NPA OPS-30 COMMENTS & RESPONSES - Aircraft Security

Transcription

1 NPA OPS-30 COMMENTS & RESPONSES - Aircraft Security Prepared by the ad-hoc WG (4 vember 2002) Introduction A total number of 110 comments were received, of which 67 were proposals for changes. The ad hoc WG, formed by members of the JAA Task Force(OPS Division, CERT division) on Security Matters, have reviewed all comments and have grouped the comments under the headings of the respective JAR-OPS paragraphs for easier evaluation by the OST. The comment on the NPA in general and the Explanatory tes are grouped separately. The ad hoc WG have checked the NPA-30 against the NPA-25D-336 and NPA and have found a few inconsistencies that has to be corrected. The ad hoc WG s proposed redrafted text, based on a first evaluation of the received comments are added as the last comment under the respective group of comments. Comments and proposals have mainly been concentrated on: The proposed training requirements concerning physical defence training, the use of non-lethal protective devices and live situational training exercises; The proposed periods for the locking/unlocking of the flight compartment door which is found by most to be too restrictive; Equipment related matters and functions as well as establishing of operational procedures; and The applicability dates. NPA (General) Comm 037 Servair NPA-30 General comment: operation ted Private not affected Charter, Switzerland 048 CAA, Czech NPA-30 comments ted Republic Justification/Comment(s) Proposed text OST NPA OPS 30 CRD Page 1 of 35

2 050 NOVA NPA-30 Propose to delete all. ted Airlines, Sweden General comment: The comments on the cost are related to a situation where all three NPAs are adopted. The basic opinion is that the fight against terrorism shall be carried out on the ground (- -) technical costs for modification will amount to EUR for each aircraft (- -) cost for loss of production revenue during introduction will amount to EUR for each A330 and EUR for each B737 (- -) If the measures proposed in this consultation draft are implemented, the cost cannot burden the company but must be funded through the Government authorities Justification/Comment(s) Proposed text OST The public confidence in safe flight must be restored and unfortunately this requires appropriate measures on board of aeroplanes. It should be stressed that on board security measures is the last line of defence, and due to the specific security environment on board of aeroplanes, security measures taken on board can never be a substitute for security measures taken on ground. Funding by National Authorities of modifications of aeroplanes to meet security requirements according to JAR 25/26 and JAR-OPS 1 must thus be negotiated by the individual operator. NPA OPS 30 CRD Page 2 of 35

3 052 JAA EQSC NPA-30 General comment: Equipment related matters ted should be dealt with within subpart K of JAR-OPS 1 and be certified according to JAR-OPS Justification/Comment(s) Proposed text OST This issue has been debated by the OST and the OST concluded that all ICAO Annex 6 Amendment 27 requirements should be contained in Section S. Implementation times are unrealistic and, in addition the entire door area outside the flight crew compartment has not been defined. There are currently no airworthiness standards available for any door monitoring equipment including corresponding features and specifications. EQSC strongly recommends to delay the applicability dates considerably ted ted ted Implementation times are derived from Amendment 27 to ICAO Annex 6. For monitoring of door area s see ( c)(2) no. 042, 064 and 095 JAA will harmonise airworthiness standards for monitoring equipment with the FAA. FAA NPRM is pending. Applicability dates are dictated by ICAO Annex 6 part 1 chapter 13, Amendment 27. The applicability, as defined hereafter, may be affected by and be changed in accordance with National Aviation Security Programmes addressing onboard security. NPA OPS 30 CRD Page 3 of 35

4 Explanatory tes Comm 003 ITF Explanatory General comment: Agreed te 7 Procedures for crew communication, alarming procedures from cabin to cockpit, procedures for flight crew leaving cockpit, procedures for cabin crew admission to cockpit etc should be in place before aircraft are 004a 074 CAA, The Netherlands IFALPA Explanatory te 6 Explanatory note 7 operating with locked doors Rearranging paragraphs: JAR-OPS 1,1255(2)(a) should be (c)(1) General comment: Text missing. Reason for comment: CJAA should issue a TGL to ensure that all interphone/intra-crew communication systems onboard are operational and functioning for an aircraft to operate with a locked cockpit door ted ted Justification/Comment(s) Proposed text OST OST has invited invited topsg and FCCCSG to address such procedures once specifications for required systems become available (See no.039) Final version of NPA OPS-1-30 has already been changed accordingly. A TGL is not acceptable. MMEL/MEL requirements must be fulfilled. Equipment manufacturer are required to obtain approval of MMEL according to current procedure. (See no 086) NPA OPS 30 CRD Page 4 of 35

