A18-03 - Compliance with Canadian Aviation Regulations subsection 602.11(2)

A18-03 – “The Department of Transport and air operators take action to increase compliance with Canadian Aviation Regulations subsection 602.11(2) and reduce the likelihood of aircraft taking off with contaminated critical surfaces.”

Transport Canada's response to recommendation A18-03

TC agrees with the recommendation; efforts to increase compliance with CARs subsection 602.11(2) and reduce the likelihood of aircraft taking off with contaminated critical surfaces will focus on a two-pronged targeted risk-based inspection campaign, and an education and awareness campaign.

In the winter of 2019-20, TC will conduct an inspection campaign to increase compliance with CARs subsection 602.11(2)^{Footnote 1} and reduce the likelihood of aircraft taking off with contaminated critical surfaces.

First, inspections will be targeted based on risk using the information gathered from the survey of northern and remote airports available de-icing and anti-icing services; the AGIP submissions from operators; the information on icing equipment availability included in the CFS; and, information on the likelihood of icing / historical reporting of icing conditions from airport authorities.

Second, TC will gather intelligence based on reporting by airport authorities, the public, and other potential sources (e.g., SECURITAS reports) to target inspections where there is reporting of non-compliance. This will aid in focusing resources where they are most likely able to identify and address potential non-compliance by air operators.

TC will conduct an evaluation of the impact of these targeted campaigns at the end of winter 2019-20. In consultation with associations including the Air Transport Association of Canada (ATAC) and the Northern Air Transport Association (NATA), TC will examine additional targeted inspection approaches and promotional measures based on the outcomes of this evaluation, and TC will update the TSB on the results and additional actions taken. Further, any outcomes of this evaluation will be considered, in part, with the recommendations of the working group referenced in A18-02.

To complement and inform this two-pronged inspection campaign, TC will also conduct an education and awareness campaign that will focus on two different communities:

• 1) airline operators and pilots; and,
• 2) the travelling public.

As an immediate measure, information was sent to all air operators and airport associations on February 1, 2019. The purpose was to remind associations and operators of recommended practices and procedures for de-icing, and provide links to the relevant TC guidance material. It also called on operators to verify that the training portion of their AGIP meets the most recent industry-accepted standards. TC inspectors will follow-up with operators during the summer and fall of 2019 to ensure continued compliance with the AGIP. A copy of the information sent is attached in Annex C.

During the summer of 2019, TC will develop an education and awareness campaign focused on passengers in more remote communities. This will serve as a “force-multiplier” to increase public knowledge and expectations about winter operations and help inform the targeted inspection planning that was referenced above. The passenger campaign will resemble previous campaigns such as the one developed for Seaplane Safety (https://tc.canada.ca/sites/default/files/2021-06/TP14346.pdf). Specific messaging and engagement will be targeted to occasional travelers and more frequent users (e.g., public officials who visit these communities on a regular basis).

In addition, by the fall of 2019, TC will conduct a targeted communications campaign to raise awareness of the available documents and information related to airframe icing. As part of this campaign, TC will also create an “icing landing page” on its website ahead of the next winter season with links to these materials and promote it to stakeholders through regular association meetings (e.g., NATA , ATAC , and the Canadian Business Aviation Association), by correspondence and through established distribution lists (e.g., the Civil Aviation Regulatory Advisory Council, social media).

On an ongoing basis, TC continues to engage Canadian stakeholders on a biennial basis through the Standing Committee on Operations Under Icing Conditions (SCOUIC) meeting. SCOUIC is mandated with the promotion of safe aircraft operations and airworthiness procedures under icing conditions. TC will explore the potential for applying data models to better identify and predict potential icing conditions, thereby raising the real-time awareness of air operators and airport authorities of potential icing conditions on-site. The next meeting is planned for October 2019. The Terms of Reference for SCOUIC are attached for reference in Annex D.

The above response to the two recommendations incorporates urgent actions taken to immediately address the safety concerns identified; short-term actions to help position TC , air operators, airports, and other authorities to be prepared to address the risks in the upcoming 2019-20 winter season; and medium-term actions that will help further strengthen existing mechanisms.

Annex A
Summary of Information Gathering Carried out by TCCA Regions in response to recommendations A18-02 and A18-03.

Following receipt of recommendations A18-02 and A18-03, Director Standards requested all Regional Directors Civil Aviation to contact air operators and airport operators to identify what de-icing equipment they currently have access to.

