Airworthiness
This webpage provides information to States and operators to assist in maintaining an acceptable level of safety and aircraft airworthiness while addressing the challenges associated with the return to normal flight operations subsequent to the impact of COVID -19 crisis. It includes recommendations that are aligned with the aircraft OEM perspective on the continuing airworthiness of their products.
Aircraft parking and storage
Aircraft and equipment disinfection
Safety considerations for use of alcohol-based hand sanitizers in aircraft
Alcohol-based hand sanitizer in aircraft
Target audience
- Operators covered under Annex 6 – Operation of Aircraft, part 1 – International Commercial Air Transport - Aeroplanes
- Civil Aviation authorities, Governments and airports
References:
https://www.cdc.gov/handhygiene/firesafety/index.html
According to the CDC (Centers for Disease Control and Prevention), hand hygiene is a critical component for the safety of the public; however, alcohol-based hand sanitizers (ABHS) contain alcohol, which readily evaporates at room temperature into an ignitable vapour, and is considered a flammable liquid. Although the incidence of fires related to ABHS is very low, it is vital that ABHS is stored safely and that bulk dispensers are installed and maintained correctly. It is important to make sure ABHS dispensers are accessible and in locations that do not increase the chances of igniting or spreading a fire.
While it's true that most hand sanitizers have a flashpoint around room temperature, that doesn't mean the liquid will catch fire if it reaches that temperature. Flashpoint is a technical term used to characterize the propensity of a liquid to burn. It defines the temperature at which a liquid gives off enough vapour to become ignitable in the air. At that temperature, however, an ignition source, like a flame or electric spark, is required for ignition to occur. Spontaneous ignition involves a substance self-heating to a point where it ignites, without the need for any outside ignition source like a flame. Hand sanitizer is not subject to self-heating and would require temperatures to reach over 700 degrees Fahrenheit to spontaneously ignite, according to Guy Colonna, director of Technical Services at NFPA (National Fire Protection Association).
The ABHS is for use during the boarding / disembarking and is to be stored for TTOL and during the flight. Note: the installation of the ABHS should not conflict with other certification requirements (no obstruction into the emergency evacuation access path, etc.).
The elements associated with the use of alcohol-based hand sanitizer in aircraft are listed below.
Element 1: Required distance of alcohol-based hand sanitizer from ignition sources in aircraft
Element 2: Limit quantities of alcohol-based hand sanitizer on aircraft
Element 3: Flight crew use of alcohol-based hand sanitizer
On-site inspection and surveillance
This section provides guidance to ensure that operators, approved maintenance organizations, and maintenance control organizations remain in compliance with State requirements regarding their respective responsibilities and that an appropriate and equivalent level of safety is maintained after the impact of the COVID -19 crisis.
ICAO requirements on Operators' continuing airworthiness responsibilities
Annex 6 Part I Chapter 8, 8.1 and Annex 6 Part III Section II Chapter 6, 6.1, respectively require the following:
- Operators in accordance with procedures acceptable to the State of Registry, ensure that each aircraft they operate is maintained in an airworthy condition
- Operators shall employ a person or group of persons to ensure that all maintenance is carried out in accordance with the maintenance control manual.
To meet the intent of the abovementioned Standard, some States issue acceptances or approvals to a person or group of persons within the operator or a maintenance control organization with a specific approval (e.g. EASA Part M, Subpart G) to manage the continuing airworthiness responsibilities of the operator, both with requirements to maintain the continued validity of the acceptance/approval.
Where a State has issued an acceptance/approval to an operator or to a maintenance control organization with continuing airworthiness responsibilities it means it has determined that:
a) the operator or the maintenance control organization has a satisfactory regulatory compliance history and the on-site inspection activities required to be completed could not be performed by the States issuing the acceptance/approval for the:
- continuation of acceptance of a person or group of persons within an operator with continuing airworthiness responsibilities; or
continuation of the specific approval for a maintenance control organization with continuing airworthiness responsibilities (e.g. EASA Part M, Subpart G, Part-CAMO) for an operator;
and
b) the person or group of persons within an operator or a maintenance control organization with continuing airworthiness responsibilities holding a valid acceptance/approval have met the requirements for the continuation of the acceptance/approval, except for the State's on-site inspection.
ICAO requirements on Continued validity of maintenance organization approvals
Annex 8 Part II Chapter 6, 6.2.4 requires States to ensure that the continued validity of the approval depends upon the organization remaining in compliance with the appropriate requirements defined in the chapter and with the relevant provisions regarding safety management system contained in Annex 19 for an approved maintenance organization.
To meet the intent of the abovementioned Standard, some States have regulations to issue organizations approvals (Airworthiness Maintenance Organizations (AMOs) or organizations performing maintenance under an accepted equivalent system) with or without an expiry date, but with requirements to maintain the continued validity of the approval.
Where a State has issued an acceptance/approval to AMOs or organizations performing maintenance under an accepted equivalent system it means it has determined that:
the organization has a satisfactory regulatory compliance history;
continuation of approval of such organizations relies on the on-site surveillance activities required to be completed, by the States issuing the approval;
the CAAs are unable to perform on-site surveillance activities due to COVID-19 crisis;
the maintenance organizations holding a valid approval and all the requirements for the continuation of the approval of the organization(s) have been met, except for the CAAs on-site surveillance.
Risk-based prioritization for conducting on-site inspections /surveillance
The use of a risk-based approach, including the risk profile of the operators, maintenance control organizations, and maintenance organizations to determine which organizations are of greater risk or concerns and prioritize the resources and on-site inspection/surveillance required for such organizations should be considered. In determining the risk profile, States may consider the following:
- the organization's current level of risk given the changing landscape of aviation operations.
- changes in activity and/or capability during the COVID-19 contingency.
- the robustness of the organization's quality system.
In the event that States have difficulties in performing high priority on-site inspection/surveillance activities, the alternatives adopted should ensure continued compliance with appropriate requirements by the operator, maintenance control organization with continuing airworthiness responsibilities, or maintenance organizations. The alternatives could comprise:
- Desktop audits to assess the effectiveness of the procedures contained in the accepted Maintenance Control Manual (MCM) or the approved Maintenance Organization Procedures Manual (MOPM), and to ensure the availability of adequate systems for the planning of maintenance as applicable.
- Other systems/tools to remotely review documentation (e.g. maintenance programmes, records and certifications, maintenance and personnel training records, maintenance certification, etc.) and address issues, which require interaction between the operator, maintenance control organization with continuing airworthiness responsibilities, or the maintenance organization and the CAA.
- Other interactive means such as remote interviews and inspections to assess the adequacy of the facilities, equipment and the structure of the applicant's maintenance control organization, tools and materials, etc.
For a person or group of persons within the maintenance control organization with continuing airworthiness responsibilities located outside the State issuing the approval, the State's ability to make on-site visits may be significantly lower than that of the State in which the maintenance control organization with continuing airworthiness responsibilities is based.
For a maintenance organization approved by the State of Registration (SoR) and located in a State other than the SoR, the State's ability to make on-site visits may be significantly lower than that of the State in which the organization is based.
In these cases, it is recommended that before adopting the alternatives above, the approving State considers alternative arrangements between States to reduce duplication of on-site inspection/surveillance by:
- giving credit and/or recognize the on-site inspection/surveillance activity performed by the State where the maintenance control organization is based, which benefits from proximity and easier access to the maintenance control organization; or
- delegating the on-site inspection/surveillance activity to the State the maintenance control organization is based.
The use of such alternatives to on-site inspection/surveillance activities is not recommended when a person or group of persons within the operator or maintenance control organization with continuing airworthiness responsibilities, AMOs or organizations performing maintenance under an accepted equivalent system approval is subject to relevant enforcement, or any suspension, revocation or cancellation action.
The timeframe in which this guidance is used should be limited to a period needed to continue operation and should be revoked once compliance with the standard can be achieved through normal inspection/surveillance activities. It is important that States consider the management of the change to re-establish normal on-site inspection/surveillance activities in an orderly way post-COVID-19 contingencies.
ICAO's Risk-Based Surveillance Tool (RBST) allows for the building of risk-based inspection schedules for air operators.
Useful references
- Annex 19 (Safety Management)
- Airworthiness Manual (Doc 9760)
- ICAO Handbook for CAAs on the Management of Aviation Safety Risks related to COVID-19 (Doc 10144)
- Manual of Procedures for Operations Inspection, Certification and Continued Surveillance (Doc 8335)
- Safety management manual (Doc 9859)
- Airworthiness Manual (Doc 9760)
- Safety Oversight Manual (Doc 9734) Part A