5 086 ECA Explanatory General comment: ted notes 7 Text missing. Reason for comment: It is unacceptable that no preparatory work on security equipment or provisions to be included in the MMEL/MEL is being carried out until 'Phase 2' doors, seeing that 'Phase 1' doors are already in use. Preparatory work must be carried out by CJAA OPS in the form of a TGL and followed by formal amendments, so as to ensure that at least all interphone/intra-crew communication systems are 100% operational/functioning for an aircraft to opwerate with a locked cockpit door Justification/Comment(s) Proposed text OST A TGL is not acceptable. MMEL/MEL requirements must be fulfilled. Equipment manufacturer are required to obtain approval of MMEL according to current procedure. (See no 074) JAR-OPS Comm 002 ITF ted Original first part of text (deleted in NPA) should be retained Justification/Comment(s) Proposed text OST The intent of the security requirements, as described in paragraph ensures that all appropriate personnel complies with the relevant requirements of the National Aviation Security pprogrammes. (See comment no. 089) (See no 011, 028 and 049) NPA OPS 30 CRD Page 5 of 35

6 European Air General Comment: ted Transport IEM on items (c), (d) and (f). What is judged "adequate" FCCCSG Insert new paragraph before revised text: "An operator shall establish, maintain and conduct approved JAR-OPS 1 training programmes which enables the operator s personnel to take appropriate action to prevent acts of unlawful interference such as sabotage or unlawful seizure of aeroplanes" Virgin Atlantic NCCU, rway In relation to ( c), (d) and (f): Inquiring if present VA training programmes will cover requirements Delete "this programme shall include the following elements", insert instead "the individual crewmember shall have the knowledge and competence of" Partly accepted ted Partly accepted Justification/Comment(s) Proposed text OST IEM can be produced before JAR-OPS has been adopted. The intent of the security requirements, as described in paragraph ensures that all appropriate personnel complies with the relevant requirements of the National Aviation Security Programmes. (See comment no.089) (See no 002, 028 and 049) Virgin Atlantic s training programme s conformance with security requirements is a matter for CAA,UK. The intent of the security requirements, as described in paragraph ensures that all appropriate personnel complies with the relevant requirements of the National Aviation Security Programmes. (See no. 089) (See no 002, 011 and 049) NPA OPS 30 CRD Page 6 of 35

7 SLV, General Comment: Agree Denmark Some non-lethal protective devices may be regarded as weapons by national authorities. A permission to carry non-lethal protective devices being regarded as weapons by national authorities in Denmark will normally not be granted, neither to Danish operators, nor to foreign operators JU AIR, Switzerland operating in Denmark Delete all after: "unlawful interference" ERAA, UK Delete whole paragraph ETF General comment: The existing paragraph which the NPA proposes to delete should be maintained t accepted See no. 089a Justification/Comment(s) Proposed text OST The National Aviation Security Programme must be in conformance with National Laws. The respective State may alter their laws according to the Chicago Convention principle of sovereignty t Accepted Amendment 27 to ICAO Annex 6 Part 1, chapter 13 requires a training programme to be defined for on board security measures. The intent of the security requirements, as described in paragraph ensures that all appropriate personnel complies with the relevant requirements of the National Aviation Security Programmes. (See no 089a) (See no 002, 011 and 028) NPA OPS 30 CRD Page 7 of 35

8 056 Justification/Comment(s) Proposed text OST LBA, General comment: Agree (See (c), no 036) Germany CRM training regarding security issues has to be amended in subpart N App 1 to JAR-OPS and subpart O App 1 to JAR-OPS and 1010 AMC OPS 1.943/1.943(a) - - CRM table 6.1 has to be updated with security issues 059 Virgin Atlantic, UK TGL 24 table has to be updated with security issues General comment: Conducting courses for cabin crew in passenger restraint techniques. Questions time "off the flying roster" for live situational exercises ted The question has to be put by VA to CAA, UK NPA OPS 30 CRD Page 8 of 35

9 066a DGAC, Partly France Delete "crew members" and accepted insert instead "all operational personnel concerned". Delete "As a minimum, this programme shall include the following elements:" and insert instead "For all concerned personnel defined above, this security training programme shall include the basic preventive measures and techniques in relation to passengers, baggage, cargo, mail, equipment, stores and supplies intended for carriage on an aeroplane so that they contribute to the prevention of acts of sabotage or other forms of unlawful interference. The programme shall include the following elements" IFALPA Delete " ensuring crew members act in the most appropriate manner to minimise the consequences of" ECA Delete " ensuring crew members act in the most appropriate manner to minimize the consequences of" Partly accepted Partly accepted Justification/Comment(s) Proposed text OST The intent of the security requirements, as described in paragraph ensures that all appropriate personnel complies with the relevant requirements of the National Aviation Security Programmes.. (See no.089a) Text will be redrafted. (See no 089a) Text will be redrafted. (See no 089a) NPA OPS 30 CRD Page 9 of 35