This annex provides a summary of the information received, to date, as a result of these inquiries and will be updated as information comes in.

Responses

Region	Response	Results
Atlantic	Yes	- No Labrador Coast airports have de-icing services. - Contacted PAL (operator): they have invested in ground equipment at St. Anthony and placed heated backpack-type sprayers at some remote location in Labrador.
Ontario	Yes	- Pickle Lake is only MTO -operated airport in N. Ont. that has de-icing published in CFS. - MTO does not provide de-icing services at any of their 29 remote airports.
Pacific	In progress	- No data
Prairie and Northern	Yes/in progress	- Are in the process of reaching out to territorial governments. - Working on establishing a list of air operators that need to be contacted re: remote base operations.
Québec	Yes	- POIs for 704 and 705 operators serving northern communities reached out to their operators. - Mostly, de-icing is carried out by the operator’s personnel. - Air Inuit has de-icing capability at the airports they serve with their B737. They do not want this capability published in the CFS as it is not a service offered to other operators.

Additional Comments from Regions:

Atlantic:

• - “Operators and crews tend to avoid remote airports with limited de-icing capability during ground icing situations because they will likely get stuck there, which causes a lot of problems.” – about Nfld and& Labrador
• - Some equipment available (either on board or at remote locations): small pressure sprayers, heated backpack type sprayers, electric covers or blankets, other simple wing or tail covers and perhaps, depending on the size of the aircraft, they may have an option to use a heated hangar
• - Atlantic is implementing an oversight program of ground de-icing facilities in the region… can call Brian Bayne for more info
• - The equipment is of limited capability and creates other problems, such as potential for slip and fall accidents with ladders, crews not having access to all surfaces of the aircraft and so on. PAL has never used their portable equipment to de-ice their Beech 1900’s to date.
• - PAL’s Dash 8 aircraft only operate into locations where there are ground de-icing facilities, 705 operations are more controlled and larger aircraft tend to operate into larger airports with more de-icing capability.

Ontario:

• - One air operator advised they have deice ability at all destinations where they operate a scheduled service and for charter service, they have wing covers and can carry portable spray units, in case the flight requires a hold at a remote destination.
• - One operator indicated that in Timmins they have a truck available to deice but other than that, everything they have is self-sufficient. At their schedule stops on the James Bay coast, they have small spray units to take care of flight ice. In Thunder Bay they use the sprayers or they put the plane in the hanger.
• - Another operator indicated, in the case the aircraft is sent to a location that does not have de-ice equipment the crews bring equipment (portable units) with them.
• - Outsourcing to communities is difficult as communities have little interest. They have approached the Chiefs Council to explore a First Nations business opportunity to de-ice aircraft.
• - Stored equipment is subject to theft and vandalism.
• - MTO have pushed back on glycol clean up. It is not possible for Operators to clean up de-ice fluid after aircraft spray.

PNR:

• - Suggested that it may be helpful if HQ could provide the regions with some info to ensure that all are at an equal understanding:
  • What are the requirements/interpretation of the regulation?;
  • Are there any other questions that we need to be asking? (i.e. OSH requirements, Dangerous Goods requirements);
  • Are all the other regions approaching this the same way?;
  • What are the next steps required to bring this information together for a national response?

Quebec:

Below is a list of regional airports that appear in the CFS , including whether or not they offer de-icing services. The list is followed by a colour code for the airports.

Checks were performed with air operators and principal inspectors from companies (704-705) whose areas of service include northern communities. Findings show that for the majority of them, de-icing is conducted on site by the carrier’s staff.

With very few exceptions, airports in the region do not manage aircraft de-icing services. In certain cases, such as those at YUL or YMX, de-icing is done at a central location at an airport by a contractor (Aéro Mag 2000). In other places, certain refuelling operators offer this service, but carriers regulated by 704-705 must follow the requirements of Standard 622.11.

According to Standard 622.11 (Ground Icing Operations), operators must put into place a program that complies with this standard. They must establish and implement a management plan approved by Transport Canada that includes levels of responsibility, applicable procedures, and required training. As the chapter states, “An operator's Ground Icing Operations Training Program shall include: (a) initial and annual recurrent training for all (…) personnel who have responsibilities within the program.”

