Do the evacuation procedures with a reduced number of required cabin crew during ground operations or in unforeseen circumstances require prior approval according to the new Air OPS Regulations?
Reference: Regulation (EU) No 965/2012 on Air Operations, ORO.CC.205, GM3 ORO.GEN.130(b)
The minimum number of cabin crew and the related procedures for evacuation are approved as part of the OM. As reducing the minimum cabin crew is a deviation from the required minimum number (which must be determined based on the number established by certification rules for each aircraft type), it requires close monitoring. Therefore changes to evacuation procedures with a reduced number of cabin crew require prior approval by the Authority.
This requirement originates from EU-OPS 1.311(a):
1. the operator has established a procedure for the evacuation of passengers with this reduced number of cabin crew that has been accepted by the Authority as providing equivalent safety;”
However, for legal certainty and clarity purposes, the term 'accepted' is now avoided by the EU, as well as by the ICAO. The items for which 'accepted' was used in JAR/EU-OPS were assessed and, depending on their nature/potential impact, have been changed in the new rules into 'notified' or 'approved'. Changes requiring prior approval are now clearly identified.