10 089a CAA, UK Accepted New text: "An operator shall establish, maintain and conduct approved training programmes which enable the operator s personnel to take appropriate action to prevent acts of unlawful interference such as sabotage or unlawful seizure of aeroplanes and to minimise the consequences of such events should they occur" Ad hoc WG Proposed redrafted text JAR- OPS Justification/Comment(s) Proposed text OST The redrafted proposed text takes into the respective Regulations on Security as specified by the National Aviation Security Programme. "An operator shall establish, maintain and conduct approved training programmes which enable the operator s crew members to take appropriate action to prevent acts of unlawful interference such as sabotage or unlawful seizure of aeroplanes and to minimise the consequences of such events should they occur. The training programme shall be compatible with Regulations on security as specified in the National Aviation Security Programme and the individual crewmember shall have the knowledge and competence of the following elements:" NPA OPS 30 CRD Page 10 of 35

11 JAR-OPS (c) Comm 007 Lufthansa, (c) Partly Germany "appropriate" should be accepted substituted with "basic rules of" Justification/Comment(s) Proposed text OST Security and Law Enforcement experts emphasise that proficiency in such skills is difficult to gain in the first place, and even more difficult to maintain at an adequate level over time. If defence responses are required, they should be limited to the demonstration of very basic rules only a FCCCSG (c) "self-defence" should be substituted with "situational management" AEA (c) Add new sentence: "This does not imply a mandatory requirement for physical self defence training" (See no 089b) Accepted (See no 089b) Partly accepted Physical self-defence training should not be mandatory and would not be compatible with the attitude and culture of most European Airlines towards the use of martial arts. (See no: 043a and 062a) 020 Private Express, Switzerland (c) Delete paragraph t accepted NPA OPS 30 CRD Page 11 of 35

12 036 Justification/Comment(s) Proposed text OST FOCA, (c) General comment: Agree (See , no 056) Switzerland CRM training regarding security issues has to be amended in subpart N App 1 to JAR-OPS and subpart O App 1 to JAR-OPS and a CAA, Finland (c) An Appendix has to be developed, giving examples for syllabi as required by JAR-OPS Add: "This does not imply a mandatory requirement for physical self defence training" Partly accepted Physical self-defence training should not be mandatory and would not be compatible with the attitude and culture of most European Airlines towards the use of martial arts. 062a SAS, Sweden (c) Add: "This does not imply a mandatory requirement for physical self defence training" Partly accepted (See 016a and 062a) Physical self-defence training should not be mandatory and would not be compatible with the attitude and culture of most European Airlines towards the use of martial arts. 060 Monarch Airlines, UK (c), (d) and (f) General comment: Strongly opposes requirements ted (See 016a and 043a) NPA OPS 30 CRD Page 12 of 35

13 066b 089b DGAC, (c) ted France Delete subparagraph text. New text: "Emergency response plan defined in accordance with the National Aviation Security Programme of the State of the operator." CAA, UK (c) Accepted New text: "appropriate situational management response" Justification/Comment(s) Proposed text OST Emergency response plans cover only operational ground staff. Security and Law Enforcement experts emphazise that proficiency in such skills is difficult to gain in the first place, and even more difficult to maintain at an adequate level over time. If defence responses are required, they should be limited to the demonstration of very basic rules only. Ad hoc WG ( c) Proposed redrafted text JAR- OPS ( c) (See 007) "appropriate situational management response" JAR-OPS (d) Comm 008 Lufthansa, (d) t accepted Germany Delete subparagraph text. Insert: "if the operator assigns non-lethal protective devises to crew members whose use is authorised by the State of the operator the crew member must be trained in handling those devices" Justification/Comment(s) Proposed text OST Use of non-lethal protective devices included in a proposed training programme implies such training to be conducted. (See no 038) NPA OPS 30 CRD Page 13 of 35

