European Aviation Safety Agency Notice of Proposed Amendment 2015-18 (B) Update of the rules on air operations (Air OPS Regulation — all Annexes & related AMC/GM) sub-NPA (B) ‘Draft AMC/GM’ RMT.0516 & RMT.0517 — 27.11.2015 EXECUTIVE SUMMARY This sub-Notice of Proposed Amendment (NPA) includes proposed changes to the acceptable means of compliance (AMC) and guidance material (GM) to Regulation (EU) No 965/2012. Sub-NPA (B) includes the following key changes: — Editorial changes to AMC and GM to all Annexes; — Amendment related to the management system of the authority; — Proposed new AMC/GM on inspector qualifications; — Amendments to AMC/GM related to RAMP inspections; — Safety management in the AMC/GM related to organisation requirements (Part-ORO); and — Proposed AMC/GM on leasing agreements between EU operators. — Proposed change to AMC on carriage of the emergency medical kit for certain CAT operators, providing more flexibility to operators regarding a secure location of the EMK. Sub-NPA (B) is the part of a series of three sub-NPAs (constituting NPA 2015-18) addressing a safety and regulatory coordination issue related to air operations. The main objective is to ensure an efficient and proportionate set of implementing rules (IRs), AMC and GM on air operations and to resolve any inconsistencies identified after the adoption of the air operations IRs. This is necessary to ensure that the EASA regulatory system includes state of the art IRs, AMC and GM and reflects best practices. The following safety recommendations (SRs) were assessed during the development of this NPA: GERF-2006-009, UNK- 2005-148, DENM-2012,004, HUNG-2012-004, ITAL-2012-009, SPAN-2009-025, and SWED-2011-013. The specific objective of this NPA is to maintain a high level of safety for air operations by ensuring a harmonised implementation of Regulation (EU) No 965/2012. Sub-NPA (A):Explanatory Note and proposed changes to the IRs of Annexes I–VII. Sub-NPA (B): Proposed changes to the existing AMC and GM text. Sub-NPA (C): Proposed changes related to passenger seating and briefing. Applicability Process map Affected regulations AMC/GM to the Annexes to Concept Paper: No and decisions: Regulation (EU) No 965/2012 Terms of Reference: 6.10.2014 Rulemaking group: No Affected air operation organisations; national RIA type: None stakeholders: competent authorities Technical consultation during NPA drafting: Yes Driver/origin: Safety; level-playing field; Duration of NPA consultation: 2 months proportionality; RMT OPS.001 Review group: TBD Focused consultation: Yes Reference: ICAO Doc 8335 Publication date of the Opinion: 2016/Q3 Publication date of the Decision: 2017/Q3 TE.RPRO.00034-004 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 1 of 117 An agency o t he European Union European Aviation Safety Agency NPA 2015-18 (B) Table of contents Table of contents 1. Procedural information ............................................................................................................................... 3 1.1. The rule development procedure .................................................................................................................. 3 1.2. The structure of this NPA and related documents ....................................................................................... 3 1.3. ow to comment on this NPA .......................................................................................................................... 3 1.4. The next steps in the procedure .................................................................................................................... 4 2. Explanatory Note ........................................................................................................................................ 5 2.1. Overview of the proposed amendments ...................................................................................................... 5 2.1.1. GM to Annex I (Definitions) ..................................................................................................................... 5 2.1.2. AMC/GM to Annex II (Part-ARO) ............................................................................................................. 5 2.1.3. AMC/GM to Annex III (Part-ORO) ............................................................................................................ 7 2.1.4. AMC/GM to Annex IV (Part-CAT)........................................................................................................... 10 2.1.5. AMC/GM to Annex V (Part-SPA) ............................................................................................................ 11 2.1.6. AMC/GM to Annex VI (Part-NCC) .......................................................................................................... 