With regard to the training ensured by a contractor, “An operator who contracts de-icing/anti-icing services from another organization is responsible for ensuring that the training program of the contractor and application of de-icing/anti-icing operations standards meet the operator's own Ground Icing Operations Program criteria. Through the operator, the contractor's procedures and training programs shall be documented.”

Air Inuit serves the 14 communities in Nunavik. The Puvirnituq (YPX) and Kuujjuak (YVP) airports receive, among other planes, their B-737s. The carrier is equipped at those locations for de-icing and anti-icing; however, this service is limited to their aircraft, “sister” companies, and the Service Aérien Gouvernemental (mainly for medical evacuations). Air Inuit crews will not go to an airport whose current or forecast weather conditions present risks. Nevertheless, if an aircraft experiences difficulties at one of the northern airports other than YPX or YVP , a Twin Otter based at the La Grande airport will be available with the de-icing equipment required to assist the affected aircraft. Air Inuit is particularly considering improving their de-icing equipment at airports in the near future.

Since this carrier wants to keep this service exclusive, it is not interested in having information about the service published in the CFS. This is also true for Air Creebec, which mainly services the James Bay and Hudson Bay airports. This is why so many airports do not show any information in the CFS on de-icing services.

CFS / Airport De-icing Services
Quebec Region
2018-2019

	Airport	I.D. Code	File	De-icing	Anti-icing	Administration
1	Akulivik	CYKO	581	No	No	Regional Administration Kativik
2	Alma	CYTF	250	No	No	Other
3	Aupaluk	CYLA	593	No	No	Regional Administration Kativik
4	Baie-Comeau	CYBC	507	Type I	Other	Other
5	Bonaventure	CYVB	216	Yes	Other	Transports Québec
6	Bromont	CZBM	401	No	No	Other
7	Chevery	CYHR	225	No	No	Transport Canada
8	Chibougamau /Chapais	CYMT	628	Yes	Other	Transports Québec
9	Chicoutimi /St-Honoré	CYRC	148	No	No	Transports Québec
10	Chisasibi	CSU2	607	No	No	Other
11	Eastmain River	CZEM	198	No	No	Transport Canada
12	Gaspé	CYGP	186	No	No	Other
13	Gatineau (CFS -Ottawa / Gatineau)	CYND	349	Yes	Yes	Other
14	Havre-St-Pierre	CYGV	224	Yes	Other	Transport Canada
15	Iles-de-la-Madeleine	CYGR	303	Yes	Other	Transport Canada
16	Inukjuak	CYPH	184	No	No	Regional Administration Kativik
17	Isle-aux-Grues	CSH2	345	No	No	Transports Québec
18	Ivujivik	CYIK	301	No	No	Regional Administration Kativik
19	Kangiqsualujjuaq	CYLU	338	No	No	Regional Administration Kativik
20	Kangiqsujuaq	CYKG	333	No	No	Regional Administration Kativik
21	Kangirsuk	CYAS	181	No	No	Regional Administration Kativik
22	Kattiniq /Donaldson	CTP9	426	No	No	Other
23	Kégaska	CTK6	803	No	No	Transports Québec
24	Kuujjuaq	CYVP	121	No	No	Regional Administration Kativik
25	Kuujjuarapik	CYGW	117	No	No	Regional Administration Kativik
26	La Grande Rivière	CYGL	441	No	No	Other
27	La Macaza / Mont-Tremblant Intl Inc	CYFJ	228	Yes	Yes	Other
28	La Romaine	CTT5	883	No	No	Transports Québec
29	La Tabatière	CTU5	937	No	No	Transports Québec
30	Lourdes-de-Blanc-Sablon	CYBX	131	Yes	Other	Transport Canada
31	Mont-Joli	CYYY	140	Yes	Other	Other
32	Montmagny	CSE5	246	No	No	Transports Québec
33	Montréal / Pierre-Elliott-Trudeau Intl	CYUL	142	Yes	Yes	Other
34	Montréal /St-Hubert	CYHU	173	Other	Other	Other
35	MontréalIntl(Mirabel)	CYMX	418	Yes	Yes	Other
36	Natashquan	CYNA	144	No	No	Transport Canada
37	Port-Ménier	CYPN	152	No	No	Transports Québec
38	Puvirnituq	CYPX	194	No	No	Regional Administration Kativik
39	Quaqtaq	CYHA	132	No	No	Regional Administration Kativik
40	Québec /Jean-Lesage	CYQB	153	Yes	Yes	Other
41	Roberval	CYRJ	157	No	No	Other
42	Rouyn-Noranda	CYUY	158	No	No	Other
43	Salluit	CYZG	300	No	No	Regional Administration Kativik
44	Schefferville	CYKL	160	Yes	Other	Transport Canada
45	Sept-Îles	CYZV	161	Yes	Yes	Transport Canada
46	St-Augustin	CYIF	385	No	No	Transports Québec
47	St-Jean	CYJN	165	No	No	Other
48	Tasiujaq	CYTQ	337	No	No	Regional Administration Kativik
49	Tête-à-la-Baleine	CTB6	801	No	No	Transports Québec
50	Trois-Rivières	CYRQ	169	Yes	Yes	Other
51	Umiujaq	CYMU	670	No	No	Regional Administration Kativik
52	Vald'Or	CYVO	170	No	No	Other
53	Waskaganish	CYKQ	197	No	No	Transport Canada
54	Wemindji	CYNC	554	No	No	Transport Canada

