Today we launch our Summer Safety Information Bulletin (SIB). This article explains will help you make sense of everything in the SIB and how it links to our Summer Safety Campaign 2023 - "No Compromise on Safety". We are here to help you prepare for a summer of safe and effective operations. and it’s all about ensuring our passengers can enjoy lots of thrilling summer adventures that are also safe and secure.
You can access the SIB itself via the EASA Safety Publications Tool here.
You can also access all the presentations and material from Safety Week 2023 here and watch back the sessions from EASA Safety Week 2023 from 30 May to 2 June (7 Webinars covering the different operational domains).
Summer 2023 Campaign – What do we mean by “No Compromise on Safety”
Firstly, the whole title of campaign is designed to get you thinking and talking about safety. The reality is that there will be some compromises to made in your operations this summer. The challenge is to make sure that you make any difficult decisions following a clear risk-based, decision-making process that result in risk being owned by the organisation and not by the front-line staff.
We ask you to consider if your organisation is “Ready, Resilient and Responsive enough for this summer's challenges?” Rules provide the baseline – hence the no compromise element. It’s vital that you identify and manage your risks while also looking after your people so they can perform to their best.
- Ready: You have enough competent people and the resources you need to manage risks effectively so that you can ensure safe and effective operations.
- Resilient: You are prepared for any operational challenges and external threats and support your staff to perform to their best. You don't push the boundaries of the rules and are on guard for risk transfer.
- Responsive: You have the mindset to promote safety reporting and encourage collaborative safety conversations. You react positively and quickly to challenges or changing situations and communicate effectively.
What are the top safety issues and risks that can be expected this summer?
Even though summer hasn't officially begun, we've already seen signs of possible disruptions in April and May 2023. That's why EASA is closely monitoring the situation, continually collecting data, and analyzing information to help you address potential safety risks. Following analysis with our collaborative partners the following issues have been identified.
- Ineffective management of change
- Shortage of operational and technical staff (not limited to flight and cabin crew)
- Various aspects of cyber-attacks
- Loss of knowledge, expertise and transfer of experience following
- Ground handling training programmes disruption
- Missing suppliers and low availability of parts
- Lack of time to properly train staff
- Disruptive passengers (for this topic we will launch a separate campaign from 19 June – register for the webinars on the Ready to Fly Campaign page here).
- Capacity issues
Of course there will other issues that you will face within your own operation so make sure to identify them as part of the “Being Ready” part of your summer preparations. Of course things will change over the summer, this is why “Being Responsive” is so important. You need to have a positive approach to reporting and make sure that having open safety conversations is part of normal daily operations in your organisation.
Safety Risk Management (SRM)
The first batch of actions in the SIB cover the management of safety risks. As described earlier, it is important to identify how the risks above might apply in your organisation. It’s a good idea to brainstorm what other risks you have that might be specific to your operation.
A key part of “Being Resilient” is to stress test your risks and their mitigations. You could be faced with many different challenges this summer, perhaps even multiple challenges at the same time. The more you identify them in advance and consider what you would do to mitigate the risk, the better placed you will be for a safe summer. Don’t forget to include psycho-social risks that impact your staff’s ability to perform to their best.
It cannot be said enough, having a positive safety culture that encourages reporting is vitally important this summer.
- As part of their safety risk management process, consider conducting a specific risk assessment to identify areas where safety risks may increase as a result of the issues listed above, or as a result of traffic disruptions generally.
- When performing risk assessments, consider interactions between different safety issues (e.g. potential lack of qualified staff and fatigue) that are relevant to their activities or operations.
- Based on the results of the safety risk assessment, strengthen their monitoring of the affected areas and take appropriate mitigating measures.
- Ensure that operational pressure will not adversely impact the reporting and safety culture in their organisations.
- Emphasise, at all levels, the importance of fostering a positive safety culture that encourages staff to report occurrences and hazards with confidence.
Flight Time Limitations (FTL)
There is a huge risk of fatigue this summer. The key word is “summer”, this busy period will last to September so you need to manage fatigue effectively for the whole time. The specific recommendations from the SIB are these:
- When planning crew monthly rosters, consider operational disruptions (e.g. provision of ground services, ATM congested area) with a known high proportion of flight delays and cancellations (e.g. time needed for crew security check, taxiing, longer turnaround times), in order to avoid reaching duty period limits that may potentially impact crew fatigue.
- The exercise of commander’s discretion is an exceptional measure. Extension of flight duty period when operating to and from aerodromes with a known high propensity for delays should not rely on excessive use of exceptional relief solutions. Furthermore, any scheduling of crews, with commander’s discretion already included is not acceptable and the planning of extensions should be limited as much as possible. Moreover, commander’s discretion should be avoided at the air operator’s home base and/or hubs, where standby or reserve crew members should be sufficiently available.
For operators, there are also these important recommendations:
- Frequently review and adjust the schedule to take into account the availability of qualified crews (flight and cabin), maintenance and technical staff, availability of aircraft and spare parts, ATM network performance, adequacy of ground services at the airports where they operate.
- Avoid pairing of newly upgraded commanders with inexperienced first officers.
- Avoid scheduling cabin crew together where all have less than 6 months experience.
- Avoid potentially challenging crew training activities so that the quality of training is not adversely impacted by operational disruptions (e.g. introduction of new aircraft, operators conversion courses, initial SPA training, etc) during the summer months.
- Anticipate an increase in the number of unruly passengers and ensure that crew and, where applicable, ground handling personnel are trained on how to detect, defuse and prevent critical situations, including the causes of unruly behaviour and how to handle and report these situations.
- Remind all staff of their role, including line supervisory level, in ensuring thatsafe and reliable operations is given first priority.
From a planning perspective, there are also these recommendations for operators:
- Carefully plan the availability of aircraft to cover the summer schedule. If wet leased aircraft are to be used, operators are recommended to notify their competent authority in due time. This will allow a smooth process and potentially avoid delays.
- Plan activities considering a realistic availability of qualified personnel (operational personnel and crew).
- Adapt the flight plan (e.g. discretionary and/or additional fuel) to the available information related to possible delays en-route or at arrival in order to avoid any unnecessary diversions.
Recommendations specifically for the Aerodromes and Ground Handling Community
When it comes to aerodromes, the SIB has some specific recommendations for you. Although the SIB specifically only applies to aerodrome operators falling under the scope of Commission Regulation (EU) n°139/2014, these actions would hopefully be useful for everyone in this community.
- Aerodrome operators should increase collaboration with ground handling service providers, air operators, security services providers and other Member State agencies, to ensure the best use of all available human resources and of the aerodrome infrastructure.
- In order to optimise the use of ground handling personnel, aerodrome operators with several ground handling service providers could consider supporting the allocation of aircraft at stands grouped for each ground handling service provider, provided that the characteristics of the aircraft are also taken into account.
- Aerodrome operators should coordinate the management of overflow traffic on the ground with the air traffic services by identifying possible areas where overflow traffic can wait until aircraft stands are available.
- Aerodrome operators should apply a collaborative decision-making process with the relevant aerodrome stakeholders based on actual operational information, to identify any emerging operational or capacity issues due to staff shortages, and implement actions to mitigate the impacts. Local Runway Safety Teams, Airport Security and/or Facilitation Committees and Apron Safety Committees may increase collaboration and monitoring.
- Aerodrome operators should assess safety risk performance data in their safety committees and share it with other stakeholders during meetings of the local runway safety teams or during other meetings with other organisations with safety relevant activities at the aerodrome.
When it comes to training, there are the following recommendations:
- Aerodrome operators should identify the necessary training for each person (initial, recurrent, refresher) in accordance with ADR.OR.D.017 of Regulation (EU) No 139.
- With regards to training of ground handling personnel, the aerodrome operator should collaborate with ground handling service providers and air operators to obtain an overview of training performed for ground handling personnel.
- Ground handling service providers should ensure that their personnel are adequately trained and qualified and their competencies are maintained.
- Ground handling service providers should inform their customer airlines and the aerodrome on the training provided to its personnel to ensure their continued competence, especially when the organisation experiences a high turnover of staff or increased workload, which could negatively impact the capacity for training.
It is vitally important that ATM/ANS providers maintain and potentially enhance collaboration with air operators, aerodrome operators and the Network Manager. The main thing to keep everyone information about any anticipated sector capacity issues.
The main recommendations for the ATM community are these:
- Meet rostering obligations to avoid potential fatigue for all duty staff and to balance workload and rest, especially in sectors close to maximum capacity.
- Roster the team in the manner such that newly qualified ATCO’s are supported by experienced staff ( e.g. planners) when managing busy sectors.
- Ensure there are sufficient personnel on stand-by shifts in case there is a need to manage busy sectors.
- Be prepared to react to potential severe weather phenomena, which could, amongst others, impact ATC operations in case of en-route rerouting and/or diversions.
- Anticipate and mitigate against a possible lack of spare parts, to ensure that the ATM system can maintain full operational capability.
Recommendations for the Maintenance Community
Continuing Airworthiness Management Organisation (CAMO) and Maintenance Organisation’s have specific challenges around the lack of sufficient qualified personnel and problems with the supply chain can be increased by the commercial pressure of operational circumstances. This commercial pressure can then lead to a potential safety risk through increasing levels of fatigue and shortcuts in internal procedures.