14 016b a 043b 062b 066b Justification/Comment(s) Proposed text OST AEA (d) Accepted (See 043b and 062b) Insert "when" between "devices" and "assigned" BMI (d) ted Regional, Delete subparagraph Scotland UK Belair Airlines, Switzerland CAAd, Finland (d) (d) General comment: n-lethal protective devices are difficult to handle and may be dangerous in aeroplanes Insert "when" between "devices" and "assigned" SAS, Sweden (d) Insert "when" between "devices" and "assigned" DGAC, France (d) Delete subparagraph (e) renamed (d) (f) delete (g) renamed (e) (h) renamed (f) Ad hoc WG (d) Proposed redrafted text JAR- OPS (d) ted Accepted (See no 016b and 062b) Accepted (See no 016b and 043b) t accepted The proposed redrafted text covers also comment no 38 under JAR OPS "use of non-lethal protective devices when assigned to crew members whose use is authorised by the State of the Operator;" NPA OPS 30 CRD Page 14 of 35

15 JAR-OPS (f) Comm 016c AEA (f) Accepted Delete subparagraph b 043c 062c 066b c Edelweiss, Switzerland (f) Delete subparagraph Accepted (See no 016c) Belair (f) General comment: Agree (See no 016c) Airlines, Additional self-defence training Switzerland is too difficult for existing personnel. CAAd, (f) Accepted (See no 016c) Finland Delete subparagraph SAS, Sweden (f) ted Rephrase subparagraph DGAC, (f) Accepted (See no 016c) France Delete subparagraph (g) rename (e) (h) rename (f) IFALPA (f) New text: "live situational training exercises regarding various threat situations" ECA (f) New text: "live situational training exercises regarding various threat situations" CAA, UK (f) Delete "live" Justification/Comment(s) Proposed text OST Each National Aviation Security Programme should detail to what extent live situational exercises regarding threat situations should be conducted by respective national operators. ted (See no 016c) ted (See no 016c) ted (See no 016c) NPA OPS 30 CRD Page 15 of 35

16 Ad hoc WG (f) Proposal to delete JAR-OPS (f) JAR-OPS (g) Comm 089d CAA, UK (g) Accepted Insert "and cabin crew" between "flight deck" and "procedures to" and add: "and its occupants" to last sentence Each National Aviation Security Programme should detail to what extent live situational exercises regarding threat situations should be conducted by respective national operators. JAR-OPS (f) to be deleted. Justification/Comment(s) Proposed text OST Proposed redrafted text JAR- OPS (g): "flight deck and cabin crew procedures to protect the aeroplane and its occupants" JAR-OPS (h) Comm Justification/Comment(s) Proposed text OST 077 IFALPA (h) Delete subparagraph text.new text: "aeroplane search procedures and guidance on least-risk bomb/improvised Explosive Device (IED) Accepted A bomb is a munition of war. "Improvised Explosive Device" (IED) is the correct terminology, and will reinforce the view that IEDs can look like absolutely anything. location where practicable" 082 ECA (h) New text: "aeroplane search procedures and guidance on least-risk bomb/improvised Explosive Device (IED) location where practicable" Accepted (See no 077) NPA OPS 30 CRD Page 16 of 35

17 Ad hoc WG (h) Proposed redrafted text JAR- OPS (h) Justification/Comment(s) Proposed text OST A bomb is a munition of war. "Improvised Explosive Device" (IED) is the correct terminology, and will reinforce the view that IEDs can look like absolutely anything. "aeroplane search procedures and guidance on least risk bomb/improvised Explosive Device (IED) locations where practicable" JAR-OPS Comm Justification/Comment(s) Proposed text OST 013 FCCCSG Accepted (See no 046 and 090) Delete "if provided" 024 JU AIR, Already implemented ted Switzerland 030 FOCA, comments ted Switzerland 046 ERAA, UK Accepted (See no 013 and 090) Delete "if provided". Add "provided by the aircraft original equipment manufacturer" 058 Virgin Atlantic, UK General Comment: All Aircraft equipped with ted 090 amber/red search checklists CAA, UK Delete "if provided" Accepted (See no 013 and 046) NPA OPS 30 CRD Page 17 of 35

18 Ad hoc WG Proposed redrafted text JAR- OPS Justification/Comment(s) Proposed text OST Taking into account the proposed text JAR-OPS (h) "An operator shall ensure that there is on board a checklist of the procedures to be followed in search of a bomb or Improvised Explosive Device (EID) in case of suspected sabotage and for inspecting aeroplanes for concealed weapons, explosives or other dangerous devices where a well founded suspicion exists that the aeroplane may be the object of an act of unlawful interference. The checklist shall be supported by guidance on the appropriate course of action to be taken should a bomb or suspicious object be found and information on the leastrisk bomb location specific to the aeroplane where provided by the aircraft original equipment manufacturer" ACJ to be developed. NPA OPS 30 CRD Page 18 of 35