Annex B

Part 121.629 is the operational rule of the Federal Aviation Regulations (FAR) of Title 14 of the Code of Federal Regulations (CFR) in the United States as implemented and enforced by the FAA. It is the equivalent to sections 602.11 and 701.25 of the CARs.

FAR 121.629 - Operation in icing conditions

• (a) No person may dispatch or release an aircraft, continue to operate an aircraft en route, or land an aircraft when in the opinion of the pilot in command or aircraft dispatcher (domestic and flag operations only), icing conditions are expected or met that might adversely affect the safety of the flight.
• (b) No person may take off an aircraft when frost, ice, or snow is adhering to the wings, control surfaces, propellers, engine inlets, or other critical surfaces of the aircraft or when the takeoff would not be in compliance with paragraph (c) of this section. Takeoffs with frost under the wing in the area of the fuel tanks may be authorized by the Administrator.

The European Air Regulation (Air OPS regulation (EU) 965/2012) is in force in all 28 EU countries and also includes Switzerland, Liechtenstein, Norway and Iceland. It is implemented by the European Aviation Safety Agency (EASA) as well as correspondent European Member National Aviation Authorities (NAA).

CAT.OP.MPA.250 Ice and other contaminants — ground procedures

• (a) The operator shall establish procedures to be followed when ground de-icing and anti-icing and related inspections of the aircraft are necessary to allow the safe operation of the aircraft.
• (b) The commander shall only commence take-off if the aircraft is clear of any deposit that might adversely affect the performance or controllability of the aircraft, except as permitted under (a) and in accordance with the AFM.

Annex C

From: Sincennes, Robert
Sent: Friday, February 01, 2019 9:58 AM
To: [redacted]
Subject: De-icing / Anti-icing Procedures | Procédures de dégivrage/d’antigivrage

(le français suit)

The cold weather is upon us, and the season for de-icing is in full swing. As you may recall, the Transportation Safety Board (TSB) released recommendation A18-03 ahead of their final report publication on the investigation into the December 13, 2017 crash of an ATR -42 passenger plane in Fond-du-Lac, SK. Residual ice on the wings of the aircraft was not removed before takeoff and the investigation team identified safety deficiencies in need of urgent attention.

To reduce the likelihood of aircraft taking off with contaminated critical surfaces, we encourage you to please share with your members the following links:

Attention all air operators

• Chapter 8 of TP 14052 provides guidance on the use and recommended practices for de-icing fluids application: https://www.tc.gc.ca/eng/civilaviation/publications/tp14052-menu-314.htm#toc-8
• To learn more on preventative measures and de/anti-icing procedures, refer to chapter 10 of TP 14052: https://www.tc.gc.ca/eng/civilaviation/publications/tp14052-menu-314.htm#toc-10
• Verify that the training portion of your approved ground icing program (AGIP) meets the most recent industry-accepted standards and practices: https://www.tc.gc.ca/eng/civilaviation/publications/tp14052-menu-314.htm#toc-2

Robert Sincennes, P.Eng.
Director, Standards Branch
Directeur, Normes
Tel: 613-991-2738 cell: 613-859-2796 facsimile / télécopieur : 613-952-3298
Internet: robert.sincennes@tc.gc.ca
Transport Canada | Transports Canada
330 Sparks St
Ottawa (Ontario) K1A 0N5
Government of Canada | Gouvernement du Canada

