EASA’s New Ground Handling Rule: Progress or Parallel Complexity?

Is standardisation of Ground Operation procedures an important objective? – Yes
Is Ground Operations today an uncontrolled “wild west”? – No
Is the new EASA regulation ensuring that Ground Operations procedures are being standardised? – No

So what do we have?    

EASA recently as the first CAA published a regulation for Ground Operations seeking through a certification program to enhance the safety of aircraft operations…an obviously admirable objective.

The regulation do not include concrete procedures but foresee that the Ground Service Providers (GSP) to have their operations certified based on their own procedures and that these must be in line with best industry practices, ICAO recommendations, latest science etc and can differ by size and complexity of operation (a bit fluffy).

So has Ground Operations until now been an uncontrolled “wild west” with accidents just waiting to happen? No, of course not. Until now, and outside the EU continuing for now, the airlines have under the regulations underlying their Arline Operators Certificate (AOC) been responsibility for Ground Operations as an integral part of its aircraft operation, and this regardless whether done by the airline itself or outsourced to a GSP (“you can outsource the execution but not the responsibility”).

So airlines are today globally responsible for Ground Operations. In their efforts to demonstrate the consistent safety hereof to the CAA that issued their AOC airlines consequently have a system in place that includes just culture policies, risk management practices, operational procedures, training, operational oversight, reporting and audits.        

A consequence of the present set-up is that each airline has its own Ground Ops procedures and these might indeed differ a bit in various details.

And this is a problem in at least two dimensions:

1. The GSP staff on duty has to adhere to slightly different procedures when walking from aircraft to aircraft on the ramp or from cargo shipment to cargo shipment in the warehouse. And while these slightly different procedures are typically developed by airlines in response to risk assessments the presence of slightly different procedures from airline to airline is a safety risk in itself that airlines have so far not really reflected on.
2. The GSPs are audited by all their airline clients at every station in a 2 or 3 year cycle whereby larger GSP then can have a few extra staff doing nothing else than facilitating airline audits, which is in addition to the disturbance audits always cause even if for sure not intended by the airlines, is disturbing and inefficient.

Given the change that the airline is no longer responsible for Ground Operations EASA has also issued an amendment to the Operator regulation that clarifies that the airline remain responsible for “Flight Dispatch”, “Load Control” and “Ground Supervision” and more importantly it also makes it a “may” and not a “must or shall” that the airline chooses to accept the procedures of a GSP at a station (ref ORO.GEN 315(c)). 

So, as airlines anyway remain responsible for some activities as mentioned above even by relying on GSP for the other procedures they will still have to provide the full range of procedures, oversight and audits for the elements they are responsible for, e.g. the verification process that the aircraft was actually loaded as per Loading Instruction.    

Finally comes the issue of auditing a regulation or a program. No audit certificate is any stronger than the weakest entity being found good enough. How hard are the EU audits going to be? Will it be difficult to be certified?… One would hope so.

So, airlines in their Safety Boards will have to make a decision whether they consider the policies and procedures of the certified GSP good enough for it to accept them as replacement of their own procedures…This is quit a call for the “Nominated Person, Ground Operations” and the “Accountable Manager” and will likely at least call for a detailed risk assessment of the difference station by station given the lack of fixed procedures (which busy airline teams may not have the time available to conduct) and airline legal teams will be seeking clarity whether the airline is now really not responsible when an incident or accident happens with a loss of life as the consequence of not having full oversight of GSP activities.

Some airline senior management may next to the formal clarifications mentioned above also have a view on the overall risk to brand and reputation by letting go of an area of own operational control.

The EASA initiative would probably have been one step more solid if it had been backed by concrete detailed procedure to be adhered to as part of the certification. Such procedures preferably co-developed by Airlines and GSPs…IATA & ASA do you get the hint? IGOM has a possibly great future when finished with the needed level of detail and further not as now being accepted by some airlines with a list of airline specific variations rendering the standard non-standard from a GSP perspective.

So, EASA has taken a bold step and with everything new there will be some adjustments to be done by all stakeholders to avoid what nobody wants: a new regulation giving the GSP another certification to achieve and audit scheme to facilitate while airlines keep on doing business as usual…