- Raise awareness to staff about safety risks emerging from increased commercial demand.
- Planning activities based on a realistic manpower plan, including CAMO subcontractor staff and all Part-145 staff.
- Nominate adequate deputies for the essential activities to ensure the necessary continuity.
- Establish a pro-active supply chain management.
- Remind staff that there are no short cuts to safety (e.g continually apply the internal procedures and to report any deviation or event).
- Continuously adjust the hazard identification based on the available data (e.g availability of spare parts, extension of MEL, staff fatigue).
Approved Training Organisations (ATOs)
Potential disruptions in training means you have a key role to play in keeping operations flowing. There are specific challenges caused by not having enough qualified instructors or the unavailability of suitable Flight Simulation Training Devices (FSTD). In particular, ATOs should anticipate that qualified instructors who also fly for Air Operators may not be available to provide training during peak periods.
The ATO should consider the following actions:
- Engage in collaborative efforts with Air Operators to ensure the presence of instructors.
- Establish standardised procedures for instructors regarding Air Operator operations, ensuring their qualifications align with the training requirements.
- Coordinate and proactively address training needs in coordination with Air Operators, giving priority to training tasks that minimisze disruptions in operations.
- Plan training sessions by optimizing the utilization of FSTDs.
- Explore the possibility of utiliszing alternative training facilities to enhance the availability of suitable FSTDs for training purposes.
According to data collected and reviewed by the EASA Cyber Threat Intelligence Team, Distributed Denial of Service (DDoS) attacks and ransomware are currently the most common threats to the aviation industry.
DDoS and defacement attacks rarely have a major impact on critical systems of the targeted organisations and are often carried out by cyber activists. However, successful ransomware attacks are more complex and sophisticated, and therefore could be extremely damaging.
In Q1 2023, ransomware gangs targeted all aspects of the aviation industry and current data suggests that this trend is likely to continue for the foreseeable future. Cybercriminals target the aviation industry primarily by means of initial access for resale and credential theft.
Airlines and airports were the most targeted parts of the aviation industry by a considerable margin. This is likely due to a number of factors, including that both sectors handle commercial and strategically sensitive information. Airlines hold significant amounts of proprietary data and customer PII. The publication of both data types could have reputational and regulatory consequences for the victim organisations and can also be sold for competitive sums on criminal dark web forums.
Recommendations after a ransomware attack:
- Isolate and disconnect affected systems.
- Report the incident.
- Assess the impact.
- Determine the ransomware variant.
- Restore from backups (if not also infected).
- Engage law enforcement and cybersecurity experts.
- Strengthen security measures.
- Educate and train employees (to improve cyber resilience).
- Improve incident response plan.
- Lessons learned from the incident shall be shared.
National Competent Authorities (NCA)
The national aviation authorities are officially termed National Competent Authorities (NCAs) in the SIB. This is because they are not always the CAA, especially in some domains such as ATM. All authorities have a key role to play in ensuring the safe of the aviation system this summer.
The SIB included some key recommendations for them:
- NCAs should prioritisze oversight activities based on the results of organisational risk profiling and should consider the identified potential contributors to possible disruptions (e.g delays and possible consequences of staff shortages and fatigue). As an example in the OPS domain NCAs should focus on the implementation of Subpart Flight Time Limitations of Annex III (PART-ORO of Commission Regulation (EU) 965/2012) monitoring how air operators are planning flight duty periods and, in particular, how air operators ensure that crew members remain sufficiently free from fatigue in order to operate at a satisfactory safety level under all circumstances.
- NCA should be aware that possible urgent operational needs might be requested by air operators which might require approval process that need specific consideration about qualified inspectors availability.
- NCAs should consider holding the meeting with the organisation's Accountable Manager sooner than normal, in order to increase awareness regarding possible operational difficulties and to assess the organisation’s preparedness.
- NCAs should consider the EASA SIB during the risk-based oversight planning activities.
Additional EASA Guidance Materials
Stakeholders should consider relevant EASA guidance material and safety information bulletins, notably SIB 2020-13, SIB 2020-07R2 and SIB 2022-06 that are relevant to the possible summer disruption situation. EASA has also published systemic and conjunctural safety issues in EPAS Volume III – Safety Risk Portfolios, edition 2023 some of which might be relevant to the possible summer disruption situation. Furthermore, stakeholders should consider the safety promotion material of the EASA Safety Weeks of 2022 and 2023 and safety material on the EASA Air Ops Community developed as part of the Stronger, Safer, Together Campaign.