12 2.1.7. AMC/GM to Annex VII (Part-NCO)......................................................................................................... 13 2.1.8. AMC/GM to Annex VIII (Part-SPO) ........................................................................................................ 13 3. Proposed amendments ............................................................................................................................. 14 3.1. Draft Acceptable Means of Compliance and Guidance Material (Draft EASA Decision) .......................... 14 3.1.1. GM to Annex I (Definitions) ................................................................................................................... 15 3.1.2. AMC/GM to Annex II (Part-ARO) ........................................................................................................... 16 3.1.3. AMC/GM to Annex III (PART-ORO) ........................................................................................................ 38 3.1.4. AMC/GM to Annex IV (Part-CAT)........................................................................................................... 86 3.1.5. AMC/GM to Annex V (Part-SPA) ......................................................................................................... 100 3.1.6. AMC/GM to Annex VI (Part-NCC) ....................................................................................................... 105 3.1.7. AMC/GM to Annex VIII (Part-NCO)..................................................................................................... 110 3.1.8. AMC/GM to Annex VII (Part-SPO) ...................................................................................................... 113 4. References .............................................................................................................................................. 116 4.1. Related regulations .................................................................................................................................... 116 4.2. Affected CS, AMC, and GM ........................................................................................................................ 116 TE.RPRO.00034-004 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 2 of 117 An agency of the European Union European Aviation Safety Agency NPA 2015-18 (B) 1. Procedural information 1. Procedural information 1.1. The rule development procedure The European Aviation Safety Agency (hereinafter referred to as the ‘Agency’) developed this Notice of Proposed Amendment (NPA) in line with Regulation (EC) No 216/20081 (hereinafter referred to as the ‘Basic Regulation’) and the Rulemaking Procedure2. This rulemaking activity is included in the Agency’s Rulemaking Programme for 2013–2016 under RMT.0516 & RMT.0517. The text of this NPA has been developed by the Agency. It is hereby submitted for consultation of all interested parties3. The process map on the title page contains the major milestones of this rulemaking activity to date and provides an outlook of the timescale of the next steps. 1.2. The structure of this NPA and related documents Due to the size of the documents to be published, it has been decided to split the NPA into sub-NPAs, namely (A), (B), and (C). — Sub-NPA (A): Chapter 1 contains the procedural information related to this task. Chapter 2 ‘Explanatory Note’ explains the core technical content of all parts (sub-NPAs) of the NPA. Chapter 3 contains the proposed text for the new requirements with the proposed changes included in the consolidated version provided by EASA of the Cover Regulation of Regulation (EU) No 965/2012, Annexes I–VIII including the amendments to Regulation (EU) No 965/20124 (hereinafter referred to as the ‘Air OPS Regulation’). — Sub-NPA (B) contains the amendments to the AMC/GM material associated with the Air OPS Regulation. — Sub-NPA (C) contains proposed changes related to passenger seating and briefing. 1.3. How to comment on this NPA Please submit your comments using the automated Comment-Response Tool (CRT) available at http://hub.easa.europa.eu/crt/5. The deadline for the submission of comments is 27 January 2016. 1 Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002 and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1). 2 The Agency is bound to follow a structured rulemaking process as required by Article 52(1) of the Basic Regulation. Such process has been adopted by the Agency’s Management Board and is referred to as the ‘Rulemaking Procedure’. See Management Board Decision No 01-2012 of 13 March 2012 concerning the procedure to be applied by the Agency for the issuing of Opinions, Certification Specifications and Guidance Material (Rulemaking Procedure). 3 In accordance with Article 52 of the Basic Regulation and Articles 5(3) and 6 of the Rulemaking Procedure. 