Annex D

Terms of Reference

Transport Canada Civil Aviation

Standing Committee on Operations Under Icing Conditions (SCOUIC)

December 01, 2017

Background

The Commission of Inquiry into the Air Ontario crash at Dryden heard evidence that led it to conclude that information regarding winter operations of aircraft, and especially the adoption of the “clean wing” concept, must be made available to persons at all levels of flight operations. This resulted in Moshansky Commission Recommendation (MCR) 83 which states;

“Transport Canada give serious consideration to appointing an appropriately qualified person as a national resource specialist dedicated to all matters pertaining to aircraft surface contamination and the ground de-icing and anti-icing of aircraft in Canada, in the broadest sense, based upon a similar position in the Federal Aviation Administration of the United States and with similar objectives and responsibilities.”

The Task Group assigned to review this recommendation concluded that, because it would provide a visible Office of Prime Interest (OPI) for aircraft operations in icing conditions and yet maintain the current organizational distribution of functional specialists, a team approach to the collection and dissemination of information would make maximum use of existing expertise.

Purpose

1. To provide a focal point for monitoring the effectiveness of regulations pertaining to operations under icing conditions.
2. To serve as a focus group, when appropriate, regarding the development or updating of regulations and standards pertaining to aircraft operations in icing conditions.
3. To provide a focal point for the collection and dissemination of information on all matters related to aircraft surface contamination and icing operations for aircraft in Canada.
4. To promote safe aircraft operations and airworthiness procedures under icing conditions;
5. To encourage and where possible promote aircraft icing related research and development.

Scope

The scope of subject matter would be as broad as possible and would include airborne and ground de-icing/anti-icing operations, airport considerations, icing research and development, aircraft operations and pilot training.

Organization

Chairperson: Yvan Chabot, Flight Technical Engineer, Commercial Flight Standards (AARTFT)

Members: Representative(s) include the following;

Transport Canada Civil Aviation

• Standards Branch
• Policy and Regulatory Services Branch
• National Aircraft Certification Branch
• National Operations Branch
• TCCA Regions

Transport Canada Transportation Development Centre

Foreign Aviation Authorities

• FAA
• AESA
• NASA

Canadian Transportation Safety Board

National Research Council Canada

Environment and Climate Change Canada

Industry Representatives

• Air Line Pilots Association (ALPA)
• Air Canada Pilots Association (ACPA)
• National Airlines Council of Canada (NACC)
• Air Transport Association of Canada (ATAC)
• Canadian Airports Council (CAC)
• Fluid Manufacturers
• Independent Fluid Testing Facilities
• Aircraft Manufacturers
• Central De-Ice Facilities
• Air Operators
• Private Operators

Methodologies:

1. Establish and maintain an information portfolio on all topics relating to the de-icing/anti-icing of aircraft both on the ground and in flight;
2. Be the initial point of contact for the aviation industry when seeking information on ground and in-flight icing operations in Canada;
3. Attend conferences and meetings to promote and report on Canada’s views and issues emanating from the SCOUIC meetings as well as maintaining currency in developing ideas related to the subject, and should include representation on international committees such as the International Air Transport Association (IATA) Global De/anti-icing Forum, the Society of Automotive Engineers (SAE) Aircraft Icing Committee; and the SAE / ICAO / IATA Council for Globalized Aircraft Deicing Standards;
4. Monitor the effectiveness of regulations, standards and guidance relating to aircraft surface contamination and to recommend changes as appropriate;
5. Monitor aircraft icing related research and development efforts and to provide the necessary input and recommendations to TCCA with respect to the most pressing areas where further research is required;
6. Educate the aircraft icing community via ongoing information exchange and update sessions.

Office of functional specialist branches

To nominate and commit resources to sub-committees, which may, for specific topics, request resources from the functional specialists.

Meetings

Meetings should be held at the call of the chairperson at least biannually, preferably preceding the winter operating season.

Accountability

Accountable to the Civil Aviation Management Executive (CAMX).

Budget

Members of the Committee will be responsible for their own expenses.

Administrative support

AARTF will be responsible for providing administrative support to the Committee.

A. McCrorie
Director General, Aviation Safety Regulatory Framework
Civil Aviation

Accepted by: