should be 

sought not only from the operator’s own personnel and employees, 

but also from those personnel working for service providers 

conducting contracted-out safety critical functions. 

SAF3.f. AMC to OR.GEN.205 Contracting and purchasing – clarification 

can be provided to this AMC such that SMS activities, including 

reporting of “unsafe acts”, are included in the written agreement 

between operator and service provider, as well as details of the 

safety services to be provided. The written agreement referred to 

could be subject to oversight and monitoring as required under 

AMC 2 AR.GEN.300.2, mentioned above in Option SAF3.b. 

SAF4. To conduct an Industry-wide review of, and lobby for amendment to, Directive 

2003/42/EC on Occurrence Reporting; in order to align the Directive with 

ICAO SMS requirements. Thereby encouraging States to meet the needs of 

the Directive and encouraging a harmonised interpretation. 

SAF4.a. NAAs to ensure that the intent of the Directive is enforced: the 

need for all personnel to report occurrences (Clause 7); and the 

need to share this information (Clause 8). 

SAF4.b. Lobby to amend, or expand, the definition of “occurrence” to 

include specifically: human, procedural and system errors 

considered by the reporter to increase risk. 

SAF4.c. Lobby to expand the Scope of the Directive (Article 3), to include 

specifically de-icing / anti-icing activities, by including examples in 

the Appendix to Annex I. 

SAF4.d. NAAs to take up their responsibilities to ensure de-icing / anti-icing 

operatives comply with mandatory occurrence reporting (Article 4, 

1.g) and they shall (rather than may) encourage voluntary reporting 

(Article 9). 

SAF4.e. NAAs to interpret the Directive from the point of view of de-icing / 

anti-icing operations and issue relevant awareness and guidance 

material.



NOTE: Any safety initiative, and/or re-interpretation of regulations from the perspective of deicing 

/ anti-icing operations, may easily be extended to all unregulated safety critical 

activities, and therefore provide a greater opportunity to improving aviation safety. 

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4.3 Options to improve communication and coordination – 

de-icing / anti-icing subject-matter experts 

During the Study, it became apparent that one of the key difficulties in obtaining feedback 

from NAAs and operators was identifying a single post-holder within each of these 

organisations who could identify their own lines of responsibility and understand all the 

issues concerning de-icing / anti-icing relevant to their whole organisation. For example, 

within operators’ organisations day-to-day decision-making often lays within flight operations, 

training programmes often fall under the remit of post-holder training, the knowledge-base 

may reside within the maintenance department, long-term strategy for contract provision may 

sit elsewhere, and yet the responsible post-holder is often ground operations. Similarly, 

within NAAs several departments are responsible for different aspects of de-icing / anti-icing 

of aircraft on the ground. This situation was pre-empted by the Study Team and 

questionnaires were developed as follows: 

− NAAs: 

− Operators: 

o General Data and Safety 

o Oversight of Operators – flight operations 

o Oversight of Operators - continuing airworthiness 

o Oversight of Aerodromes 

o Oversight of Service Providers 

o Flight Operations 

o Maintenance and Quality 

Despite this, it was often difficult for the person nominated by the Director and contacted by 

the Team, to coordinate responses between these different departments and gather all the 

associated data. Often, the same questionnaire was completed by different people within an 

organisation and their answers were different; and where similar questions were posed in 

different questionnaires the answers also frequently contradicted each other. 

Coordination, communication and clear channels of responsibility are all areas highlighted by 

existing documentation and safety data, as weaknesses in the system. 

The options available to improve coordination between different organisations, and within 

organisations are: 

SME1. EASA to appoint its own subject-matter expert for internal and external 

communication and coordination of de-icing / anti-icing issues. 

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Require EASA to appoint a suitably experienced subject-matter expert for deicing 

/ anti-icing. This person shall be the focal point for all communications 

on de-icing / anti-icing matters within the organisation, between the Agency 

and the NAAs, and with all other relevant agencies, bodies and organisations. 

Furthermore to require EASA to define this person’s responsibilities, including 

the coordination, communication and interpretation of the Agency’s 

regulations and oversight activities for all de-icing / anti-icing matters. 

SME2. EASA to establish, maintain and publish a record of nominated de-icing / antiicing 

subject-matter experts. 

Require EASA to establish, maintain and publish a repository of nominated 

subject-matter experts from all NAAs, all operators and all aerodromes within 

the Member States, plus any others deemed to be of interest (e.g. FAA, AA, 

AEA, SAE etc). 

SME3. NAAs to appoint their own subject-matter experts for internal and external 


Require NAAs to appoint a suitably experienced subject-matter expert for deicing 

/ anti-icing. This person shall be the focal point for all communications 

on de-icing / anti-icing matters within the organisation, between the NAA and 

all other agencies, bodies and organisations. Furthermore to require NAAs to 

define this person’s responsibilities, including the coordination and 

communication of the Authority’s regulation and oversight of all de-icing / antiicing 

matters, including: 

a policy 

b programme 

c safety performance 

d flight operations 

e continuing airworthiness 

f aerodromes 

g service providers 

h training 

i environmental protection. 

SME4. Operators to appoint their own subject-matter experts for internal and external 


Require operators to appoint a suitably experienced subject-matter expert for 

de-icing / anti-icing, and not necessarily a nominated post-holder. This person 

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shall be the focal point for all communications on de-icing / anti-icing matters 

within the organisation, between the operator and service providers, and 

between the operator and the Authority. Furthermore to require operators to 

define this person’s responsibilities, including the coordination and 

communication of the operator’s de-icing / anti-icing: 

a policy 

b programme 

c procedures 

d operations 

e continuing airworthiness 

f training 

g contractual agreements (technical contents) 

h advising Safety Manager (AMC2 OR.GEN.200(a)(3)2.b.vii, viii, ix). 

SME5. Aerodromes to appoint their own subject-matter experts for internal and 

external communication and coordination of de-icing / anti-icing issues. 

Require aerodromes to appoint a suitably experienced subject-matter expert 

for de-icing / anti-icing, and not necessarily a nominated post-holder. This 

person shall be the focal point for all communications on de-icing / anti-icing 

matters within the organisation, between the aerodrome and the Authority, 

operators and service providers. Furthermore to require aerodromes to define 

this person’s responsibilities, including the coordination and communication of 

de-icing / anti-icing: 

a operations 

b facilities 

c fluid storage and handling 

d traffic flow. 

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4.4 Pathways to regulation 

The Technical Specifications for the Study require that recommendations are made for the 

most effective ways in which NAAs could regulate de-icing / anti-icing service providers, 

based on investigations into how they accomplish this already. However, it is apparent from 

the investigations that none of the EASA Member State’s NAAs actually regulate the 

standards of de-icing / anti-icing by service providers in any direct way at all (see Data 

Summary and Analysis). Several Member States do impose certain organisational 

requirements onto their service providers (using Directive 96/97/EC), but they do not address 

standards of fluid handling and application, communication or coordination. Furthermore, 

many stakeholders have recommended to the Study Team that the direct regulation of deicing 

/ anti-icing service providers is essential to improve standards of de-icing / anti-icing, 

however, there is no mechanism for doing so directly; either within Member States or EASA. 

This “call”, by elements of the Industry, for the regulation of de-icing / anti-icing service 

providers has been extant for about a decade. Since the winter of 2005/6 EASA has decided 

to act on several recommendations made by the UK AAIB and German BFU (EASA A-NPA- 

2007-11) including the request to consider the future need for certification, licensing, 

approval and training of organisations who provide de-icing / anti-icing services and their 

personnel. 

The lack of a clear and direct pathway for regulation of service providers is probably a 

fundamental reason why standards of de-icing / anti-icing service provision vary. One 

“indirect” pathway from regulator to service provider, and the one currently used, is via the 

regulation of AOC holders; for example the requirement for airlines to establish Quality 

Systems (EU OPS 1.035), ensures some oversight, by airlines, of de-icing / anti-icing service 

providers and their operations. There is also the requirement for airlines to establish 

procedures for de-icing / anti-icing (EU OPS 1.345). However, the regulatory requirements 

imposed on airlines concerning de-icing / anti-icing are neither precise nor comprehensive, 

which introduces a lot of scope for variation in interpreting these regulations. 

Since EU OPS superseded Member States’ national regulations based on JAR OPS 1, there 

is no harmonised pan-European guidance material or acceptable means of compliance for 

airlines to follow concerning de-icing / anti-icing operations. Although some JAR OPS 1 

Section 2 material was elevated to become Appendices in EU OPS, this was not the case for 

de-icing / anti-icing. Some NAAs retain JAR OPS 1 Section 2 “support” material as an aid for 

both airlines and regulators as to how to apply the Rules provided in EU OPS. Prior to EU 

OPS becoming law, and when JAR OPS 1 was valid, there is no doubt that many airlines 

used the Section 2 material as the sole means of applying some of their National 

Requirements. In some areas of airline operations this has effectively resulted in 

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harmonised (pan-European) application of some rules. For example, this may have been the 

case for Quality Systems, but unlikely for de-icing / anti-icing procedures. JAA ACJ OPS 

1.345 was a late amendment to JAR OPS 1 (Amendment 8, 01/01/2005), and was issued as 

an Advisory Circular rather than an Acceptable Means of Compliance. So, it is difficult to 

judge whether this had much impact before JAR OPS 1 was withdrawn within the EU 

Member States. However, it did contain both information and guidance necessary for an 

airline to establish adequate de-icing / anti-icing procedures, and the content is still relevant 

today. 

JAR OPS 1 made reference to relevant ICAO, ISO, EUROCAE, SAE and AEA documents as 

sources from which operational procedures could be established. Many service providers, 

airlines, aerodromes and national authorities use, in particular, the AEA and SAE documents 

for this purpose. However, these documents are not regulations, and adoption of the 

principles recommended in these documentations is voluntary, their interpretation varied, and 

a harmonised application of standards is not achieved. 

Other possible pathways for indirectly regulating service providers may be through 

regulations for aerodromes; specifically ICAO Annex 14 and Directive 96/97/EC on Ground- 

Handling. Both of these documents are considered as options in this Study. In the near 

future, another indirect path may exist through EASA Implementing Rules for aerodromes. 

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4.5 Options concerning raising standards of de-icing / anti-icing 

Our investigations show that, currently, the achievement and maintenance of high standards 

of de-icing / anti-icing is achieved in several ways: 

− Motivated by a professional attitude some service providers unilaterally adopt (and in 

some cases surpass) industry best practice (commensurate with AEA 

Recommendations). This approach can also be advocated on the grounds of 

improved aviation safety and improved business advantage over rivals; especially 

when airlines are looking for quality, reliability and flexibility in a service and not just a 

good price. 

− Some airlines require these high standards and ensure them by competently and 

vigilantly overseeing de-icing / anti-icing service providers’ operations. This may be 

enhanced where the airline works in collaboration with service providers, most notably 

in training standards and syllabus and in the exchange of operational safety 

information. 

− When an aerodrome is involved to some extent in providing de-icing / anti-icing 

services to airlines, and it considers that a professional, safe and efficient de-icing / 

anti-icing service is commensurate with a professional, safe, efficient and profitable 

aerodrome; then proper investment is made towards facilities, equipment and training, 

and good cooperation and coordination is achieved with the airline customers and high 

standards maintained. 

− At locations where the climate and weather dictate that de-icing / anti-icing operations 

are in frequent and regular demand, the risks appear greater and therefore the subject 

is very much at the forefront of all stakeholders’ minds. 

Many organisations achieve the above, but many others do not, and the reasons for this are 

also multiple, including for example the following: 

− For many service providers de-icing / anti-icing is only a small part of their business 

(as shown by the Study) and profit margins may be larger in other ground-handling 

activities – often running at a loss. 

− Where service providers rely more, or totally, on their de-icing / anti-icing service 

provision for profits, and where sale prices cannot be raised due to competition, this 

will always produce a pressure to reduce overheads. 

− Some airlines do not always consider fully the advantages of selecting those service 

providers with the highest standards; and others are driven partially by cost. 

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− Many airlines require de-icing / anti-icing services at multiple locations from a 

multitude of organisations (sometimes they have no choice). Whilst one can argue 

that it’s the same for ticketing, or catering, these are commercial activities and present 

a much lower Risk to flight operations, therefore, variations in these services can be 

absorbed and dealt with in slower time. 

− Many service providers provide de-icing / anti-icing for a multitude of airline customers, 

whose requirements may all differ. Again, whilst one can argue that it’s the same for 

ticketing, or catering, these are commercial activities and present a much lower Risk to 

flight operations, therefore, variations in these services can be absorbed and dealt 

with in slower time. Whereas relying on de-icing / anti-icing operatives to recall and 

apply numerous variations can lead to confusion. 

− At some locations the need (due to climate and weather) for de-icing / anti-icing 

services can vary dramatically year-to-year, and may also be very small and in short 

bursts. The pressure to invest heavily may be small, and this can lead to inadequate 

provision of services during those bursts when demand is temporarily high. At such 

locations the experience levels of service provider de-icing / anti-icing operatives may 

also be low. 

Why are some organisations motivated to invest heavily in facilities, equipment and training? 

In some cases this is probably due to the perspective from which they view de-icing / antiicing 

activities and the need for a clean aircraft at take-off. This attitude may be labelled 

“safety perspective”, where de-icing / anti-icing services are viewed as necessary safety 

activities and the associated costs seen as the “price for safety”. If de-icing / anti-icing 

services are viewed from the perspective of a commercial service (such as baggage 

handling) then the associated fees may be seen as the “cost of doing business”. In an 

environment where this latter case prevails, then there will always be calls to justify these 

fees and room for discussions on driving down costs. Between these two perspectives lie 

many variations and this can lead to confusion of priorities. 

There need not be any confusion between what’s good for business and what’s good for 

safety. For example, an aerodrome may make a considerable investment in acquiring, 

installing and making operational an ILS, even though the climate and local weather patterns 

may only impose low visibility operations on few occasions during any single year. 

Maintaining a full flight programme in all weather conditions is good for business and the 

investment is easily justified. An ILS is not mandatory and when the visibility and/or cloudbase 

are below limits the aerodrome cannot be used for landing. However, once installed, 

and if it is used, there are clear, strict rules and guidelines for airlines, aerodromes, ATC, 

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controllers and pilots in its use, limitations, maintenance and capabilities. The ILS is viewed 

from the “safety” and not the “commercial perspective”. De-icing / Anti-icing services are not 

mandated, nor do they have to be used when available: in both these cases departure during 

“winter” conditions will not be possible. However, if de-icing / anti-icing services are available 

and used, then, like an ILS, there does need to be clear, strict rules and guidelines for all 

those involved on how these services operate. Currently this is not the case. 

Status Quo 

While some individual stakeholders argue that the existing situation is adequate and that 

further regulation is not required, a majority of others (from all stakeholder groups) wish to 

see changes.. This Study was launched on a wave of support, lobbying and 

recommendations made during the past 5 years. 

ZERO: Do nothing; maintain the status quo. Not recommended. 

This is not an option for change, but it is still an option to be considered. 

However, to select this option would ignore recommendations made by 

accident investigators, regulators, industry stakeholders and also the available 

data – all introduced above and elsewhere in this Report. Agency Opinion to 

A-NPA-2007-11 dismissed this option for service providers and aerodromes, 

but kept it as an option for operations. 

Direct Regulation of Service Providers 

Examining mechanisms for the direct regulation of service providers is part of the Study. 

Some stakeholders consider this a difficult and unnecessary option; preferring to improve 

standards through amendments to regulation of operators and aerodromes. However, a 

large representation of service providers is supportive of a system of direct oversight and 

certification. 

REGSP: To implement direct regulation of de-icing / anti-icing service providers by 

EASA or NAAs. 

This option would provide a completely new and untested model. The Study 

found that de-icing / anti-icing service providers are not regulated directly by 

Member States. On the few occasions where an Authority declared it did 

regulate service providers, it was found that this was actually only indirectly 

achieved through The Ground-Handling Directive 96/67/EC, Aerodrome and 

Air Operations regulations. Ultimate responsibility always remains with the 

operator; and this requirement would probably need to always remain. This is 

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reinforced by the proposed GM 1 AR.GEN.300 (Continuing Oversight OPS); 

where there is a clear intention for the Authority to devolve more responsibility 

onto the operator to monitor the safety of operations. Adopting direct 

regulation and oversight of service providers may be in opposition to these 

proposals. Also, the Explanatory Note to EASA NPA 2009-02A, Appendix 1, 

Paragraph 9, explains how for the time being the regulation of ground de-icing 

/ anti-icing service providers is outside the Agency’s remit. Agency Opinion to 

A-NPA-2007-11 also dismissed this option. Possible options to achieve the 

direct regulations of de-icing / anti-icing service providers include: 

REGSP1. To undertake regulatory reform, making some (or all) aspects of de-icing / 

anti-icing the responsibility of service providers. Long-term option. 

To commence a programme of regulatory reform to effect an amendment to 

the Basic Regulation, and the drafting of Essential Requirements and 

Implementing Rules for service providers. 

REGSP2. To make de-icing / anti-icing fully a maintenance task. Not recommended. 

If de-icing / anti-icing operations and the associated inspections were 

considered a maintenance task (in opposition to ICAO Doc 9640 and Annex 

6), then service provider organisations would be required to hold a 

“restricted/limited” Part 145, or operators and maintenance organisations 

would be the sole providers of de-icing / anti-icing. Numbers of providers 

would still need to be restricted, due to available space, and therefore 

operators would still need to negotiate contracts with a third-party. Agency 

Opinion to A-NPA-2007-11 dismissed this option. 

REGSP3. To make de-icing / anti-icing service provision fully a responsibility of the 

aerodrome. Not recommended. 

This would require re-interpretation of ICAO Annex 14 and Doc 9640, the 

turning of recommendations into hard requirements, and the elimination of 

competition, i.e. only aerodromes could provide de-icing / anti-icing services. 

Operators would still need to demand their own (and the aircraft 

manufacturers’) requirements, negotiate contracts and conduct quality 

oversight. 

GHDSP. To regulate certain aspects of de-icing / anti-icing service provision through 

Directive 96/97/EC on Ground-Handling. 

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This option is partially used in a few Member States whereby service 

providers of de-icing / anti-icing need to demonstrate to the Authority that they 

have the financial, organisational, and managerial experience necessary to 

conduct their operations (as per Clause 22 and Article 14 to the Directive), 

and that their operating/procedures manual is fit for purpose. The Authority 

then has the option to audit the service provider at regular intervals against 

these criteria. To ensure a harmonised and fairly implemented application of 

national regulations based on this Directive, EASA, NAAs and Industry would 

need to initiate a process of review, agree on the outcomes, and lobby for 

amendment to the Directive. 

GHDSP1. Permit States to limit the number of de-icing / anti-icing service providers at 

aerodromes. 

The number of de-icing / anti-icing service providers operating at any single 

aerodrome can directly influence the quality of service: space constraints and 

difficulties in coordination are both hazards, and investment levels can be 

affected. Amendment to Article 6 of Directive 96/97/EC would be necessary, 

and this can linked to the provisions of Clauses 11, 12, 22 and 23. Any 

decision to limit the number of service providers may be based on a sound 

risk assessment conducted by the State, in addition to the conditions outlined 

in Article 9. 

GHDSP2. Require States to approve organisations for the supply of de-icing / anti-icing 

services against a set of minimum administrative standards and technical 

specifications. 

Currently this is acceptable within the Directive: approval (Clause 22); 

necessary technical specifications for use of infrastructure (Clause 23 and 

Article 11); and administrative standards (Article 14). Such a policy can be inline 

with acceptable minimum standards demanded by operators, but will 

allow direct scrutiny of service providers by the State. An agreed 

interpretation of the Directive amongst all Member States, facilitated by EASA 

may be effective. 

The Study revealed an example of an airline gaining a National Vocational Qualification for a 

de-icing / anti-icing training course, allowing those participants who pass to gain an 

appropriate vocational qualification. Maintaining a qualified status requires annual renewal 

following recurrent training. The qualifying body, City & Guilds, is Europe-wide, and a 

Europass Certificate Supplement can also be applied for. Other vocational qualification 

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systems could design and deliver similar courses. States may wish to investigate this option 

with a view towards offering a form of approval to the training organisations and their de-icing 

/ anti-icing training courses (NB: UKCAA is already exploring this option through the UK 

National Occupational Standards). In support of Option GHDSP2 above, States may then 

require that service provider operatives must be in possession of a vocational qualification 

from an approved/acceptable training organisation. As the Study Team is only aware of one 

example of such a course and qualification this would need to be a long-term option; 

furthermore, many service providers who currently conduct their own training may need to 

seek appropriate accreditation from their national vocational qualification system, which will 

no doubt take time. 

TRGSP: As part of the State approval/selection of service providers through Directive 

96/97/EC on ground-handling, require de-icing / anti-icing operatives to 

possess a valid vocational qualification in de-icing / anti-icing. 

Improving the Regulation of Air Operations 

The regulation of standards of de-icing / anti-icing services is currently met through 

operators’ requirements for de-icing / anti-icing, and their quality control programmes. This 

arrangement is clearly not satisfactory to a large number of stakeholders, and may be due to: 

− the provision of inadequate rules and/or guidance material; 

− poor interpretation of these rules and guidance; and/or, 

− the ineffective oversight of operators’ de-icing / anti-icing policies, programmes and 

quality systems. 

The regulations applicable to operators concerning de-icing / anti-icing are minimal; imposing 

the single assurance of an airworthy aircraft at take-off. Guidance material for operators is 

comprehensive, detailed and plentiful, and also from a variety of sources. This in itself can 

present the situation where interpretation of such guidance material is variable, and this is 

transposed into operators’ procedures, training, contracts and quality programmes. 

REGAO: To improve the existing regulations for operators; improve the interpretation of 

those regulations; and improve the oversight of operators in this regard. 

Recommended. 

There are many options available to amend and improve interpretation of the current 

regulations for operators (Attachment B), not all of them are sensible, or liable to be effective. 

The options included here are considered achievable and they address specifically the areas 

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of weakness highlighted in “The Summary and Analysis of Safety Data”, the 

recommendations made by stakeholders, and the ToRs to this Study, all previously 

described within this document. 

REGAO1. Require the approval of operators’ de-icing / anti-icing programmes against 

minimum requirements defined within the regulations. 

REGAO2. Develop an effective AMC in the form of an example of, or framework for, an 

operator’s de-icing / anti-icing programme. 

These three options, and a combination thereof, will need to be undertaken with 

consideration given to the intended aims of harmonising programmes and raising standards. 

ICAO recommends (Doc 9640) that the operator’s de-icing / anti-icing programme, or 

procedures, is “approved” by the NAA; with special focus on responsibilities and training. 

De-icing / anti-icing is not included as an item requiring Authority approval, merely 

“acceptance” through a technical evaluation (Attachment F to Annex 6 Part 1). EASA no 

longer differentiates between “approval” and “acceptance”, although the means of evaluation 

may vary. Such an evaluation must consider whether the specific policies and procedures 

would result in the desired outcome. For a satisfactory evaluation to be made, the facilities, 

procedures and equipment available at each location would need to be considered. 

EU OPS 1.345 and JAA ACJ OPS 1.345 do not require any approval by the NAA, but they 

do provide adequate direction for an operator as to the requirements, however, not towards 

the detail. With several informative and comprehensive reference documents highlighted as 

sources for operators to develop their de-icing / anti-icing policies, procedures and 

programmes, the outcomes will naturally vary and harmonisation of procedures is unlikely. 

De-icing / anti-icing procedures are not an element of the OM that requires specific approval 

(JAA IEM OPS 1.1040(b)), instead the operator only needs to ensure that the structure of the 

OM is acceptable to the NAA (OPS 1.1045). The required contents of the OM contain little 

guidance and focus mainly on fluid types. There is no presentation of an “acceptable” set of 

procedures, nor a standard template for both procedures and training syllabus. Furthermore, 

there is no direct requirement for an operator to establish coordination and communication 

procedures between flight operations, flight crew, aerodromes and service providers, 

adequate for all their destinations. 

The proposed OPS.GEN.100 and associated AMC and GM does not improve the current 

regulatory situation, (Attachment B). However, AMC under the Basic Regulation and as 

described in NPA 2009-02A (paragraph 56 and Appendix II, paragraph 6) are part of a 

commercial operator’s approval, and therefore have the same status as a regulation. Such 

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an AMC can be divided into the “essential” elements, and the “supporting information” 

elements. 

Overall, in addressing these three options, attention should be given to the following: 

REGAO2.a. providing operators with a clear framework for an acceptable de-icing / 

anti-icing policy, procedures, training programme, 

REGAO2.b. providing operators with clear guidelines for establishing and maintaining 

effective communication and coordination procedures, 

REGAO2.c. providing operators with template communication messages and 

meanings connected with all inspections, checks and operations; in 

particular review of the anti-icing code, and clarification of the “all clear” 

signal/message (refer to COMM), 

REGAO2.d. providing operators with a structured framework for the relevant section 

of the OM (A8), 

REGAO2.e. clarifying responsibilities for key decision-makers, 

REGAO2.f. requiring and defining the minimum elements required for an effective 

contract between operator and service provider, and 

REGAO2.g. requiring operators to seek approval for any deviations (in certain areas) 

from the published AMC. 

REGAO3. Require operators to appoint a subject-matter expert as per Option SME4. 

This contributes towards the need for improved internal and external 

communication and may help promote improved knowledge amongst the 

relevant employees and ensure an effective homogenous de-icing / anti-icing 

policy and programme. Combined with other SME options, this may also 

contribute towards a harmonisation of standards required of service providers. 

EU OPS 1.175 details the requirement for operators to appoint nominated 

post-holders in the areas of flight and ground operations, maintenance and 

crew training. No preference is given as to which Post-Holder should be 

responsible for de-icing / anti-icing. This will be detailed in their 

responsibilities published in the Operations Manual (OM). However, one of 

these Post-Holders is to be responsible for ensuring contracted organisations 

maintain proper standards. This particular nominated Post-Holder could be 

made responsible for appointing a suitably qualified and experienced subjectmatter 

expert to coordinate the operators de-icing / anti-icing programme. 

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This would align with the requirement for operators to have a sound and 

effective management structure. JAA AMC OPS1.035 specifies clearly that 

sub-contracted de-icing / anti-icing services are to be subject to quality 

inspections and audits, under the responsibility of the Quality Manager; this 

may exclude the QM from assuming the role of the expert. 

REGAO4. Operators to define specific training requirements and knowledge base for 

operations and dispatch staff concerning de-icing / anti-icing. 

During this Study, it has become apparent how critical the operators’ flight 

operations departments can be in either contributing or hindering de-icing / 

anti-icing operations, through their role as a communication hub between the 

service provider, aerodrome and flight crews. Specifying in-house training 

requirements for flight operations/dispatch staff in de-icing / anti-icing matters 

may improve safety at very little cost. EU OPS 1.205 and JAA ACJ OPS1.205 

refer. 

REGAO5. States to require that operators develop a targeted programme within their 

SMS, specifically aimed at de-icing / anti-icing. 

This Option is in conformity with Options SAF2 and SAF3. In order to improve 

performance in the area of de-icing / anti-icing, operators will need to collect 

safety data from service providers to identify those hazards to their own 

operations that can only be “seen” from the service provider’s/operative’s 

perspective. This can be applied through EU OPS 1.037 and 1.420, and 

OR.GEN.200(a) and associated AMC. 

REGAO6. Operators to be required to provide flight crew with a checklist system that 

specifically addresses aspects of de-icing / anti-icing. 

One area of risk and inconsistency is both poor decision-making and the 

technical and procedural knowledge of flight crew. De-icing / anti-icing is a 

demanding operation, often occurring within the environment of a pressured 

operational and traffic situation. Furthermore, when other operational, system, 

environmental, etc., threats emerge during this period, decision-making and 

access to technical knowledge can be hampered. Providing a set of pilots’ 

notes in a checklist, or in diagrammatic style (in line with HF principles) will 

greatly enhance decision-making. 

REGAO7. Require the inclusion of an operator’s de-icing / anti-icing programme and 

procedures within the operator’s conversion course ground training. 

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Under the existing regulations there is a risk that pilots may operate during 

winter conditions without having undertaken any instruction in the operator’s 

de-icing / anti-icing procedures. Lack of pilot knowledge is a frequent 

occurrence in reported incidents. Currently de-icing / anti-icing instruction is 

only included in the operator’s recurrent training programme (EU OPS 1.965) 

and is not included in the operator’s conversion course (Appendix 1 to EU 

OPS 1.945). 

REGAO8. Require the inclusion of applicable elements of the operator’s de-icing / antiicing 

programme, and any new knowledge, within the operator’s differences 

and familiarisation training requirements. 

It may be possible, under existing regulations, for pilots to be unaware of the 

need for a variation in de-icing / anti-icing procedures when operating a new 

variant (of the same type) or type (of the same class) of aircraft. Lack of pilot 

knowledge is a frequent occurrence in reported incidents. Currently de-icing / 

anti-icing differences and new knowledge are not included in the operator’s 

differences and familiarisation training requirements (EU OPS 1.950). 

REGAO9. Review and expand the required contents of the operator’s de-icing / anti-icing 

policy and programme that shall form part of the Operations Manual. 

Appendix 1 to EU OPS 1.1045 (A 8) and AMC5 OR.OPS.015.MLR contain a 

list of 5 specific subjects concerning fluid types which must be described 

within the OM. Limiting the relevant contents of the OM to these few elements 

detracts from other critical aspects of the programme. OPS.GEN.600 omits 

the OM from the list of documents to be carried on all aircraft. The omission 

of certain information may hinder pilots’ decision-making during winter 

operations. Providing more guidance on the contents of this section of the 

OM will increase the harmonisation amongst operators of how this information 

is presented. It is an option to revise this Appendix and include other 

elements, such as: 

- the operator’s communication and coordination procedures (for deicing 

/ anti-icing); 

- the anti-icing code; 

- inspection and checking procedures; 

- re-assessment of HOT in changing conditions; 

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- affect of frozen contamination on flying control surfaces; 

- affect of re-hydrated fluid residues on flying control surfaces; and 

- details of the operator’s standard contract for de-icing / anti-icing 

service provision at all destinations. 

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4.6 Alternative models for regulating de-icing / anti-icing through 

operations regulations 

Like de-icing / anti-icing, other activities exist which 

− need to be fulfilled by operators 

− rely on third-party contracted organisations and persons 

− can be classified as safety critical 

These activities include: 

− loading (OPS 1.625) 

− the carriage of dangerous goods (OPS 1.1145), and 

− maintaining the integrity of navigation data (OPS 1.873). 

In each case, a different framework of regulations and guidance material has been 

developed to meet the needs of each activity. However, certain aspects of how these 

activities are regulated (or not) may provide an insight into potential amendments to de-icing 

/ anti-icing regulation. 

Loading 

This particular alternative model does not lead to a radical alternative proposal for regulation, 

but it does highlight the importance given to communication; and the options proposed stand 

on their own as valid, and would fit within Options REGAO and REGAO3 above. 

Unlicensed personnel, employed by non-certified organisations, working under contract to 

the airline and sometimes sub-contracted through another body (aerodrome, groundhandling 

agent) are weighing cargo, loading aircraft and completing load documentation. 

The captain is responsible for ensuring that the aircraft is loaded correctly and within 

performance limitations. He/she does this by determining whether the mass and balance 

documentation is acceptable. 

The mass and balance documentation must enable the commander to determine that 

the load and its distribution is such that the mass and balance limits of the aeroplane 

are not exceeded. 

Incorrect weighing, loading, and/or calculations and form-filling may result in an incident or 

accident. The parallels with de-icing / anti-icing are significant. 

For a captain to determine whether de-icing has been successful he/she is relying on the 

passing of a message, not usually paperwork, but often verbal or visual. The verbal 

message can be delivered in person, or via VHF; sometimes this message is passed via a 

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third-party. The visual message can be delivered by a “thumbs-up”, or via a message board; 

and, potentially via data-link; also sometimes via a third-party. 

Also for a captain to determine a HOT following anti-icing, the same system can apply. 

Usually the two elements are combined into the “anti-icing code”. Unlike loading, de-icing / 

anti-icing protection degrades gradually and variably, and the information contained in the 

anti-icing code is essential for the captain to determine whether the aircraft remains in an 

airworthy condition. In this sense the anti-icing code, or any information, passed to the 

captain should have the same status as the mass and balance documentation. However, 

whereas mass and balance documentation is “designed”, fit for purpose, contains all the 

required information, and is able to be interpreted uniformly by personnel from different 

organisations and states, the anti-icing Code is not. 

Like the other elements of an operator’s de-icing / anti-icing programme, the Code is 

recommended best-practice, and is described in ICAO Doc 9640, JAA ACJ OPS, AEA and 

SAE Recommendations. However, like those other elements of an operator’s de-icing / antiicing 

programme the Code is open to interpretation, and this Study has discovered that the 

understanding attributed to the Code varies considerably. For example, in the fourth and 

final element of the Code, as recommended in ICAO Doc 9640 5.4(d), confirmation is given 

that the aeroplane complies with the clean wing concept. Whereas, in the sixth and final 

element of the Code, as recommended by AEA 3.14.3(f), confirmation is given only that the 

post treatment check has been completed. Some service providers issue the Code only to 

confirm that the service requested have been provided and not necessarily that a post 

treatment check has been conducted and no contamination found. Some operators believe 

that the issue of the Code implies that the aircraft is now clean of contamination. Another 

aspect for confusion is the connection (or not) of the issuing of the Code and the 

communication to the flight crew that all de-icing / anti-icing personnel and vehicles are 

“clear” of the aircraft; and furthermore, confusing this with a communication that the aircraft is 

clear to taxi. 

For a safe de-icing / anti-icing operation and subsequent flight, the flight crew need to know 

certain information, it can be argued that this information is equally as important as an ATC 

clearance; therefore, it needs to be unambiguous, standardised, and delivered by someone 

who has the required understanding and capability. Furthermore, best-practice protocol 

should be utilised, such as message “read-back”. The elements of communication between 

the flight crew and ground crew (and other bodies) include: 

− results of contamination check (even if conducted by one or both pilots, the results 

need to be communicated to the rest of the crew, to airline operations, and the 

“iceman”) 

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− the location of the de-icing / anti-icing operation (ramp, remote) and any special 

instructions (engines running/not running, services/fluid available etc) 

− request to configure the aircraft for de-icing 

− permission to configure the aircraft for de-icing 

− request to configure the aircraft for anti-icing (if required prior to the second step) 

− permission to configure the aircraft for anti-icing (if required prior to the second step) 

− request to commence de-icing / anti-icing (what activity, and with what fluid) 

− permission to commence de-icing / anti-icing and any special instructions 

− request to reconfigure the aircraft post de-icing / anti-icing 

− permission to reconfigure the aircraft post de-icing / anti-icing 

− request to run-up engine(s) (if required to prevent engine stall) 

− permission to run-up engine(s) 

− de-icing complete 

− anti-icing complete 

− anti-icing Code – including, fluid type, fluid/water ratio, time of commencement of antiicing 

application – may also include date 

− confirmation and results of post treatment check (aircraft clean/not clean) and any 

details 

− clearance for de-icing / anti-icing crew to depart 

− confirmation that the de-icing / anti-icing crew and equipment are clear of the aircraft 

(including jet blast areas) 

− request to taxi 

− permission to taxi 

Unambiguous and standardised messages demand that each message element does not 

have two meanings. That is, the anti-icing Code should not mean both “definition of the 

application” and “the aircraft is clean”, because this will not always be the case. Nor should it 

also mean that the ground equipment and personnel are “clear”. Furthermore a “thumbs-up” 

is inadequate for any type of safety critical communication by itself. It should only be used in 

conjunction, and to support, a verbal message. However, the meaning of a thumbs-up is not 

necessarily globally standardised, and should be discouraged. 

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Most of these messages are essential for safe coordination, and as such would benefit from 

international standardisation and use, as well as continuously open channels of instant 

communication during de-icing / anti-icing. The adherence to special instructions, the Code 

and the results of the post treatment check effectively (like the mass and balance 

documents) allow the captain to establish whether the aircraft is airworthy, and whether it 

remains in that condition. Therefore, the communication from the service provider should be 

from a suitably qualified person, who ought to be willing to “sign-off” his/her work, by 

communicating their name (perhaps as part of the “aircraft clean” or Code messages). 

Furthermore, this person should be present at the operation, in charge of the operation and 

able to conduct the post treatment check. The Code and “aircraft clean” elements should 

also be recorded. If, for contractual reasons the post treatment check is conducted by 

another organisation, then this element of the communication should also be delivered by the 

qualified person, who is present and also provides his/her identity. 

COMM. Standardise communication elements and their meaning. 

COMM1. Clarify that the anti-icing Code only provides those information elements within 

it and does not infer anything else. 

COMM2. Require a separate “aircraft clean/aircraft not clean” message following the 

post treatment check. 

COMM3. Require a separate “equipment and personnel clear of aircraft” message. 

COMM4. Require continuous verbal contact between de-icing / anti-icing crew chief and 

flight deck. 

COMM5. Require critical messages (aircraft clean) to be delivered by qualified person 

who is present at the operation. 

COMM6. Require this qualified person to provide his/her name/number with either the 

Code, or the post treatment check results. 

COMM7. Require operators to include these elements in their contracts with service 

providers. 

Dangerous Goods 

This is another area where unlicensed personnel working for non-certified organisations are 

responsible for activities, which if not carried out to the required standards will introduce 

hazards and therefore introduce risk into aircraft operations. Unlike de-icing / anti-icing, the 

regulators have found a way of ensuring that all operators and their handling agents comply 

with the same set of standards. 

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EU OPS 1.1145 and OPS.GEN.030 refer. These rules require operators and their handling 

agents to comply with ICAO Doc 9284-AN/905 (Technical Instructions for the Transport of 

Dangerous Goods). This document is accepted globally, and updated regularly with 

contributions from many NAAs and Industry organisations. Operators are approved to 

transport dangerous goods by their Authority; this may, or may not be applied to operators to 

approve their operations when de-icing / anti-icing is required. 

An EASA ruling in the future OR.OPS could be considered whereby the Agency requires an 

operator to comply with the applicable provisions contained in the latest edition of Technical 

Instructions for the safe de-icing / anti-icing of aircraft on the ground. Specific references can 

then be made to ensure that the de-icing / anti-icing service provider follows certain 

checklists and procedures in accordance with these Instructions, and that any personnel 

involved (whether employees of the operator or not) should also apply the standards within 

the Instructions. The ultimate result would be that operators draft their de-icing / anti-icing 

programmes and associated contracts from a single source document. 

There are various options available for the source of these Technical Instructions: 

− ICAO Doc 9640. Useful as a basis for a regulation, and indeed this is the case 

existing today. Although reference to an ICAO document is a direct parallel with the 

regulation of dangerous goods, it is not very useful as a source of technical 

instructions, checklists and templates. 

− EASA AMC to OPS.GEN.100 can be developed into a suitable set of Technical 

Instructions, with which operators would be obliged to comply unless they sought 

approval for an alternative means of compliance. Such an AMC could be used to 

direct operators towards standardised means of coordination, communication, training, 

training etc, and the template used for the AMC could be designed to assist operators 

construct their programmes, OM entries and contracts. Options REGAO2 and 

REGAO3 refer. 

− SAE ARP 4737 Aircraft de-icing / anti-icing methods is a technical manual; useful for 

training, designing procedures and also developing an operator’s de-icing / anti-icing 

policy and programme. However, as an AMC, or set of Technical Instructions it is too 

broad and not specific enough. However, referring to SAE Recommended Procedures 

may be considered similar to other references made within regulations to EUROCAE 

and RTCA documents. One benefit of using SAE is that both Industry and Authorities 

participate in their update – which is also regular. Another benefit of using SAE is that 

a family of documents is available covering application, fluids and their handling, 

equipment and training; these are referred to from within ARP 4737. 

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− AEA Recommendations; this is the predominant reference document for operators. It 

is designed, published and updated regularly by operators, with input from aircraft 

manufacturers. Because operators rely on this document, service providers also use 

this as a reference, together with ICAO , ISO and SAE documents. However, as an 

AMC, or set of Technical Instructions the AEA Recommendations is too broad and not 

specific enough. 

− ISO 11075/6/7/8 are used by service providers who may wish to benefit from ISO 

9001 accreditation, however, operators prefer to use the documents mentioned above 

to these ISO documents. It is worth investigating whether a service provider 

accredited for Quality Management under ISO, specifically against the relevant deicing 

/ anti-icing standards, has a safer operation than those who are not. If a benefit 

can be identified and the Industry agrees that the ISO accreditation results in a 

worthwhile standard and quality of service, then operators may be “required” to obtain 

their services only from ISO accredited organisations. This concept would be 

structured in a similar way to Option REGLOA shown below, but more investigation is 

required. 

Identifying, or creating an acceptable source reference set of technical instructions for the 

safe de-icing / anti-icing of aircraft on the ground may allow EASA to regulate de-icing / antiicing 

in a manner similar to the carriage of dangerous goods. Operators de-icing / anti-icing 

programmes may be approved against these instructions, or not. 

TECIN1. EASA develops a set of Technical Instructions against which operators deicing 

/ anti-icing programmes shall be approved. 

This Option should be considered alongside Option REGAO1. Operations 

other than the carriage of dangerous goods which also require special 

operations approval (OPS.SPA) include: operations in RVSM airspace; 

operations in airspace with specified navigation performance; and, low 

visibility operations. Not so easy to draw parallels with de-icing / anti-icing 

here; the regulation of these operations does involve a lot of technical 

instruction within the regulations themselves, and therefore a precedent has 

been set for detailed direction for operators within the regulatory framework. 

The format of applying for a special operational approval is quite straightforward. 

Applicants provide the competent authority with the documentation 

required by the applicable subpart as well as a description of the intended 

operation. Applicants then need to demonstrate that: 

- they comply with the requirements of the applicable section; 

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- the aircraft and required equipment comply with the applicable 

airworthiness requirements/approvals; 

- a training programme has been established for flight crew and, as 

applicable, personnel involved in these operations; and 

- operating procedures in accordance with the applicable subpart have 

been specified in the operations manual. 

It can clearly be seen how these criteria for application of special operations 

approval could be adjusted to suit de-icing / anti-icing operations. Both 

service providers’ equipment and personnel can be included with reference to 

external standards of maintenance and training respectively. 

TECIN2. EASA identifies an external source document and adopts it as a set of 

Technical Instructions which operators are required to follow, and which 

operators are required to impose on service providers. 

TECIN3. EASA, in collaboration with Industry and other agencies (EU NAAs, FAA, TC) 

develops an AMC to OPS.GEN.100 which can be used as a template for 

operators’ de-icing / anti-icing policies, programmes and OM entries (refer to 

REGAO2). 

Navigation Data 

Uploading electronic navigation data into an aircraft’s navigation database and system is not 

a process that allows for the cross-checking of that data at the moment of upload. The 

operator is entirely dependent on the supplier of data, or equipment (if pre-loaded), to ensure 

that the data is accurate. Inaccurate navigation data can introduce hazardous conditions and 

increase the risk of flight operations. Some data can be checked by the flight crew when the 

data is actually being used, or immediately prior to it being used, however, this is unreliable, 

and does not ensure the accuracy of the rest of the database. Any errors will remain latent 

until exposed through use. The similarities with de-icing / anti-icing are plain to see: the flight 

crew are reliant upon the service provider’s “accuracy”, and while some post treatment 

checking by the flight crew is possible, the crew have to rely on someone else to conduct the 

check and provide assurances. Undetected errors may have an immediate effect, or may 

remain latent until exposed. 

Whereas operators are responsible entirely for ensuring that de-icing / anti-icing is conducted 

to an acceptable standard, they are not always responsible for ensuring the accuracy of 

navigation databases. Instead, a system of “approval” of the supplier is used. Operators can 

obtain their navigation databases from suppliers who hold a Letter of Acceptance (LoA) and 

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this itself satisfies their responsibility for assuring that the data is accurate. EASA issues the 

LoA to appropriate suppliers who meet the criteria; this is accomplished in accordance with 

EASA Opinion 01/2005. Operators can still obtain databases from suppliers who do not hold 

a LoA, but they then have to demonstrate to the Authority that their procedures are adequate 

to assure the same standards. In both cases, the operator’s Quality System still needs to be 

employed. One of the aims of the LoA is to ease the obligation on operators to perform what 

would be nearly impossible and unimplementable controls and processes. 

The option of EASA issuing LoAs to service providers of de-icing / anti-icing would introduce 

different challenges. First there are only a few air navigation database suppliers, therefore 

the Agency’s commitment of resources is limited. Secondly, if EASA did audit every de-icing 

/ anti-icing service provider, this is only a process that operator’s are obliged to do anyway; 

therefore, the duplication would be wasted effort, and to against whose standard would the 

Agency be conducting audits – each individual operator’s? The benefit of using an LoA 

process is that standard “conditions and guidance” can be established against which audits 

and inspections can take place. 

In EASA Opinion 01/2005, the Agency has the view that the best solution would certainly be 

that the industry organizes itself to verify the quality of the navigation data provided by the 

suppliers and used by the aircraft operators. Such an option, similar to that developed by 

IATA for the operational safety audit of its member airlines (IOSA). This view points towards 

a possible hybrid system of regulation and oversight. The IATA DAQCP provides a model 

where member airlines agree a common standard audit checklist (based on AEA 

Recommendations), and accept the audit results of shared audits within the pool of 

members. The auditors are provided by the pool members and are trained in accordance 

with the DAQCP’s own accepted standards. In effect, any service provider passing a 

DAQCP audit is issued with an Industry seal of approval, much like IOSA, whilst not 

removing the ultimate responsibility from the operator. It could be conceivable that any 

organisation (like IATA) wishing to establish a de-icing / anti-icing quality control pool can be 

“approved” or “accepted” by EASA and issued with their own LoA (perhaps LoA1); this would 

then permit the pool’s own qualified auditors to issue, on behalf of the Agency, LoAs 

(perhaps LoA2) to service providers who meet the necessary standards. Currently, the 

DAQCP is established from the perspective of their own airline membership, and this limits 

the number of destinations and service providers included in the scheme. An improvement 

to the scheme would be to allow service provider membership where they either paid for the 

privilege of being audited and thereby “accepted”, or they paid a fee and contributed to the 

pool of auditors. 

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The regulatory control would be established if EASA accepted that a shared audit from one 

of it’s “accepted” schemes would ease the obligation of participating operators to conduct 

their own audits. Whereas if an operator wished to use the services of a provider who sat 

“outside” of any scheme and did not possess an LoA, they would have to demonstrate to 

their competent Authority that they could meet the same standards through their own 

contract provisions and quality programme. 

REGLOA. EASA to investigate the possibility, and the potential for an LoA system of 

quality assurance of de-icing / anti-icing service providers. 

In support of the Option REGLOA, or instead of, it may be possible for the Industry to 

establish a voluntary system of accrediting service providers. Such a system could still be 

based on ensuring the standards of for example AEA Recommendations, through an audit 

scheme like the IATA DAQCP. For such a scheme to be successful, all airlines and all 

service providers would need to agree to participate. However, if a voluntary scheme was 

established, whereby service providers could opt to be “accredited” by Industry, then this 

could be used as the basis of lobbying for EASA “approval” of such schemes. 

VOL: Industry commence a system whereby service providers can opt to be 

accredited through a recognised audit scheme based on acceptable 

standards. 

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4.7 FAA SIAGDP 

Attachment C provides some description of the proposed FAA Standardised International 

Aircraft Ground De/Anti-icing Programme (SIAGDP). This programme is relevant to this 

Study because as stated in FAA Notice N 8900.26 Dec 2007 Policies, procedures, and 

requirements are currently under development to authorize an aircraft ground deicing service 

provider to be issued a letter of authorization (LOA) to provide aircraft ground deicing 

services under an industry standardized aircraft ground deicing program. 

This FAA SIAGDP also involves a detailed overhaul of FAA AC 120-60B the document 

against which carriers have their de-icing / anti-icing programmes approved by the FAA. A 

mechanism that does not exist in EASA Member States. Naturally, to avoid duplication and 

confliction, any proposed changes to the method of regulation and oversight of operators’ deicing 

/ anti-icing requirements ought to be shared with the FAA (and TC) in order to promote 

a harmonised system of regulation between the two continents. 

LIASFAA. EASA should take this opportunity to liaise closely with the FAA, and TC, with 

the aim of harmonising future de-icing / anti-icing regulations and thereby 

avoiding differing requirements, giving rise to ambiguity and confusion. 

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4.8 National authority requirements for oversight of operations 

Without a system of direct oversight of service providers it is possible that some NAAs rely 

on their relationships with operators to understand this dynamic and safety critical activity 

which takes place within their territory. In such cases, there is no relationship between the 

NAA and providers of de-icing / anti-icing services. The difficulty, encountered during this 

Study, in determining a responsible person within EASA Member State NAAs for de-icing / 

anti-icing service provision is evidence that this lack of working relationship, and possibly 

knowledge can exist. Option SME3, above, addresses this particular issue. 

The oversight of an operator’s de-icing / anti-icing programme relies on the NAA accepting 

the operator’s OM, and quality assurance programme. With the emphasis on compliance 

with operations regulations, the important element of how operators arrange contracts with 

service providers may be overlooked. How these contracts are arranged and constructed 

should be of interest to NAAs in determining the standards against which operators audit 

third-party contractors. 

EASAAR1. EASA to require all NAAs to establish and maintain a monitoring programme 

of de-icing / anti-icing service providers exercising activities on their territory. 

This requirement will exist in the new Authority Requirements, but may not be 

implemented fully by all States. AR.GEN.305 Monitoring of activities – 

requires NAAs to conduct oversight of non-certified bodies and personnel 

when they are conducting activities on their territory – such programmes and 

audit schedules shall be proportionate. A unified purpose for such 

programmes would encourage their development and use, and also provide 

useful feedback which could be compared between States. 

EASAAR2. EASA to develop guidance for NAAs in how to implement a monitoring 

programme of de-icing / anti-icing service providers in compliance with 

AR.GEN.305. 

EASAAR3. EASA to amend AMC2 AR.GEN.300 Continuing Oversight Ops – to include 

an operator’s arrangements for ground-handling. 

Ill-conceived contracts and arrangements made with de-icing / anti-icing 

providers can be a source of confusion, or worse. AMC 2 AR.GEN.300 

Continuing oversight OPS – specifies a list of items which an operator should 

at least be subject to inspections and monitoring by the Authority. Although 

not an exclusive list, the inclusion of an operator’s arrangements for ground- 

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handling (including de-icing / anti-icing) would increase awareness of the 

issue. 

With regard to the issue of re-hydrated residues and the management thereof, the data 

available concerning operator’s residue management programmes and their efficacy is not 

shared, and is mostly anecdotal. Considering this issue has been raised as a serious safety 

matter, and aircraft manufacturers and operators obliged to focus on eliminating the 

associated risks, little is actually known as to what should comprise best-practice. It is not 

known, for certain, whether increased use of type I use is beneficial in reducing the risk, or 

whether a washing cycle after 3 applications of thickened fluid is better than a cycle after 5 

applications. Also, there is no consensus on whether preventive anti-icing increases the risk 

of residues considerably. 

What does seem apparent, however, is that since awareness of the issue was raised, and 

inspection and cleaning programmes introduced, fewer incidents of frozen/obstructed 

controls are occurring. 

What is not known is how much residue is still being found and consequently removed. It 

would be beneficial to the Industry if a set of data could be collected to allow all interested 

stakeholders to quantify the existing risks and also compare best-practices. For this, a 

dataset would need to be established and a method of sharing and analysing agreed, 

perhaps through a central facilitator. The data that would be helpful includes the following: 

− aircraft type 

− aircraft identity 

− history of applications of de-icing / anti-icing fluid, including: 

o type of fluid 

o procedure 

o location of application 

− history of inspections 

− brief description of inspection methods, including any variations 

− findings – quantitative or qualitative measure of residue formation 

− history of cleaning - quantitative or qualitative assessment of effectiveness 

− brief description of cleaning methods, including any variations. 

A programme of such data collection and analysis would complement any associated data 

received under Option SAF1, above. 

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RESDATA1. EASA and NAAs to agree a dataset and method of collection, distribution and 

analysis for ascertaining the existing levels of risk from residue formation. 

RESDATA2. NAAs to require operators, and where applicable maintenance organisations, 

to record and submit data, relevant to individual aircraft, concerning 

applications of de-icing / anti-icing fluid, and the effect of inspections for, and 

removal of, residues. 

RESDATA3. NAAs to request brief descriptions of operators’ residue management 

programmes, including inspection and cleaning methods, and how 

assessment of their effectiveness is made. 

The second option here would naturally follow the first option, and therefore would not be 

retrospective. The third option could be undertaken immediately. 

Protection of the environment surrounding aerodromes from noise is usually tightly regulated 

by NAAs. One consequence of this is that the allocation of active runways by ATC is often 

made after consideration is given to reducing noise. During winter operations it is crucial that 

aircraft that have been anti-iced are provided with the most expeditious route to the 

departure runway. This can be achieved by utilising de-icing / anti-icing areas close to the 

active runway threshold, or by selecting an appropriate runway closest to the de-icing / antiicing 

area – so as to reduce taxi time (Option REGAD6 below). A conflict of interest can 

arise where access to the preferred runway for compliance with noise limitations involves a 

longer taxi than access to the closest suitable runway (Runway 18R/36L at Amsterdam 

Schipol is one clear example). 

NOISE. NAAs should issue instructions to aerodromes and ANSPs to emphasise that 

during winter operations priority should be given to shorter taxi times (post deicing 

/ anti-icing) rather than noise limitation. 

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4.9 Regulating de-icing / anti-icing through regulation of 

aerodromes 

Some aerodromes are in a privileged position, in that they can choose whether to provide deicing 

/ anti-icing services themselves when it is profitable. Some benefit from being the sole 

provider of these services, whereas others, who are also acting as sole providers, do so at a 

financial loss. The Data Summary and Analysis section of this Report provides more details 

concerning the varying degrees of involvement aerodromes have in de-icing / anti-icing 

provision. Regardless of whether an aerodrome provides these services themselves, or not, 

they do have responsibilities for facilitating the infrastructure and also for the safety of 

activities conducted at the aerodrome. How much responsibility, and in what areas, can be 

debated. Whether de-icing / anti-icing vehicles, fluid storage and equipment are considered 

“infrastructure”; and, whether activities conducted by parties under contract to operators have 

anything to do with the aerodrome management can be, and are being, debated. The lack of 

clarity may be considered by some to be useful in providing some degree of practical 

flexibility, whereas others may consider it to be a source of confusion. 

REGSP3, above, is an Option to make de-icing / anti-icing service provision fully a 

responsibility of the aerodrome. An alternative pathway to raising standards of de-icing / 

anti-icing service provision could be to utilise existing, and proposed, aerodrome regulation 

to encourage closer scrutiny and a greater involvement in de-icing / anti-icing operations by 

the aerodrome. This need not be in conflict with operators’ programmes and contracts, nor 

interfere with any market access that may exist. 

Furthermore, the aerodrome is in a unique position in hosting airport users’ committees and 

boards, where all relevant stakeholder groups are represented. These bodies can generate 

opportunities to establish local consensus on infrastructure, traffic management, procedures 

and to address local hazards. 

An aerodrome’s certification by the appropriate Authority includes the acceptance/approval of 

the airport manual, which shall contain details of the de-icing / anti-icing facilities and 

services (ICAO Annex 14, 1.4.4). Interpretation of, and compliance with, Annex 14 is nonstandard 

within EASA Member States (airsight Study on Annex 14 Implementation). 

Depending on an Authority’s interpretation of Annex 14 in respect of de-icing / anti-icing 

facilities, services and location, determines how the responsibilities of aerodromes are 

currently defined and therefore their compliance with these responsibilities. EASA is currently 

undertaking the task of creating Implementing Rules for aerodromes, and following this 

process the question of varied interpretation and application should be resolved. 

Aerodromes must also comply currently with ICAO SMS Standards, which NAAs are obliged 

to enforce. Options SAF1, SAF2, and SAF3 above, address the need for specific focus onto 

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de-icing / anti-icing. Similarly, the requirement for aerodromes to define lines of safety 

responsibility will help support Option SME5, above. 

Often, the choice of an operator to undergo two-step de-icing / anti-icing is considered as an 

“additional” requirement, especially at aerodromes where one-step is the norm. In such 

cases, the aerodrome may be planning its winter operations around traffic flow times 

associated with one-step de-icing / anti-icing. However, ICAO Doc 9640 is clear in its 

statement that, concerning facilities, aerodromes should plan for the two-step de-icing / antiicing 

procedure for all de-icing / anti-icing operations even though some operators may 

choose the one-step procedure on some occasions. 

Doc 9640 also defines an aerodromes facilities as having the following components: 

a) de-icing / anti-icing pads for the manoeuvring of aeroplanes; 

b) de-icing / anti-icing system comprising one or both of the following: 

1) mobile vehicles, and 

2) fixed equipment; 

c) bypass taxiing capability; 

d) environmental run-off mitigation measures; 

e) permanent or portable night-time lighting system; and 

f) support facilities that may include: 

1) storage tanks and transfer systems for de-icing / anti-icing fluids; and 

2) de-icing crew shelter. 

The inclusion of vehicles supports Option GHDAD2, below. De-icing / anti-icing fluids are not 

specifically mentioned, however, if an aerodrome has some responsibility over the de-icing / 

anti-icing vehicles (directly or indirectly), and it needs to plan for two-step operations, then 

having Type I fluid available must be an inferred requirement. 

Two key elements of an aerodrome’s de-icing / anti-icing facilities are the location and size of 

the de-icing / anti-icing areas (pads, aprons, ramps). Specifically, they should present the 

shortest distance possible to departure runway thresholds to preserve HoTs (Doc 9640 9.5), 

and they should be able to cope with all expected weather conditions, all relevant aircraft 

types, all de-icing / anti-icing application methods, and the capability of the de-icing / antiicing 

vehicles and equipment (Annex 14, 3.15.6). NAAs could require aerodromes to explain 

how they ensure that the de-icing / anti-icing facilities available at their aerodrome meet the 

requirements of their winter traffic plan. In some cases, this may require aerodromes to 

explain how the desired winter traffic plan is not met, due to inadequate de-icing / anti-icing 

facilities and/or services. 

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By agreeing to enforce these Recommendations as Requirements, NAAs will ensure that 

aerodromes invest effort, and possibly finances, into establishing a fully capable, safe and 

effective de-icing / anti-icing system, and thereby enhance the safety of the activities and 

operations occurring at each aerodrome. 

REGAD1. EASA to incorporate within future rules for European aerodromes, 

responsibilities towards de-icing / anti-icing facilities, operations, services etc. 

REGAD2. EASA to require that European aerodromes plan and provide for two-step deicing 

/ anti-icing. 

REGAD3. EASA to require that European aerodromes are responsible for ensuring that 

the de-icing / anti-icing facilities (including vehicles) are appropriate to meet 

the needs of all relevant operators using their aerodrome. 

REGAD4. EASA to require that European aerodromes are responsible for ensuring that 

the de-icing / anti-icing services available are appropriate to meet the needs of 

all relevant operators using their aerodrome. 

REGAD5. EASA to consider the possibility of including de-icing / anti-icing fluid as part of 

an aerodrome’s facilities. 

REGAD6. NAAs to require aerodromes to include in their winter operations plans (within 

the aerodrome manual) a supporting case in favour of each de-icing / antiicing 

area, with specific reference to how these chosen areas support the HOT 

in different weather conditions. 

Some European aerodromes will fall outside of the scope of future EASA rules: this may be 

due to size, capacity and / or facilities. In such cases the relevant NAA will remain as the 

regulator. Where such aerodromes are used by commercial air transport operators, EASA 

considers that it would be favourable to maintain the same standards as met at the larger 

aerodromes. 

REGAD7. NAAs to impose the same standards (for de-icing / anti-icing) on those 

aerodromes that fall outside the scope of future EASA rules, and which are 

used by commercial air transport. 

Directive 96/97/EC on ground-handling is designed to protect open competition in the 

provision of various ground-handling services. De-icing / anti-icing is included in the list of 

ground-handling services, with other services such as baggage, ramp, oil and fuel, and mail 

handling. The aerodrome is permitted to limit the number of suppliers in each of these other 

services, but not de-icing / anti-icing. Establishing a de-icing / anti-icing service requires a 

significant amount of investment, and providing the service requires sufficient space within 

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which to operate safely. Both of these would be reason enough to allow any particular 

aerodrome to limit the number of de-icing / anti-icing service providers. Clause 11 of the 

Directive suggests that this is a possibility, but Article 6 excludes de-icing / anti-icing. Option 

GHDSP1, above, addresses the possibility of aerodromes limiting the number of providers. 

The ultimate extension of this concept is to remove de-icing / anti-icing altogether from the 

constraints of the Directive. This Study has no evidence that aerodromes with only one 

provider of de-icing / anti-icing causes detriment to either safety or cost to the customer. In 

fact, having one supplier may encourage: more long-term investment; a growing level of 

experience; providers solely dedicated to de-icing / anti-icing; an effective relationship 

between provider and aerodrome / aerodrome users; and, therefore higher levels of service. 

In support of Options REGAD3 and REGAD5 above, the Directive allows certain high value 

elements of de-icing / anti-icing equipment and infrastructure to be brought within the 

aerodrome centralised infrastructure (Clause 13 and Article 8). Within the terms of the 

Directive this would then allow States to define technical specifications to which service 

providers would have to comply, or risk losing their license to operate (Clause 23 and Article 

11). Such technical specifications could vary between simple minimum requirements 

concerning equipment standards, through availability of fluids, and up to full-blown regulation 

of procedures and training. The quality, capability and maintenance of de-icing / anti-icing 

vehicles can have a direct affect on the standard of service delivered. Declaring these 

vehicles as part of the aerodrome centralised infrastructure will bring their capability and 

maintenance under the oversight of the NAA. This will not restrict service providers from 

sharing their use, however, any aerodrome effectively “renting” such high value assets will 

ensure strict control over how they are used, and who uses them. 

GHDAD1. Remove de-icing / anti-icing from the list of ground-handling activities within 

the Directive 96/97/EC. 

GHDAD2. Allow, or mandate, that aerodromes specify de-icing / anti-icing vehicles as 

part of the aerodrome’s centralised infrastructure. 

GHDAD3. Member States to agree on a set of minimum technical specifications for the 

proper functioning of de-icing / anti-icing equipment and infrastructure. 

The Directive requires that aerodromes establish and facilitate Airport Users’ Committees 

(AUC). There is no mandate as to the regularity of meeting, method of meeting and 

communication, or the subjects to be discussed. At some aerodromes, the AUC is used, 

prior to each winter season, to discuss aerodrome operations concerning the coordination of 

traffic during de-icing / anti-icing operations. It is rare that subject-matter experts in aircraft 

de-icing / anti-icing procedures (from the operators, providers and aerodrome) meet under 

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the auspices of the AUC to discuss matters specifically related to fluids, procedures, 

vehicles, communication, safety etc. 

GHDAD4. Aerodromes to agree, with other stakeholder subject-matter experts, a format 

and remit for special meetings of the AUC which specifically address de-icing / 

anti-icing operations and service provision. 

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4.10 Availability of de-icing / anti-icing fluid types 

The Study did not reveal any mechanism currently in use by any NAA which can act as an 

example of how to influence the availability of fluids at aerodromes within the Member 

States. However, existing regulations may provide some possibility for Authority influence 

over the types of fluid supplied at aerodromes within their territory. In considering whether a 

need exists for compulsory provision of Type I fluid in all, or just some, aerodromes, regard 

must be given towards the existing risks associated with residues from thickened fluids. That 

is, since the raising of awareness of the issues associated with residues, and the subsequent 

introduction of residue maintenance programmes, has the risk been reduced significantly? 

Furthermore, if Type I fluids were made compulsory, consideration should be given to 

whether operators would choose to use Type I fluids more than they currently do. Failing 

any regulation to demand operators always use Type I fluid for de-icing, there is no 

guarantee that there would be any increased uptake. 

There are several options that can be considered, which may increase the availability, and/or 

the use of, Type I fluids. 

If the conditions required for an individual aircraft to maintain its Certificate of Airworthiness 

included limitations on the use of certain de-icing / anti-icing fluids, then operators would be 

obliged to adhere to these limitations (EU OPS 1.005 (c)). By means of the instructions for 

continuing airworthiness, manufacturers could influence operators’ use of Type I fluid by: 

− insisting that Type I, Type I/water mix, and hot water are the only viable de-icing fluids 

acceptable, or 

− defining a limit to the number of one-step de-icing / anti-icing procedures that can be 

undertaken before critical areas are cleaned. 

For any amendment to the TC, or issue of an STC, evidence would be required as to the 

necessity. Such evidence could be forthcoming from either the manufacturer following 

appropriate testing (for all fluids and combinations of fluids), or from operational data 

indicating loss of airworthiness, due to thickened fluid residues, in certain circumstances. 

EASA has already taken action by requesting specific information from Type Certificate 

Holders [14 April 2009 PBL/ein/C(1.1) 2009(D)61465] concerning any recommended 

procedures and limitations for each aircraft type. Aircraft manufacturers have already issued 

Operational Notices concerning maintenance procedures for preventing and managing fluid 

residues. Any regulation in this respect would need to consider the evidential affects of 

thickened fluid application to each different aircraft type and the associated variation in 

impact. An alternative approach could be that unless an aircraft manufacturer could provide 

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evidence that their required residue management programme was effective, then they should 

require operators to always use Type I in a two-step procedure. 

FLUID1. Aircraft manufacturers instructions for continuing airworthiness to effectively 

“ban” the use of thickened fluid. 

FLUID2. Aircraft manufacturers to provide evidence that their proposed residue 

management procedures are effective; otherwise, to require operators to 

always use a two-step procedure with Type I in the first step. 

If NAAs, or EASA, consider that de-icing with a thickened fluid produces an unwarranted 

increase in risk, or that current mitigation measures are unreliable, then operators could be 

mandated to always use a two-step process, and not allow thickened fluids to be used in the 

de-icing phase. In effect, the regulator could re-define de-icing fluids as being only Type I, 

Type I/water mix, or hot water. Again, any evidence that one-step de-icing / anti-icing does 

not increase risks due to residues, provided a suitable inspection and cleaning programme is 

followed, could be used to counter this concept. 

FLUID3. EASA redefines de-icing fluid as being only Type I, Type I/water mix, and hot 

water. 

It may be possible to influence the availability of Type I fluid through NAA regulation of 

aerodromes; several possibilities exist. 

If a State determines that de-icing / anti-icing fluid is part of the aerodrome centralised 

infrastructure/facilities (Options GHDAD2 and REGAD5 above), then it may be possible to 

require that all fluid types are available to fulfil the infrastructure/facilities requirements; this 

responsibility to provide all fluid types may be passed to service providers as necessary and 

supported by Directive 96/97/EC on ground-handling. ICAO Doc 9640 recommends that all 

de-icing / anti-icing services and fluids be planned for by the aerodrome, regardless of 

whether they are used or not. This recommendation could be enforced as a requirement, 

however, a safety case would need to support the enforcement. 

FLUID4. NAAs mandate that all appropriate aerodromes should always offer Type I 

fluids and a two-step de-icing / anti-icing procedure. 

An alternative to the above strategy would be to mandate the availability of Type I fluid and 

the two-step procedure whenever any “user operator” makes a formal request, based on 

their own safety case, or desired procedures. Of course, this option would also necessarily 

have to include Type III. 

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FLUID5. EASA mandates that an aerodrome shall provide Type I fluid and a two-step 

de-icing / anti-icing procedure whenever a user operator makes the 

appropriate request. 

As part of a State Safety Programme (ICAO SMS Standards), the relevant Authority may 

consider that to reduce the risks associated with fluid residues a certain percentage of traffic 

should be exposed to Type I fluid in a two-step procedure. Determining the concentration of 

aerodrome traffic involving “affected” aircraft, may assist in such a task, and lead to the 

mandate of Type I fluid and two-step procedure at certain aerodromes. 

FLUID6. NAAs should include within their State Safety Programmes a plan to reduce 

the risks associated with thickened fluid residues, by assuring appropriate 

availability of Type I fluid throughout a percentage of those aerodromes within 

their jurisdiction. The selection of participating aerodromes shall be justified 

by an analysis of traffic profiles of affected aircraft. 

If either a voluntary system or Letter of Acceptance mechanism were established to raise 

standards of de-icing / anti-icing (see Options REGLOA and VOL), then the audit checklist 

used to issue the LoA or Industry Accreditation could include a requirement for service 

providers to provide Type I fluids and two-step procedure to meet operators’ requirements. 

For this to be acceptable, all participants in the pooled auditing programme would have to be 

in agreement with this addition to the audit checklist, and be certain that this would benefit 

operators. 

FLUID7. LoA or Industry Accreditation requirements include the provision of Type I 

fluids and two-step procedure. 

Unlike some of the options included in this Report which are aimed at improving de-icing / 

anti-icing standards, these options aimed at improving the availability of fluids at aerodromes 

are likely to require a greater consensus before introducing and possibly some appropriate 

transition measures. Therefore the opening of debate around these options, or those options 

deemed most practical and possible by EASA, could be beneficial in attaining a high 

consensus for any changes. Of course any debate would need to give due consideration to 

whether any regulatory influence over availability of fluids is necessary. 

WRKSHP. EASA facilitate a fluids availability workshop to discuss these options (FLUID 

1 to 7) and any others, with the aim of determining a consensus opinion on a 

way forward. 

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4.11 Additional options 

Knowledge of this Study is widespread and much interest in the final result has been 

expressed from all stakeholder groups. The collected and analysed data is of interest to the 

Industry by itself, and the options presented, together with the Pre-RIA will facilitate the 

continuation of debate. Such debate may prove fruitful by itself, but will also prepare the 

ground for any NPA, or programme, that the Agency wishes publish in the future; thereby 

raising the quality of comments in response to any NPA. 

PUBREP. EASA publishes the Final Report to this Study and distributes it freely to 

interested parties. 

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5 Information paper and briefing 6 December 2010 

Presentation of options to stakeholder representatives 

The purpose of the Stakeholder Representative’s Briefing (SRB) is for the Study Team to 

present and obtain feedback on the options available. By avoiding any recommendations it 

will be more likely that feedback from stakeholders is objective and informative – providing 

useful material for the pre-RIA. However, as can be seen in this document a lot of options 

have been developed. It is not the intention of the Study Team to present each and every 

option at the Briefing, nor in the associated Information Paper. Therefore some filtering will 

occur, and in this process, any excluded options may indicate a preference for those 

remaining. This is not necessarily the case. The Study Team will select the higher level 

options, and omit the specific. 

Clarification on these options to be included in the SRB will be made before the planned 

teleconference on 12 Nov 2010. EASA may then have the opportunity to make an input to 

the SRB Agenda. 

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APPENDIX 1: List of Options 

Ref Options for Change Notes 

REC1 

SAF1 

SAF1.a EASA alone. 

It is recommended that all those involved in de-icing / anti-icing 

operations on the ground, and all those who have an interest in 

ensuring the standards of these operations are the highest 

possible, do whatever they can to make the task of the post 

treatment inspector as easy as possible. 

Conduct an Industry-wide collaborative safety initiative: 

including data collection and analysis; awareness activities; 

and development of recommendations and, where possible, 

tools. 

SAF1.b EASA in partnership with Industry; perhaps through the ESSI. 

SAF1.c EASA in conjunction with Member State NAAs. 

SAF1.d 

SAF2 

SAF3 

SAF3.a 

Industry alone; perhaps through FSF, IATA, the airline 

Associations etc. 

Reinterpret existing regulations for operators and aerodromes 

to motivate greater collection and analysis of relevant safety 

data. 

Amend proposed EASA regulations for authorities and 

operators to ensure effective collection and analysis of relevant 

safety data. 

AR.GEN.30.(a) Exchange of Information & AR.GEN.40.(a) 

Reporting – interpretation of these requirements may include 

guidance for Authorities to include the exchange of safety data 

including “unsafe acts” arising through operators’ contracted 

out service providers, and that this data is not restricted to 

incidents and accidents. 

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SAF3.b 

SAF3.c 

SAF3.d 

SAF3.e 

AMC 2 AR.GEN.300.2 Continuing Oversight Ops – this AMC 

can be amended to include oversight and monitoring (as 

required) of the mechanism through which operators ensure 

service providers maintain an appropriate safety culture 

(professional attitude) through collection of safety data – 

specifically self-reporting of “unsafe acts”. This may be 

achieved through the inspection of those elements of a basic 

contract with service providers (excluding commercial clauses) 

that are relevant to safety. 

AMC 2 to OR.GEN.200(a)(2) Management System – can be 

expanded to include the need for operators to include service 

providers within their SMS as a source of safety data, such that 

hazards encountered by service providers can be identified and 

the associated risks to operations assessed by the operator. A 

programme for achieving this may be required. 

AMC 2 to OR.GEN.200(a)(4) Management System, Training 

and Communication on Safety – this AMC might be amended 

to include the need for operators to explain safety matters to 

service providers, and give support where necessary, in 

particular why certain safety data should be collected and 

analysed. 

AMC to OR.GEN.200(a)(5) Management System, Occurrence 

Reporting – this AMC can be expanded to include the objective 

of collecting and analysing valuable data such as that obtained 

through the self-reporting of unsafe acts, thereby providing an 

operator with an insight into potential accident pre-cursors and 

areas of high risk. It may be made clear that this data should 

be sought not only from the operator’s own personnel and 

employees, but also from those personnel working for service 

providers conducting contracted-out safety critical functions. 

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SAF3.f 

SAF4 

SAF4.a 

SAF4.b 

SAF4.c 

SAF4.d 

SAF4.e 

AMC to OR.GEN.205 Contracting and purchasing – 

clarification can be provided to this AMC such that SMS 

activities, including reporting of “unsafe acts”, are included in 

the written agreement between operator and service provider, 

as well as details of the safety services to be provided. The 

written agreement referred to could be subject to oversight and 

monitoring as required under AMC 2 AR.GEN.300.2, 

mentioned above in Option SAF3.b. 

To conduct an Industry-wide review of, and lobby for 

amendment to, Directive 2003/42/EC on Occurrence 

Reporting; in order to align the Directive with ICAO SMS 

requirements. Thereby encouraging States to meet the needs 

of the Directive and encouraging a harmonised interpretation. 

NAAs to ensure that the intent of the Directive is enforced: the 

need for all personnel to report occurrences (Clause 7); and 

the need to share this information (Clause 8). 

Lobby to amend, or expand, the definition of “occurrence” to 

include specifically: human, procedural and system considered 

by the reporter to increase risk. 

Lobby to expand the Scope of the Directive (Article 3), to 

include specifically de-icing / anti-icing activities, by including 

examples in the Appendix to Annex I. 

NAAs to take up their responsibilities to ensure de-icing / antiicing 

operatives comply with mandatory occurrence reporting 

(Article 4, 1.g) and they shall (rather than may) encourage 

voluntary reporting (Article 9). 

NAAs to interpret the Directive from the point of view of deicing 

/ anti-icing operations and issue relevant awareness and 

guidance material. 

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SME1 

SME2 

SME3 

SME4 

SME5 

EASA to appoint its own subject-matter expert for internal and 

external communication and coordination of de-icing / anti-icing 

issues. 

EASA to establish, maintain and publish a record of nominated 

de-icing / anti-icing subject-matter experts. 

NAAs to appoint their own subject-matter experts for internal 

and external communication and coordination of de-icing / antiicing 

issues. 

Operators to appoint their own subject-matter experts for 

internal and external communication and coordination of deicing 

/ anti-icing issues. 

Aerodromes to appoint their own subject-matter experts for 

internal and external communication and coordination of deicing 

/ anti-icing issues. 

ZERO Do nothing; maintain the status quo. 

REGSP 

REGSP1 

To implement direct regulation of de-icing / anti-icing service 

providers by EASA or NAAs. 

To undertake regulatory reform, making some (or all) aspects 

of de-icing / anti-icing the responsibility of service providers. 

REGSP2 To make de-icing / anti-icing fully a maintenance task. 

REGSP3 

GHDSP 

GHDSP1 

To make de-icing / anti-icing service provision fully a 

responsibility of the aerodrome. 

To regulate certain aspects of de-icing / anti-icing service 

provision through Directive 96/97/EC on Ground-Handling. 

Permit States to limit the number of de-icing / anti-icing service 

providers at aerodromes. 

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GHDSP2 

TRGSP 

REGAO 

REGAO1 

REGAO2 

REGAO2.a 

REGAO2.b 

REGAO2.c 

REGAO2.d 

Require States to approve organisations for the supply of deicing 

/ anti-icing services against a set of minimum 

administrative standards and technical specifications. 

As part of the State approval/selection of service providers 

through Directive 96/97/EC on ground-handling, require deicing 

/ anti-icing operatives to possess a valid vocational 

qualification in de-icing / anti-icing. 

To improve the existing regulations for operators; improve the 

interpretation of those regulations; and improve the oversight of 

operators in this regard. 

Require the approval of operators’ de-icing / anti-icing 

programmes against minimum requirements defined within the 

regulations. 

Develop an effective AMC in the form of an example of, or 

framework for, an operator’s de-icing / anti-icing programme. 

providing operators with a clear framework for an acceptable 

de-icing / anti-icing policy, procedures, training programme, 

providing operators with clear guidelines for establishing and 

maintaining 

procedures, 

effective communication and coordination 

providing operators with template communication messages 

and meanings connected with all inspections, checks and 

operations; in particular review of the anti-icing code, and 

clarification of the “all clear” signal/message (refer to COMM), 

providing operators with a structured framework for the relevant 

section of the OM (A8), 

REGAO2.e clarifying responsibilities for key decision-makers, 

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REGAO2.f 

REGAO2.g 

REGAO3 

REGAO4 

REGAO5 

REGAO6 

REGAO7 

REGAO8 

REGAO9 

requiring and defining the minimum elements required for an 

effective contract between operator and service provider, and 

requiring operators to seek approval for any deviations (in 

certain areas) from the published AMC. 

Require operators to appoint a subject-matter expert as per 

Option SME4. 

Operators to define specific training requirements and 

knowledge base for operations and dispatch staff concerning 

de-icing / anti-icing. 

States to require that operators develop a targeted programme 

within their SMS, specifically aimed at de-icing / anti-icing. 

Operators to be required to provide flight crew with a check-list 

system that specifically addresses aspects of de-icing / antiicing. 

Require the inclusion of an operator’s de-icing / anti-icing 

programme and procedures within the operator’s conversion 

course ground training. 

Require the inclusion of applicable elements of the operator’s 

de-icing / anti-icing programme, and any new knowledge, 

within the operator’s differences and familiarisation training 

requirements. 

Review and expand the required contents of the operator’s deicing 

/ anti-icing policy and programme that shall form part of 

the Operations Manual. 

COMM Standardise communication elements and their meaning. 

COMM1 

Clarify that the anti-icing Code only provides those information 

elements within it and does not infer anything else. 

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COMM2 

COMM3 

COMM4 

COMM5 

COMM6 

COMM7 

TECIN1 

TECIN2 

TECIN3 

REGLOA 

VOL 

Require a separate “aircraft clean/aircraft not clean” message 

following the post treatment check. 

Require a separate “equipment and personnel clear of aircraft” 

message. 

Require continuous verbal contact between de-icing / anti-icing 

crew chief and flight deck. 

Require critical messages (aircraft clean) to be delivered by 

qualified person who is present at the operation. 

Require this qualified person to provide his/her name/number 

with either the Code, or the post treatment check results. 

Require operators to include these elements in their contracts 

with service providers. 

EASA develops a set of Technical Instructions against which 

operators de-icing / anti-icing programmes shall be approved. 

EASA identifies an external source document and adopts it as 

a set of Technical Instructions which operators are required to 

follow, and which operators are required to impose on service 

providers. 

EASA develops an AMC to OPS.GEN.100 which can be used 

as a template for operators’ de-icing / anti-icing policies, 

programmes and OM entries (refer to REGAO2). 

EASA to investigate the possibility, and the potential for an LoA 

system of quality assurance of de-icing / anti-icing service 

providers. 

Industry commence a system whereby service providers can 

opt to be accredited through a recognised audit scheme based 

on acceptable standards. 

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LIASFAA 

EASAAR1 



RESDATA1 

RESDATA2 

RESDATA3 

NOISE 

EASA should take this opportunity to liaise closely with the 

FAA, and TC, with the aim of harmonising future de-icing / antiicing 

regulations and thereby avoiding differing requirements, 

giving rise to ambiguity and confusion. 

EASA to require all NAAs to establish and maintain a 

monitoring programme of de-icing / anti-icing service providers 

exercising activities on their territory. 

EASA to develop guidance for NAAs in how to implement a 

monitoring programme of de-icing / anti-icing service providers 

in compliance with AR.GEN.305. 

EASA to amend AMC2 AR.GEN.300 Continuing Oversight Ops 

– to include an operator’s arrangements for ground-handling. 

EASA and NAAs to agree a dataset and method of collection, 

distribution and analysis for ascertaining the existing levels of 

risk from residue formation. 

NAAs to require operators, and where applicable maintenance 

organisations, to record and submit data, relevant to individual 

aircraft, concerning applications of de-icing / anti-icing fluid, and 

the effect of inspections for, and removal of, residues. 

NAAs to request brief descriptions of operators’ residue 

management programmes, including inspection and cleaning 

methods, and how assessment of their effectiveness is made. 

NAAs should issue instructions to aerodromes and ANSPs to 

emphasise that during winter operations priority should be 

given to shorter taxi times (post de-icing / anti-icing) rather than 

noise limitation. 

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REGAD1 

REGAD2 

REGAD3 

REGAD4 

REGAD5 

REGAD6 

REGAD7 

GHDAD1 

GHDAD2 

EASA to incorporate within future rules for European 

aerodromes, responsibilities towards de-icing / anti-icing 

facilities, operations, services etc. 

EASA to require that European aerodromes plan and provide 

for two-step de-icing / anti-icing. 

EASA to require that European aerodromes are responsible for 

ensuring that the de-icing / anti-icing facilities (including 

vehicles) are appropriate to meet the needs of all relevant 

operators using their aerodrome. 

EASA to require that European aerodromes are responsible for 

ensuring that the de-icing / anti-icing services available are 

appropriate to meet the needs of all relevant operators using 

their aerodrome. 

EASA to consider the possibility of including de-icing / anti-icing 

fluid as part of an aerodrome’s facilities. 

NAAs to require aerodromes to include in their winter 

operations plans (within the aerodrome manual) a supporting 

case in favour of each de-icing / anti-icing area, with specific 

reference to how these chosen areas support the HOT in 

different weather conditions. 

NAAs to impose the same standards (for de-icing / anti-icing) 

on those aerodromes that fall outside the scope of future EASA 

rules, and which are used by commercial air transport. 

Remove de-icing / anti-icing from the list of ground-handling 

activities within the Directive 96/97/EC. 

Allow, or mandate, that aerodromes specify de-icing / anti-icing 

vehicles as part of the aerodrome’s centralised infrastructure. 

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GHDAD3 

GHDAD4 

FLUID1 

FLUID2 

FLUID3 

FLUID4 

FLUID5 

FLUID6 

FLUID7 

Member States to agree on a set of minimum technical 

specifications for the proper functioning of de-icing / anti-icing 

equipment and infrastructure. 

Aerodromes to agree, with other stakeholder subject-matter 

experts, a format and remit for special meetings of the AUC 

which specifically address de-icing / anti-icing operations and 

service provision. 

Aircraft manufacturers instructions for continuing airworthiness 

to effectively “ban” the use of thickened fluid. 

Aircraft manufacturers to provide evidence that their proposed 

residue management procedures are effective; otherwise, to 

require operators to always use a two-step procedure with 

Type I in the first step. 

EASA redefines de-icing fluid as being only Type I, Type 

I/water mix, and hot water. 

NAAs mandate that all appropriate aerodromes should always 

offer Type I fluids and a two-step de-icing / anti-icing 

procedure. 

EASA mandates that an aerodrome shall provide Type I fluid 

and a two-step de-icing / anti-icing procedure whenever a user 

operator makes the appropriate request. 

NAAs should include within their State Safety Programmes a 

plan to reduce the risks associated with thickened fluid 

residues, by assuring appropriate availability of Type I fluid 

throughout a percentage of those aerodromes within their 

jurisdiction. The selection of participating aerodromes shall be 

justified by an analysis of traffic profiles of affected aircraft. 

LoA or Industry Accreditation requirements include the 

provision of Type I fluids and two-step procedure. 

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WRKSHP 

PUBREP 

EASA facilitate a fluids availability workshop to discuss these 

options (FLUID 1 to 7) and any others, with the aim of 

determining a consensus opinion on a way forward. 

EASA publishes the Final Report to this Study and distributes it 

freely to interested parties. 

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OPTIONS FOR CHANGE – ATTACHMENT A 

Summary and Analysis of Available Safety Data 

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Germany 

Phone: +49 30 45803177 

Fax: +49 30 45803188 

www.airsight.de

INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT A 




1.1 Caveat.......................................................................................................................1 

2 Study Team survey questionnaires ..............................................................................2 

2.1 National Authorities ................................................................................................2 

2.2 Operators .................................................................................................................2 

2.3 Manufacturers..........................................................................................................2 

3 Other data sources.........................................................................................................4 

3.1 ADREPS....................................................................................................................4 

3.2 ECCAIRS ..................................................................................................................4 

3.3 NASA Aviation Safety Reporting System (ASRS) – Summary of the Study 1968 

– 1993........................................................................................................................4 

3.4 NASA ASRS – Summary of Reports 1999 – 2009 .................................................7 

3.5 Flight Safety Foundation (FSF) Air Safety Network – Summary of Accident 

Report 1980 – 2009 ..................................................................................................9 

3.6 Confidential Human Factors Incident Reporting Programme (UK) ....................9 

4 Conclusions..................................................................................................................11 

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To assist the Study Team in the selection of options to improve the standards of de-icing / 

anti-icing, it was deemed necessary to collate available safety data to determine whether any 

clear patterns emerge which highlight contributory and causal factors. 

This document includes summaries of data collected. Note that the Terms of Reference of 

the Study did not require, nor resource, a Safety Study. The Study Team do not claim that 

this document constitutes a comprehensive, or scientifically-based Safety Study; however, 

from the data collected, two clear messages can be identified: 

− There is a lack of coordinated and detailed safety data concerning de-icing / anti-icing 

in respect of human factors. That is, compared to some other safety critical activities 

centred on human skills, knowledge and attitude, and relying on procedures and 

equipment, such as maintenance personnel and flight-crew. 

− The contributory factors to these accidents and incidents deduced from each dataset 

are very similar, centring on: 

o ineffective communication 

o inadequate coordination 

o inadequate procedures 

o wrongly implemented procedures 

o lack of knowledge 

o lack of appropriate training 

Specifically, these factors often applied to inspections as well as operations. 

1.1 Caveat 

The collected data has been gathered, and therefore, presented in different formats and will 

have different degrees of validity for which the Study Team does not have the resources to 

standardise and create comparative descriptors. Also, many of the events occurred outside 

EASA Member States and some involved aircraft not usually associated with commercial air 

transport. For the events involving non-commercial operations, and those events occurring 

more than 20 years ago, the regulatory and safety awareness environments would be 

different to those existing today. However, it is data which ought not to be ignored and from 

which National Authorities, operators and service providers may be able to draw some 

insight to help reduce risk in their own areas of responsibility and operations. 

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2 Study Team survey questionnaires 

2.1 National Authorities 

Only 7 of the 12 NAAs questionnaire respondents answered the questions 1,2 on the number 

of occurrences related to improper de-icing / anti-icing, or anti-icing fluids residues between 

the Winter seasons 2005/2006 and 2009/2010. 

− 4 of 7 NAAs mentioned they experienced occurrences related to improper de-icing / 

anti-icing within the analysed period (Austria: 3, Switzerland: 3, Spain: 3, Iceland: 1). 

− 3 of 7 NAAs mentioned they experienced occurrences related to anti-icing fluids 

residues within the analysed period (Hungary: 1, Switzerland: 9, Iceland: 1). 

2.2 Operators 

11 out of the 26 operators who responded to the questionnaires mentioned they experienced 

incidents related to improper de-icing / anti-icing 3 . 

The same number (11 operators) stated being subject to events related to anti-icing fluids 

residues. However, it was not possible to differentiate between in-flight incidents and findings 

of residues during maintenance and cleaning. 

2.3 Manufacturers 

Responses from the manufacturers are encouraging with regard to reducing numbers of 

occurrences caused by frozen re-hydrated residues since 2005. 

− Airbus reported no in-flight incidents and only two events of stiff rudders found during 

ground checks. 

− ATR only reported one incident, and that was in 2006. 

− BAE Systems statistics clearly show a dramatic reduction in annual occurrences, with 

87 in year 2004/05, and only 7 in 2008/09. Whereas before 2005, 25% of reports 

1 NAA Questionnaire – Question 1.4: Indicate the number of reported occurrences related to 

inappropriate standards of de-/anti-icing: 

2 NAA Questionnaire – Question 1.5: Indicate the number of reported occurrences related to anti-icing 

fluids residues: 

3 

Aircraft Operator Questionnaire – Question 1.6: How many events, occurrences, or incidents due to 

residues and/or incorrect de/anti-icing has your airline experienced since and including the 2005/06 

winter season? 

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concerned “ice in gaps” and since 2005 there have been none. This may, however, 

be due to a change in diagnosis. 

− Boeing reported that, prior to 2005, they had more occurrences per year of gel residue 

build-up than they have had in total since 2005. They attribute the new Potassium and 

Sodium-based Runway De-icing Fluids as contributing to the residues. 

− Bombardier stated that the “classic” residue incidents have reduced with time, and 

only a handful have occurred in the past 5 years. 

All the manufacturers attribute the fall in incidents and occurrences to: 

− raised awareness, 

− recommendations to use Type I and the two-step procedure (NB: there’s no evidence 

that operators are actually complying with these recommendations), and 

− implementation of inspection programmes and regular cleaning. 

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3 Other data sources 

3.1 ADREPS 

The Study Team acquired 1014 occurrence reports from the ICAO ADREP database. 

There has not been enough time to filter these (many will be associated with in-flight icing 

conditions), nor to summarise and classify them. No doubt there will be some interesting 

information contained within; however, it is the opinion of the Study Team that any analysis 

will only confirm the conclusions reached by the other summaries contained in this paper. 

This dataset can be forwarded to EASA for further examination if required. 

3.2 ECCAIRS 

A search of ECCAIRS, made by EASA Safety Analysis Department, was requested for all 

de-icing / anti-icing related occurrences since 2000. 

There were 5 accidents recorded, and 3 occurrences of engine failure not resulting in an 

accident. The results comprise 27 occurrence reports, 8 of which are related to known 

occurrences of elevator movement restrictions due to either ice or frozen residues. 7 

occurrences were caused by inadequate de-icing / anti-icing, and 4 due to a failure to de-ice. 

Due to the lack of detail provided in the report summaries, conclusions cannot be made as to 

the primary reasons why de-icing / anti-icing was inadequate, nor why pilots failed to request 


3.3 NASA Aviation Safety Reporting System (ASRS) – Summary of 

the Study 1968 – 1993 4 

This study analysed 52 reports which were submitted to ASRS between January 1986 – 

January 1993. 

81% involved air carrier jet aircraft and 19% involved air carrier turboprops. The main events 

reported were: 

− takeoff with contaminated wing/tail surfaces in 52% of reports, 

− engine damage and/or failure due to ice ingestion, 

− aircraft control difficulties, and 

− rejected takeoffs. 

4 

Report Summary published in NASA ASRS Direct Line – Issue No5, March 1993, written by Robert 

L. Sumwalt, and available from: http://asrs.arc.nasa.gov/publications/directline/dl5_ice.htm ; last 

accessed 21.10.2010. 

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The majority of the problems found in this study may be classified into three major 

categories: 

− Problems associated with detection of and inspection for ice during pre-flight 

inspections; 

− Problems with ice removal, or the confirmation of successful ice removal after de-icing; 

and 

− Difficulties in confirming that aircraft critical surfaces were free from frozen 

contamination before takeoff. 

The procedural problems observed in 25% of reports included: 

− failure of de-icing crews to follow prescribed procedures, 

− inadequately designed procedures for de-icing and/or post de-icing checks, 

− poor communication between de-icing crews and flight crews, 

− improperly prepared de-icing fluids, 

− lack of reliable equipment, and 

− inadequate staffing levels to conduct de-icing. 

Inspections: 25% of the problems noted were the result of difficulties in detecting ice on 

aircraft wings during pre-flight. Half of these cited the elevated height of wing and tail 

surfaces as a major factor in ice inspection/detection difficulties. 11% cited ice detection 

problems such as crews being unable to see ice due to poor lighting conditions, the 

transparent nature of clear ice, or ice that was otherwise hidden from view. Not being able to 

reach ice during a tactile wing inspection was also cited. Schedule (time) pressures were 

also reported as contributing to inadequate inspections. 

Ice Removal: 50% of reports mentioned problems with ice removal and/or verification of ice 

removal. 25% cited problems of ice remaining on aircraft critical surfaces after de-icing was 

completed. In 12 cases where de-icing was ineffective at removing all the contamination the 

flight crew relied on the de-icing crew's statement or hand signals that de-icing had been 

completed, and therefore, failed to verify ice removal for themselves. 

Before Takeoff: A quarter of the reports in this study referenced problems with the captain 

making the determination of a “clean wing”. In the absence of an external pre-take-off 

contamination check by ground crew, pilots found checking the wings from the cockpit and 

cabin impossible to accomplish, in many cases due to anti-icing fluid obscuring the view 

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through windows. Also such a check impacts on flight safety by having a flight-crew member 

absent from the flight-deck at a critical time immediately prior to line-up and take-off. 

Knowledge: Inadequate pilot knowledge also played a significant role in many reports, for 

example: 

− Some pilots were using the “clean-wings” of other aircraft as confirmation of their own 

clean surfaces 

− in 12 reports, pilots viewed the snow/ice on their aircraft surfaces as inconsequential, 

or that it will blow off during taxi or takeoff. 

CRM: This study also highlighted that Crew Resource Management (CRM) can have a 

valuable application for ground icing situations. In ASRS reports where ground icing 

problems were identified after the aircraft had left the ramp, it was usually the cabin crew 

who notified the flight crew of the problem. 

Recommendations and Possible Solutions: Management must resolve to help flight crews 

and de-icing crews by providing them with suitable tools for them to perform their functions 

properly. These tools are in the form of hardware, such as equipment and supplies, and also 

such things as well thought-out policies and procedures. Also, a healthy, well-advertised, and 

consistently practiced corporate philosophy of total commitment to safety is absolutely and 

positively essential. 

A sound corporate safety philosophy, reinforced by clearly written policies, procedures, and 

management attitudes, can help relieve a crewmember's self-imposed (or management 

imposed) schedule pressure. It is human nature for many people to hurry their tasks in order 

to "get the job done," so it is imperative that management establish a corporate culture that 

encourages crews to set safety as their top priority. 

An additional post-de-icing/anti-icing check can be accomplished by someone other than the 

de-icing crew. This quality control measure is similar to maintenance practices, where one 

mechanic performs the work, but final inspection of that work is accomplished by another 

person. 

To increase the likelihood that problems are caught before takeoff, consideration could be 

given to training cabin crewmembers to recognize wing ice formation. Furthermore, all 

crewmembers could be taught and encouraged to clearly voice their concerns. (NB: this 

recommendation has since been implemented through EU OPS). 

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3.4 NASA ASRS – Summary of Reports 1999 – 2009 

The Study Team conducted its own search of the NASA ASRS database using the following 

criteria: 

− between February 1999 – October 2009 

− Keywords: [Ice, icing, snow, freezing, deicing, de-icing, antiicing, anti-icing, parked, 

taxi, take-off]. 

418 reports were accessed. These were manually filtered to select the 103 events directly 

connected to the de-icing / anti-icing of aircraft on the ground for commercial air transport 

and/or involving aircraft typically used for commercial air transport within Europe. 

The occurrences recorded include: 

− engine stalls due to ice ingestion, and/or fan-blade and inlet contamination 

− fan-blade damage 

− inappropriate flying control responses during take-off run, and after take-off 

− frozen deposits in control surface gaps 

− decisions not to de-ice despite contamination visibly present 

− ice and snow remaining on aircraft surfaces following the post-treatment “all clear” 

communication 

− ice and snow remaining on aircraft surfaces following pre-take-off contamination 

checks from the flight deck 

The NASA ASRS own analysis allocated the primary causes of the 103 reports as follows: 

− Company (Operator) Policy – 38 

− Human Factors – 33 

− Aircraft – 10 

− Ambiguous – 10 

− Weather – 8 

− Airport – 3 

− ATC – 1 

There is a variety of contributing factors; however, Company Policy and Human Factors arise 

in 50% of the reports. 

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From the summary accounts recorded in each report, the Study Team have made the 

following deductions: 

− On 27 occasions an aircraft was dispatched by the de-icing / anti-icing crew with 

contamination still on the aircraft surfaces, 

− On 19 occasions a flight was conducted with contamination still on, or in, the aircraft, 

The following specific elements are highlighted as problem areas in these reports, as follows: 

− Operator’s Procedures – 49 

− Service Provider’s Procedures – 38 

− Training (including lack of knowledge and skills) –35 

− Communications – 30 

− Coordination – 28 

− Inspections – 25 

− CRM – 16 

− Aircraft Systems – 11 

− Anti-icing Code – 9 

− Ground Equipment (GE) – 8 

− Collisions (aircraft to GE = 4; GE to aircraft = 4) – 8 

− Fluids – 2 

− Weather (including Observations) – 2 

− Violation – 1 

Problems with procedures include: 

− poor procedures, 

− non-compliance, and 

− lack of knowledge. 

Clearly, these have an impact on the number of reports involving communication, 

coordination and inspection errors. Thus, it can be inferred that these events may be 

occurring due to inadequate training. 

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3.5 Flight Safety Foundation (FSF) Air Safety Network – Summary 

of Accident Report 1980 – 2009 

A search was made of this publicly available database for accidents connected with de-icing / 

anti-icing of aircraft on the ground between 1980 and 2009. 

It must be noted that during this time, although awareness of the dangers to flight with 

contaminated aircraft surfaces had increased, the spread of accidents included in the results 

was unchanged: 

− 1980 – 89: 13 events 

− 1990 – 99: 13 events 

− 2000 – 09: 12 events 

Also note that many of the accident aircraft were types not necessarily associated with 

commercial air transport in Europe today; however, the results do show that if procedures 

are inadequate, or not followed, and aircraft depart with contaminated surfaces, then the risk 

of an accident is extremely high. 

In the search of the FSF database, 38 accident reports were identified. Of these, the 

probable cause quoted was the failure to de-ice in 28 cases (74%), although failure to de-ice 

was evident in 36 cases (95%). 

Contributing factors are quoted below: 

− 10 (26%) failure to inspect, or inadequate inspection, 

− 9 (24%) inappropriate procedures and/or supporting regulations, 

− 9 (24%) lack of awareness by pilots, and 

− 8 (21%) failure to de-ice (only contributing because other factors were involved such 

as overweight take-off). 

3.6 Confidential Human Factors Incident Reporting Programme 

(UK) 

A search of the CHIRP database was requested for de-icing / anti-icing related events. 

10 reports were recovered, spanning January 2004 to October 2010. 

Of these, 5 were reported by flight-crew and 5 by cabin-crew. 

This is a surprisingly low number of reports, bearing in mind that CHIRP is a confidential 

repository. One explanation for this might be that there is growing confidence in the 

effectiveness of in-house company confidential reporting systems, which are very effective 

and trusted these days, and therefore CHIRP is probably used less often. Nothing 

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conclusive can be deduced from these search results; however, they do highlight the 

following problems: 

− overriding environmental noise protection measures by airports, resulting in long taxi 

times to distant runways, when closer runways are physically available, thereby 

increasing the likelihood of HoTs being breached. 

− aircraft taxiing for take-off with contaminated wings, before returning for de-icing 

− aircraft departing with frost and ice on the wing without de-icing 

− pilots over-ruling cabin crew observations of contamination 




4 Conclusions 

Most of the accidents and serious incidents summarised above are what may be termed the 

“top of the triangle”. Referring to the Heinrich Triangle (see Options for Change) we can ask 

ourselves – what about the 600 low-level events for every accident? We just do not know 

what the situation is concerning these regular slips, errors, oversights, problems, hazards etc 

that must be visible to the de-icing / anti-icing operatives. 

With the advent of ICAO SMS SARPs there can be no denying the facts that are available. It 

is now the responsibility of everyone involved, through SMS regulations, best-practice safety 

management, and within a positive safety culture, to collect this data, analyse it and share 

the results. 

This short Summary and Analysis of available safety data provides some guidance as to 

where effort and safety resources should be directed. Notably, this includes improvements 

to: 

− communication, 

− coordination, 

− inspections/checks 

− procedures, 

− adherence to procedures, 

− knowledge, and 

− training. 

These issues may be addressed via: 

− the creation of new direct and indirect regulations, 

− the provision of clear concise and unique regulatory interpretive and guidance 

material, or 

− an Industry-wide awareness programme and associated voluntary accreditation 

scheme for operations and training. 

The available options are discussed and presented in full detail in Options for Change. 






OPTIONS FOR CHANGE – ATTACHMENT B 

References from Regulations 

and Other Documents 

airsight GmbH 



13355 Berlin 

Germany 

Phone: +49 30 45803177 

Fax: +49 30 45803188 

www.airsight.

INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B 


Introduction 

This Attachment contains extracts from relevant Regulations, Directives, Standards and 

Guidelines, which have been used as references within the Interim Report - Options for 

Change. 

Each referenced regulation or document is presented in a standard format, with each excerpt 

followed by notes and comments in the following order: 

- EXCERPT QUOTE FROM DOCUMENT 

- NOTES AND EXPLANATION OF RELEVANCE 

- POTENTIAL OPTIONS FOR CHANGE 

- BRIEF NOTES ON POTENTIAL IMPACTS 

The “options” introduced and discussed in the sections below are not recommendations for 

action; and not all of them have been included in the Options for Change section of this 

Report. 

The “impact” discussions are neither complete nor comprehensive; they are included as a 

beginning for further discussion, and to assist selection of the most practical options for 

consideration in the main Report. Full impact assessments will be conducted for any options 

that are recommended to EASA for consideration within the Final Report. Decisions on 

which options are viable and acceptable will be made after the Stakeholders’ 

Representatives’ Briefing at EASA on 6 December 2010. Some options have been omitted 

from this paper already in order to maintain discussions within what is reasonable. 

A full list of reference documents relevant to de-icing / anti-icing is included at Appendix 1 to 

this document. Immediately below, is a list of those documents used as references in the 

main Report – Options for Change; and shown in the order they are presented. In particular, 

where references are made to “proposed” EASA rules, such as Authority Requirements, 

Operator’s Requirements and Implementing Rules for Operations, the versions used in this 

Report (and shown in this Attachment) are taken from EASA NPAs 2008-22 and 2009-02. 

Whilst some of the associated Comment-Response Documents have been recently 

published, the versions used here remain the originals from the NPAs. This provides a 

consistent approach and allows the Agency to consider the results of this Study alongside 

those of other respondents. 

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Documents Referenced in this Paper 

Document 

Source 


Document Title/Reference Page 

EC Reg 3922/91 Annex III – EU OPS 4 

ICAO Annex 6, Part 1 – Operation of Aircraft 23 

EASA NPA 2009 – 02A IR /ARs/ORs OPS Explanatory Notes 30 

EASA NPA 2009 – 02B IR OPS / PART OPS 32 

EASA NPA 2008 – 22C IR – ORs General 36 

EASA NPA 2009 – 02C IR – ORs OPS 45 

EASA NPA 2008 – 22B Authority Requirements ARs 48 

EASA NPA 2009 – 02D ARs General and OPS 51 

ICAO Document 9640 - Manual of Aircraft De-icing / Anti-icing Ops 56 

ICAO Annex 14 – Aerodromes 63 

EC Reg 1108/2009 – Essential Requirements Aerodromes 69 

EC 

Directive 96/97/EC on Ground Handling market access in 

Community airports 

EC/EASA Reg 2042/2003 (2010) – EASA PART M, 145 & AMC PART M 82 

EC Directive 2003/42/EC on Occurrence Reporting in Civil Aviation 87 

73



Definition of Terms 

(Taken from Council Regulation EEC 3922/91 as amended by 859/2008) 

‘certification’ (of a product, service, organization or person) means any form of legal 

recognition that such a product, service, body or person complies with the applicable 

requirements. Such certification comprises two acts: 

(i) the act of checking that technically the product, service, organization or person 

complies with the applicable requirements; this act is referred to as ‘making the 

technical findings’; 

(ii) the act of formal recognition of such compliance with the applicable requirements 

by the issue of a certificate, licence, approval or other document in the manner 

required by national laws and procedures; this act is referred to as ‘making the legal 

findings’ 

‘the Authority’ in EU OPS means the competent authority that has granted the air operator's 

certificate (AOC). 

‘operator’ means a natural person residing in a Member State or a legal person established 

in a Member State using one or more aircraft in accordance with the regulations applicable in 

that Member State, or a Community air carrier as defined in Community legislation; 

“accepted/acceptable” means not objected to by the Authority as suitable for the purpose 

intended. 

“approved (by the Authority)” means documented (by the Authority) as suitable for the 

purpose intended. 

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EC 

EU OPS 

Annex III to Reg 

3922/91 


Amended by EC Reg 859/2008 

Applicability: Direct EC law in Member States: ie it has to be adopted as National Law, and 

applicable to air operators. Effectively JAR OPS 1 Part 1. Some States have retained JAR 

OPS 1 Section 2 material as maintained in TGL 44. 

Options: As this is the current set of requirements for operators to comply with, any 

improvement to the rules contained within would seem the sensible approach; and certainly 

making recommendations to alter EU OPS is still a valid exercise. However, pending the 

approaching agreement and publication of EASA Implementing Rules for operators (Part 

Ops), the better option is to ensure that any recommendations to amend EU OPS are taken 

into account within Part Ops. Laid out below are options available for amending the text of 

EU OPS. 

Impact: Amending EU OPS would have little impact, but take considerable effort, which 

might be better directed at ensuring Part Ops contains any recommendations to improve the 

regulatory situation vis-à-vis the de-icing / anti-icing of aircraft on the ground. 

Article 7 

Member States shall recognise the certification granted pursuant to this Regulation by 

another Member State or by a body acting on its behalf, to bodies or persons placed under 

its jurisdiction and under its authority, who are concerned with the maintenance of products 

and the operation of aircraft. 

This allows for the transfer of any license, certificate or approval of any service provider from 

one Member State to any other; promoting a level field for commercial competition. 

No options or need to amend this Article. 

If licensing, certification, and /or approvals of service providers are recommended, the 

impacts would need to be considered. For example, whether the issuance of an approval 

was dependent on location specific criteria such as facilities; such as is usual with audits and



site inspections. In such a case restrictions in the transference of qualification would need to 

apply. 

Article 9 

Member States shall take the necessary steps to coordinate their research programmes to 

improve the safety of civil aircraft and their operation and to inform the Commission thereof. 

After consulting the Member States, the Commission may take any relevant initiative to 

promote such national research programmes. 

A question for NAAs was included in the Study asking for details of any research being 

conducted. The responses show that none is being conducted. 

There are Options available for any Body (EASA, NAA, Industry) to lobby the Commission to: 

− request details of any research being conducted by Member States in the area of deicing 

/ anti-icing, e.g. fluid properties, HOTs, new technology 

− require that those Member States who are conducting research coordinate their efforts 

to avoid duplication and ensure universal acceptance, and 

− take an initiative in promoting a research programme into the relevant aspects of deicing 

/ anti-icing. 

The initial impact on EASA and NAAs is slight. NAAs may need to coordinate, under EASA’s 

facilitation, a process to establish an agenda and a plan; although efforts might be better 

coordinated through the SAE G-12 working groups and meetings where there is already 

some NAA involvement and this has the added benefit of involving Industry expertise. 

However, much research conducted by members of SAE G-12 is voluntary and limited, due 

to lack of resources. Any ambitious research programme would need funding and adequate 

facilities. 

OPS 1.005 

General 

(c) Each aeroplane shall be operated in compliance with the terms of its Certificate of 

Airworthiness and within the approved limitations contained in its Aeroplane Flight Manual. 

There is a route to influence what fluids and/or what de-icing / anti-icing procedures 

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can/cannot be used, via the aircraft manufacturer. It is currently normal that manufacturers 

indicate that airworthiness is compromised by contamination (eg ice, snow, slush etc) on 

aircraft surfaces, and it should already be made clear in the AFM whether certain amounts of 

certain contamination (eg frost) on certain surfaces is acceptable and in compliance with the 

CoA. 

No options or need to change this rule. 

EASA has already taken action by requesting specific information from Type Certificate 

Holders [14 April 2009 PBL/ein/C(1.1) 2009(D)61465] concerning any recommended 

procedures and limitations for each aircraft type. Aircraft manufacturers have already issued 

Operational Notices concerning maintenance procedures for preventing and managing fluid 

residues. 

OPS 1.035 

Quality system 

(a) An operator shall establish one quality system and designate one quality manager to 

monitor compliance with, and adequacy of, procedures required to ensure safe operational 

practices and airworthy aeroplanes. Compliance monitoring must include a feed-back 

system to the accountable manager (see also OPS 1.175 (h)) to ensure corrective action as 

necessary. 

(b) The quality system must include a quality assurance programme that contains 

procedures designed to verify that all operations are being conducted in accordance with all 

applicable requirements, standards and procedures. 

It is through this Rule that airlines are obliged to ensure that their own procedures are 

adequate to ensure airworthy aeroplanes. Furthermore, as well as meeting regulatory 

requirements, the airline must verify that all operations are being conducted in accordance 

with all applicable standards and procedures. There is no definition or explanation of what 

these standards and procedures may include. EU OPS has no supporting material, and no 

mention is made to contracted-out services. Whereas JAR OPS 1, Section 2 used to provide 

interpretive information (some excerpts below) especially AMC OPS 1.035. 5.1 dealing 

directly with sub-contractors: 

JAA AMC OPS 1.035 

2.3 Purpose of the Quality System 

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2.3.1 The Quality System should enable the operator to monitor compliance with 

JAR-OPS 1, the Operations Manual, the Operator's Maintenance Management 

Exposition, and any other standards specified by that operator, or the Authority, to 

ensure safe operations and airworthy aircraft. 

This gives the Regulatory Authority the power to specify standards of de-icing / antiicing, 

and one assumes to then allow, for example, AEA Recommendations as AMC? 

Similarly, if the airline (operator) should opt to follow the AEA Recommendations and 

make it a requirement, then a functional Quality System should assure that these 

standards are achieved and maintained. 

2.4.4.c. The Quality Manager should have access to all parts of the operator’s and, as 

necessary, any sub-contractor’s organisation. 

4.2.2.b. Typical subject areas for quality inspections are Ground De-icing/Anti-icing; 

It is not made clear here whether this applies to the airline’s own procedures or those 

of a sub-contractor. 

5.1 Sub-Contractors 

5.1.1.a. Operators may decide to sub-contract out certain activities to external 

agencies for the provision of services related to areas such as Ground De-icing/Antiicing; 

5.1.2 The ultimate responsibility for the product or service provided by the subcontractor 

always remains with the operator. A written agreement should exist 

between the operator and the sub-contractor clearly defining the safety related 

services and quality to be provided. The sub-contractor’s safety related activities 

relevant to the agreement should be included in the operator’s Quality Assurance 

Programme. 

5.1.3 The operator should ensure that the sub-contractor has the necessary 

authorisation / approval when required and commands the resources and 

competence to undertake the task. If the operator requires the sub-contractor to 

conduct activity which exceeds the sub-contractor’s authorisation/approval, the 

operator is responsible for ensuring that the sub-contractor’s quality assurance takes 

account of such additional requirements. 

Regardless of whether a service provider is authorised (licensed/certificated) and/or 

approved, the operator is still responsible for ensuring its procedures are followed and 

standards maintained. This is achieved through writing an effective agreement (contract), 

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conducting quality inspections and audits, attaining feedback, and then assuring remedial 

action is undertaken to rectify any deviations. 

There are options for EASA to propose amendments to EU OPS such that clear direction 

concerning sub-contracted services is addressed. However, the Agency has already 

indicated (NPA 2009 – 02a) that it supports the use of the existing JAR OPS 1 section 2 

material, as issued through JAA TGL 44, until such time as it releases its own operations 

regulations and supplementary material. This issue is addressed through the proposed AMC 

to OR.GEN.205. 

Amending EU OPS would be a wasted effort due to its projected short life expectancy. Any 

effort would be better focused on ensuring EASA Part Ops met any desired requirements to 

improve performance. Therefore any recommendations to change EU OPS also need to 

consider the proposed EASA OPS regulations. 

OPS 1.037 

Accident prevention and flight safety programme 

(a) An operator shall establish and maintain an accident prevention and flight safety 

programme, which may be integrated with the quality system, including: 

1. programmes to achieve and maintain risk awareness by all persons involved in operations; 

and 

2. an occurrence reporting scheme to enable the collation and assessment of relevant 

incident and accident reports in order to identify adverse trends or to address deficiencies in 

the interests of flight safety. The scheme shall protect the identity of the reporter and include 

the possibility that reports may be submitted anonymously; and 

3. evaluation of relevant information relating to accidents and incidents and the promulgation 

of related information, but not the attribution of blame; and 

4. a flight data monitoring programme for those aeroplanes in excess of 27 000 kg MCTOM. 

Flight data monitoring (FDM) is the pro-active use of digital flight data from routine operations 

to improve aviation safety. The flight data monitoring programme shall be non-punitive and 

contain adequate safeguards to protect the source(s) of the data; and 

5. the appointment of a person accountable for managing the programme. 

(b) Proposals for corrective action resulting from the accident prevention and flight safety 

programme shall be the responsibility of the person accountable for managing the 

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programme. 

(c) The effectiveness of changes resulting from proposals for corrective action identified by 

the accident and flight safety programme shall be monitored by the quality manager. 

This Regulation is very much “interpreted” to be aimed at the operator, and personnel 

employed by the operator, and it is not clear that it extends to sub-contracted service 

providers and their personnel. Also this regulation has an emphasis on accident and incident 

reports, and not on safety data per se (of the type associated with Human Factors that might 

be appropriate to de-icing / anti-icing operatives). The supplementary information contained 

within JAA ACJ OPS 1.037(a)(2) does not expand on this emphasis and does not improve 

interpretation of the Regulation. 

Amending this Regulation to address the need for operators to collect safety data from 

subcontracted service providers and their personnel would make it clear that this is required 

(and beneficial). The inclusion of ICAO SMS Standards within Part Ops may achieve this 

task. Providing expanded and more explicit explanatory, and/or supplementary material may 

help operators interpret and follow the requirements. 

A broadening of operators’ safety focus, the integration of sub-contracted service providers, 

and the provision of more explanatory material within operators’ SMS’s will have a positive 

impact on safety. 

OPS 1.175 (i) 

General rules for air operator certification 

The operator must have nominated post holders, acceptable to the Authority, who are 

responsible for the management and supervision of the following areas: 

1. flight operations; 

2. the maintenance system; 

3. crew training; and 

4. ground operations. 

Appendix 2 to OPS 1.175 

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The management and organisation of an AOC holder 

(a) General 

An operator must have a sound and effective management structure in order to ensure the 

safe conduct of air operations. Nominated post holders must have managerial competency 

together with appropriate technical/operational qualifications in aviation. 

(b) Nominated post holders: 

1. A description of the functions and the responsibilities of the nominated post holders, 

including their names, must be contained in the Operations Manual and the Authority must 

be given notice in writing of any intended or actual change in appointments or functions. 

2. The operator must make arrangements to ensure continuity of supervision in the absence 

of nominated post holders. 

3. A person nominated as a post holder by the holder of an AOC must not be nominated as a 

post holder by the holder of any other AOC, unless acceptable to the Authorities concerned. 

4. Persons nominated as post holders must be contracted to work sufficient hours to fulfil the 

management functions associated with the scale and scope of the operation. 

(c) Adequacy and supervision of staff: 

2. Ground Staff 

(i) The number of ground staff is dependent upon the nature and the scale of operations. 

Operations and ground handling departments, in particular, must be staffed by trained 

personnel who have a thorough understanding of their responsibilities within the 

organisation. 

(ii) An operator contracting other organisations to provide certain services retains 

responsibility for the maintenance of proper standards. In such circumstances, a nominated 

post holder must be given the task of ensuring that any contractor employed meets the 

required standards. 

This Regulation details the need for the operator to appoint a nominated post-holder whose 

responsibilities implicitly include ensuring that sub-contracted de-icing / anti-icing service 

providers meet the required standards. Which nominated post-holder is not specified 

(operators may choose either the flight or ground operations nominated post-holders). JAA 

ACJ OPS 1.175(i) does not insist on any requirements for knowledge or experience of deicing 

/ anti-icing amongst its nominated post-holders. Furthermore, this Regulation only 

requires ground staff to have a thorough understanding of their responsibilities and not 




necessarily the technical complexities of sub-contracted services. 

Requiring operators to nominate one single person as their de-icing / anti-icing 

“coordinator/expert/post-holder” may improve communication between all departments, and 

also with the NAA. The results of our Study show that de-icing / anti-icing experience and 

knowledge within operators’ organisations are fragmented, and therefore one assumes the 

decision-making process on matters concerning de-icing / anti-icing is not efficient. Providing 

more detailed supporting information detailing the roles and responsibilities of nominated 

post-holders may also have the same effect. 

The act of nominating a focal-point, any necessary in-house training, and any subsequent 

establishment of new procedures can all be achieved within the existing management 

organisation; however, the benefits derived from improved coordination, communication and 

awareness could be substantial. 

OPS 1.175 (m) 

General rules for air operator certification 

The operator must arrange appropriate ground handling facilities to ensure the safe handling 

of its flights. 

This is more like an Essential Requirement, high level regulation, than an Implementing Rule. 

There is no expansion or explanation, however, accepting de-icing / anti-icing as a groundhandling 

operation, this Regulation would apply. In practice the de-icing / anti-icing facilities 

are often owned and managed by the aerodrome management, which is often separate from 

the de-icing / anti-icing service provision. Therefore, this requirement will need to be met by 

the operator through the quality system oversight of both aerodromes and service providers. 

The Regulation could be amended to state that the operator must ensure through the quality 

system etc, this is merely cosmetic, but it would be appropriate. Otherwise, far more detailed 

information could be given to explain to operators exactly what is required, both in the Rule 

and as supporting information. 

No great positive or negative impact to be made from these options. 

OPS 1.205 

Competence of operations personnel 




An operator shall ensure that all personnel assigned to, or directly involved in, ground and 

flight operations are properly instructed, have demonstrated their abilities in their particular 

duties and are aware of their responsibilities and the relationship of such duties to the 

operation as a whole. 

ACJ OPS 1.205 

Competence of Operations personnel 

If an operator employs Flight Operations Officers in conjunction with a method of 

Operational Control as defined in JAR-OPS 1.195, training for these personnel should 

be based on relevant parts of ICAO Doc 7192 D3. This training should be described 

in Subpart D of the Operations Manual. It is not to be inferred from this that there is a 

requirement for Licensed Flight Dispatchers or for a flight following system. 

This Rule complements Appendix 2 OPS 1.175 (c)(2)(i) shown above, and adds the need for 

training and ability as well as just knowledge of responsibilities. 

There is an option here to specify in detail, within the training requirements for flight 

operations/dispatch staff, elements of de-icing / anti-icing. 

During this Study it has become apparent how critical the operators’ flight operations 

departments can be in either contributing or hindering de-icing / anti-icing operations, through 

their role as a communication hub between the service provider, aerodrome and flight crews. 

Specifying in-house training requirements for flight operations/dispatch staff in de-icing / antiicing 

matters may improve safety at very little cost. 

OPS 1.210 

Establishment of procedures 

(a) An operator shall establish procedures and instructions, for each aeroplane type, 

containing ground staff and crew members’ duties for all types of operation on the ground 

and in flight. 

(b) An operator shall establish a check-list system to be used by crew members for all 

phases of operation of the aeroplane under normal, abnormal and emergency conditions as 

applicable, to ensure that the operating procedures in the Operations Manual are followed. 

This is clear and precise and should include de-icing / anti-icing operations and apply to both 

flight crew and flight operations/dispatch staff. 




There is an option to provide supporting information to detail specifically what these duties 

may be concerning de-icing / anti-icing operations. 

Providing supporting material would be useful in reinforcing the need for operators to play 

their role in ensuring safe de-icing / anti-icing operations. Although, to do so here may 

duplicate the requirement of OPS 1.345, shown below. 

OPS 1.290 (b) 1. 

Flight preparation 

The commander shall not commence a flight unless he/she is satisfied that the aeroplane is 

airworthy. 

OPS 1.345(b) 

A commander shall not commence take-off unless the external surfaces are clear of any 

deposit which might adversely affect the performance and/or controllability of the aeroplane 

except as permitted in the Aeroplane Flight Manual. 

These Rules complement each other: one general and the other specific. 

OPS 1.345 

Ice and other contaminants — ground procedures 

(a) An operator shall establish procedures to be followed when ground de-icing and anti-icing 

and related inspections of the aeroplane(s) are necessary. 

ACJ OPS 1.345 

Ice and other contaminants Procedures 

Too large to include here. This supporting material is very broad and includes: 

background educational material; requirements for operators’ procedures; 

maintenance considerations; and, training recommendations. The content is good 

(based on current best-practices), however, because of its range of subjects and mix 

of requirements, recommendations and background information it is not perfectly 

clear, nor necessarily helpful to operators in establishing their procedures. The final 

section is included here because of its relevance: 

10. Subcontracting (see AMC OPS 1.035 sections 4 and 5) 




The operator should ensure that the subcontractor complies with the operator’s 

quality and training/qualification requirements together with the special requirements 

in respect of: 

a. De-icing and/or anti-icing methods and procedures; 

b. Fluids to be used, including precautions for storage and preparation for use; 

c. Specific aeroplane requirements (e.g. no-spray areas, propeller/engine de-icing, 

APU operation etc.); 

d. Checking and communications procedures. 

Ostensibly this Rule together with the associated supporting material and one of the better 

reference documents (AEA Recommendations) should be enough for an operator to 

establish suitable and safe procedures appropriate to all personnel involved and covering all 

aspects of de-icing / anti-icing operations, including contingency procedures. However, there 

is no link to an “acceptable” set of procedures, nor a standard template for both procedures 

and training syllabus. Furthermore, there is no direct requirement for an operator to establish 

coordination and communication procedures between flight operations, flight crew, 

aerodromes and service providers, adequate for all their destinations. 

1. It is an option to review the supporting material and re-present it in more easily digestible 

chunks; this would also allow for a division of what is definitely required and what is 

recommended as well as the expected (or demanded) minimum standards acceptable. 

This is partially proposed in AMC.2.OPS.GEN.100. 

2. A template for operators’ procedures could be included. 

3. Another option would be for each operator’s de-icing / anti-icing procedures to be 

accepted/approved by the Authority: option 2 would also then be required. 

4. A strong connection can be made here towards OPS 1.175, 1.205 and 1.210 to 

emphasise that procedures are required for ground staff and also to highlight the 

nominated post-holder’s responsibilities. 

5. A requirement can be added to ensure that operators develop and use adequate 

coordination and communication procedures that are effective at all their destinations 

where de-icing / anti-icing is undertaken. 

6. A connection can also be made to OPS 1.037 to emphasise the need for operators to 

improve the collection (and analysis) of occurrence and human factors reports from deicing 

/ anti-icing service providers; and this element may need to be included in any 

contracts. 




1. The impact would be a clarification and perhaps a move towards more standardisation; 

the process would allow for further progress in other areas of de-icing / anti-icing if it 

involved industry expertise. 

2. This is easily included in option 1, and it would further increase the move towards 

standardisation (from the operators’ point of view). 

3. Likely to incur more work for both operators and NAAs, and also some cost in NAA 

manpower. This will further motivate operators to standardise their procedures and also 

NAAs to demand this. 

4. As this is reinforcing already existing Rules there should be no effort required, but it may 

ensure better coordination and communication between flight operations, ground staff, 

flight crew, aerodromes, and service providers. 

5. Creating more procedures and training will require time and effort, however, it should 

ensure better coordination and communication between flight operations, ground staff, 

flight crew, aerodromes, and service providers. 

6. This would be of great benefit, as currently very little safety data is collected and 

analysed on the occurrences that de-icing / anti-icing operatives encounter. 

OPS1.420 

Occurrence Reporting 

This Rule covers the need for the operator’s employees to file occurrence reports, but does 

not cover the need to encourage sub-contractors to file reports. No mention is made of 

human factors reporting. 

Reinforcement of OPS 1.037 could be made here by requiring operators to establish the 

procedures by which third-parties can file occurrence reports, and the need for the operator 

to promote this. 

Little effort required; the clause can be inserted when contracts are renewed, but before then 

voluntary schemes may develop alongside safety awareness programmes. These 

programmes can be delivered at the same time as operator specific requirements for de-icing 

/ anti-icing are delivered. The result should be: directly – an increase in safety data available 

for analysis; and indirectly – greater safety awareness and improved culture amongst service 

providers. 




OPS 1.625 

Mass and balance documentation 

(See Appendix 1 to OPS 1.625) 

(a) An operator shall establish mass and balance documentation prior to each flight 

specifying the load and its distribution. The mass and balance documentation must enable 

the commander to determine that the load and its distribution is such that the mass and 

balance limits of the aeroplane are not exceeded. The person preparing the mass and 

balance documentation must be named on the document. The person supervising the 

loading of the aeroplane must confirm by signature that the load and its distribution are in 

accordance with the mass and balance documentation. This document must be acceptable 

to the commander, his/her acceptance being indicated by countersignature or equivalent. 

(See also OPS 1.1055 (a)12). 

(b) An operator must specify procedures for last minute changes to the load. 

(c) Subject to the approval of the Authority, an operator may use an alternative to the 

procedures required by paragraphs (a) and (b) above. 

This Rule is included because of the similarities with de-icing / anti-icing in respect of the 

effect on airworthiness if the task of loading is incorrectly carried out, and the fact that 

loading and the creation of the documentation is often conducted by sub-contracted service 

providers. 

It is conceivable that a similar regulation for de-icing / anti-icing could be proposed. That is, 

any documentation and/or communication passed from the de-icing / anti-icing service 

provider to the operator and/or captain, must enable the captain to determine an accurate 

holdover time and that the aircraft is free of contamination. 

If operators want to use alternative procedures, then they would be required to seek 

Authority approval. 

Details of the anti-icing code can be placed in an Appendix. 

This would confirm that the anti-icing code has a specific purpose, and that service providers, 

flight crew and flight operations were all interpreting the code in the same way: thus 

eliminating confusion as to the meaning of the code. Operators would have to amend 

contracts in order to ensure that service providers were aware of their post de-icing / antiicing 

inspection and communication responsibilities. 




OPS 1.873 

Electronic navigation data management 

(a) An operator shall not use a navigation database which supports an airborne navigation 

application as a primary means of navigation unless the navigation database supplier holds a 

Type 2 Letter of Acceptance (LoA) or equivalent. 

(b) If the operator’s supplier does not hold a Type 2 LoA or equivalent, the operator shall not 

use the electronic navigation data products unless the Authority has approved the operator’s 

procedures for ensuring that the process applied and the delivered products have met 

equivalent standards of integrity. 

(c) An operator shall not use electronic navigation data products for other navigation 

applications unless the Authority has approved the operator’s procedures for ensuring that 

the process applied and the delivered products have met standards of integrity acceptable 

for the intended use of the data. 

(d) An operator shall continue to monitor both the process and the products according to the 

requirements of OPS 1.035. 

(e) An operator shall implement procedures that ensure timely distribution and insertion of 

current and unaltered electronic navigation data to all aircraft that require it. 

Agency Opinion 01/2005 

On the acceptance of navigation database suppliers 

In the Agency’s view the best solution would certainly be that the industry organizes 

itself to verify the quality of the navigation data provided by the suppliers and used by 

the aircraft operators. Such an option, similar to that developed by IATA for the 

operational safety audit of its member airlines (IOSA). 

In line with the above policy a stand-alone document is produced which will be used 

for the investigation of navigation database suppliers in Europe and, after satisfactory 

results, for the issuance of a letter of acceptance (LoA). This document consists of 

“Conditions” and “Guidance”. Finally, to facilitate the work of the investigation team 

and to allow for a better preparation by the organisation to be assessed, a 

compliance checklist in line with the above document is provided. The letter of 

acceptance does not constitute a mandatory requirement since it is not a mandatory 

certification attesting compliance with a binding act. The letter of acceptance will not 

attest that the data produced by these organisations can be used by operators, but 




that the organisation has put in place an appropriate quality system for the control of 

the processing of data. This will ease the obligation on the operator to do the same 

control and facilitate the issuing by the national competent authorities of the approval 

for the operators to fly in dedicated airspace where reduced separations are 

implemented. 

There is no obligation on operators to buy their data only from organisations holding 

the letter of acceptance. Operators can either make the verifications themselves or 

use another competent organisation for this purpose and convince directly their 

responsible authority that they can be allowed to fly in P-RNAV airspace. The 

decision whether or not to apply for an EASA letter of acceptance is therefore entirely 

up to the navigation database supplier concerned. However, by applying, the 

organisation automatically declares to accept all the obligations that are linked to the 

letter of acceptance and which are described in the applicable conditions and 

guidance material. On the other hand the issuance of a letter of acceptance does not 

give any rights to its holder except the confirmation by the Agency that the 

organization concerned is in compliance with the applicable and published conditions 

and guidance. 

This Rule is included here because of the similarity with de-icing / anti-icing in respect of the 

critical nature of the navigation data and the consequences if it is in error, and also the 

reliance of the operator on a third-party to provide such data. 

Also EASA has an opinion and found a solution to a similar problem as that of de-icing / antiicing; 

within this solution is the tacit acceptance of pooled auditing of service providers by 

Industry. 

It may be possible for EASA to form an Opinion on the use of pooled auditing of de-icing / 

anti-icing service providers as an acceptable means of complying with OPS 1.035. Such 

audits can be based on a checklist which is derived from a document containing “conditions” 

and “guidance”. Such a document could be derived by the Industry, such as AEA 

Recommendations, backed up with a checklist such as the DAQCP audit. 

Due to the multitude of de-icing / anti-icing service providers compared with database 

suppliers a solutions would need to be found to “qualify and license” Industry auditors to 

ensure that the “acceptance” process of service providers was standardised. 

The DAQCP currently operates from the airline membership perspective and involves only 

those destinations and service providers with whom member airlines have business. It may 

be necessary for a universal scheme to consider membership from the service providers 




perspective, where they pay a fee, but member airlines continue to provide the auditors. 

It is possible that conditions may be placed on operators who use service providers who 

have not been “accepted” under such a scheme. 

The attraction of reducing the number of required audits of service providers by operators 

may encourage more operators to join the scheme. The attraction for service providers of 

having, effectively, only one or two audits per year may encourage them to request auditing 

under this scheme. The system should be self-funding and indeed provide some economic 

gain. As membership of the scheme increases then the Industry will move closer to a 

universal standard. 

There is no coercion or mandatory requirement, however, for those service providers who 

apply for the scheme they would be committed to accept the obligations outlined in any 

supporting documentation: this can contain procedures, quality assurance, training, 

documentation, equipment etc. 

OPS 1.945 

Conversion training and checking 

Appendix 1 to OPS 1.945 

Operator’s conversion course 

(a) An operator’s conversion course shall include: 

1. ground training and checking including aeroplane systems, normal, abnormal and 

emergency procedures; 

2. emergency and safety equipment training and checking which must be completed before 

aeroplane training commences; 

3. aeroplane/flight simulator training and checking; and 

4. line flying under supervision and line check. 

(b) The conversion course shall be conducted in the order set out in subparagraph (a) above. 

(c) Elements of crew resource management shall be integrated into the conversion course, 

and conducted by suitably qualified personnel. 

(d) When a flight crew member has not previously completed an operator’s conversion 

course, the operator shall ensure that in addition to subparagraph (a) above, the flight crew 




member undergoes general first aid training and, if applicable, ditching procedures training 

using the equipment in water. 

AMC OPS 1.945 

Conversion Course Syllabus 

There is no mention in the JAA supporting material, either, of de-icing / anti-icing 

being part of the ground training syllabus. 

Appendix 1 to OPS 1.965(a)1.(i)(B) 

Recurrent training and checking — Pilots 

Recurrent training shall comprise ground and refresher training; the ground and refresher 

training programme shall include operational procedures and requirements including ground 

de-/anti-icing. 

These Rules explain the stages and content of an operator’s conversion course for pilots, 

and also the recurrent training syllabus. No mention is made of the operator’s de-icing / antiicing 

policy, procedures and contracts within the conversion course; however, there is a 

reference to de-icing / anti-icing in the recurrent training programme. For both elements of 

training it is required that elements of CRM are integrated into the course. 

It is possible to ensure that flight crew learn and understand the operators de-icing / anti-icing 

policy and procedures before commencing line flying, by making this a requirement of a 

conversion course. Emphasis can then be placed on the use of CRM to overcome 

communication and coordination problems that typically arise during winter operations (OPS 

1.943). 

There should be a positive impact from introducing this option, as pilots are guaranteed to be 

exposed to the operator’s de-icing / anti-icing policy and procedures earlier and perhaps 

have time to study it in more depth. Any re-emphasis to address CRM issues during winter 

operations would help towards more positive outcomes during problems with communication 

and coordination during winter operations. 

Appendix 1 to OPS 1.1045 A 8 

Operations Manual Contents 

An operator shall ensure that the Operations Manual contains the following: 

8.2.4 De-icing and anti-icing on the ground. A description of the de-icing and anti-icing policy 

and procedures for aeroplanes on the ground. These shall include descriptions of the types 




and effects of icing and other contaminants on aeroplanes whilst stationary, during ground 

movements and during take-off. In addition, a description of the fluid types used must be 

given including: 

(a) proprietary or commercial names; 

(b) characteristics; 

(c) effects on aeroplane performance; 

(d) hold-over times; and 

(e) precautions during usage. 

This short paragraph contains very little guidance, and focuses on one element (fluid types) 

but omits many others. The de-icing /anti-icing policy and procedures are not one of the OM 

contents that requires specific approval by the Authority (JAA IEM OPS 1.1040(b)); instead 

the operator only has to ensure that the detailed structure of the Operations Manual is 

acceptable to the Authority (OPS 1.1045). 

It is an option to revise this Appendix and include other elements, such as: the operator’s 

communication and coordination procedures (for de-icing / anti-icing); the anti-icing code; 

inspection and checking procedures; re-assessment of HOT in changing conditions; affect of 

re-hydrated fluid residues on flying control surfaces; and contents of the operator’s standard 

contract for de-icing / anti-icing etc. 

Revision of the OM contents for de-icing / anti-icing may have the effect of operators 

reviewing their procedures (especially if the revision is in conjunction with other regulatory 

changes); this may then have the effect of the revision of training programmes and 

awareness campaigns. Raised awareness and more valuable information available in the 

OM will be good for safety. 

OPS 1.1145 

Dangerous Goods - General 

An operator must comply with the applicable provisions contained in the latest effective 

edition of the Technical Instructions for the Safe Transport of Dangerous Goods by Air, 

including the Supplement and any addenda, approved and published by decision of the 

Council of the International Civil Aviation Organisation (ICAO Doc 9284–AN/905). 

This paragraph is included as an example of how an EU (EASA) Regulation can be linked to 

an ICAO Document making the ICAO Document binding. Although ICAO Doc 9640 is 




neither comprehensive nor practical, it may be a long-term goal of Industry and NAAs to 

lobby ICAO to update this Document such that it can become a world-wide standard for both 

EASA and the FAA (for example) to refer their own regulations towards. 

The impact would be a single-source (and accepted) reference document from which 

operators would develop their procedures; this would lead to greater consistency and more 

standardised procedures. 




ICAO Annex 6 8 Edition, Amendment 30 

OPERATION OF AIRCRAFT – Part 1 – International Commercial Air Transport - 

Aeroplanes 

Applicability: Minimum Standards applicable to the operation of aeroplanes by operators 

authorized to conduct international commercial air transport operations. Applied indirectly 

through States – has been achieved Nationally through Cyprus Agreement to comply with 

JAR OPS (no guarantee) and now through EC Reg 3922/91 – EU OPS. 

This is the ICAO source requiring operators to take responsibility for ensuring that 

“appropriate de-icing / anti-icing treatment” is given and that the aeroplane is “kept in an 

airworthy condition prior to take-off”. EU OPS complies with this through OPS 1.035 and 

OPS 1.345. 

Options: There is no option to amend Annex 6 in the short term, and without widespread 

support from NAAs and Industry it is unlikely to happen in the medium and long terms either. 

However, EASA and NAAs can review Annex 6, in conjunction with ICAO Doc 9640, and 

reinterpret how best to comply with the Standards and Recommended Procedures, in light of 

current day knowledge of best-practice. The opportunity is presented for EASA as they 

develop Implementing Rules and supplementary material for Operations. 

3.2 Safety management (and 8.7.3) 

3.2.1 States shall establish a safety programme in order to achieve an acceptable level of 

safety in the operation of aircraft. 

3.2.2 The acceptable level of safety to be achieved shall be established by the State(s) 

concerned. 

Note.— Guidance on safety programmes is contained in the Safety Management Manual 

(SMM) (Doc 9859), and the definition of acceptable levels of safety is contained in 

Attachment E to Annex 11. 

3.2.4 From 1 January 2009, States shall require, as part of their safety programme, that an 




operator implement a safety management system acceptable to the State of the Operator 

that, as a minimum: 

a) identifies safety hazards; 

b) ensures that remedial action necessary to maintain an acceptable level of safety is 

implemented; 

c) provides for continuous monitoring and regular assessment of the safety level achieved; 

and 

d) aims to make continuous improvement to the overall level of safety. 

3.2.5 A safety management system shall clearly define lines of safety accountability 

throughout the operator’s organization, including a direct accountability for safety on the part 

of senior management. 

Most EASA Member States, and operators, have not yet changed their management of 

safety from the mechanisms of accident prevention that comply with OPS 1.037 and 

overseen by the quality system according to OPS 1.035. This SARP allows the NAA to be 

more precise about what is required as part of an operator’s safety programme. The key 

element is the introduction of safety performance measurement, monitoring and 

improvement. 

It is an option, when EASA takes up this SARP within Part Ops, to include specific 

references to different areas of operation, including de-icing / anti-icing. This may form part 

of an operator’s de-icing / anti-icing policy and procedures (OPS 1.345 and OPS 1.1045) to 

define with respect to de-icing / anti-icing operations: 

- examples of typical hazards, 

- ways and means of taking preventive action to reduce risk (procedures, contracts, 

fluids, training etc) 

- ways and means of taking remedial action, 

- how the safety level is to be monitored and assessed on a regular basis (includes the 

collection of safety and human factors data from the service providers), 

- what the key safety goals are, 

- who is in overall “charge” of the de-icing / anti-icing process (Doc 9640), who 

provides the information that the aircraft is free from contamination, what are the 




pilots responsibilities, and which post-holder is responsible for the policy, procedures 

and programme? 

It is also an option for States, either unilaterally or in unison with EASA, to conduct a Safety 

Initiative, commencing with a promotion for the collection of more safety data from the 

service providers. 

The impact from adopting these options would be positive from the safety perspective, in the 

short and medium term respectively. Operators would need to “show” how they intend to 

improve levels of safety within their de-icing / anti-icing operations. Naturally this will take 

effort, however, a NAA/EASA led initiative would ease the burden and also improve the 

chances for harmonisation of effort and the results attained. 

4.2.2 Operations manual 

4.2.2.1 An operator shall provide, for the use and guidance of operations personnel 

concerned, an operations manual in accordance with Appendix 2. The operations manual 

shall be amended or revised as is necessary to ensure that the information contained therein 

is kept up to date. All such amendments or revisions shall be issued to all personnel that are 

required to use this manual. 

4.2.2.2 The State of the Operator shall establish a requirement for the operator to provide a 

copy of the operations manual together with all amendments and/or revisions, for review and 

acceptance and, where required, approval. The operator shall incorporate in the operations 

manual such mandatory material as the State of the Operator may require. 

Appendix 2 Operations Manual 

2. Contents 

The operations manual referred to in 1.1 and 1.2 shall contain at the least the following: 

2.1.9 Ground handling arrangements and procedures. 

2.1.15 Instructions for the conduct and control of ground de-icing/anti-icing operations. 

Doc 9640 

NAA - Responsibilities 

The regulatory authority ensures that every operator shall have an approved de- 




icing/anti-icing programme or procedures. 

The de-icing/anti-icing programme shall: 

− clearly define areas of responsibility for the operator 

− cover all locations within the operator’s route network including de-icing/anti-icing 

accomplished by subcontract.. 

All persons involved in ground de-icing/anti-icing activities shall be trained and 

qualified in the procedures, communications and limitations of their area of 

responsibility. 

This SARP is complied with in OPS 1.1045 (OM), however, ICAO recommends (Doc 9640) 

that the operator’s de-icing / anti-icing programme, or procedures, is “approved” by the NAA. 

There is special focus on responsibilities and training. Attachment F to Annex 6 Part 1 (AOC 

& Validation) does not include de-icing / anti-icing as an item that needs Authority “approval” 

(para 3.3); it refers only to the contents of the OM as requiring “acceptance” through a 

technical evaluation. 

4.3.2 The State’s technical evaluation should, in addition to ensuring that all required 

contents are addressed, consider if the specific policies and procedures would result 

in the desired outcome. 

It can be deduced that an Authority’s technical evaluation must consider whether the 

operator’s policy and procedures would work at all of the operator’s destinations where deicing 

/ anti-icing is expected. Therefore this evaluation is dependant on the facilities, 

procedures and equipment available at each location; making the evaluation dependant on 

aerodrome management and/or service providers. 

It is an option for NAAs/EASA to amend their regulations to conform with Annex 6 as 

interpreted by Doc 9640, and use an approval process for operator’s de-icing / anti-icing 

programmes, or procedures. 

Also, another option would be to limit the approval to particular elements of the programme, 

in particular the training syllabus and methods, and responsibilities of all those involved. This 

could be extended to the contents of contracts with service providers. 

An alternative would be for NAAs/EASA to specify (through means of an AMC) the contents 

of an operator’s de-icing / anti-icing programme, and the standards to be achieved; then any 

operator wishing to deviate from this would need an approval. 

The problem remains as to whether the operator’s policy and procedures/programme is 

applicable and viable to all of the operator’s destinations. One solution would be for a 

universal audit programme to be used by all operators, acceptable to NAAs/EASA, and 




applied to all service providers. 

Both the first two options would incur effort on the part of the NAAs; the amount of effort will 

depend on the mandatory elements and detail required for approval. There is no guarantee 

for harmonisation using the full approval method unless NAAs/EASA define carefully each 

element and the standards required. 

The third option would result in less effort from NAAs and more likelihood of harmonisation 

amongst operators. 

Flight preparations – Weather Conditions 

4.3.5.4 

A flight to be planned or expected to operate in suspected or known ground icing conditions 

shall not take off unless the aeroplane has been inspected for icing and, if necessary, has 

been given appropriate de-icing/anti-icing treatment. Accumulation of ice or other naturally 

occurring contaminants shall be removed so that the aeroplane is kept in an airworthy 

condition prior to take-off. 

Note.— Guidance material is given in the Manual of Aircraft Ground De-icing/Anti-icing 

Operations (Doc 9640). 

OPS 1.345 

Ice and other contaminants — ground procedures 

(a) An operator shall establish procedures to be followed when ground de-icing and 

anti-icing and related inspections of the aeroplane(s) are necessary. 

(b) A commander shall not commence take-off unless the external surfaces are clear 

of any deposit which might adversely affect the performance and/or controllability 

of the aeroplane except as permitted in the Aeroplane Flight Manual. 

This SARP is covered by OPS 1.345, which inherently (but not clearly) covers also post deicing 

/ anti-icing inspections and pre-take-off contamination checks, which the SARP does 

not. 

An option would be to expand on this SARP and include in NAA/EASA regulations a clear 

requirement for both pre and post-de-icing / anti-icing checks/inspections, as well as other 

checks/inspections whenever doubt exists concerning the state of the external surfaces. 

This could be expanded upon by requiring the operator’s de-icing / anti-icing procedures to 

specifically include details of check/inspection procedures together with the coordination and 

communication processes to cater for all variations of location, equipment and contract that 

the operator currently is exposed to. 




The impact of this would be to ensure that operators have considered the problems that exist 

for service providers, ground-crew and flight-crew when checks/inspections are required, and 

how various means of communication make the coordination of this difficult (if not 

impossible). Thus resulting in remedial and preventive action being taken and flight-crew 

being supported through firm procedures and clear management decision processes. 

Duties of Flight Operations Officer/Flight Dispatcher 

4.6.1 

A flight operations officer/flight dispatcher in conjunction with a method of control and 

supervision of flight operations in accordance with 4.2.1.4 (issue of AOC) shall: 

a) assist the pilot-in-command in flight preparation and provide the relevant information; 

10.3 Flight Operations Officer/Flight Dispatcher 

A flight operations officer/flight dispatcher shall not be assigned to duty unless that person 

has: 

a) satisfactorily completed an operator-specific training course that addresses all the specific 

components of its approved method of control and supervision of flight operations specified 

in 4.2.1.4; 

c) demonstrated to the operator a knowledge of: 

1) the contents of the operations manual described in Appendix 2; 

2) the radio equipment in the aeroplanes used; and 

3) the navigation equipment in the aeroplanes used; 

d) demonstrated to the operator a knowledge of the following details concerning operations 

for which the officer is responsible and areas in which that individual is authorized to exercise 

flight supervision: 

1) the seasonal meteorological conditions and the sources of meteorological 

information; 

2) the effects of meteorological conditions on radio reception in the aeroplanes used; 

3) the peculiarities and limitations of each navigation system which is used by the 

operation; and 

4) the aeroplane loading instructions; 




e) demonstrated to the operator knowledge and skills related to human performance relevant 

to dispatch duties; and 

f) demonstrated to the operator the ability to perform the duties specified in 4.6. 

These SARPS do not adequately deal with the need for operations personnel to have a good 

understanding of the operator’s de-icing / anti-icing programme, together with the necessary 

coordination and communication procedures that may be required. They only require that 

officers/dispatcher have knowledge of de-icing / anti-icing procedures as a content of the 

OM. Whereas for example, a knowledge of the loading instructions must be “demonstrated” 

to the operator. This inadequacy is also reflected in OPS 1.205, where no mention is made 

concerning de-icing / anti-icing. 

The only option would be for a review of OPS 1.25 and any related EASA Part Ops 

regulations for the responsibilities and content of training programmes for operations 

personnel and dispatch staff. 

Ensuring that all operators employ and train operations personnel and dispatch staff 

adequately in the procedures for de-icing / anti-icing operations – especially coordination and 

communication, will impact positively on aircraft dispatch during winter operations by 

ensuring that decision-making is based on sound knowledge. 




EASA NPA 2009 – 02a Under Review following CRD 

Implementing Rules for Air Operations of Community Operators - 

Explanatory Note and Appendices 

Applicability: The first of seven separate NPAs aimed at developing an Opinion on the 

Implementing Rules for Air Operations of Community Operators and a Decision on the 

related Acceptable Means of Compliance (AMC) and Guidance Material (GM). The scope of 

this rulemaking activity is outlined in the Terms of Reference (ToR) OPS.001 and is 

described in more detail below. This particular NPA provides an explanation of the contents 

of the other 6 by means of an introduction. 

Options: For all elements of this NPA 2009 – 02, there may be time and motivation to 

include, in the first publication, amendments related to improving the standard of de-icing / 

anti-icing, through operators’ procedures and programmes, and also through the 

requirements for Authorities. Otherwise, amendments can be proposed after publication of 

the Implementing Rules for Operations and Authority Requirements. 

Impact: Any changes to these proposed regulations and associated supporting material will 

be immediately applicable on publication of the rules (pending any legal or practical periods 

allowed for adjustment). 

A.IV. Contents of draft Opinions and Decisions 

Para 14: The intention is to retain elements and spirit of JAR OPS 1 Section 2 material as 

extant in JAA TGL 44; thus allowing the better elements of ACJ 1.345 to be maintained. 

Para 21: Implementing Rules are to reflect state of the art and best practices in the field of 

operations; therefore reference is valid to the most respected and used documents such as 

AEA Recommendations. 

Para 44: Subpart D of Part OPS, OPS.SPA, contains requirements for specific operations 

that require a specific approval. Thus giving a vehicle to include de-icing / anti-icing as a 

special approval operation, such as the transport of dangerous goods. 

Para 56: To maintain the necessary level of flexibility it is imperative that only essential 




safety elements are contained in the rule, leaving nonessential implementation aspects to CS 

or AMC, so as to provide for a sufficient flexibility as required by the principle of subsidiarity. 

Such is the fundamental reason for the ‘performance based approach’ to rulemaking that the 

Agency has followed. Careful thought must be given to the essential aspects of de-icing / 

anti-icing regulation; allowing too much flexibility in interpreting the rules will harm the aim of 

harmonization. 

Para 67: The Agency wishes make use of as many AMCs as possible by encouraging 

industry to promote their best-practices for that cause. This opens the way for inherent 

acceptance of, for example, the AEA Recommendations to be amended and adopted as 

AMC material. 

Appendix 1 para 9: On 31 July 2007, the Agency published the Advance Notice of 

Proposed Amendment (ANPA) 200711 to consult stakeholders on appropriate measures to 

be taken to address potential safety hazards associated with the residues of fluids used for 

the ground deicing and antiicing of aircraft. In the Comment Response Document (CRD) 43 , 

the Agency described the outcome of the consultation and the possible course of action to 

address these potential safety hazards. One of the proposed actions was to consider the 

input from stakeholders on “OPS.GEN.100 Ice and other contaminants” and the associated 

AMC2 and GM1, 2, and 3. The Agency welcomes any comment on how to improve the 

existing material. It should be noted that, for the time being, the regulation of ground deicing / 

antiicing service providers is out of the Agency’s remit. Confirmation that the direct 

regulation of de-icing / anti-icing service providers, by EASA, is not a short term option. 

However, the Study can include feedback from the CRD to the mentioned references above 

and furthermore include recommendations for amendment as appropriate to feedback 

gathered during the Study. 

Appendix II para 6: There is one important change compared to EUOPS/JAROPS 3 insofar 

as the operations manual, when first presented to the competent authority, needs to be fully 

approved. Previously, this was only the case for certain parts. This change has been 

introduced following the new AMC procedure explained in paragraph 56 of the explanatory 

note, as means of compliance are now part of the approval for commercial operators. These 

means of compliance are usually described as procedures in the manual. Therefore, the 

procedures defined in EASA AMC effectively carry the same status as regulations: limiting 

de-icing / anti-icing operators’ programmes to only one AMC would ensure harmonisation 

amongst operators and probably the same for service providers who carry out many of these 

procedures.. 




EASA NPA 2009 – 02b Under Review following CRD 


Draft Opinion and Decision Part-OPS 

Applicability: The second of the seven separate NPAs aimed at developing an Opinion on 

the Implementing Rules for Air Operations of Community Operators and a Decision on the 

related Acceptable Means of Compliance (AMC) and Guidance Material (GM). This section 

is the recognisable replacement for EU OPS and JAA JAR OPS Section 2/TGL 44, known as 

Part Ops. 









OPS.GEN.030 Transport of dangerous goods 

(a) The transport of dangerous goods by air shall be conducted in accordance with the 2007- 

2008 Edition of the Technical Instructions for the Safe Transport of Dangerous Goods by Air 

published by decision of the Council of the International Civil Aviation Organization. (ICAO 

Doc 9284-AN/905.). 

AMC OPS.SPA.001.DG(b)(2)(ii) Approval to transport dangerous goods 

ACCEPTANCE OF DANGEROUS GOODS 

2. An operator or his handling agent should use an acceptance check list which 

allows for: a. all relevant details to be checked; and b. the recording of the results of 

the acceptance check by manual, mechanical or computerised means. 

GM OPS.SPA.001.DG(b)(1) Approval to transport dangerous goods 

PERSONNEL 




Personnel include all persons involved in the transport of dangerous goods, whether 

they are employees of the operator or not. 

This is included as a potential mechanism to be copied for de-icing / anti-icing, although 

ICAO Doc 9640 is inadequate as a source of Implementing Rules. The AMC demonstrates 

the ability for EASA to determine “what” a third-party unregulated body “should” do. 

It may be possible to find a way, legally, for the Agency to refer to a document produced by 

Industry as an accepted set of standards and procedures, this would ensure operators are 

harmonised with their de-icing / anti-icing programmes. References to EUROCAE or RTCA 

documents provide workable examples. 

Another option would be for the Agency to develop its own reference document; and this may 

be better placed as AMC to Part Ops. 

Finding a solution where Industry best-practices can be adopted universally as the sole 

standard will greatly enhance harmonisation in this field. 

Finding a mechanism to directly affect unregulated service providers, and their personnel, via 

the operator’s procedures, policies and contracts will also encourage greater harmonisation. 

OPS.GEN.100 Ice and other contaminants 

(a) At the commencement of a flight the external surfaces of the aircraft shall be clear of any 

deposit which might adversely affect its performance or controllability. 

(b) The operator shall apply ground de-icing/anti-icing processes whenever determined 

necessary, on the basis of inspections and weather conditions. 

AMC2 OPS.GEN.100 

GM1 OPS.GEN.100 



Comments made on this Rule and associated material are contained in an 

Attachment/Appendix XX to this Interim Report. 

There are many options to amend and improve this material, including: 

- offering more detailed guidance to assist operators create their procedures, such that 




harmonisation is more likely, 

- clarification of responsibilities of all those involved, 

- clarification over who conducts checks/inspections, 

- expanding on the need for coordinated communication and decision-making, and the 

variety of ways this can, and is, achieved, 

- taking the opportunity to review the contents and meaning of the anti-icing code, such 

that there is no doubt amongst the ground-crew and flight-crew as to the meaning; 

the aim being to clarify that the trained and qualified person who conducts the post 

treatment check specifically states that the aircraft is free of contamination, 

- separation and delineation of the “all clear” communication from the anti-icing code, 

- encourage the use of safety data in the training programme, 

- the addition of requirements/recommendations for operators when contracting deicing 

/ anti-icing services, as well as training which is included already, 

- with respect to the maintenance inspection and cleaning intervals, consideration to 

current knowledge concerning the use of Type I and whether it does reduce residue 

formation, and also the use of preventive anti-icing and whether this increases the 

risk of residue formation. 

The impacts would be: 

- greater harmonisation of operators’ de-icing / anti-icing procedures and therefore it 

will be mean fewer variations for service providers which will eliminate risk connected 

with confusion, 

- improved clarity in those areas where confusion and misinterpretation frequently 

occur (ref to our Study results?), 

- reduction of risks associated with de-icing / anti-icing. 

OPS.GEN.600 Documents and information to be carried on all aircraft 

(a) On any aircraft, the following documents shall be carried on each flight: 

The Operations Manual is not included in this list. 

Annex IV to Regulation 216/2008 – Essential Requirements for Air Operations 

1.b. A flight must be performed in such a way that the operating procedures specified 




in the Flight Manual or, where required the Operations Manual, for the preparation 

and execution of the flight are followed. To facilitate this, a checklist system must be 

available for use, as applicable, by crew members in all phases of operation of the 

aircraft under normal, abnormal and emergency conditions and situations. 

Procedures must be established for any reasonably foreseeable emergency situation. 

The Operations Manual, and therefore the operator’s de-icing / anti-icing procedures are 

omitted from this list; even the reference in Essential Requirements is unclear. However, the 

checklist for use in all phases of operation will cover de-icing / anti-icing. 

Thought could be given to requiring operators to provide checklists containing 

communication procedures, including the anti-icing code, for pilots to use during de-icing / 

anti-icing operations; other useful information concerning, for example, what to do when 

doubts about HoT exist, and how to conduct inspections/checks. 

Reinforcement could be achieved by including specifically the operator’s de-icing / anti-icing 

procedures and policy in the list of documents to be carried. 

The impact of using a checklist could prevent miscommunication and confusion and also aid 

decision-making. 




EASA NPA 2008 – 22c Under Review following CRD 


Draft Opinion and Decision Organisation Requirements (General) 

Applicability: One of six NPAs issued on “Authority and Organisation Requirements” 

containing draft Opinion on the Implementing Rules for Authorities, draft Opinion on the 

Implementing Rules for Organisations and the related draft Decisions. This NPA specifically 

contains requirements for establishing management systems and performance-based 

methods of operation. 









AMC 2 to OR.GEN.200(a)(2) Management System 

SAFETY MANAGEMENT SYSTEM – SAFETY RISK MANAGEMENT 

OTHER ORGANISATIONS 

1. Hazard identification processes. 

a. Proactive hazard identification processes should be the formal means of collecting, 

recording, analysing, acting on and generating feedback about hazards and the 

associated risks that affect the safety of the operational activities of the organisation. 

b. Hazards, events or safety concerns should be assessed, analysed, reported, the 

data collected and stored. 

c. Information provided by analysis should be distributed. 

d. Confidential reporting systems should be based on established human factors 




principles including an effective feedback process. 

2. Risk assessment and mitigation processes. 

a. A formal risk management process should be developed and maintained that 

ensures analysis (in terms of probability and severity of occurrence), assessment (in 

terms of tolerability) and control (in terms of mitigation) of risks to an acceptable level. 

b. The levels of management who have the authority to make decisions regarding 

safety risks tolerability should be specified. 

3. Internal safety investigation. 

a. The scope of internal safety investigations should include occurrences that are not 

required to be investigated or reported to the competent authority. 

4. Safety performance monitoring and measurement. 

a. Safety performance monitoring and measurement should be the process by which 

the safety performance of the organisation is verified in comparison to the safety 

policies and objectives. 

b. This process should include: 

i. safety reporting; 

ii. safety studies; 

iii. safety reviews including trends reviews; 

iv. safety audits; and 

v. surveys. 

c. The process should be proportional to the size of the organisation and complexity 

of the activities and be compatible with other management systems and processes 

used by the organisation. 

5. The management of change. 

a. The management of change should be a formal process that identifies external and 

internal change that may affect the activities of the organisation. It utilises the organisation’s 

existing hazard identification, risk assessment and mitigation processes to ensure that there 

is no adverse effect on safety. 

6. Continuous improvement of the safety system. 

a. Continuous improvement should determine the immediate causes of below 




standard performance and their implications for the management system, and rectify 

situations involving below standard performance identified through safety assurance 

activities. The changes should be tracked to ensure that they are effective. 

b. Continuous improvement should be achieved through proactive evaluation of: 

i. facilities, equipment, documentation and procedures through safety audits 

and surveys; 

ii. Individual performance to verify the fulfilment of their safety responsibilities; 

and 

iii. reactive evaluations in order to verify the effectiveness of the system for 

control and mitigation of risk. 

Introduces ICAO SMS SARPS. 

1.a Highlights the need to ensure operators are encouraging and providing the means for 

service providers to collect and supply safety data concerning human factors, and 

organisational factors within their own organisation. Linking this to the operator’s de-icing / 

anti-icing policy/programme will highlight the need. 

2.b A nominated post-holder may be the person responsible to make the decision to either 

take mitigating measures or not, however, they will need to consult an expert on the subject 

of de-icing / anti-icing. The safety manager may not be suitably qualified or experienced, and 

therefore requiring the operator to nominate a subject-matter-expert will resolve this. 

3.a Human slips, errors and deviations made by service provider personnel are not required 

to be reported, let alone investigated. Mandatory occurrence reporting schemes tend to 

control the focus of some operators; however, under the auspices of a performance-driven 

regulation, such as SMS, the requirement to go beyond MORs is clear. 

4.a Encouraging operators to include safety objectives within their de-icing / anti-icing policy 

should drive the need to collect data in order to measure performance. Such performance 

initially may revolve around increasing reports from service providers from zero in some 

cases to what they would be expected to be. (Quote Kevan Baines of Baines-Simmons: 

when speaking about maintenance organisations at an IFA conference 22 Sep at Gatwick, 

he said “they should be receiving on average 2 human factors reports per person per year, 

because that’s what airlines get from their pilots”. This need may be met through AMC to 

OR.GEN.205 Contracting and Purchasing, shown below. 

5.a Highlights the need to assess new providers for safety performance before, or when new 




contracts are signed. 

6. Extends the activities of the Quality/Compliance System to assessing a service provider’s 

own safety management system. 

Operators could be required, through their de-icing / anti-icing programmes to actively 

encourage service providers to provide them with human factors and occurrence reports (or 

summary analyses); this will help operators comply with the SMS requirements and also to 

understand where the greatest risk exists. 

A subject-matter-expert could be nominated by an operator to provide advice to the safety 

manager concerning risk reduction measures and risk analysis. 

Across Europe there is almost a complete lack of the gathering and dissemination of de-icing 

/ anti-icing safety; a centrally-driven and facilitated safety initiative, including survey, would 

provide a suitable kick-start. 

Operators can be encouraged to set safety objectives within their de-icing / anti-icing 

programmes. 

New contracts with new or existing service providers can be accompanied by a safety 

assessment. 

Ensuring that the SMS requirements are met and followed in the area of de-icing / anti-icing 

will have a positive effect on identifying currently unknown hazards and reducing risk. 

Providing motivation and guidance for operators to accomplish this and bring about a culture 

change within service providers will help to make this more successful. 

NB: The collection of safety data by service providers and the presentation of this data to 

operators may require a universal system. Either many operators collect all the data from a 

service provider and they each conduct analyses, which is a duplication of effort; or each 

operator is only presented with safety data specific to them, which will “hide” other precursors 

from their view. A third system would be for service providers to supply safety data to a 

central organisation for analysis and the results then distributed universally and used to 

improve safety. Such a system could operate voluntarily, therefore requiring a coordinating 

body for all service providers; or it could operate through the requirements of operators as a 

condition of contract. The benefits to the Industry of a centralised system is that it can be 

extended to other unregulated areas where safety data is scarce. 





SAFETY MANAGEMENT SYSTEM – ORGANISATION AND ACCOUNTABILITIES 


The management system of an organisation should encompass safety by implementing the 

following: 

1. SMS organisational structure. 

a. Typically this should include a safety manager, a safety review board and a safety 

action group. 

2. The safety manager. 

a. The safety manager should be responsible and the focal point for the development, 

administration and maintenance of an effective safety management system. 

b. The functions of the safety manager should be to: 

i. manage the implementation plan on behalf of the accountable manager; 

ii. facilitate hazard identification, risk analysis and management; 

iii. monitor corrective action to ensure their accomplishment; 

iv. provide periodic reports on safety performance; 

v. maintain safety documentation; 

vi. plan and organise staff safety training; 

vii. provide independent advice on safety matters; 

viii. advise senior managers on safety matters; 

ix. assist line managers; 

x. oversee hazard identification systems; 

xi. be involved in occurrence / accident investigations; and 

xii. monitor compliance. 

5. Safety accountabilities and responsibilities. 

a. The organisation should define the accountabilities of the accountable manager 

and the safety responsibilities of key personnel. 

2.b. The safety manager will need to “seek and consult” with relevant experts in order to 

accomplish vii, viii and ix. The safety manager may not be an expert in de-icing / anti-icing; 




having a subject-matter-expert nominated by the operator will resolve this issue. 

5.a. A good safety policy should also define the minimum safety responsibilities of all staff, 

furthermore all personnel in positions where decisions are made that affect operations 

(indirectly or directly) will need to have their safety responsibilities defined; at a minimum this 

should cover a set of requirements for all managers. See AMC 2 to OR.GEN.200(a)(4)1.a&b 

below. 

A subject-matter-expert could be nominated by an operator to provide advice to the safety 

manager concerning risk reduction measures and risk analysis. 

Safety responsibilities of all those involved with de-icing / anti-icing and connected 

coordination, communication and decision-making can be defined within the operators 

policy/programme. 

Clearly defined responsibilities will enhance coordination and communication, and therefore 

enhance safety. 


TRAINING AND COMMUNICATION ON SAFETY 


1. Training. 

a. All staff should receive safety training as appropriate for their safety responsibilities. 

b. In particular all managers, supervisors and operational personnel should be trained and be 

competent to perform their SMS duties. 

2. Communication. 

a. The organisation should establish communication about safety matters that: 

i. ensures that all staff are fully aware of the SMS; 

ii. conveys safety critical information, and especially that related to assessed risks 

and analysed hazards; 

iii. explains why particular actions are taken; and 

iv. explains why safety procedures are introduced or changed. 

2.a.ii. As per previous comments made above to AMC 2 OPS.GEN.100 para 6 Training, it is 




essential that this information is fed back into the training programme, and at intervals 

dependant on the critical nature. 

Operators can be required to use relevant safety data to amend the de-icing / anti-icing 

training programme, and where this information is critical to ensure that it is communicated 

effectively and immediately. 

The feedback of safety critical information on de-icing / anti-icing matters will raise vigilance 

to potential hazards and known areas of risk. 

AMC to OR.GEN.200(a)(5) Management System 

OCCURRENCE REPORTING SCHEME 

1. The overall objective of the scheme is to use reported information to improve the level of 

flight safety and not to attribute blame. 

2. The objectives of the scheme are: 

a. to enable an assessment of the safety implications of each relevant incident and 

accident to be made, including previous similar occurrences, so that any necessary 

action can be initiated; and 

b. to ensure that knowledge of relevant incidents and accidents is disseminated, so 

that other persons and organisations may learn from them. 

3. The scheme is an essential part of the overall monitoring function and it is complementary 

to the normal daytoday procedures and ‘control’ systems and is not intended to duplicate or 

supersede any of them. The scheme is a tool to identify those occasions where routine 

procedures have failed. 

4. Occurrence reports should remain in the database when judged reportable by the person 

submitting the report as the significance of such reports may only become obvious 

subsequently. 

Emphasis on incidents and accidents detracts from the many unreported events which are 

most valuable in preventing further incidents and accidents. There is benefit in including 

direct reference to human factors – errors, slips, deviation, omissions etc. The AMC also 

highlights the benefits of sharing information with other organizations; therefore encouraging 

service providers to collect and share their safety data is also valid. 




Explanation of the occurrence reporting scheme can include an emphasis on the need to 

collect “lower level” safety data, such as self-reported errors etc. Operators can be required 

to feedback their safety data to their service providers. 

Sharing information will increase trust within service provider personnel and therefore 

encourage a change of culture leading to more self-disclosure. 


COMPLIANCE MONITORING SYSTEM GENERAL 

AMC to OR.GEN.205 Contracting and purchasing 

Compliance monitoring responsibility by contracting. 

1. Contracted activities. 

a. An organisation may decide to contract certain activities to external organisations. 

b. A written agreement should exist between the organisation and the contracted 

organisation clearly defining the safety related services and quality to be provided. 

c. The contracted safety related activities relevant to the agreement should be 

included in the organisation's Compliance Monitoring Programme. 

d. The organisation should ensure that the contracted organisation has the necessary 

authorisation or approval when required, and commands the resources and 

competence to undertake the task. 

e. If the organisation requires the contracted organisation to conduct activity which 

exceeds the contracted organisation’s authorisation or approval, the organization is 

responsible for ensuring that the contracted organisation's compliance monitoring 

takes account of such additional requirements. 

GM OR.GEN.205 Contracting and purchasing 

CONTRACTING OPERATORS 

1. Operators may decide to outsource certain activities to external organisations for the 

provision of services related to areas such as: 

a. Ground Deicing/Antiicing; 

b. Ground handling; 

d. Flight Support (including performance calculations, flight planning, navigation database 




and dispatch); 

d. Training; and 

e. Manual preparation. 

2. The ultimate responsibility for the product or service provided by external organizations 

should always remains with the operator. 

AMC 1 to OR.GEN.200(a)(7) outlines the compliance monitoring system, previously known 

as Quality System. No specific paragraph is dedicated to sub-contracted services as exists 

in JAA AMC OPS 1.035 para 5.1. However, this is addressed in AMC and GM to 

OR.GEN.205. 

AMC to OR.GEN.205 provides the mechanism by which operators can define, within 

contracts, the need for service providers to supply safety data. 

GM OR.GEN.205 The ways in which operators ensure integrity of navigation data (LoA) 

provided by external organisations may be valuable as a template for how operators ensure 

the integrity of de-icing / anti-icing services. 

Operators can be encouraged to re-draft contracts with service providers to include safety 

related activities. 

Considerations can be given to regulation of other contracted safety critical activities, such as 

navigation data integrity and fuel quality to determine whether a parallel can be drawn with 


Review and revision of contracts will enable operators to re-focus service providers onto 

safety. 




EASA NPA 2009 – 02c Under Review following CRD 


Draft Opinion and Decision Part-OR Sub-part OPS 

Applicability: The third of the seven separate NPA 2009 – 02 is aimed at developing an 

Opinion on the Implementing Rules for Air Operations of Community Operators and a 

Decision on the related Acceptable Means of Compliance (AMC) and Guidance Material 

(GM). This section is designated as Organisation Requirements concerning Operations with 

recognisable elements from EU OPS and JAA JAR OPS Section 2/TGL 44, known as Part 

Ops. 









OR.OPS.015.MLR Operations Manual 

(a) The operator shall establish an Operations Manual (OM) containing all necessary 

instructions, information and procedures, including standard operating procedures and 

training programmes and syllabi, for all personnel involved in air operations to perform 

their duties and for the aircraft operated. 

AMC5 OR.OPS.015.MLR Operations Manual 

CONTENTS – COMMERCIAL AIR TRANSPORT 

8.2.4 Deicing and anti-icing on the ground. A description of the deicing and anti-icing policy 

and procedures for aircrafts on the ground. These should include descriptions of the types 

and effects of icing and other contaminants on aircrafts whilst stationary, during ground 

movements and during takeoff. In addition, a description of the fluid types used should be 

given including: 

a. Proprietary or commercial names; 




b. Characteristics; 

c. Effects on aircraft performance; 

d. Holdover times; and 

e. Precautions during usage. 

This Rule and AMC remains the same as Appendix 1 to OPS 1.1045 A.8. They contain very 

little guidance, and focus on one element (fluid types) but omit many others. The de-icing 

/anti-icing policy and procedures are not one of the OM contents that requires specific 

approval by the Authority (JAA IEM OPS 1.1040(b)); instead the operator only has to ensure 

that the detailed structure of the Operations Manual is acceptable to the Authority (OPS 

1.1045). 

It is an option to revise this Appendix and include other elements, such as: the operator’s 

communication and coordination procedures (for de-icing / anti-icing); the anti-icing code; 

inspection and checking procedures; re-assessment of HOT in changing conditions; affect of 

re-hydrated fluid residues on flying control surfaces; and contents of the operator’s standard 

contract for de-icing / anti-icing etc. 

Revision of the OM contents for de-icing / anti-icing may have the effect of operators 

reviewing their procedures (especially if the revision is in conjunction with other regulatory 

changes); this may then have the effect of the revision of training programmes and 

awareness campaigns. Raised awareness and more valuable information available in the 

OM will be good for safety. 

OR.OPS.210.AOC Personnel requirements 

(a) The operator shall, in accordance with OR.GEN.210(b) nominate post holders 

responsible for the management and supervision of the following areas: 

(1) flight operations; 

(2) crew training; 

(3) ground operations; and 

(4) compliance monitoring. 

(b) Adequacy and competency of staff. 

(1) The operator shall employ sufficient staff for the planned ground and flight 

operations. 

(2) All personnel assigned to, or directly involved in, ground and flight operations 




shall: 

(c) Supervision of staff 

(i) be properly trained; 

(ii) demonstrate their capabilities in the performance of their assigned duties; 

and 

(iii) be aware of their responsibilities and the relationship of their duties to the 

operation as a whole. 

(1) The number of supervisors to be appointed shall be sufficient in relation to the 

structure of the operator and the number of staff employed. 

(2) The duties and responsibilities of these supervisors shall be defined, and any 

other necessary arrangements shall be made to ensure that they can discharge their 

supervisory responsibilities. 

(3) The supervision of crew members and personnel involved in the operation shall 

be exercised by individuals with adequate experience and the skills to ensure the 

attainment of the standards specified in the operations manual. 

There is no specific mention of dedicated safety critical areas of operations in this Rule, only 

ground and flight operations. In the case of de-icing / anti-icing, it is difficult to find a single 

contact within an operator’s organisation who fully understands this whole aspect of the 

operation and who takes responsibility for all aspects of the operator’s de-icing / anti-icing 

policy and procedures. 

A list can be provided in (b)(2) of specific ground operations tasks, such as loading, 

dangerous goods, etc and including de-icing / anti-icing, where an operator should nominate 

a suitably knowledgeable and experienced staff member as a focal point for each of these 

technical issues. The areas involved may cover flight-crew, ground-crew, de-icing / antiicing 

operatives, equipment, storage facilities, compliance auditing and contracting service 

providers. 

De-icing / anti-icing tasks are commonly dispersed amongst several employees; nominating 

a focal point, or subject-matter-expert would ensure that actions and decisions made by the 

individuals are at least coordinated, and communications with NAAs and service providers 

are efficient and congruent. 




EASA NPA 2008-22b Pending review of CRD 

Authority Requirements 

Applicability: The NPA on “Authority Requirements” contains draft Opinion on the 

Implementing Rules for Authorities, draft Opinion on the Implementing Rules for 

Organisations and the related draft Decisions. This is the equivalent of JAA Joint 

Implementations Procedures (JIPS), relating instead to the relevant EASA Implementing 

Rules. 

Options: For all elements of this NPA 2008 – 22b, there may be time and motivation to 


anti-icing, through authority requirements. Otherwise, amendments can be proposed after 

publication of the Implementing Rules for Operations and Authority Requirements. 




AR.GEN.030 Mutual exchange of information 

(a) In order to contribute to the improvement of air safety, the competent authorities shall 

participate in a mutual exchange of all necessary information, including all finding raised and 

followup actions taken as a result of oversight of persons and organizations exercising 

activities on the territory of a Member State. 

AR.GEN.035 Mandatory safety information 

(a) The competent authorities shall issue mandatory safety information to react to a safety 

problem which involves person(s) or organisation(s) subject to the Basic Regulation and its 

implementing rules and requiring immediate action. 

(b) Mandatory safety information shall be made publicly available and contain, as a 

minimum, the following information: 

(1) the identification of the safety problem; 

(2) the identification of the affected activities; 

(3) the actions required and their rationale; 




(4) the time limit for compliance with the actions required by the mandatory safety 

information; and 

(5) its date of entry into force. 

AR.GEN.040 Reporting 

(a) In addition to the reports required by the applicable legislation on occurrence reporting in 

civil aviation, the competent authority shall provide reports on safety significant occurrences 

to the Agency. 

These three requirements adequately highlight: 

− the need for NAAs to cooperate with each other by exchanging information on de-icing 

/ anti-icing issues if it is deemed safety improvements can be made 

− the need for NAAs to issue mandatory safety information, including actions to be 

taken, when a safety matter is identified, and 

− the need for NAAs to collect data other than through MORs. 

The most effective and efficient way to achieve this is for the Agency to coordinate and 

facilitate a safety initiative aimed at de-icing / anti-icing. 

The impact would be a harmonised programme which ensures more data is collected and 

analysed and any recommendations for action likely to be taken up. 

AR.GEN.305 Monitoring of activities 

(a) The competent authority shall establish and maintain an oversight programme to monitor 

persons and organisations exercising activities on the territory of the Member State or 

certified by the competent authority that is proportionate to the complexity of the activities 

and the risks involved. The programme shall be developed taking into account the size of the 

organisation, local knowledge, possible certification according to industry standards and past 

surveillance activities. 

(b) The oversight programme shall include: 

(1) sample inspections, including unannounced inspections; 

(2) for each organisation, at least once every 24 months: 

(i) regular audits at intervals determined by the results of past surveillance 

activities; 




(ii) meetings convened with the accountable manager to ensure they remain 

informed of significant issues arising during audits.. 

(c) The oversight shall focus on a number of key risk elements and identify any finding. 

(d) The competent authority shall keep and update the continuing oversight programme, 

including a list of the approved organisations under its supervision, the dates when audit 

visits are due and when such visits were carried out. 

Requires NAAs to monitor non-certified, as well as certified, organisations through a 

programme of audits and inspections. I am not convinced this is the meaning intended, 

however it is useful. 

It may be possible to use this requirement to prompt NAAs into an oversight programme of 

de-icing / anti-icing service providers directly in addition to that conducted through the 

operators. 

24-monthly audits would involve effort and investment, however, a NAA programme which 

enhanced the operators’ auditing would provide the NAA with a greater insight into any 

variability of service provision standards. 




EASA NPA 2009 – 02D Pending review of CRD 

“Implementing Rules for Air Operations of Community Operators” - Draft Opinion and 

Decision PartAR – Subparts GEN, OPS and CC. 

Applicability: This NPA contains the draft Opinion on the Implementing Rules for Air 

Operations of Community Operators, the Subparts related to Air Operations of the draft 

Opinion on the Implementing Rules for Organisation Requirements, the Subparts related to 

Air Operations of the draft Opinion on the Implementing Rules for Authority Requirements 

and the related draft Decisions (AMC, CS and GM). 



anti-icing, through authority requirements. Otherwise, amendments can be proposed after 

publication of the Implementing Rules for Operations and Authority Requirements. 




AMC 1 AR.GEN.300 Continuing oversight OPS 

GENERAL 

1. The competent authority should assess the operator and monitor the continued 

competence to conduct safe operations in compliance with the applicable requirements. The 

competent authority should ensure that accountability for assessing operators is clearly 

defined. This accountability may be delegated or shared, in whole or in part. Where more 

than one agency is involved, an individual department manager should be appointed under 

whose personal authority operators are assessed. 

Not directly applicable to our topic of de-icing / anti-icing, however this AMC highlights a 

useful principle which should be transferable to other areas and situations. That is, the 

appointment of a single person to accept authority where multiple agencies are involved. 

An NAA attempting to oversee de-icing / anti-icing operations and associated activities is 

faced with multiple agencies (aerodromes, service providers, operators, maintenance 




organisations): it is an option that NAAs can appoint one single person as the de-icing / antiicing 

authority, whose responsibility is to coordinate oversight of this safety critical activity. 

The impact would be easier and improved communication of issues between authorities, the 

Agency, and operators. The success of any harmonised cooperative programmes and 

initiatives will be greatly enhanced. 

GM 1 AR.GEN.300 Continuing oversight OPS 

1. Responsibility for the conduct of safe operations lies with the operator. Under these 

provisions a positive move is made towards devolving upon the operator a share of the 

responsibility for monitoring the safety of operations. The objective cannot be attained unless 

operators are prepared to accept the implications of this policy including that of committing 

the necessary resources to its implementation. Crucial to success of the policy is the content 

of PartOR which requires the establishment of a management system by the operator. 

2. The competent authority shall continue to assess the operator's compliance with the 

applicable requirements, including the effectiveness of the management system. If the 

management system is judged to have failed in its effectiveness, then this in itself is a breach 

of the requirements which may, among others, call into question the validity of a certificate, if 

applicable. 

3. It is essential that the competent authority has the full capability to adequately assess the 

continued competence of an operator by ensuring that the whole range of activities is 

assessed by appropriately qualified personnel. 

4. The safety manager, designated by the operator in accordance with PartOR, shall have 

direct access to the accountable manager. The accountable manager is accountable to the 

competent authority as well as to those who appoint him. It follows that the competent 

authority cannot accept a situation in which the accountable manager is denied sufficient 

funds, manpower or influence to rectify deficiencies identified by the management system. 

This AMC clearly states the intention of performance-based regulation to devolve 

responsibility for oversight away from the regulator and onto the operator; therefore, any 

recommendation for NAA oversight of service providers is moving against the current 

regulatory impetus, and may be met with resistance on this fact alone. The operators’ 

management systems do have to prove themselves capable though, and in this respect the 

NAA can legitimately require more scrutiny and the submission of more evidence from 




operators. 

Supporting such proposals is an option for improvement; as is encouraging the provision of 

guidance for NAAs specifically on how operators can/should improve their oversight of deicing 

/ anti-icing service providers. 

Time will tell whether the adoption and implementation of performance-based regulation will 

make an impact on operators’ oversight of service providers; however, if applied in a spirit of 

positive safety culture, and support provided to service providers to change their culture, the 

impact on safety should be positive. 

AMC 2 AR.GEN.300 Continuing oversight OPS 

OPERATIONS INSPECTIONS AND MONITORING PROCEDURES 

2. Inspection and monitoring, on a scale and frequency appropriate to the operation, should 

include at least: 

- infrastructure 

- manuals 

- training 

- crew 

- records 

- maintenance 

- equipment 

- release of flight/despatch 

- dangerous goods 

- operator's management system. 

It would be easy for an NAA to omit inspecting how operators oversee contracted-out 

services as they are not specifically mentioned. Specifically how operators attempt to meet 

their own requirements through the contracts they hold; how they communicate and collect 

safety data with service providers; and what influence they have over the service providers 

training etc. The caveat ‘should include at least’ is a week point in this AMC. 

An option would be to append a suitable option such as “ground handling”, together with an 




explanation, or guidance material. 

The impact would be clearer instructions for NAAs to take some notice of how effective 

operators are at influencing the standards set by service providers. 

AMC 3 AR.GEN.305 Monitoring of activities OPS 

1. The competent authority should establish a schedule of inspections appropriate to each 

operator's business. The planning of inspections should take into account the results of the 

hazard identification and risk assessment conducted and maintained by the operator as part 

of the operator’s management system. Inspectors should work in accordance with the 

schedule provided to them. 

Assuming that the operator’s SMS is effective and suitably resourced, this AMC could be 

effective. However, unless NAAs are specifically looking to learn whether operators are 

collecting adequate safety data from service providers with which to effectively identify all 

hazards, the effects of this AMC will be less than desired. Similarly, to limit (in this respect) 

inspections to only cover the results of an operator’s hazard identification and risk 

assessment system, deters the NAA scope to inspections in response to valid safety data 

attained from elsewhere. 

It may help to define clearly that inspections programmes ought to take account of any 

relevant safety data regardless of source (eg FAA, FSF, ERA, other operators etc). A 

dedicated safety initiative would help to inform NAAs of the hazards that exist in the Industry. 

This would have the effect of NAAs helping to cross-fertilise best-practices across operators. 

AMC to AR.OPS.300 Certification procedure OPS 

PROCEDURES FOR THE APPROVAL OF CARRIAGE OF DANGEROUS GOODS 

The competent authority should verify that: 

1. the applicant is in compliance with the applicable requirements and recognized standards; 

2. the procedures specified in the procedures manual are sufficient for the safe transport of 

dangerous goods; 

3. operations personnel is properly trained; and 

4. a reporting scheme is in place. 

This is shown as an example, if de-icing / anti-icing was ever considered as requiring special 




operations approval. 

The NAA could verify compliance with recognised standards (AEA etc), and that the 

operator’s own procedures (as per the OM) and contracts with service providers were 

sufficient. It would also allow the NAA to verify the operator’s winter operations training 

programme was effective and ensure that the operator was actively collecting safety data 

from service providers. 

This would require NAA effort and investment; it would also raise the issue that where 

special operations approval was not granted that an operator would not be able to operate 

effectively in conditions of contamination. 




ICAO Doc 9640 2 nd Edition, 2000 

MANUAL OF AIRCRAFT DE-ICING / ANTI-ICING OPERATIONS 

Applicability: Useful because de-icing / anti-icing involves many stakeholders, and they are 

all addressed in this document. Otherwise this guidance would be distributed across several 

different Annexes – for operators, maintenance, aerodromes, and air traffic control. It also 

provides some basic guidance for service personnel. 

Guidance only – from which “standardised procedures and guidance material” can be 

developed for various segments of Industry, eg: manufacturers, air operators, engineering, 

maintenance, and service organisations. 

Relevance is lost – updates are few and far between. Not generally used by Industry as 

better Industry standards exist such as AEA and SAE. 

Options: In the long-term there may be scope to update this document, however, this would 

only duplicate more readily accessible and relevant standards which already exist, and which 

are updated annually. 

NAAs have the option to adopt/adapt elements of this document into their regulations for 

operators. 

NAAs/EASA can consider a similar document (reviewed and amended) so that a single 

source document is available for all stakeholder groups involved. 

Impact: Without a coordinated approach, there would be little effect as there is no 

requirement and harmonisation of procedures would not be improved. 

Forward 

A review of the history of aeroplane accidents in the air transportation industry revealed that 

a substantial number are related to winter operations. An examination of these accidents 

showed a need for formally developed regulations and procedures governing aeroplane deicing/anti-icing 

operations, directed towards all segments of aviation, including aeroplane 

manufacturers, airline operators, and engineering, maintenance and service organizations. 

This material was intended, in particular, for use by flight crews of all aeroplane types and 

categories, as well as aeroplane maintenance and service personnel. 

This statement can be considered as still valid, and that all segments of aviation still need 

formally developed regulations and procedures. In Europe this also infers harmonisation 




across states. 

This paragraph also adequately highlights the multitude of stakeholders involved. 

1.6 The only known method for positively ascertaining that an aeroplane is clean prior to 

take-off is by close inspection. 

1.7 It is essential for all personnel to recognize that final assurance for a safe take-off rests in 

a thorough pre-take-off inspection or check. 

2.4 Numerous techniques for complying with the Clean Aircraft Concept have been 

developed. Proper and adequate deicing, followed by an application of appropriate anti-icing 

fluid, provides the best protection against contamination. A visual or physical check of critical 

aeroplane surfaces to confirm that the treatment has been effective and that the aeroplane is 

in compliance with the Clean Aircraft Concept must be carried out. 

The message can not be clearer: whoever conducts these checks and inspections is the last 

link in the chain before the person responsible (the aircraft captain) can decide whether the 

aircraft is airworthy or not. Yet there is no regulated method of ensuring that these checks 

and inspections are conducted by appropriately trained and qualified personnel to an 

acceptable standard. NAAs have no direct control over how this is achieved, as they 

delegate all responsibility to the operator. Even if operators are diligent, they have to (in 

practice) delegate responsibility to a multitude of different service providers and/or other third 

parties; each with varying capabilities, experience and possibly procedures. 

If NAAs/EASA take these paragraphs as critical and understand the inevitability of human 

error occurring amongst the cadre of inspectors and checkers, then regulatory action must 

be considered as a potential risk mitigation measure. 

To do nothing does not address the known facts highlighted simply and clearly in these three 

paragraphs and the history of accidents related to winter operations as indicated in the 

forward. 

5.4 At the completion of aeroplane de-icing/anti-icing, the pilot-in-command will be provided 

with the following information: 

a) fluid type; 

b) fluid/water ratio (Type II, III or IV only); 

c) start time of the final anti-icing application; and 




d) confirmation that the aeroplane is in compliance with the clean aircraft concept. 

This basic information will assist the pilot-in-command in estimating an appropriate holdover 

time from the range provided in the operator’s table. 

There is no reference as to who passes this information, however, it can be clearly inferred 

that it is the intention for this information message (anti-icing code) to include confirmation 

that the “clean wing concept” applies, and that the person who confirms this is the person 

conducting the post treatment check, as per para 2.4 above. In fact this should apply to any 

external check – either the aircraft is “clean” or not. 

It will be helpful to require (clearly and directly) all operators to ensure that whoever they use 

to conduct external checks is both trained and qualified to do so and that only such a person 

can pass the final element of the anti-icing code. 

This may reduce some uncertainty by ensuring operators cover this aspect clearly in their 

contracts, and where a service provider will not (for whatever reason) provide this 

confirmation, that a suitable third-party is used. 

CHECKS AFTER THE APPLICATION OF DE-ICING/ANTI-ICING FLUIDS 

6.3 A check to ensure compliance with the Clean Aircraft Concept is made immediately 

following the application of deicing/anti-icing fluids and is carried out by a qualified person in 

accordance with the approved operator plan and procedures. 

6.4 The pre-take-off check, which is the responsibility of the pilot-in-command, ensures that 

the critical surfaces of the aeroplane are free of ice, snow, slush or frost just prior to take-off. 

This check shall be accomplished as close to the time of take-off as possible and is normally 

made from within the aeroplane by visually checking the wings or other surfaces. 

6.5 The pre-take-off check procedures are a critical part of the ground operation and become 

the only means by which the pilot-in-command can ensure that the aeroplane is in 

compliance with the Clean Aircraft Concept prior to take-off. If stipulated by the regulatory 

authority, aeroplane manufacturer, or operational specification or if requested by the pilot-incommand, 

an external check of aeroplane critical surfaces shall be conducted by qualified 

ground personnel. 

6.6 The pilot-in-command has the responsibility to continually monitor the weather and 

aeroplane condition to ensure compliance with the Clean Aircraft Concept. If this requirement 

cannot be satisfied by either an internal or external check of aeroplane critical surfaces, then 

another de-icing/anti-icing of the aeroplane must be accomplished. Special equipment or 




procedures may be required to carry out this check at night or under severe weather 

conditions. 

It is clear that any external check should be conducted by a qualified person. As these 

checks should be in accordance with the operator’s plan and procedures, the operator shall 

stipulate, or agree to, the training and qualification standard required. 

Reinforcement can be made of the need for external checks to be conducted by a trained 

and qualified person, and a clear connection made with the final element of the anti-icing 

code. 

This may reduce some uncertainty by ensuring operators cover this aspect clearly in their 

contracts, and where a service provider will not (for whatever reason) provide this 

confirmation, that a suitable third-party is used. 

Authority’s Responsibilities 

7.1 The regulatory authority ensures that every operator shall have an approved deicing/anti-icing 

programme or procedures. The programme shall require that operators 

comply with the Clean Aircraft Concept. 

7.3 The de-icing/anti-icing programme shall clearly define areas of responsibility for the 

operator. All persons involved in ground de-icing/anti-icing activities shall be trained and 

qualified in the procedures, communications and limitations of their area of responsibility. 

The de-icing/anti-icing programme shall cover all locations within the operator’s route 

network including de-icing/anti-icing accomplished by subcontract. 

In Europe, NAAs do not approve operators’ de-icing / anti-icing plans, policies, procedures or 

programmes. “Ensuring that every operator shall have an approved programme or 

procedures” may be interpreted differently if the NAA offered AMC. 

NAAs/EASA can be encouraged to agree (create) an AMC, in support of robust rules, which 

operators can adopt and gain tacit approval, or request specific approval for 

variations/deviations. 

A coordinated development programme would be needed, however, there is sufficient 

expertise and knowledge readily available that this should be relatively simple. The largest 

problem would be acquiring subject-matter-experts appointed by each NAA to participate. 

The positive impact would be greater harmonisation of operators procedures and/or 

programmes, which may impact positively on standards of service provision. 




Operator’s Responsibilties 

7.4 Ground de-icing/anti-icing is, technically, a part of the operation of the aeroplane. The 

person in charge of the deicing/anti-icing procedure is responsible for accomplishing this 

procedure and verifying the results of the de-icing/anti-icing treatment. Additionally, the deicing/anti- 

icing application information reported to the flight deck crew is also a part of the 

technical airworthiness of the aeroplane. 

7.5 The person responsible for the de-icing/anti-icing process must be clearly designated, 

trained and qualified. This person shall check the aeroplane for the need to de-ice, shall 

initiate de-icing/anti-icing, if required, and is responsible for the correct and complete deicing/anti-icing 

treatment of the aeroplane. The final responsibility for accepting the aeroplane 

after de-icing/anti-icing rests, however, with the pilot-in-command. 

7.4 Introduces the concept of a person in charge, and it can be inferred here that ICAO mean 

it to be someone “outside” of the aircraft. In reality, there may be confusion as to who is in 

charge, as many people may be involved in the decision-making: operator’s flight operations 

dept; captain, ground operative; crew chief; service provider control dept; third-party 

“inspector”. 

7.4 Makes it clear that the anti-icing code has meaning other than just information for 

calculation of HoT; it confirms that the final element must confirm, or not, that the clean wing 

concept is met. 

7.5 Places all decision-making responsibilities on the shoulders of the “outside” person 

referred to in the earlier paragraph 7.4. Again, in practice this is a coordinated operation with 

many inputs. 

It is possible to require operators make it clearer as to where responsibilities lay, and who 

makes which decisions. This can be achieved by requiring, within an operators 

procedures/programme, a coordination and communication plan and procedures; these 

should assist the pilot in establishing for all destinations who is “in charge” and what 

responsibilities they uphold. 

Any rules, AMC or GM which help operators establish more full-proof procedures will have a 

positive impact on safety. AMC and GM can help to increase harmonisation. 

DE-ICING/ANTI-ICING COMMUNICATIONS 

10.1 The communications between ground and flight crews are an integral part of the de- 




icing/anti-icing process and must be included in every de-icing/anti-icing procedure. 

10.3 Upon completion of the de-icing/anti-icing procedure and the associated check of the 

aeroplane, the flight crew shall be provided with information about the final step of the deicing/anti-icing 

process which ensures that the aeroplane is in compliance with the Clean 

Aircraft Concept; this information shall be given in the form of de-icing/anti-icing code. 

10.4 The de-icing/anti-icing codes, which are to be recorded, shall be communicated to the 

flight crew in the following sequence: 

Element A: specify type of fluid used, 

Element B: specify the percentage of de-icing/anti-icing fluid in the fluid/water mixture, 

Element C: specify in local time, in hours and minutes, the beginning of the final de-icing/antiicing 

step, 

The transmission of elements A, B and C to the flight crew confirms that the de-icing/antiicing 

was completed and that the aeroplane is clean. 

10.6 After de-icing/anti-icing and prior to departure, the flight crew must receive an “all 

clear” signal from the ground crew that it is safe to taxi. 

This highlights the need for clear and precise communications, and a common understanding 

of the meaning of these communications. 

10.6 There is a potential for confusion, especially when the same person communicates the 

anti-icing code and the “all clear” signal. “All clear” is perhaps too “close” a phrase to 

“contamination is now all cleared”, and the recommended anti-icing code does not contain a 

specific “aircraft clean” communication. Having pilots “infer” that the aeroplane is clean from 

the three elements of the code is prone to error, as these elements can be passed before an 

inspection is conducted, and can be passed (required) even if the treatment failed. 

Clear communication plans and procedures are essential for safe de-icing / anti-icing 

operations; guidance can be provided to operators. 

Review and universally agreed amendments to the anti-icing code can be undertaken to 

include a definite “success/fail” element, and to clearly separate the code from any “all clear” 

signal. 

Clearer and less ambiguous communications will enhance safety. 

Clarifying the meaning of a final element (aeroplane clean) will reinforce the responsibilities 

of the service provider. 

9.5 Details of the ATC winter operations plan shall be included in all air traffic controllers’ 




manuals. It shall provide for the shortest possible taxi time to the departure runway for takeoff 

after the completion of the de- icing/anti-icing of an aeroplane. It shall, where appropriate, 

contain provisions for centralized de-icing/anti-icing and remote pad de-icing/anti-icing and 

for secondary de- icing/anti-icing at the aerodrome. 

This is useful information for operators to include in their de-icing / anti-icing programmes. 

Operators can be recommended/required to consult with ATC concerning taxi times, at those 

aerodromes where HoT is critical. 

This will raise awareness of potential problem areas; perhaps save money through requests 

for inappropriate de-icing / anti-icing, and it may create an impetus amongst concerned 

stakeholders for investment in facilities at certain aerodromes. 




ICAO Annex 14 5 th Edition, July 2009 

AERODROMES 

Applicability: This Annex contains Standards and Recommended Practices (specifications) 

that prescribe certain facilities and technical services normally provided at an aerodrome. It 

is not intended that these specifications limit or regulate the operation of an aircraft. 

The specifications, unless otherwise indicated in a particular context, shall apply to all 

aerodromes open to public use in accordance with the requirements of Article 15 of the 

Convention. 

Indirect Regulation. National responsibility to implement (States “shall”). EASA competence 

not extended yet to Implementing Rules, but Essential Requirements (EC Reg 1108/2009) 

introduced into Basic Reg 216/2008. 

Options: Reconsideration to how these SARPS are interpreted and implemented by NAAs 

and eventually EASA could be considered. 

Impact: Depending on any reconsiderations, the impacts may be variable. If nothing is 

reconsidered or changed, then there will be nil impact. 

1.4.4 As part of the certification process, States shall ensure that an aerodrome manual 

which will include all pertinent information on the aerodrome site, facilities, services, 

equipment, operating procedures, organization and management including a safety 

management system, is submitted by the applicant for approval/acceptance prior to granting 

the aerodrome certificate. 

1.1 De-icing/anti-icing facility: A facility where frost, ice or snow is removed (de-icing) 

from the aeroplane to provide clean surfaces, and/or where clean surfaces of the 

aeroplane receive protection (anti-icing) against the formation of frost or ice and 

accumulation of snow or slush for a limited period of time. 

The de-icing / anti-icing facilities are clearly to be approved (indirectly) by the NAA, therefore 

implying standards that need to met and consideration towards safety on the part of the 

Authority. For example, a de-icing / anti-icing facility located at the Ramp, may not be 

approved in certain weather conditions due to length of taxi to runway (eg at Schipol, de-icing 

/ anti-icing on the ramp for runway 18R/36L departures may not be approved for snow below 




14°C, or light freezing rain below 0°C). 

Encouraging NAAs to review how they approve de-icing / anti-icing facilities through approval 

of the aerodrome manual could be part of an overall strategy. See 3.15 below. 

The impact may highlight some areas of operational difficulty which present pilots with 

unnecessary risk. 

1.5 Safety management 

1.5.1 States shall establish a safety programme in order to achieve an acceptable level of 

safety in aerodrome operations. 

1.5.2 The acceptable level(s) of safety to be achieved shall be established by the State(s) 

concerned. 

1.5.3 States shall require, as part of their safety programme, that a certified aerodrome 

operator implements a safety management system acceptable to the State that, as a 

minimum: 

a) identifies safety hazards; 

b) ensures that remedial action necessary to maintain an acceptable level of safety is 

implemented; 

c) provides for continuous monitoring and regular assessment of the safety level 

achieved; and 

d) aims to make continuous improvement to the overall level of safety. 

1.5.4 A safety management system shall clearly define lines of safety accountability 

throughout a certified aerodrome operator, including a direct accountability for safety on the 

part of senior management. 

Aerodrome operations clearly include, for all practical purposes, de-icing / anti-icing 

operations. therefore, aerodromes should be concerned about the level of safety that is 

being achieved in this area, and their SMS should be used to asses and monitor this, and 

also address deficiencies. Even if no direct influence can be made by the aerodrome, the 

aerodrome should be interested to know that service providers are operating safely. This 

may be achieved through cooperation and information sharing with the relevant operators. 

Aerodromes should be required to establish a means, either directly with service providers, 

or via operators, by which the safety of de-icing / anti-icing operations can be assessed, and 

recommendations for improvement made. 




Aerodromes can also be required to nominate a post-holder/subject-matter-expert to take 

responsibility for the application of the SMS in this respect. This person may be the focalpoint 

for all de-icing / anti-icing matters. 

Where risks can be reduced through aerodrome actions, this can be highlighted. 

The impact could be an improved environment of safety data exchange amongst 

aerodromes, operators and service providers. 

Also aerodromes may take an active approach to facilitating de-icing / anti-icing operations, 

as a safety critical function for operators’ use, similar to ILS protection zones and lighting 

systems, rather than a commercial ground-handling service. 

3.15 De-icing/anti-icing facilities 

General 

3.15.1 Recommendation.— Aeroplane de-icing/anti-icing facilities should be provided at an 

aerodrome where icing conditions are expected to occur. 

Doc 9640 Aerodrome Facilities 

Aerodrome de-icing/anti-icing facilities are required at aerodromes where ground 

snow and icing conditions are expected to occur. This would include aerodromes 

which serve aeroplanes that can develop frost or ice on critical surfaces as a result of 

having cold soaked wings. 

The aerodrome should plan for the two-step de-icing/anti-icing procedure for all 

deicing/anti-icing operations even though some operators may choose the one-step 

procedure on some occasions. 

8.6 De-icing/anti-icing facilities have the following components: 

a) de-icing/anti-icing pads for the manoeuvering of aeroplanes; 

b) de-icing/anti-icing system comprising one or both of the following: 

1) mobile vehicles, and 

2) fixed equipment; 

c) bypass taxiing capability; 

d) environmental run-off mitigation measures; 

e) permanent or portable night-time lighting system; and 

f) support facilities that may include: 




Location 

1) storage tanks and transfer systems for de-icing/anti-icing fluids; and 

2) de-icing crew shelter. 

3.15.2 Recommendation.— De-icing/anti-icing facilities should be provided either at aircraft 

stands or at specified remote areas along the taxiway leading to the runway meant for takeoff, 

provided that adequate drainage arrangements for the collection and safe disposal of 

excess de-icing/anti-icing fluids are available to prevent ground water contamination. The 

effect of volume of traffic and departure flow rates should also be considered. 

Note 1.— One of the primary factors influencing the location of a de-icing/anti-icing 

facility is to ensure that the holdover time of the anti-icing treatment is still in effect at 

the end of taxiing and when take-off clearance of the treated aeroplane is given. 

Note 2.— Remote facilities compensate for changing weather conditions when icing 

conditions or blowing snow are expected to occur along the taxi-route taken by the 

aeroplane to the runway meant for take-off. 

Doc 9640 

Off-terminal de-icing/anti-icing 

8.11 De-icing/anti-icing facilities away from the terminal are recommended when 

terminal de-icing/anti-icing facilities (including apron facilities) cause excessive gate 

delays and/or taxi times that frequently cause holdover times to be exceeded. 

Remote pad de-icing/anti-icing facilities 

8.12 Remote de-icing/anti-icing facilities located near departure runway ends or along 

taxiways are recommended when taxi times from terminals or off-terminal deicing/anti-icing 

locations frequently exceed holdover times. The proper design of 

these facilities can also improve flow control by permitting repeat de-icing/anti-icing of 

aeroplane critical surfaces without the aeroplane having to return to more distant 

treatment sites. 

3.15.4 Recommendation.— The remote de-icing/anti-icing facility should be so located as to 

provide for an expeditious traffic flow, perhaps with a bypass configuration, and not require 

unusual taxiing manoeuvre into and out of the pads. 

Note.— The jet blast effects caused by a moving aeroplane on other aeroplanes 

receiving the anti-icing treatment or taxiing behind will have to be taken into account 

to prevent degradation of the treatment. 

3.15.6 Recommendation.— The number of de-icing/anti-icing pads required should be 




determined based on the meteorological conditions, the type of aeroplanes to be treated, the 

method of application of de-icing/anti-icing fluid, the type and capacity of the dispensing 

equipment used, and the departure flow rates. 

Note.— See the Aerodrome Design Manual (Doc 9157), Part 2. 

Environmental considerations 

Note.— The excess de-icing/anti-icing fluid running off an aeroplane poses the risk of 

contamination of ground water in addition to affecting the pavement surface friction 

characteristics. 

3.15.11 Recommendation.— Where de-icing/anti-icing activities are carried out, the surface 

drainage should be planned to collect the run-off separately, preventing its mixing with the 

normal surface run-off so that it does not pollute the ground water. 

Doc 9640 

De-icing/anti-icing facilities must be designed in accordance with local environmental 

rules and regulations. Environmental factors that have to be considered are: 

a) protecting the environment against toxic substances; 

b) isolating and collecting used glycol and any other de-icing/anti-icing contaminants 

to prevent run-off into the aerodrome storm drainage system; and 

c) recycling the used glycol. 

All of these criteria are “recommended” and not “required”, therefore there is no 

encouragement for the development of new facilities which may enhance safety and improve 

coordination. Instead decisions to “upgrade” will likely be taken mainly on commercial 

grounds. 

The list of what are items are included as facilities from Doc 9640 includes the de-icing / antiicing 

vehicles, fluid storage etc. This is interesting if the aerodrome should be providing. 

Even if the aerodrome allows third-parties to provide some of the facilities, it remains 

responsible through Annex 14. 

The environmental considerations (backed-up by local government regulations) to 

recommend drainage will restrict some aerodromes to only conduct de-icing / anti-icing on 

the Ramp, even though it may not be the most convenient or safe option. Moving operations 

to a remote area may involve great expense. 

The emphasis in Doc 9640 is different than in the Annex: ie facilities are required compared 

to the Annex should be provided. 

Doc 9640 contains an interesting recommendation that aerodromes should for two-step deicing 

/ anti-icing for all operations, regardless of whether it is taken-up or not. 




If NAAs/EASA decided to create a similar document to 9640, they could adopt some of the 

criteria from Annex 14 shown here; effectively turning some recommendations into 

requirements. 

Depending on any new requirements the cost and effort impacts would vary. However, any 

approach which would provide a single source reference which carried the weight of a 

regulatory body may impact positively on standards. 




EC Reg 1108/2009 Active 21 Oct 2009 

EASA - ESSENTIAL REQUIREMENTS FOR AERODROMES 

Applicability: Amends the Basic Regulation and constitutes Annex Va to that document, 

plus preliminary clauses. 

Direct Regulation for Member states to adopt and enforce. 

Design, maintenance and operation of aerodromees, and equipment, as well as personnel 

and organisations involved therein. 

Options: To interpret this regulation from the perspective of de-icing / anti-icing operations; 

and make recommendations for adoption in Implementing Rules, yet to be developed. 

Impact: Early interpretation and recommendations should be given due consideration by the 

Agency Team developing the Implementing Rules. 

Preliminaries: 

(7) Taking into account the large variety of aerodromes and their highly individual 

infrastructures and environments, common aerodrome safety rules should provide for the 

necessary flexibility for customised compliance, through an adequate balance between 

implementing rules, certification specifications and acceptable means of compliance. These 

rules should be proportionate to the size, traffic, category and complexity of the aerodrome 

and nature and volume of operations thereon, thereby avoiding unnecessary bureaucratic 

and economic burdens in particular for smaller aerodromes which only involve very limited 

passenger traffic. 

This highlights the fact that proscriptive one-size-fits-all regulation of de-icing / anti-icing will 

not necessarily be effective nor desirable. 


(12) Under the Community institutional system, implementation of Community law is primarily 

the responsibility of the Member States. Certification tasks required by this Regulation and its 

implementing rules are therefore to be executed at national level. In certain clearly defined 

cases, however, the Agency should also be empowered to conduct certification tasks as 




specified in this Regulation. The Agency should, for the same reason, be allowed to take the 

necessary measures related to the fields covered by this Regulation when this is the best 

means to ensure uniformity and facilitate the functioning of the internal market. 

In principle this indicates that either EASA or NAAs could establish a licensing/certification 

scheme for service providers, providing a link can be made between de-icing / anti-icing 

operations with this Regulation. 


(17) With regard to the regulation of professions which are not covered by this Regulation, 

the competence of Member States should be retained to establish or maintain at their own 

discretion, inter alia, certification or licensing requirements of the personnel. 

Where a link between de-icing / anti-icing operations and this regulation cannot be made, or 

EASA does not wish to establish a licensing/certification scheme for service providers, then 

the option remains with individual Member States. 

Amendments to Articles of 216/2008: 

‘Article 1 

Scope 

1. This Regulation shall apply to: 

(c) the design, maintenance and operation of aerodromes, as well as personnel and 

organisations involved therein and, without prejudice to Community and national legislation 

on environment and land-use planning, the safeguarding of surroundings of aerodromes; 

(d) the design, production and maintenance of aerodrome equipment, as well as personnel 

and organisations involved therein; 

Article 3 

(n) “aerodrome equipment” shall mean any equipment, apparatus, appurtenance, software or 

accessory, that is used or intended to be used to contribute to the operation of aircraft at an 

aerodrome; ‘ 

Article 8a 

Aerodromes 

1. Aerodromes and aerodrome equipment as well as the operation of aerodromes shall 

comply with the essential requirements set out in Annex Va and, if applicable, Annex Vb. 

The scope shown here could be interpreted as pertaining to personnel and organisations 

“involved” in the operation of the aerodrome, and the maintenance of aerodrome equipment. 




De-icing / anti-icing equipment and fluid storage facilities do contribute to the operation of 

aircraft at an aerodrome, and therefore can fall within the scope of this regulation – if so 

desired. 

B — Operations and management 

(a) the aerodrome operator shall have, directly or under contracts, all the means necessary 

to ensure safe operation of aircraft at the aerodrome. These means shall include, but are not 

limited to, facilities, personnel, equipment and material, documentation of tasks, 

responsibilities and procedures, access to relevant data and record-keeping; 

This connects the aerodrome to service providers, by giving it some responsibility in how 

they conduct their operations, even if under contract to an operator. This Requirement was 

highlighted in EASA CRD A-NPA-2007-11 as a mechanism for indirect regulation of service 

providers. 

(e) the aerodrome operator shall ensure that procedures to mitigate risks related to 

aerodrome operations in winter operation, adverse weather conditions, reduced visibility or at 

night, if applicable, are established and implemented; 

(f) the aerodrome operator shall establish arrangements with other relevant organisations to 

ensure continuing compliance with these essential requirements for aerodromes. These 

organisations include, but are not limited to, aircraft operators, air navigation service 

providers, ground handling service providers and other organisations whose activities or 

products may have an effect on aircraft safety; 

This can be interpreted as including de-icing / anti-icing operations and service providers; 

thereby giving the aerodrome responsibilities in this respect. Para (f) was also highlighted in 

EASA CRD A-NPA-2007-11 as a mechanism for indirect regulation of service providers. 

It may be possible to use the requirements B(a, e, f) above to impose some responsibilities 

onto aerodromes the de-icing / anti-icing services. 

Such responsibilities may include facilitation of safety data collection and analysis, scrutiny of 

procedures, training and equipment, inspections and audits etc. 

Any such proposals would work best if coordinated with the relevant operators. 

The impact might include improved communications and coordination amongst aerodrome, 

ATC, operator, and service provider. Also the aerodrome may be persuaded to invest into 

facilities and equipment to ensure improved levels of safety. 




2. Management systems 

(a) The aerodrome operator shall implement and maintain a management system to ensure 

compliance with these essential requirements for aerodromes and to aim for continuous and 

proactive improvement of safety. The management system shall include organisational 

structures, accountability, responsibilities, policies and procedures. 

(b) The management system shall include an accident and incident prevention programme, 

including an occurrence-reporting and analysis scheme. The analysis shall involve the 

parties listed in point 1(f) above, as appropriate. 

(c) The aerodrome operator shall develop an aerodrome manual and operate in accordance 

with that manual. Such manuals shall contain all necessary instructions, information and 

procedures for the aerodrome, the management system and for operations personnel to 

perform their duties. 

To be linked with Annex 14 SMS requirements and pending Implementing Rules for SMS, 

these requirements should ensure that aerodromes collect data on the safety of de-icing / 

anti-icing operations. 

EASA can reinforce these requirements specifically for de-icing / anti-icing operations; 

perhaps in cooperation with service providers and operators under a coordinated and 

harmonised initiative. 

The impact would be to involve aerodromes more closely, as participants or facilitators, in the 

standards of operation of service providers operating at their location. 




EC Directive 96/97/EC Amended 20/11/2003 

GROUND HANDLING DIRECTIVE 

– on access to the ground handling market at Community airports. 

Applicability: Indirect law for EU Member States to adopt into their own laws. Includes deicing 

of aircraft as a ground-handling service. The Directive applies to all Community airports 

open to commercial traffic whose annual traffic is not less than two million passenger 

movements or 50 000 tonnes of cargo (Article 1). 

Annex List of Ground-Handling Services 

6. Aircraft services comprise: 

6.2. the cooling and heating of the cabin, the removal of snow and ice, the de-icing of 

the aircraft; 

This Directive does not mention “anti-icing” which must be assumed to be an oversight. 

Options: 

Given the universal recognition that de-icing / anti-icing is an operational procedure 

necessary to ensure and maintain the airworthiness of aircraft, one key option would be to 

remove it from this Directive, or exempt it from certain clauses and Articles. As a necessary 

safety critical function it may be sensible not to consider de-icing / anti-icing alongside 

“commercial” activities such as baggage handling and postal services. 

Otherwise the amending of this Directive would require a consistent and perhaps coordinated 

effort from EASA, NAAs, Aerodromes and Airline Associations. However, if this could be 

achieved then the options introduced below could each be considered within an overall 

review of the entire Directive. 

Impact: 

Removing de-icing / anti-icing from this Directive would restrict competition amongst 

providers unless an alternative mechanism was developed, and consideration would also 

need to be given to removing fuel/oil supply and loading from the Directive. 

Assuming amendments were made with the support of all stakeholders, with the aim of 

improving standards of de-icing / anti-icing, then the impact should be positive. 

Clause 11 




Whereas for certain categories of ground-handling services access to the market and selfhandling 

may come up against safety, security, capacity and available-space constraints; 

whereas it is therefore necessary to be able to limit the number of authorized suppliers of 

such categories of ground-handling services; whereas it should also be possible to limit selfhandling; 

Clause 12 

Whereas if the number of suppliers of ground-handling services is limited effective 

competition will require that at least one of the suppliers should ultimately be independent of 

both the managing body of the airport and the dominant carrier; 

Clause 11 can allow an aerodrome to limit the number of de-icing / anti-icing service 

providers based on space constraints and also safety considerations. Clause 12 safeguards 

against an aerodrome implementing this for financial gain. 

If it was considered that risk could be reduced through limiting the number of de-icing / antiicing 

service providers, then allowing aerodromes to apply this clause is an option. 

The impact would be reduced commercial competition, and perhaps choice of service and 

fluid available. With fewer service providers there would be less overall investment in 

equipment and training etc which hitherto may be multiplied and duplicated across several 

providers. However, the remaining provider(s), through larger revenue, would be in a 

position to invest more money into equipment and training etc. 

Clause 13 

Whereas if airports are to function properly they must be able to reserve for themselves the 

management of certain infrastructures which for technical reasons as well as for reasons of 

profitability or environmental impact are difficult to divide or duplicate; whereas the 

centralized management of such infrastructures may not, however, constitute an obstacle to 

their use by suppliers of ground-handling services or by self-handling airport users; 

Clearly the main de-icing / anti-icing infrastructures (ramp, pad, lights, signage) will be owned 

and maintained by the aerodrome. Fluid storage and handling facilities can also be large 

infrastructures, and in many cases the aerodrome owns these, however, these facilities may 

be considerably cheaper to invest in, and maintain, than a fleet of de-icing / anti-icing 

vehicles, which are mostly owned by the service providers. It may be argued that for 

technical reasons and for those of economics an aerodrome may declare the fleet of de-icing 




/ anti-icing vehicles as part of the aerodrome infrastructure, and service providers would 

share this fleet (see Article 8 below). 

An option would be to allow the aerodrome to include de-icing / anti-icing vehicles as part of 

the aerodrome infrastructure and effectively “rent” them to any service providers. 

The impact would be, perhaps, a larger investment in vehicles and some form of oversight of 

the quality and maintenance of these vehicles through the NAA oversight of the aerodrome. 

Clauses 22 

Whereas, in order to enable airports to fulfil their infrastructure management functions and to 

guarantee safety and security on the airport premises as well as to protect the environment 

and the social regulations in force, Member States must be able to make the supply of 

ground-handling services subject to approval; 

Clause 23 

Whereas, for the same reasons, Member States must retain the power to lay down and 

enforce the necessary rules for the proper functioning of the airport infrastructure; whereas 

those rules must relate to the intended objective and must not in practice reduce market 

access or the freedom to self-handle to a level below that provided for in this Directive; 

These two clauses indicate that, in the interests of safety, States must implement an 

approval system allowing approved organisations to supply their services; and to be able to 

achieve this States have the power to enforce any necessary rules. 

States may therefore decide to define technical rules for the proper functioning of de-icing / 

anti-icing; such technical rules could vary between simple minimum requirements concerning 

equipment standards, through availability of fluids, and up to full-blown regulation of 

procedures and training. 

The impact would vary depending on the level and quantity of technical rules defined. 

Article 4 

The managing body of an airport, the airport user or the supplier of ground-handling services 

must, under the supervision of the designated auditor, rigorously separate the accounts of 

their ground-handling activities from the accounts of their other activities. 




This Article is designed to prevent organisations subsidising their ground-handling services 

from other activities in order to maintain a false edge over rival companies, by making the 

fact transparent. Clearly this denies an airport the ability to include de-icing / anti-icing 

services as part of the aerodrome infrastructure, and charges through landing fees for 

example. Likewise, operators who decide to provide their own de-icing / anti-icing services 

by self-handling would need to separate those accounts from their main business. Yet if deicing 

/ anti-icing, as declared in Doc9640 and Annex 6 is an operational activity, then there 

should be no requirement to do so; even if an operator considers it continuing airworthiness. 

This Article could be amended to exclude de-icing / anti-icing from the necessity to separate 

the accounts from other activities. 

The impact may be a less fair commercial playing field, where aerodromes could undercut 

other service providers by subsidising a loss-making activity, perhaps de-icing / anti-icing, 

from their other activities. However, it would also support the concept of aerodromes 

collecting revenues for de-icing / anti-icing through indirect means from all airport users. 

Article 5 – Airport Users' Committee 

1. Member States shall ensure that, for each of the airports concerned, a committee of 

representatives of airport users or organizations representing airport users is set up. 

2. All airport users shall have the right to be on this committee, or, if they so wish, to be 

represented on it by an organization appointed to that effect. 

Without recommended agendas and powers allocated to the AUC, this Article is pointless. 

An option would be to specify how decisions made by the AUC could, or should, be 

addressed by the airport users, and also what types of decisions ought to be made on what 

topics. 

The impact may improve the effectiveness of those AUC’s that rarely meet, and those that 

are ineffective in making change. 

Article 6 

2. Member States may limit the number of suppliers (not below 2) authorized to provide the 

following categories of ground-handling services: 

— baggage handling, 




— ramp handling, 

— fuel and oil handling, 

— freight and mail handling 

De-icing / anti-icing is not included, indicating that States cannot limit the number of de-icing / 

anti-icing suppliers at any location. 

To align this Article with clauses 11, 22 & 23, as discussed above, de-icing / anti-icing could 

be added to this list. It would seem fair to add a caveat that where a State provided a safety 

case in favour of limiting the number of suppliers in any category of ground-handling service, 

then it should be free to do so. Such safety cases should be scrutinised by an independent 

body. 

State involvement should not be to its own commercial benefit (directly or indirectly), and 

such a rule may also reduce commercial fairness. However, where a safety case can be 

made the impact on safety should be positive. 

Article 8 – Centralized infrastructures 

1. Notwithstanding the application of Articles 6 and 7 (self-handling), Member States may 

reserve for the managing body of the airport or for another body the management of the 

centralized infrastructures used for the supply of ground-handling services whose complexity, 

cost or environmental impact does not allow of division or duplication, such as baggage 

sorting, de-icing, water purification and fuel-distribution systems. They may make it 

compulsory for suppliers of ground-handling services and self-handling airport users to use 

these infrastructures. 

2. Member States shall ensure that the management of these infrastructures is transparent, 

objective and non-discriminatory and, in particular, that it does not hinder the access of 

suppliers of ground-handling services or self-handling airport users within the limits provided 

for in this Directive. 

Complimenting clause 13. Although there is no defining what centralised infrastructure 

constitutes de-icing / anti-icing, interpretation can include ramps, pads, lights, signs, 

communication, fluid storage and handling, and also the vehicles. These may all be argued 

on the case of cost and/or complexity. 

An option would be to allow the aerodrome to include de-icing / anti-icing vehicles as part of 




the aerodrome infrastructure and effectively “rent” them to any service providers. 

The impact would be, perhaps, a larger investment in vehicles and some form of oversight of 

the quality and maintenance of these vehicles through the NAA oversight of the aerodrome. 

Article 9 - Exemptions 

1. Where at an airport, specific constraints of available space or capacity, arising in particular 

from congestion and area utilization rate, make it impossible to open up the market and/or 

implement self-handling to the degree provided for in this Directive, the Member State in 

question may decide: 

(a) to limit the number of suppliers for one or more categories of ground-handling services 

other than those referred to in Article 6 

(2) in all or part of the airport; in this case the provisions of Article 6 (2) and (3) shall apply; 

(b) to reserve to a single supplier one or more of the categories of ground-handling services 

referred to in Article 6 (2); 

(d) to ban self-handling or to restrict it to a single airport user for the categories of groundhandling 

services referred to in Article 7 (2). 

This can provide aerodromes and/or states with the leverage to argue for restricted markets 

in some areas. However, it is surprising that de-icing / anti-icing is not included on the list of 

ground-handling activities, because space and capacity are legitimate reasons for limiting the 

number of providers. 

An amendment could be proposed to include de-icing / anti-icing within this exemption; 

provided an adequate case was made and supported. 

Where a “free” market does exist at an aerodrome with restricted space, and the competition 

is affecting capacity, then the operational impact could be positive. 

Article 11 

Selection of suppliers 

1. Member States shall take the necessary measures for the organization of a selection 

procedure for suppliers authorized to provide ground-handling services at an airport where 

their number is limited in the cases provided for in Article 6 (2) or Article 9. This procedure 

must comply with the following principles: 




(a) In cases where Member States require the establishment of standard conditions or 

technical specifications to be met by the suppliers of ground-handling services, those 

conditions or specifications shall be established following consultation with the Airport Users' 

Committee. The selection criteria laid down in the standard conditions or technical 

specifications must be relevant, objective, transparent and non-discriminatory. 

(d) Suppliers of ground-handling services shall be selected for a maximum period of seven 

years. 

As described in Clauses 22 & 23 above, para 1(a) here indicates that states can require 

aerodromes (with inferred support of AUC) to establish and adhere to standards and 

technical specifications for de-icing / anti-icing providers. Therefore allowing an indirect 

ruling for these providers, and a degree of harmonised standardisation. 

An agreement amongst NAAs to agree to one standard (eg AEA), and supported by Industry 

through the AUCs could be proposed. 

A proposal could be made to extend the licensing period beyond 7 years for de-icing / antiicing. 

This would not necessarily bring about complete harmonisation, however, it should ensure 

involvement from the aerodrome in which standards the providers are obliged, by the 

operators, to uphold; and through the AUC agreements could be made for harmonisation at a 

local level. The aerodrome could still defer oversight to the operators. This option may also 

allow for the supply of Type I. 

Extending the licensing period may encourage more investment and greater competition. 

De-icing equipment (vehicles) and glycol recovery vehicles (GRV) are expensive items which 

typically have lifecycle and investment cycle between 10 to 15 years (as discovered during 

the Study). After 7-years the capital remaining in a vehicle can still be 50% of the initial cost, 

and the second-hand market is not necessarily buoyant. Extending the period could also see 

prices falling, as investment can be recovered over a longer period. 

Article 14 

Approval 

1. Member States may make the ground-handling activity of a supplier of ground-handling 

services or a self-handling user at an airport conditional upon obtaining the approval of a 




public authority independent of the managing body of the airport. The criteria for such 

approval must relate to a sound financial situation and sufficient insurance cover, to the 

security and safety of installations, of aircraft, of equipment and of persons, as well as to 

environmental protection and compliance with the relevant social legislation. 

This Article aims to ensure a business is fit-for-purpose legally, administratively and 

financially, however, it does not require that any technical specifications or operational 

standards need be approved by an external public authority. 

An option could be to include technical specifications and operational standards for de-icing / 

anti-icing within this Article. 

The impact would be that de-icing / anti-icing service-providers would be obliged to seek and 

gain approval from their NAA before being granted a license to operate at an aerodrome. 

Such approval could be an extension of the fit-for-purpose assessment, similar to EU OPS 

Sub-part B, or forthcoming ORs. This would not preclude the need for operators to conduct 

full oversight through issue of contracts and quality system procedures. However, it would 

give NAAs a greater insight into the ground-handling organisations operating at aerodromes 

within their jurisdiction. 

Article 15 

Rules of conduct 

A Member State may, where appropriate on a proposal from the managing body of the 

airport: 

— prohibit a supplier of ground-handling services or an airport user from supplying groundhandling 

services or self-handling if that supplier or user fails to comply with the rules 

imposed upon him to ensure the proper functioning of the airport; 

A safety clause to reduce risk, provided the aerodrome management is adequately taking 

measures to monitor the standards and safety of ground-handling services, either directly, or 

indirectly through the operators. Operators too have duty to feedback relevant data to the 

aerodrome. This clause does not promote high-levels of practice, only allows (consistent) 

unsatisfactory performers, or those who deliberately violate expected standards of 

professionalism, to halt operations. 

This Article could be amended in alignment with proposals to amend Articles 9, 11 and 14 

above, and thus include the right for an NAA to remove an “approval” or license from a de- 




icing / anti-icing service provider. 

The impact would be as for the proposals to amend Articles 9, 11 and 14 above. 




EC/EASA Reg 2042/2003 Amendment 4, 5 March 2010 

EASA - PART M/PART 145 & AMC TO PART M 

Applicability: Direct Requirements enforced by Member States on entities. 

CA of aircraft registered in Member State, or operated by entity overseen by a Member 

State. 

Options: Consideration could be given to including de-icing / anti-icing as a maintenance 

task, instead of an operational task. 

Impact: The financial and political impacts would be great in terms of reorganising the 

Industry, which in itself will introduce risks. Other impacts would need to be investigated. 

Article 2 

Definitions 

(d) ‘continuing airworthiness’ means all of the processes ensuring that, at any time in its 

operating life, the aircraft complies with the airworthiness requirements in force and is in a 

condition for safe operation 

(h) ‘maintenance’ means any one or combination of overhaul, repair, inspection, 

replacement, modification or defect rectification of an aircraft or component, with the 

exception of pre-flight inspection; 

Article 3 

2. Organisations and personnel involved in the continuing airworthiness of aircraft and 

components, including maintenance, shall comply with the provisions of Annex I and where 

appropriate those specified in Articles 4 and 5 (Organisation approvals and certifying staff 

respectively). 

AMC M.A.201 (h) Responsibilities * 

2. The performance of ground de-icing and anti-icing activities does not require a 

maintenance organisation approval. Nevertheless, inspections required to detect and 

when necessary eliminate de-icing and/or anti-icing fluid residues is considered 




maintenance. Such inspections may only be carried out by suitably authorised 

personnel. 

De-icing / anti-icing could fit within the above definitions: cleaning ice off the airframe and 

maintaining a clean wing during snow is the process of ensuring a condition for safe 

operation and therefore can be interpreted as continuing airworthiness; and, applying thick 

fluid on the wings could be interpreted as a temporary maintenance modification. 

De-icing / anti-icing could be declared a maintenance task, in the same manner that cleaning 

of residues has been declared as a maintenance task. 

De-icing / anti-icing operatives would need to hold appropriate licenses/certificates, and their 

employer organisations approved. The impact would be great: some service providers would 

go out of business, some airlines would need to employ more staff, NAAs would need to 

conduct more approval/licensing/certifying tasks etc. 

M.A.201 Responsibilities 

(d) The pilot-in-command or, in the case of commercial air transport, the operator shall be 

responsible for the satisfactory accomplishment of the pre-flight inspection. This inspection 

must be carried out by the pilot or another qualified person but need not be carried out by an 

approved maintenance organisation or by Part-66 certifying staff. 

From EU OPS we know that the person who conducts the contamination check must be 

trained and qualified, as is repeated here, however, in both documents no standard is 

specified. 

A qualifying standard could be defined for personnel who conduct de-icing / anti-icing checks 

and inspections. 

A definition would be helpful. 

AMC M.A.201 (h)1 Responsibilities (*) 

7. The operator’s management controls associated with sub-contracted continuing 

airworthiness management tasks should be reflected in the associated written contract and 

be in accordance with the operator’s policy and procedures defined in his continuing 

airworthiness management exposition. When such tasks are sub-contracted the operator’s 




continuing airworthiness management system is considered to be extended to the subcontracted 

organisation. 

9. Contracts should not authorise the sub-contracted organisation to sub-contract to other 

organisations elements of the continuing airworthiness management tasks. 

13. The operator should only sub contract to organisations which are specified by the 

competent authority on the AOC or EASA Form 14 as applicable. 

If de-icing / anti-icing were adopted as a maintenance task, then this AMC imposes some 

controls on sub-contracting. 

The operator’s de-icing / anti-icing policy and procedures could be placed in the control of the 

airworthiness management exposition. 

Service providers would no longer be able to sub-contract to other organisations. 

Service providers would need to be “specified” on the AOC, or Form 14, and this would 

require NAA/EASA action. 

AMC M.A.301 -1- Continuing airworthiness tasks 

1. With regard to the pre-flight inspection it is intended to mean all of the actions necessary 

to ensure that the aircraft is fit to make the intended flight. These should typically include but 

are not necessarily limited to: 

(f) a control that all the aircraft’s external surfaces and engines are free from ice, snow, 

sand, dust etc.. and an assessment to confirm that, as the result of meteorological 

conditions and de-icing/anti-icing fluids having been previously applied on it, there are 

no fluid residues that could endanger flight safety. Alternatively to this pre-flight 

assessment, when the type of aircraft and nature of operations allows for it, the build up 

of residues may be controlled through scheduled maintenance inspections/cleanings 

identified in the approved maintenance programme. 

3. In the case of commercial air transport, an operator should publish guidance to 

maintenance and flight personnel and any other personnel performing pre-flight inspection 

tasks, as appropriate, defining responsibilities for these actions and, where tasks are 

contracted to other organisations, how their accomplishment is subject to the quality system 

of M.A.712. It should be demonstrated to the competent authority that pre-flight inspection 

personnel have received appropriate training for the relevant pre-flight inspection tasks. The 

training standard for personnel performing the pre-flight inspection should be described in the 

operator’s continuing airworthiness management exposition. 




M.A.712 

(e) In case of commercial air transport the M.A. Subpart G quality system shall be an 

integrated part of the operator's quality system. 

If a contamination check is undertaken as part of the pre-flight inspection, and contamination 

is detected, then the “control” that the aircraft surfaces are clean is postponed until the posttreatment 

check. This means that the pre-flight inspection is not completed as per the AMC. 

At this stage a sub-contracted body is usually involved, who will technically be following the 

operator’s checking/inspecting procedures as required by OPS 1.345 and defined in the 

operator’s de-icing / anti-icing programme and procedures. 

Their accomplishment by a sub-contractor is subject to the operator’s Quality Systems 

required under OPS 1.035 as well as M.A.712, which may be integrated. 

This point can be clarified further when the “control” for clean surfaces must be delayed due 

to de-icing requirements; the responsibility is passed from maintenance to operations. 

In practice this may have very limited impact. However, a clear dividing line could be drawn 

between what are the maintenance tasks and responsibilities and which are operations’. 

M.A.401 Maintenance data 

(a) The person or organisation maintaining an aircraft shall have access to and use only 

applicable current maintenance data in the performance of maintenance including 

modifications and repairs. 

(b) For the purposes of this Part, applicable maintenance data is: 

1. any applicable requirement, procedure, standard or information issued by the 

competent authority or the Agency, 

2. any applicable airworthiness directive, 

3. applicable instructions for continuing airworthiness, issued by type certificate holders, 

supplementary type certificate holders and any other organization that publishes such 

data in accordance with Part 21. 

If de-icing / anti-icing were a maintenance task, then this Rule would apply, giving the 

NAA/Agency indirect influence over service providers’ procedures. 

As this indirect and specific intervention does not exist currently through operations 




regulation, it is an option to create an OPS requirement similar to this Rule. 

The impact would be that if the NAAs/EASA decided, based on current data (eg from SAE G- 

12) that a certain procedure, or fluid, was essential, or indeed hazardous, then they could 

immediately impose this on operators who would need to respond through their contracts 

with service providers. 




EC Directive 2003/42/EC 4 July 2005 

DIRECTIVE ON OCCURRENCE REPORTING IN CIVIL AVIATION 

Applicability: Indirect and general to all elements of the Industry. 

Technically NAAs should require SPs, Fluid Manufacturers etc to “report” anything that may 

impact on the safety of flight, passengers or any other person. 

Options: To call for an Industry-wide review of this Directive to include the spirit of ICAO 

SMS SARPS and best-practice. 

Impact: All positive impacts on the improvement of safety and reduction of risk. 

Clause 7 

Various categories of personnel working in civil aviation observe occurrences of interest for 

the prevention of accidents and should therefore report them. 

Clause 8 

The efficiency of detection of potential hazard would be greatly enhanced by the exchange of 

information on such occurrences. 

This must include de-icing / anti-icing operatives and their employers. However, does not 

provide clear guidance on what types of organisations are included, nor a means to share 

this data. Therefore, may not be motivating enough to implement amongst service providers. 

Either operators and aerodromes can be required to collect such data from their de-icing / 

anti-icing service providers, or a voluntary programme to raise awareness and offer support 

can be initiated, such that this data is provided direct to the NAA, or EASA. 

The reporting by personnel working for de-icing / anti-icing organisations will greatly enhance 

safety by providing valuable human factors and systems data that can be analysed. 

Requirements to report to operator customers will complicate the system for the providers 

and introduce an element of “choice” which could be affected by contracts and politics. 

Analysis by operators will be fragmented. 

Requirements to report to NAAs/EASA will ensure the largest set of data from which a better 

analysis can be made and mitigation measures generalised for the whole Industry. Also the 




collection and submission scheme for service providers would be much simplified. 

Article 2 - Definitions 

For the purpose of this Directive: 

1. ‘occurrence’ means an operational interruption, defect, fault or other irregular 

circumstance that has or may have influenced flight safety and that has not resulted in an 

accident or serious incident, hereinafter referred to as ‘accident or serious incident’, as 

defined in Article 3(a) and (k) of Directive 94/56/EC; 

Article 3 - Scope 

1. This Directive shall apply to occurrences which endanger or which, if not corrected, would 

endanger an aircraft, its occupants or any other person. A list of examples of these 

occurrences appears in Annexes I and II. 

This extends the requirements contained in EU OPS 1.037 for operators to report incidents 

and accidents to those occurrences which are similar to the examples given; however, the 

definition could be clarified to include specifically human, procedural and system errors that 

are considered by the reporter to increase risk. 

Amending this definition and including it in the scope will greatly enhance understanding and 

give NAA motivation to encourage and support a broader collection and sharing of a broader 

range of safety data. This will enhance Article 9. 

The impact can only be positive with regards to improving safety. 

Article 4 - Mandatory reporting 

1. Member States shall require that occurrences covered by Article 3 are reported to the 

competent authorities referred to in Article 5(1) by every person listed below in the exercise 

of his/her functions: 

(g) a person who performs a function connected with the ground-handling of aircraft, 

including fuelling, servicing, load-sheet preparation, loading, de-icing and towing at an 

airport covered by Regulation (EEC) No 2408/92. 

2. Member States may encourage voluntary reporting on occurrences mentioned in Article 

3(1) by every person who exercises, in other civil aviation operations, functions similar to 




those listed in paragraph 1. 

Article 9 - Voluntary reporting 

1. In addition to the system of mandatory reporting established under Articles 4 and 5, 

Member States may designate one or more bodies or entities to put in place a system of 

voluntary reporting to collect and analyse information on observed deficiencies in aviation 

which are not required to be reported under the system of mandatory reporting, but which are 

perceived by the reporter as an actual or potential hazard. 

These two Articles go some of the way to adding to the scope, and meeting the options 

proposed above concerning Articles 2 and 3, however, it is not evident that Member States, 

through their NAAs, are ensuring that this is complied with fully. 

Member States can be reminded of these Articles, and also the current status quo 

concerning lack of safety data (or access to), with the intention of creating action. 

The impact may be to encourage cooperation in developing a programme to raise awareness 

and achieve a satisfactory reporting rate and effective analysis. 

ANNEX I - List of aircraft operations, maintenance, repair, and manufacture-related 

occurrences to be reported 

This includes – for example: 

A. OPERATIONS 

(i) (k) Breakdown in communication between flight crew (CRM) or between flight crew and 

other parties (cabin crew, ATC, engineering). 

(vii) (a) Repetitive instances of a specific type of occurrence which in isolation would not be 

considered ‘reportable’ but which due to the frequency with which they arise, form a potential 

hazard. 

(vii) (d) Any other occurrence of any type considered to have endangered or which might 

have endangered the aircraft or its occupants on board the aircraft or on the ground. 

B. AIRCRAFT TECHNICAL 

(v) (d) Any other event which could endanger the aircraft, or affect the safety of the 

occupants of the aircraft, or people or property in the vicinity of the aircraft or on the ground. 

(vii) Non-compliance or significant errors in compliance with required maintenance 




procedures. 

D. AIR NAVIGATION SERVICES, FACILITIES AND GROUND SERVICES 

(iv) (a) Failure, malfunction or defect of ground equipment used for the testing or checking of 

aircraft systems and equipment when the required routine inspection and test procedures did 

not clearly identify the problem, where this results in a hazardous situation. 

(b) Non-compliance or significant errors in compliance with required servicing procedures. 

(c) Loading of contaminated or incorrect type of fuel or other essential fluids (including 

oxygen and potable water). 

This list is not comprehensive, nor does it specifically mention de-icing / anti-icing. In the 

Appendix to this Annex, there are examples given of types of reportable occurrences, 

however, none relate to de-icing / anti-icing of aircraft on the ground. 

The Directive could be amended to specifically include examples of reportable occurrences 

for de-icing / anti-icing of aircraft on the ground. 

Operators and aerodromes could be required by NAAs, under SMS regulations, to interpret 

this Directive from the perspective of de-icing / anti-icing service providers and to take 

measures to ensure their compliance. 




APPENDIX 1: LIST OF REFERENCES 

Document Source Document Title/Reference 

ICAO Annex 6, Part 1 – Operation of Aircraft 

ICAO Annex 8, – Airworthiness of Aircraft 

ICAO Annex 14, – Aerodromes 

ICAO Document 9137 Part 8 – Airport Services Manual 

ICAO Document 9640 - Manual of Aircraft De-icing / Anti-icing Operations 

EC Reg 3922/91 Annex III – EU OPS 

EC Reg 216/2008 – The Basic Regulation (ERs –OPs, Airworthiness) 

EC Reg 1108/2009 – Essential Requirements Aerodromes 

EC/EASA Reg 2042/2003 (2010) – EASA PART M, 145 & AMC PART M 

EASA NPA 2/2009 – IR OPS 

EASA NPA 22C/2008 – ARs & ORs 

EASA A-NPA & CRD TO A-NPA 2007-11 

EASA NPA & CRD TO NPA 9/2009 

EASA SIN 2008-29 

EC 


Directive 96/97/EC on Ground Handling market access in 

Community airports 

EC Directive 2003/42/EC on Occurrence Reporting in Civil Aviation 

IATA Standard Ground Handling Agreement 

AEA Recommendations for De-icing / Anti-icing of aircraft on the ground 

AEA 

Training Recommendations and background information for de-icing 

/ anti-icing of aircraft on the ground 

AEA De-icing / Anti-icing International vendor audit checklist 

SAE AMS 1424 – De-icing / Anti-icing fluid Type I 

SAE AMS 1428 – De-icing / Anti-icing fluid Types II, III, IV 

SAE ARP 4737 – Aircraft De-icing / Anti-icing methods



SAE 


ARP 5646 – Quality programme guidelines for de-icing / anti-icing of 

aircraft on the ground 

FAA AC 120-60 Ground de-icing / anti-icing programme 

FAA AC 135-16 Ground de-icing / anti-icing training and checking 

FAA N8900-26 Outsourcing of 3 rd party provider aircraft ground de-icing





OPTIONS FOR CHANGE – ATTACHMENT C 

Notes on the FAA Standardised International Aircraft 

De-icing Programme 

airsight GmbH 



13355 Berlin 

Germany 

Phone: +49 30 45803177 

Fax: +49 30 45803188 

www.airsight.de

INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT C 


INTRODUCTION 

This document is a short summary and description of the FAA Standardised International 

Aircraft De-icing Programme (SIAGDP). It is presented in two sections: the first contains 

notes made from an FAA presentation on the background of the programme; and the second 

includes extracts from the SIAGDP document. The reason it is included in this Report is that 

any progress and changes made by the FAA concerning how de-icing / anti-icing is regulated 

may have an impact on: European Carriers flying to US aerodromes; and, European service 

providers contracted to provide de-icing / anti-icing to US carriers operating to/from European 

aerodromes. Furthermore, a goal of any future regulation, and defining of best-practice, 

must always remain as reaching global harmonisation. Option FAALIAS presented in 

Options for Change refers. 

Readers will gain a broad understanding of the FAA’s intentions from the first section. The 

extracts in the second section provide more in-depth and precise references to areas of deicing 

/ anti-icing management and operations that are discussed elsewhere in this report. 

NOTES TAKEN FROM A PRESENTATION GIVEN BY OSTRONIC & FISCUSS (FAA) 

JULY 2008 – WINTER UPDATE 

AC 120-60B 20 Dec 2004 is the primary guidance document for the development of an air 

carrier’s aircraft ground de-icing programme (compliance with 14 CFR 121.695). Originally, 

this was written when most air carriers accomplished aircraft de/anti-icing utilising 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. Also, they would have great familiarity with 

moving around aircraft and airports in an operational environment. 

However today, depending on the air carrier, approximately 70 - 80% of aircraft ground 

de/anti-icing is accomplished by third party contract service providers 

The employee of the typical contracted 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. 

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AC 120-60B simply does not address the realities of the present situation in the aircraft 

ground de-icing environment and the contractual relationships that have evolved between the 

air carriers and the third party aircraft ground de-icing service providers. 

Therefore today (2008/2009) a major re-write of AC 120-60B is underway. The aim is to 

have one standardised programme for all carriers domestic and foreign, at home and 

overseas. 

If the revision is successful then it will: 

− Improve safety by increased standardisation – a programme for use domestically and 

internationally. 

− Provide an authorisation process for third-party aircraft service providers independent 

of an air carrier’s 14 CFR 121.629 approved ground de-icing programme. 

− Improve FAA oversight through the third-party service provider authorisation process. 

− Make available and encourage the use of quality de/anti-icing fluids to a larger 

segment of the aviation industry (beyond major commercial carriers). 

FAA Notice N.8900.26 states that: 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. 

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FAA NOTICE - N 8900.26 - Dated Dec 2007 and valid for one year. 

This was issued as guidance to Safety Inspectors to check up on airline’s arrangements with 

service providers following some clear violations and general ignorance. Inspectors had 90 

days to comply. Notice 8900.33 extended the deadline for Foreign Locations, due to 

logistics. 

Extracts 

Outsourcing (commonly referred to as “third party”) of aircraft ground de-icing services is 

becoming the norm across the airline industry. When an air carrier outsources these 

services, the air carrier retains the responsibility for all aspects of its approved aircraft ground 

de-icing program. This includes the quality management of the service and the training of 

ground personnel. The FAA may authorize the air carrier to use an outsourced service 

provider as the agent for the air carrier to physically apply de/anti-icing fluids using the 

service provider’s equipment in accordance with the air carrier’s FAA-approved aircraft 

ground de-icing program (not the service provider’s unapproved program). FAA policy also 

allows an air carrier to use de-icing services provided by another air carrier that has an FAAapproved 

aircraft ground de-icing program under § 121.629(c). When using the services 

provided under another air carrier’s FAA-approved program, the contracting air carrier needs 

to provide training for the ground service personnel on the differences between the two 

programs as they relate to the specific aircraft de-icing procedures, communications, and 

record keeping. The contracting air carrier retains full responsibility for the safe operation of 

the aircraft and therefore must have a process to ensure the contracted air carrier’s aircraft 

ground de/anti-icing operation is in compliance with applicable requirements of the 

regulations and their approved aircraft ground de-icing program. 

Policies, procedures, and requirements are currently under development to authorize an 

aircraft ground de-icing service provider to be issued a letter of authorization (LOA) to 

provide aircraft ground de-icing services under an industry standardized aircraft ground deicing 

program. While this concept would allow an air carrier to be approved to use the service 

provider’s program as per the service providers LOA, no policy or procedure exists for such 

authorization at this time. 

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At some foreign locations only one aircraft ground de-icing service provider is authorised 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. It is not desirable or practicable to expect these companies, or their employees, to 

know 25 different ways of accomplishing the same basic task. 

− There was a proposal to consider using the concept of a “host” airline at each location, 

but this was rejected. 

− Use of one specific service provider programme for everyone was rejected, due to 

variation in aircraft, operations, locations etc. 

− Incorporating every service provider’s programme into the approved airline’s 

programme – rejected. 

− Revision to airline programmes to incorporate the SIAGDP for overseas destinations - 

accepted. 

SIAGDP is a comprehensive generic aircraft ground de-icing programme 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 de-icing service providers. The SIAGDP is 

more detailed and comprehensive than that specified in the current AC 120-60B, and that 

which is currently in most air carrier’s core FAA approved aircraft ground de-icing programs. 

− 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. 

o Audit checklist/form/report modelled after AEA aircraft ground de-icing 

provider audit form. 

o Audits are to be conducted by knowledgeable individuals under the oversight 

and coordination of ATA. 

o Single audit sanctioned by an ATA auditor may be shared by all SIAGDP 

participants. 

− The SIAGDP is in addition to, and does not replace, the approved programme under 

121.695 (AC 120-60). 

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NOTES AND EXTRACTS FROM THE SIAGDP DOCUMENT (2010-11 Edition, 1 July 2010) 

July 1, 2010 

Notes are made and extracts included where they highlight some of the options made in 

Options for Change, and/or reflect findings made in Data Summary and Analysis within the 

Interim Report. Comments are added in italics. 

Executive Summary 

The SIAGDP allows U.S. Commercial Air Carriers (not Domestic and on-demand operations 

Part 135) a: 

− shared, 

− approved, 

− compliant, and 

− standardised programme, 

− …. to operate in international locations. 

The core of this program is the De/Anti-icing Vendor Audit (DEVA). 

Pooling of audit results is acceptable, and participants fulfil their internal Quality Assurance 

program requirements for continuous surveillance of the vendors under contract to perform 

de/anti-icing services and requirements of the SIAGDP. 

The Air Transportation Association (ATA) will host the data repository where each 

participating airline will submit: 

1. List of designated auditors 

2. Schedule of planned audits 

3. DEVA results, including date of the audit conducted 

4. Corrective action responses including acceptance or rejection of location 

Participants are: 

− Alaska Airlines, 

− American Airlines, 

− Continental, 

− Delta, 

− FedEx Express, 

− Horizon Air, 

airsight GmbH - 5 -



− SkyWest , 

− United Air Lines, 

− United Parcel Service and 

− US Airways. 

International De/Anti-icing Chapter - Foreword 

This is only a portion of the FAA approved de/anti-icing program and does not cover detailed 

flight crew or dispatcher procedures. 

It covers international de/anti-icing differences associated with local procedures 

accomplished by third-party de-icing providers. 

Third party providers may use all procedures from the main approved de/anti-icing manual or 

substitute differences contained in the International De/Anti-icing Chapter. 

This chapter is divided into four sections: 

− Procedures Section 

− Training Section 

− Quality Control Section 

− Reference Section 

Procedures 

1 De/Anti-icing Fluids 

This section on the delivery, storage, pumping, handling and testing of fluids follows 

accurately the AEA Recommendations. It may be possible for any regulation to simply refer 

to the AEA Recommendations and Training Manual and thereby give tacit approval. 

2 De/Anti-icing Operations 

2.1 General 

The de/anti-icing operation must be suited for each airport, company and local setting. 

However, airworthiness and operational regulations state that no one can take-off in an 

aircraft that has any contamination on critical surfaces. 

The clean aircraft concept shall be set as the only way of operating. 

2.2 Preliminary work for the start of de/anti-icing 

A verification of procedures for de/anti-icing should then be made. Procedures may vary 

according to local demands. The necessary inspections and communications can be made 

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beforehand at the gate whereas at remote/centralised de-icing, necessary information must 

be informed to the de-icing crew in another way (e.g. coordinator communication). 

2.2.1 Determining the need for de/anti-icing 

Certain aspects must be considered, such as, what are the A/C specific requirements and 

precautions, is the de-icing operation performed at gate or remote, can the aircraft start the 

engines and taxi to a remote de-icing fully contaminated, who makes the request for the deicing, 

verification of proper procedure with all parties involved (ground crew / flight crew / deicing 

crew), should air-blower/brushes be used beforehand etc. 

2.2.1.1 One-step/two-step de/anti-icing 

The selection of a one- or two-step process depends upon weather conditions, available 

equipment, available fluids and the holdover time to be achieved. 

One-step procedure: some contamination, such as frost, can be removed and the surface 

protected from refreezing, all at the same time using the same fluid and same mixture. 

Two-step de/anti-icing (when the first step is performed with de-icing fluid) is a procedure 

performed whenever the contamination demands a de-icing process separately. This 

sentence reflects what is included in AEA Recommendations, and would virtually mandate 

that aerodromes provide type I fluid, because there will always be days of heavy snowfall 

and clear ice which “demand” a separate de-icing. 

2.2.2.1 Clean aircraft concept 

Contaminated fluid on the surface must not be misunderstood as a clean aircraft; this 

contamination must be removed. Anti-icing only is not permitted. 

2.3.2.2 Anti-icing fluid may be applied to aircraft surfaces at the time of arrival on 

short turnarounds during freezing precipitation and on overnight parked aircraft. This 

procedure has a potential risk of building residues and is not recommended if 

performed continuously. 

2.3.1 Aircraft surfaces 

If the wing area is large and the contamination is heavy, previously de-iced parts should be 

considered to be de-iced again before anti-icing. 

2.3.1.1 Other areas 

The Application of hot water or heated Type I fluid in the first step of the de/anti-icing process 

may minimise the formation of residues. It must be clear that de-icing or anti-icing should not 

be performed (sprayed) from the trailing edge forward. This can cause even more residue to 

collect and there is also the danger of removing grease from hinges and other parts. 

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2.4 De/anti-icing communication 

Proper communication is as important as proper de/anti-icing. There cannot be any doubt of 

the procedure, fluid used, holdover time, areas covered etc. when communicating and 

verifying the process. 

As important as the communication between the flight crew and the de-icing crew so is the 

communication between the de-icing crews themselves and the de-icing coordinator. No 

misconception can be allowed when deciding on treatment and verifying operational 

procedures. 

2.4.1.1 The Anti-Icing Code 

The Anti-Icing Code contains the minimum information needed for communication. It is 

allowed, and preferred, to give other information, such as areas treated, areas checked, 

engines and propellers, frost thickness on underwings etc, if there is a need for it or if the 

crew has requested something else. 

Note that heavy precipitation rates or high moisture content, high wind velocity or jet blast 

may reduce holdover time below the lowest time stated in the range. Holdover time may also 

be reduced when aircraft skin temperature is lower than OAT. Therefore, the indicated times 

should be used only in conjunction with a pretakeoff check. For use of holdover time 

guidelines consult Fluid Manufacturer Technical Literature for minimum viscosity limits of 

fluids as applied to aircraft surfaces. A Type II, III or Type IV fluid is considered degraded if 

the viscosity is below the minimum limit as provided by the fluid manufacturer. 

3 Off-Gate De/Anti-icing Operation 

3.1 Airport operations 

The operation of any de-icing facility should maximise efficiency where possible. 

Local settings may demand one sort of operation for one airport that could be unusable for 

another location. As long as “local settings” is not a euphemism for different levels of 

investment and capability/capacity of facilities and equipment and personnel etc. 

3.4 Management of the centralised de/anti-icing operation. 

A management and procedure plan should be available at the airport in relevant publications. 

This program shall explain the necessary procedures of the de-icing operation. The remote 

de-icing operation must be clearly determined and informed to all stakeholders. A de-icing 

program must be established irrespective of whether it is a remote only or a mix operation. 

The procedures, the throughput, the options, the checks, the communication etc. must be 

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clearly defined and responsible persons must be introduced. A remote de-icing operation 

(including a mix) must have a coordination operation. 

6 De/Anti-icing Coordination 

6.1 General 

Any winter operation needs a coordinated effort to produce an effective and efficient de-icing 

procedure. Establish coordination according to the local needs and settings. If the de-icing 

volume is reasonably large then a coordination system is a must. Coordination can be 

established for both gate and remote de-icing operations, they can even serve both 

procedures simultaneously. With coordination also goes nomination of coordinators – 

experienced and knowledgeable post-holders, with clearly defined responsibilities. It is also 

clear that more than one person needs to be coordinating – the operator and aerodrome as 

well as the service provider need to be “in the loop”. Including the aircraft captain – it is a 

team effort, which needs an overall “leader”. 

The area of responsibility lies with the: 

− allocation of de-icing work, 

− the control of de-icing vehicle resources, 

− management of de-icing events, 

− communication control, 

− safety considerations and 

− special occurrences (problem solving) or ad-hoc situations. 

Local requirements must be followed and the procedures adapted accordingly. 

6.2.1 Coordination recommendations 

Who employs the coordinator service provider or Aerodrome? What if there is more than 

one service provider operating at the same time and location? 

The coordinator must have good experience of winter operations and be able to solve 

situations as they appear. Relating requirements are explained in Training Section. The 

coordinator must be able to handle several de-icing situations at different times of operation. 

Some items included in the procedures may be to centralise resources, control vehicle fluid 

consumption and filling according to the flow of aircraft, verify quality of fluids, give taxi 

instructions at the centralized de-icing area (or provide contact information), involve 

stakeholders (e.g. apron suction trucks, other operators), record keeping and to be a source 

of information (troubleshooting) when needed. The coordinator is constantly monitoring all 

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communications and operations and can therefore supervise the safety of de-icing 

operations. The coordinator may need to be aware of environmental aspects and monitor the 

operations accordingly. Fluid availability and logistics is one important part of coordinating a 

de-icing operation. The coordinator should be able to provide the flight crew with pertinent 

information of the de-icing procedure if the de-icing crew is unable to provide such 

information. Note that at remote areas other de-icing providers may share the same de-icing 

pad but not the same coordination. This situation should be clarified beforehand and 

procedures should be set up for mutual understanding and foremost because of safety. 

6.2.2 Communication procedures 

The coordinator has a role of supervising correct communication between the de-icers to the 

aircraft and correcting possible misunderstandings. 

6.2.3 Safety considerations 

It is up to the de-icing coordinator to verify de/anti-icing procedures and take into account 

variations between company procedures. At a busy aerodrome with multiple de-icing / antiicing 

operations being conducted in parallel, this would be impossible for one person. At 

each aircraft/de-icing operation interface, a coordinator needs to be present (visually and 

verbally in communication with the flight crew); this role must rest with the service provider. 

6.2.4 Airport layout and local compliance 

The airport infrastructure must support the winter operations. 

Training 

Adds nothing to, and does not contradict, the AEA Training Manual. 25 pages as opposed to 

193. 

Quality Control 

No variation from AEA into what operators “should” do, how they should conduct audits, 

when and where, etc. 

Also includes the DEVA checklist (DE/anti-icing Vendor Audit). This is not dissimilar to the 

IATA DAQCP audit checklist. 


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