Can you share your experience

[capitaine flam]

I am carrying out independent research with respect to EASA regulations and their general user-friendliness as well people’s attitudes towards them. I am trying to find out what are the views, feelings and actions of civil aviation players with regards to EASA regulations in terms of their complexity or simplicity, whether they are easy to understand, if aviation staff know where to find them etc.

If your job is governed to a greater or lesser degree by EASA regs, I would be grateful if you could take 5 to 10 minutes of your time to complete this survey. It is not limited to UK aviation staff, but to anyone outside UK also working within the remit of EASA.

Here is the link, or please simply copy and paste it in a new page in your brower.

EASA Regulations and You (http://www.smartsurvey.co.uk/s/5DCP2/) or smartsurvey.co.uk/s/5DCP2/


Kindest regards,

Delphine Ryan BSc (Hons) MIET ARAeS
[email protected]

[Genghis the Engineer]

I've just filled out your survey Delphine, but to some extent felt that the premise behind it was flawed. Virtually nobody but the authorities themselves use the top level EC regulations. Within the industry (defined as you will) we almost invariably use the next level regulations - CS standards, EU-ops, EASA-FCL, Annex II, and so-on and so-forth. Those you didn't mention, and are highly relevant to many of our jobs; we know that there are European Community acts behind them, but few people ever actually need to access those.

G

[capitaine flam]

Hi Genghis

Thanks for your comment and I see what you are saying. I have used the 12 regulations each of which include their respective annexes. The regulations themselves are only a few pages long usually, but the annexes you refer to are the big bits. (Saying that the Basic Regulation is rather long).

For example Regulation 1321/2014 (which used to be 2042/2003) is only six pages, immediately followed by Part-M, Part-145, Part-66 and Part-147 which make up the remaining 188 pages.

The EASA website has a nice diagram showing the basic regulation, then the 12 regulations, and all their annexes.

So when I wrote this list, it was with the annexes in mind too. I should have made that clearer as I see that this could cause misunderstanding.

Are you saying that from your experience, people will just go straight to the annexe that deals with their area, but don't tend to look at the cover reg?

I am interested in seeing how users feel about reading regulations, hence the bulk of the questions on the survey, including any factors that may put people off from reading them, particularly the parts that apply to their jobs.

Thanks for your input as always. Kind regards, Delphine

[Genghis the Engineer]

Pretty much everybody will work by the working regulations - in my case typically CS.23 or CS25, EASA-FCL and then next layer interpretative materials such as the CS.23 AMCs, or UK's CAP 804. Virtually nobody goes up a layer to the encompassing regulations as they're largely irrelevant to most of us and we usually don't even know their names and definitions - and it's those regulations which you've listed.

Incidentally where in my opinion EASA most falls down is not on publishing and making accessible the regulations, but the explanations of how to use your application. I know my way around CS.23 extremely well and have no trouble constructing a technical case using it, but have at best a vague idea of the route by which I make a design application to EASA which includes that technical case.

G

[capitaine flam]

Hi Genghis

Thanks for the explanation. It's interesting to hear that most people just go straight to the Part that applies to their job and wouldn't necessarily be aware of the cover reg.

As for your remark on application process, that is beyond my knowledge since I don't work for EASA and not familiar with CS-23.

I am in the process of writing a guidance manual with the purpose of explaining how to go about finding regulations, understanding their lay-out, how to go about reading them, etc. and one of the purpose of the survey is to try to understand what are the main issues people encounter with dealing with EU regs. Hopefully, I will be able to successfully address some of these points in the manual so as to help the reader overcome any difficulties encountered when reading regs etc. It will go on my blog for free downloading by anyone who may find it useful for their work or their office.

But as you have brought up this point about application, this has made me curious, so I will have a little dig around.

Kind regards, Delphine

[Genghis the Engineer]

If I could make a suggestion as to a research route Delphine - let's say you've been given a problem to solve - how about a new baggage locker, on a middle range EASA aeroplane. Something like an Islander, which is the top end of CS.23 (or if you're happier with CS.25, a Falcon 50). Use that as a route to find the regs.

I think that you'll find the regs applicable to the baggage locker fairly easily in CS.23/CS.25; you should find advisory material in AMCs, and you can usually use some FAA ACs to help you which EASA will accept.

Then work out how EASA wants the application constructed, how you make it, to whom... At that point I think that you're likely to find the problems I'm referring to.

G

[CEng FRAeS]

[capitaine flam]

Hi Genghis

Thanks for that. I will include this problem that you have posed in my research work, it looks interesting (and I have just become curious now).

I see that you are a FRAeS. Last November I attended a Maintenance & Airworthiness workshop at the Aerosociety in London, which was really interesting, and a lot of the independent research I am doing is to contribute to some of the issues being discussed in that field at the time. If you read the Aerospace mag, I had a letter printed in last November's issue (if I remember rightly), which revolves around what I am doing, and hopefully more will come out of that.

So thanks for taking the time to always respond to my posts and surveys on this forum as you have done ever since I first posted when I was a student. Much appreciated.

Kind regards, Delphine

[Genghis the Engineer]

I missed that workshop unfortunately, but saw the programme - it looked very interesting. Always glad to help, and feel free to contact me directly if I don't pick anything up on PPrune.

G

[darkbarly]

Done.

Generally, most colleagues have no idea about linking the amc/gm to the intent of the rule, or indeed that, potentially, NO amc/gm exist if the rule contains the objective AND the means of complying with it.

:ok:

[Rigga]

Hi Delphine,
Ive just completed your questionnaire and found that I DO refer to some of the regulations you quote, though this is because I have to understand them to monitor performances against them. As you know, I know Annex II quite well and have now moved to Part 21 in some depth. In my current role I don't monitor airports and atco's.
You are right in assuming the top level regs are generally missed out from any ad-hoc quest for information. Why would people go that high? It doesn't concern them and no authority quotes them.
In my opinion, the great majority of directors, managers and qualified staff don't refer to the top level docs, as Genghis suggests and, as Darkbarly suggests, the use of AMC and GM is well beyond most end-users' grasp.

[riff_raff]

I work in the US aerospace industry, and most companies operate under the global AS9100 standard. The AS9100 standard requires everyone performing work on a project that must conform to standards such as US FAA FARs, EASA regs, etc. to receive training to understand how the standards need to be applied with their job functions, where to find the current revision of any standard, and what to do when they have any question about how to interpret the standards.

If your company is operating under an AS9100 cert, and is producing a product that must conform to EASA regs, everyone involved should already be familiar with any relevant EASA regs, know where to obtain current revisions of the regs, and how to apply them in their job functions.

[lomapaseo]

If your job is governed to a greater or lesser degree by EASA regs, I would be grateful if you could take 5 to 10 minutes of your time to complete this survey. It is not limited to UK aviation staff, but to anyone outside UK also working within the remit of EASA.

I'll second what many have already said above.

In my view, most aviation folks would have trouble interpreting and complying with a rule. With that said many rules have "How To" advisory material etc. for a means to comply, but not necessarily the only means.

I spent many countless hours arguing about what the basis of the rule meant, but in the end was able to draft a comprehensive means for others to comply with the rule to the satisfaction of the regulator But that was my job and the many others were happy to follow the advice :)

[Rigga]

Many people working in continued airworthiness organisations do not see any regulation or even references to regulations, possibly for years. This is because they do not need to see them as they work to company expositions, processes and aircraft/component manuals - all produced for, and in, compliance to the regulations within the scope of work carried out.

[capitaine flam]

Hello everyone

Thanks very much for your many useful comments. By the way, my research is looking at regs across all aviation, not just aircraft maintenance. I just happened to post on this one first as it's more my area. I am also getting surveys done with pilots, ATC staff etc. So all my comments are general for all aviation.

[capitaine flam]

You are right in assuming the top level regs are generally missed out from any ad-hoc quest for information. Why would people go that high? It doesn't concern them and no authority quotes them.
In my opinion, the great majority of directors, managers and qualified staff don't refer to the top level docs, as Genghis suggests and, as Darkbarly suggests, the use of AMC and GM is well beyond most end-users' grasp.

I just wanted to add a comment. The top level reg is really the Basic Regulation and perhaps a few odds and ends. The 12 regs in my survey are the cover regs such as Air Ops or Continuing Airworthiness which are based on the Basic Reg.

For example, Air Ops regulation is only 4 pages, followed by Part-ORO, Part-CAT etc. While I can appreciate why one may not be interested in looking at the Basic Reg, I don't really understand why one would not look at the cover reg of those parts/annexes which apply to his/her work. In our example with Air Ops, the cover reg gives the intention of all the parts in Air Ops, so surely this could be of concern to the end-user. Also, the AMCs/GMs directly affect the end user in many cases and are intended to be one way of implementing the rules. Since the parts or annexes together with their AMCs/GMs are the lowest level of the regs, surely, that's the first place one would look?

[lomapaseo]

Capitaine flam

Most companies have a high level responsible for airworthiness whose job it is to see the minions are aware of and comply with regulations. At least the processes and paperwork should be in place. Whether they are followed or not is subject to auditing first by the company office that oversees airworthiness and last by your friendly regulator.

There are many outside experts ready to step in and help if an organization is not up to the job. I really do hate to see that the regulator has let this process down but it does happen

[capitaine flam]

Thank you everyone for your helpful comments and views which offer much food for thought.

It is appreciated.