19 JAR-OPS Comm 005 Condor Rearranging paragraphs: Done Berlin Proposing (a) iso (1), (b) iso (2), new (c) beginning with "In all aeroplanes. "., subparagraph (1) iso (a) and 8"9 iso (b). Justification/Comment(s) Proposed text OST There are other doors to the cabin than designated passenger doors. E.g. Pantry doors, Floor-level cargo doors etc 019 Private Express, Switzerland 022 KLM Cityhopper In ( c)(1) insert "Passenger" between "external" and "doors" Delete whole paragraph General Comment: Specification of "means" and "entire door area outside the flight crew compartment required. Surveillance system not yet defined, therefore compliance date can not be established - should be one year from system availability General Comment: JU AIR, Switzerland Does not affect our operation IACA Delete whole paragraph. Propose further consideration of paragraph Partly accepted t accepted (See redrafted text ( c)(1)) ted (See NPA-30 no 052) ted ted NPA OPS 30 CRD Page 19 of 35

20 FOCA, t accepted Switzerland New ( c)(3) paragraph: "The Commander of the aeroplane shall have the right and the responsibility to decide which person will be authorised to enter the flight deck. Each operator shall provide procedures, acceptable to the Authority, by which the amount of flight deck entries will be kept to a SLV, Denmark minimum" General comment: Procedures for crew communication, alarming procedures, procedures for operational access and egress by authorised persons must be in place before an aircraft is being operated with locked cockpit doors. Justification/Comment(s) Proposed text OST See comment 67b to (c)(1) See redrafted text ( c)(1) Agree (See Explanatory note 7 no 003) 047 Appropriate MMEL/MEL revision must be published and approve before an aircraft is being operated with locked cockpit doors ERAA, UK t accepted 053 Britannia Airways, UK Delete whole paragraph Delete revised paragraph t accepted NPA OPS 30 CRD Page 20 of 35

21 057 Virgin General comment: ted Atlantic, UK Specific procedures in place to cover unforseeable situations and pilot incapacity JAR-OPS (a) Comm 001 Lufthansa (a) General Comment: ted City Line Clarification requested on the word "discreetly" 009 Lufthansa, (a) t accepted Germany Delete whole paragraph 010 ATR, France (a) General comment: ted There is no mentioned applicability date as for (b) and ( c). Shall the 1 november 2003 date be considered. 031 FOCA, Switzerland (a) The previous requirement was only applicable to passenger carrying aeroplanes. As it is proposed, the new (a) does not exclude the non carrying passenger aeroplanes Insert "or procedures" between "and means" and "acceptable to". Insert "or established" between "be provided" and "by which". Delete "discreetly" Accepted Justification/Comment(s) Proposed text OST Justification/Comment(s) Proposed text OST Will be deleted (See redrafted text (a)) Applicability dates are dictated by ICAO Annex 6 part 1 chapter 13, Amendment 27. The applicability, as defined hereafter, may be affected by and be changed in accordance with national security programmes addressing onboard security. (See (b) no 004) To this date the NPA-30 is not applicable to cargo aeroplane operation. (See redrafted text (a)) (See no 067) NPA OPS 30 CRD Page 21 of 35

22 067a 091 Justification/Comment(s) Proposed text OST DGAC (a) Accepted Will be deleted Delete "Discreetly" (See redrafted text (a)) CAA, UK (a) General comment: ted (See redrafted text (a)) The proposed JAR-OPS (a) is out of step with JAR 25 and 26 which add the condition "and having a lockable door installed between the pilot compartment and the passenger compartment". It has been recognised in other amendments that the "flight deck door" may in fact be aft of a crew rest area or dedicated crew toilet, and we are not requiring an additional door on the flight deck for those configurations. The door should always be referred to as the door between the pilot compartment and the passenger compartment The word "discreetly" is questioned NPA OPS 30 CRD Page 22 of 35

23 Ad hoc WG (a) Proposed redrafted text JAR- OPS (a) Justification/Comment(s) Proposed text OST The word "discreetly" has been substituted by the word "covertly" "in all aeroplanes which are equipped with a flight crew compartment door, this door shall be capable of being locked, and means or procedures acceptable to the Authority shall be provided or established by which the cabin crew cnotify the flight crew in the event of suspicious activity or security breaches in the cabin" JAR-OPS (b) Comm 004b CAA, The (b) General comment: ted Netherlands Is the date 1 november realistic? Justification/Comment(s) Proposed text OST Implementation times are derived from Amendment 27 to ICAO Annex c 004d CAA, The Netherlands CAA, The Netherlands (b) (b) Seating "capacity" greater than.. should be substituted with seating "configuration" greater than... General comment: Paragraph (2) should be paragraph (b) accepted Corrected (See (a) no 010)) The rationale is to make this requirement applicable to the actual number of passengers. Adopt MAPSC NPA OPS 30 CRD Page 23 of 35

24 021a SAS (b) Proposals: t accepted Commuter Delete reference to seating capacity greater than 60 FOCA, Switzerland LBA, Germany (b) (b) IEM with text: "If doorlocking mechanism is reachable from either pilot station, this is considered sufficient" Rearrange paragraph with subparagraphs (1) and (2) and add new subparagraph (2): "All cargo-aeroplanes will not be submitted to the changes as mentioned under (1) above. Nevertheless all security checks for cargo handling as well as the screening of the involved personnel have to be checked, taking into account the new security threat situation" Rearrange paragraph with subparagraphs (1) and (2) and add new subparagraph (2): "All cargo-aeroplanes will not be submitted to the changes as mentioned under (1) above. Nevertheless all security checks for cargo handling as well as crewmembers and additional crewmembers have to be re-established as agreed with the authority" ted ted Justification/Comment(s) Proposed text OST The SAS Commuter proposal would make this requirement applicable to all aeroplanes with 19 or more seats. IEM can be produced before JAR-OPS has been adopted. To this date the NPA-30 is not applicable to cargo aeroplane operation. Refer also to JAR-OPS (See no 055) To this date the NPA-30 is not applicable to cargo aeroplane operation. Refer also to JAR-OPS (See no 032) NPA OPS 30 CRD Page 24 of 35

25 SAS, Sweden (b) General comment: t accepted Postpone implementation date to 1 november 2004 Transport (b) t accepted Canada Insert "certified" between "with a" and "passenger" IFALPA (b) Delete "designed to resist penetration by small arms fire and grenade shrapnel, and to resist forcible intrusions by unauthorised persons." after "that is" and insert new text: designed to meet the requirements of JAR (d) and JAR " CAA, UK (b) General comment: We understand that the seating capacity is the maximum approved passenger seating configuration as indicated by JAR-OPS 1.480(a)(6) CAA, UK (b) General comment: In proposed JAR-OPS (b) we question the use of the ICAO wording, e.g. grenade shrapnel, instead of being consistent with JAR (a) and JAR as proposed by NPAs 25D-336 and respectively. Justification/Comment(s) Proposed text OST Applicability dates are dictated by ICAO Annex 6 part 1 chapter 13, Amendment 27. accepted ACJ to (b) to refer to JAR 26 d ACCEPTED ted and partly accepted See redrafted text (b)) (See no 093) See 004c ACJ to (b) to refer to JAR 26 (See no 078) In proposed JAR-OPS (b) there is the requirement for the door to be NPA OPS 30 CRD Page 25 of 35

26 capable of being locked/unlocked from either pilot s station. This requirement has not been proposed for JAR 25 or JAR 26 and could course difficulties for an airline to show compliance if it has not been taken into account upstream in the design stage. We suggest that either this requirement is included in JAR 25 and 26 or is removed from this NPA Ad hoc WG (b) Proposed redrafted text JAR- OPS (b) Justification/Comment(s) Proposed text OST "From 1 vember 2003, all passenger-carrying aeroplanes of a maximum certified take-off mass in excess of kg or with a MAPSC greater than 60 shall be equipped with an approved flight crew compartment door that is designed to meet the requirements of JAR The design of this door shall not hinder emergency operations." NPA OPS 30 CRD Page 26 of 35

27 JAR-OPS ( c)(1) FCCCSG (c) Partly (1) Requirement for locking of accepted doors too restrictive. Should be "prior to engine start (for take-off) until engines are shut down" AEA ( c) General comment: ted (1) Postpone JAA decision on surveillance issue until JAA is able to forward plan taking into account the FAA RNPM, including a cost assessment Edelweiss, Switzerland FOCA, Switzerland (c) (1) (c) (1) Delete "persons", insert instead "by persons authorised by the Commander" Rearrange (c) with 3 subparagraphs. Delete "and locked" in subparagraph (1). Insert new text as subparagraph (2) "In addition to (1) above, this door shall be locked before entering the departure runway for take-off, until leaving the runway after landing except when necessary to permit access and egress by authorised persons; and" (Subpara 3) Accepted To be considered Justification/Comment(s) Proposed text OST (See redrafted text (c)(1)) Applicability dates are dictated by ICAO Annex 6 part 1 chapter 13, Amendment 27. (See redrafted text (c)(1)) Proposed NPA-30 text may be too restrictive in case of remote holding with engines shut down. (See redrafted text ( c)(1)) NPA OPS 30 CRD Page 27 of 35

28 054 Justification/Comment(s) Proposed text OST Irish Aviation (c) General comment: ted (See (a) no o91) Authority (1) Advisory material is required to define what are acceptable (See redrafted text ( c)(1)) means by which cabin crew can discreetly notify flight crew of suspicious activity b 073 SAS, Sweden DGAC, France SNPL, France (c) (1) (c) (1) (c) (1) Is this a procedural or equipment requirement? Partly Delete "this door shall be accepted closed and locked from the time all external doors are closed following embarkation". Insert instead "The flight crew compartment door shall be locked from start of taxiing" Accepted Delete "when necessary to permit access and egress by authorised persons". Insert instead "when deemed necessary for the authorised persons to access or egress in compliance with the national aviation security programme" Partly Delete " and locked" between accepted "closed" and "from". Insert "and will be locked when required by the security procedure and/or the Commander" between "authorised persons" and "and" (See redrafted text ( c)(1)). "Authorised persons" are defined in JAR-OPS "Admission to flight deck". (See redrafted text ( c)(1)) (See redrafted text ( c)(1)) NPA OPS 30 CRD Page 28 of 35

29 ECA ( c) (1) 094 CAA, UK ( c) (1) Ad hoc WG ( c) (1) IFALPA (c) Partly (1) Delete "and locked" between accepted "be closed" and "from the". Delete "and egress by authorised persons" between "permit access" and "authorised by" Delete "and locked" between "be closed" and "from the". Delete "and egress by authorized persons" between "permit access" and "authorized by" General comment: We are of the opnion that the criteria for the locking of the flight deck door is too restrictive and that different criteria would be more appropriate such as from before engine start until after engine shutdown. (- -) Proposed redrafted text JAR- OPS ( c)(1) Partly accepted ted Justification/Comment(s) Proposed text OST (See redrafted text ( c)(1)) (See redrafted text ( c)(1)) (See redrafted text ( c)(1)) (See no 033 and 067b) "this door shall be closed prior to engine start for takeoff and will be locked when required by security procedure or the Commander, until engine shut down after landing, except when deemed necessary for authorised persons to access or egress in compliance with National Aviation Security Programme." NPA OPS 30 CRD Page 29 of 35

30 FOCA, Switzerland CAAd, Finland Airbus Industries (c) (2) ( c)- (2) (c) (2) LFV, Sweden (c) (2) JAR-OPS ( c)(2) Comm 021b SAS (c) ted Commuter (2) IEM with text: "If near door area can be monitored via a one-way window in the cockpit door, this is considered sufficient" Delete "from either pilot s station" and "entire" General comment: Postpone a JAA decision on this surveillance issue until the JAA is able to come forward with a comprehensive plan, taking into account the FAA NPRM, including a cost assessment General comment: ICAO Annex 6 Amendment 27 requires a "means", without specifying whether it should be visual or other. We understand that JAA will retain this flexibility. Guidance should be developed for a common understanding of acceptable means General Comment: The requirement to monitor the entire door area outside the flight crew compartment is too far-reaching. Adequate security can be obtained with a system based on intercommunication Partly accepted ted Yes ted Justification/Comment(s) Proposed text OST IEM cannot be produced before JAR-OPS has been adopted (See redrafted text to (c)(2) Applicability dates are dictated by ICAO Annex 6 part 1 chapter 13, Amendment 27. NPA OPS 30 CRD Page 30 of 35

31 c 080 Braathens (c) t accepted ASA, (2) Delete subparagraph rway SAS, Sweden DGAC, France IFALPA (c) (2) (c) (2) (c) (2) General comment: Wording of paragraph is not sufficiently clear Delete "from either pilot station" General Comment: Text same as proposed ted Justification/Comment(s) Proposed text OST (See NPA-30 no 052 and no 022) (See no 095) Accepted (See redrafted text to (c)(2) ted (See no 085) Reason for comment: Requirement can only be achieved by visual/video identification systems, and it is considered essential for adequate access control. It is equally important that adequate procedures and communication systems be put in place, the operation of which should be introduced into the MMEL/MEL for the dispatch of aircraft NPA OPS 30 CRD Page 31 of 35