4 Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 296, 25.10.2012, p. 1). 5 In case of technical problems, please contact the CRT webmaster ([email protected]). TE.RPRO.00034-004 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 3 of 117 An agency of the European Union European Aviation Safety Agency NPA 2015-18 (B) 1. Procedural information 1.4. The next steps in the procedure Whilst every effort has been made to include the new provisions contained in the amending Implementing Rules and related AMC/GM in this NPA, it has to be stated that this NPA is based on the consolidated version of the Implementing Rules and related AMC/GM (the so-called consolidated version). Following the closure of the NPA public consultation period, the Agency will review all the comments and will establish a Review Group in order to perform a focused consultation, which will consist of a workshop complemented by group meetings, if required. The outcome of the NPA public consultation, as well as the outcome of the focused consultation, will be reflected in the respective Comment-Response Document (CRD), which will be published (two months after the end of the public consultation period of the NPA) for further consultation (reactions period). The related Opinion will be published one month after the end of the CRD consultation period. The Opinion containing proposed changes to the Air OPS Regulation will be addressed to the European Commission, which shall use it as a technical basis in order to prepare a legislative proposal. The Decision containing AMC and GM will be published by the Agency when the related IR is adopted by the European Commission. TE.RPRO.00034-004 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 4 of 117 An agency of the European Union European Aviation Safety Agency NPA 2015-18 (B) 2. Explanatory Note 2. Explanatory Note Please refer to NPA 201X-XX (A), including the Explanatory Note for the proposed Opinion (NPA 201x-xx (A)), as well as for the proposed Decision of this NPA. 2.1. Overview of the proposed amendments 2.1.1. GM to Annex I (Definitions) The following change is proposed: (1) Insertion of a new point (t) into GM1 Annex I Definitions to introduce new guidance on the meaning of ‘mass’ and ‘weight’ in the context of the Air OPS rules. 2.1.2. AMC/GM to Annex II (Part-ARO) The following changes are proposed: (2) Development of new AMC ARO.GEN.120(e) Means of compliance on DEMONSTRATION OF COMPLIANCE by the authority whenever the authority proposes an alternative means of compliance. This is proposed in order to ensure that the authority conducts a risk assessment similar to that of the AMC for operators contained in AMC to ORO.GEN.120. (3) Development of new GM1 ARO.GEN.125(b) Information to the Agency on the MEANING OF SAFETY-SIGNIFICANT INFORMATION STEMMING FROM OCCURRENCE REPORTS. (4) Development of new GM2 ARO.GEN.125(b) Information to the Agency on RECOMMENDED CONTENT FOR A CONCLUSIVE SAFETY ANALYSIS. (5) Development of new GM3 ARO.GEN.125(b) Information to the Agency on OCCURRENCES WHERE THE AGENCY IS THE COMPETENT AUTHORITY. (6) Amendment of AMC1 ARO.GEN.200(a)(1) Management system on DOCUMENTED POLICIES AND PROCEDURES to include a new point (e) to ensure that a copy of the procedures related to the management system and their amendments shall be made available not only to the Agency for the purpose of standardisation, but also to the organisations subject to the Air OPS Regulation, if so requested. (7) Amendment of AMC1 ARO.GEN.200(a)(2) Management system to include a more detailed AMC on inspector qualifications. AMC1 ARO.GEN.200(a)(2) now also includes the text deleted from sub- paragraph (b) of AMC1 ARO.GEN.300(a);(b);(c) Oversight which reads ‘It is essential that the competent authority has the full capability to adequately assess the continued competence of an organisation by ensuring that the whole range of activities is assessed by appropriately qualified personnel.’ (8) Amendment of AMC2 ARO.GEN.200(a)(2) Management system regarding inspectors initial and recurrent training programme and in order to ensure inspectors training on assessment of effectiveness of management systems. (9) Development of a new AMC3 ARO.GEN.200(a)(2) Management system on FLIGHT OPERATIONS INSPECTOR QUALIFICATION. TE.RPRO.00034-004 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 5 of 117 An agency of the European Union European Aviation Safety Agency NPA 2015-18 (B) 2. Explanatory Note (10) Development of a new AMC4 ARO.GEN.200(a)(2) Management system on FATIGUE RISK MANAGEMENT INSPECTOR TRAINING. (11) Amendment of point (b)(1)(iv) of GM1 ARO.GEN.200(a)(2) Management system in order to ensure that authorities also take into account the estimated number of subcontracted organisations used by persons and organisations, when planning and determining the required personnel for oversight. (12) Development of a new GM2 ARO.GEN.200(a)(2) Management system on INSPECTOR COMPETENCY defining and explaining the meaning of inspector competency and including a recommendation that the inspector should by their qualifications/competency command the professional respect of the inspected personnel. (13) Development of a new GM3 ARO.GEN.200(a)(2) Management system on FLIGHT OPERATIONS INSPECTOR (FOI) QUALIFICATION. (14) Development of a new GM4 ARO.GEN.200(a)(2) Management system on the content of inspector training programmes. (15) A new GM5 ARO.GEN.200(a)(2) Management system on the content of Fatigue risk management inspector training (16) Deletion of sub-paragraph (b) of AMC1 ARO.GEN.300(a);(b);(c) Oversight, because inspector qualification elements should be placed collectively in AMC/GM to ARO.GEN.200(a)(2) on inspector qualifications. (17) Insertion of a new sub-paragraph (d) that specifies that oversight of the operator includes a review and assessment of the qualifications of nominated persons into GM1 ARO.GEN.300(a);(b);(c) Oversight. (18) Insertion of a new point (a)(5) into AMC1 ARO.GEN.305(b);(c);(d);(d1) Oversight programme to ensure that the number of subcontractors is added to the list of items leading to considerations about the operator’s size, nature and complexity. (19) AMC2 ARO.GEN.305(b) Oversight programme on PROCEDURES FOR OVERSIGHT OF OPERATIONS has been amended in point (c) to clarify that the items in brackets are examples of inspections and to ensure that those inspections include not only flight operations, but also flight and ground training inspections. (20) Development of a new GM1 ARO.GEN.305(b);(c);(d);(d1) Oversight programme on STORAGE PERIODS OF RECORDS to advise the competent authority that in the case of extended oversight cycles, minimum storage periods for records should be aligned with the extended oversight cycle. (21) Amendment of AMC2 ARO.GEN.305(c) Oversight programme to replace the phrase ‘reason to believe’ with the word ‘evidence’ whenever an authority decides on an integrated oversight schedule. (22) Amendment of point (a)(3) of AMC1 ARO.GEN.310(a) Initial certification procedure — organisations on VERIFICATION OF COMPLIANCE to ensure that the competent authority should require the conduct of one or more demonstration flights before issuing the AOC, or alternatively TE.RPRO.00034-004 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 6 of 117 An agency of the European Union European Aviation Safety Agency NPA 2015-18 (B) 2. Explanatory Note an in-flight inspection should be conducted at the earliest opportunity. This is an alignment with the previous JAR requirements and ICAO Annex 6. (23) A new GM2 ARO.GEN.350(d) Findings and corrective actions — organisations has been proposed on the corrective action implementation period to specify that the 3-month period of the corrective action implementation should commence from the date of the communication of the finding to the organisation in writing and requesting corrective action to address the non- compliance(s) identified. (24) Development of a new GM1 ARO.OPS.100(b) Issue of the air operator certificate to provide guidance for authorities when defining the area of operation in Appendix II (OPS SPECS) to Part- ARO. This GM is based on guidance from the JAA. (25) Development of a new GM2 ARO.OPS.110 Lease agreements on LONG-TERM LEASE AGREEMENTS BETWEEN OPERATORS REGISTERED IN AN EU MEMBER STATE stating that in case of a long-term lease agreement between operators registered in an EU Member State, the competent authorities of the lessee and the lessor should consider a mutual exchange of all necessary information and the competent authority of the lessee should assess the operator’s statement on how it intends to comply with ORO.GEN.205 on contracted activities during the long- term wet lease-in agreement. (26) Amendment of GM2 ARO.OPS.110 Lease agreements to provide the correct references to the current Continuing Airworthiness Regulation (Regulation (EU) No 1321/2014). (27) Amendment of AMC1 ARO.RAMP.115(b)(2) Qualification of ramp inspectors to clarify the requirements for initial appointment of senior ramp inspectors and the conditions for re- appointment. (28) Development of a new GM2 ARO.RAMP.115(b)(2) Qualification of ramp inspectors to clarify the recency requirements for senior ramp inspectors. (29) AMC1 ARO.RAMP.115(b)(3) Qualification of ramp inspectors has been amended to avoid repetition of existing rule text contained in ARO.RAMP.115(b)(3) and to include some editorial changes. (30) AMC2 ARO.RAMP.115(b)(3) Qualification of ramp inspectors has been amended to clarify conditions for re-qualification of ramp inspectors. (31) A new GM1 ARO.RAMP.115(b)(3) on Qualification of ramp inspectors indicating additional explanations on recent experience requirements. 2.1.3. AMC/GM to Annex III (Part-ORO) The following changes are proposed: (32) Amendment of AMC1 ORO.GEN.110(e) Operator responsibilities to provide the correct reference to the current Continuing Airworthiness Regulation. (33) Amendment of AMC1 ORO.GEN.130 Changes related to an AOC holder to increase the notification period for changes of nominated persons from 10 to 20 days. TE.RPRO.00034-004 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 7 of 117 An agency of the European Union European Aviation Safety Agency NPA 2015-18 (B) 2. Explanatory Note (34) Amendment of GM1 ORO.GEN.130(a) Changes related to an AOC holder on GENERAL to delete a reference to nominated postholders in point (a)(7) of this GM. Changes of nominated persons or postholders as described in ORO.GEN.210(b) do NOT constitute a change that affects the AOC or the operations specifications. Therefore, changes of nominated persons or postholders is NOT a change requiring prior approval, because it does not amend the scope of the operator’s approval. (35) Development of a new AMC1 ORO.GEN.130(b) Changes related to an AOC holder to ensure that for changes, the operator should provide the safety risk assessment to the competent authority upon request. (36) Amendment of the title of GM3 ORO.GEN.130(b) Changes related to an AOC holder to now read GM1 ORO.GEN.130(b) since this is the first GM to ORO.GEN.130(b). In addition, the correct reference to Regulation (EU) No 1178/2011 (the Air Crew Regulation) has been provided. Finally, GM3 ORO.GEN.130(b) has been amended to delete wrong references to items not requiring prior approval: — evacuation procedures with a reduced number of required cabin crew during ground operations or in unforeseen circumstances; — helicopter operations — airborne radar approaches (IR ref. CAT.OP.MPA.120); — helicopter operations — procedures for selecting off-shore alternates (IR ref. CAT.OP.MPA.181). (37) AMC1 ORO.GEN.200(a)(1);(2);(3);(5) Management system on NON-COMPLEX OPERATORS has been amended in paragraph (c) to ensure that the safety manager is responsible for the safety- management-related processes and tasks. (38) A new GM1 ORO.GEN.200(a) Management system on INTEGRATED MANAGEMENT SYSTEM has been inserted to provide guidance on how to integrate a Management System for an organisation with several certificates. (39) Amendment of point (d)(2) of GM2 ORO.GEN.200(a)(1) Management system to clarify the wording in relation to the safety action group, which should define strategies to mitigate the identified safety risks. (40) Development of a new GM3 ORO.GEN.200(a)(1) Management system on the MEANING OF THE TERMS ‘ACCOUNTABILITY’ AND ‘RESPONSIBILITY’ has been inserted to clarify the difference between the notions of ‘accountability’ and ‘responsibility’ in the English language. (41) AMC1 ORO.GEN.200(a)(3) Management system on COMPLEX OPERATORS — SAFETY RISK MANAGEMENT has been amended in paragraph (g) to ensure description of emergency training/drill as appropriate. (42) A new AMC2 ORO.GEN.200(a)(3) Management system on COMPLEX ORGANISATIONS — SAFETY RISK MANAGEMENT-INTERFACES BETWEEN ORGANISATIONS was inserted to provide extensive guidance on setting-up effective safety risk management and managing the interfaces between organisations. (43) Amendment of GM1 ORO.GEN.200(a)(3) Management system to now be an AMC, because internal reporting constitutes an important element of the organisation’s management system. TE.RPRO.00034-004 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 8 of 117 An agency of the European Union European Aviation Safety Agency NPA 2015-18 (B) 2. Explanatory Note The subtitle of the new AMC has been changed to read INTERNAL SAFETY REPORTING SCHEME, because this is more adequate to convey the message that reporting should include information on hazards and not only information on safety events. (44) Development of a new GM1 ORO.GEN.200(a)(3) Management system to provide extensive guidance on setting up effective safety risk management. (45) Amendment of sub-paragraph (a) of GM1 ORO.GEN.200(a)(5) Management system to delete the reference to training manuals, which are already included in Part-D of the Operations Manual (OM). (46) Development of a new GM5 ORO.GEN.200(a)(6) on the organisational review programme as part of the management system for non-complex organisations. (47) Development of a new GM6 ORO.GEN.200(a)(6) on the organisational review checklist as part of the management system for non-complex organisations. (48) Amendment of AMC1 ORO.GEN.200(b) Management system to include a new sub-paragraph (c) to ensure that all non-commercial operators operating a maximum of two complex-motor- powered aircraft of the same type are to be considered as non-complex organisation by default. (49) Development of a new AMC2 ORO.GEN.205 Contracted activities establishing conditions for the acceptance of audits from third-party audit providers, thus enabling the operator to pool audits of contracted organisations. The elements specifying the conditions under which a third-party provider can be used for those audits have been copied from the existing AMC related to pooling of audits of code-share agreements. This new AMC responds to a safety recommendation on pooled audits. (50) Development of a new AMC2 ORO.GEN.210(a) Personnel requirements on INFORMATION ON THE ACCOUNTABLE MANAGER to mirror the existing Form 4 from the continuing airworthiness requirements in the Air OPS rules on the approval of the accountable manager without suggesting that an EASA Form 4 should be provided. (51) Development of a new GM1 ORO.GEN.210(a) Personnel requirements on the FUNCTION OF THE ACCOUNTABLE MANAGER to explain the position and function of the accountable manager within the organisation. (52) Development of a new GM1 ORO.AOC.100(c) Application for an AOC to explain the meaning of certificate of airworthiness in relation to the applicable requirements. (53) Amendment of AMC1 ORO.AOC.110 Leasing agreement to cater for the scenario that some information regarding the leasing partner might not be available to the operator at the time of requesting the approval. (54) Amendment of AMC1 ORO.AOC.110(c) Leasing agreement to clarify that this AMC only applies for WET LEASE-IN WITH A THIRD-COUNTRY OPERATOR and introduction of a new point (f) on retroactive airworthiness requirements contained in Part-26. (55) Development of a new AMC3 ORO.AOC.110(g) Leasing agreement on LONG-TERM WET LEASE-IN AGREEMENT BETWEEN OPERATORS REGISTERED IN AN EU MEMBER STATE ensuring that the TE.RPRO.00034-004 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 9 of 117 An agency of the European Union European Aviation Safety Agency NPA 2015-18 (B) 2. Explanatory Note lessee provides the competent authority with a statement on how it intends to comply with ORO.GEN.205 on contracted activities during the long-term wet lease-in agreement. (56) Amendment of GM1 ORO.AOC.110(c) Leasing agreement to clarify that this GM only applies to SHORT-TERM WET LEASE-IN WITH A THIRD-COUNTRY OPERATOR. (57) Amendment of AMC2 ORO.AOC.115(b) Code-share agreements, since the conditions applying to the acceptance of audits of third-party providers have now been moved to a new AMC2 ORO.GEN.205 Contracted activities. This new AMC to ORO.GEN.205 will apply not only to code-share agreements, but also to other contracted activities and will enable operators to pool audits of third parties. (58) Amendment of AMC3 ORO.MLR.100 Operations manual — general to include a new point 7.3 on Fatigue Risk Management (FRM) under Chapter 7 on Flight Time Limitations (FTL). (59) Amendment of sub-paragraph (a) of AMC1 ORO.MLR.105(d)(3) Minimum equipment list to provide the correct term ‘specific approvals’. (60) Amendment of AMC1 ORO.MLR.105(g) Minimum equipment list to provide the correct reference to the current Continuing Airworthiness Regulation. (61) Amendment of GM1 ORO.MLR.105(g) Minimum equipment list to provide the correct reference to the current Continuing Airworthiness Regulation. (62) Development of a new GM1 ORO.MLR.115(c) Record-keeping to clarify the meaning of personnel records in ORO.MLR.115(c). (63) Development of a new GM1 ORO.MLR.115(d) Record-keeping to clarify the meaning of training, checking and qualification records in ORO.MLR.115(d). 2.1.4. AMC/GM to Annex IV (Part-CAT) The following changes are proposed: (64) Amendment of point (b)(4) of AMC1 CAT.OP.MPA.115 Approach flight technique — aeroplanes on CONTINUOUS DESCENT FINAL APPROACH (CDFA), since point (b)(3) should only address operations in IMC and point (b)(4) operations in VMC. (65) Amendment of the title of AMC1 CAT.OP.MPA.140(c) Maximum distance from an adequate aerodrome for two-engined aeroplanes without an ETOPS approval to include the correct reference of sub-paragraph (d) rather than (c) in the title of the AMC. In addition, a change has been made to provide the correct reference to the current Continuing Airworthiness Regulation. (66) Amendment of sub-paragraph (d) of AMC1 CAT.OP.MPA.195 Refuelling/defuelling with passengers embarking, on board or disembarking for helicopters to ensure that the AMC specifies that procedures apply when rotors are either stopped or rotors are turning. (67) Amendment of sub-paragraph (a) of GM1 CAT.OP.MPA.295 Use of airborne collision avoidance system (ACAS) to be aligned with ED Decision 2012/002/R on common airspace usage requirements and operating procedures. (68) Amendment of AMC2 CAT.IDE.A.225 Emergency medical kit on carriage under secure conditions to provide operators more flexibility by removing the text referring to the EMK in a ‘locked TE.RPRO.00034-004 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. 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