32 085 Justification/Comment(s) Proposed text OST ECA ( c) General Comment: ted (See no 080) (2) Text same as proposed. 087 LFV, rway 088 Boeing Airplanes Group ( c) (2) ( c) (2) Reason for comment: Requirement can only be achieved by visual/video identification systems, and it is considered essential for adequate access control. It is equaly important that adequate procedures and communication systems be put in place, the operation of which should be introduced into the MMEL/MEL for the dispatch of aircraft General comment: The requirement to monitor the entire door area outside the flight crew compartment too far-reaching. Adequate security can be obtained with system based on intercommunication Delete. Reason for proposal: The proposed requirement would be more stringent than current FAA requirements that have been imposed. The FAA has not indicated that it plans to require monitoring of the cockpit door area. (- -) ted (See redrafted text to (c)(2) t accepted ted JAA follows the ICAO Amendment 27 to Annex 6. JAA will produce additional guidance material NPA OPS 30 CRD Page 32 of 35

33 095 CAA, UK ( c) General comment: ted (2) The proposed requirement in JAR.OPS ( c)(2) is ambiguous by use of the words "entire door area" which has several meanings, e.g. the surface area of the door or the entire cabin which is outside the flight compartment. (- -) Ad hoc WG ( c) (2) Text of ( c)(2) should revised to: "means that shall be provided to allow for monitoring, from either pilot s station, the area outside the flight compartment, to the extend necessary to identify, persons requesting entry and to detect suspicious behaviour or potential threat" Proposed redrafted text JAR- OPS ( c)(2) Ad hoc WG Proposed optional completely revised JAR-OPS Accepted Justification/Comment(s) Proposed text OST What is actually required is that the identity of those requesting entry can be established and that suspicious behaviour or potential threat on the cabin side of the flight compartment door can be identified. (See NPA-30 no 052, no 022) (See no 042, and 064) "from either pilot s station" has been deleted. "entire door area" has been reworded and substituted by a requirement to be "able to identify and detect" Difference in wording between NPA OPS-1-30 and NPA 26-16, and JAR-25 "Locked door" issue - JAR-OPS , Flight crew "means shall be provided for monitoring the area outside the flight crew compartment, to the extent necessary to identify persons requesting entry to the flight crew compartment and to detect suspicious behaviour or potential threat" Optional proposed redrafted text JAR-OPS : (a): From 1 vember 2003, all NPA OPS 30 CRD Page 33 of 35

34 Justification/Comment(s) Proposed text OST compartment security (a) In all aeroplanes which are equipped with a flight crew compartment door, this door shall be capable of being locked, and means etc... (b)... shall be equipped with an approved flight crew compartment door etc...this door shall be capable of being locked and unlocked from either pilot's station passenger-carrying aeroplanes of a maximum certified take-off mass in excess of kg or with a passenger seating capacity greater than 60 shall be equipped with an approved flight crew compartment door that is designed to meet the requirements of JAR The design of this door shall not hinder emergency operations." - JAR , Security considerations From 1 vember..., and having a lockable door installed between etc... - JAR , Pilot compartment doors For an aeroplane... and that has a lockable door installed etc... JAR 25 is not really of relevance because it is only applicable to new or significantly changed type designs. JAR 26 speaks of "having a lockable door installed", Thus this wording does not impose the installation of the lockable door. JAR OPS (a) speaks of " which are equipped with a flight (b): "in all aeroplanes which are equipped with a flight crew compartment door, this door shall be capable of being locked, and means or procedures acceptable to the Authority shall be provided or established by which the cabin crew can covertly notify the flight crew in the event of suspicious activity or security breaches in the cabin" ( c): In all aeroplanes which are equiped with a flight crew compartment door in accordance with (a) of this paragraph: (1): "means shall be NPA OPS 30 CRD Page 34 of 35

35 Justification/Comment(s) Proposed text OST crew compartment door, this door shall be capable of being locked. This wording also does not require the installation of a door but mandates the locking system. JAR OPS (b) speaks of "shall be equipped with an approved flight door compartment door" So only this last subparagraph introduces the installation of the cockpit door. The proposal would be to reverse (a) and (b) and change in (c) the referenced subparagraph (2) into (1). This makes it much better readable and logical. You start defining the discriminants: kg or more than 60 pax. Require the door installation, the locking mechanism and finally operational procedures. The (b) (new) could simply read: In all aeroplanes which are equipped with a lockable flight crew compartment door, means or procedures acceptable to the Authority etc... provided for monitoring the area outside the flight crew compartment, to the extent necessary to identify persons requesting entry to the flight crew compartment and to detect suspicious behaviour or potential threat" (2): "this door shall be closed prior to engine start for take-off and will be locked when required by security procedure and/or the Commander, until engine shut down after landing, except when deemed necessary for authorised persons to access or egress in compliance with National Aviation Security Programme." o O o NPA OPS 30 CRD Page 35 of 35