GM3 ORA.GEN.200(a)(3) Management system

APPROVED TRAINING ORGANISATIONS - RISK MANAGEMENT OF FLIGHT OPERATIONS WITH KNOWN OR FORECAST VOLCANIC ASH CONTAMINATION

(a)     Responsibilities

The ATO is responsible for the safety of its operations, including within an area with known or forecast volcanic ash contamination.

The ATO should complete this assessment of safety risks related to known or forecast volcanic ash contamination as part of its management system before initiating operations into airspace forecast to be or aerodromes/operating sites known to be contaminated with volcanic ash. 

This process is intended to ensure the ATO takes into account the likely accuracy and quality of the information sources it uses in its management system and to demonstrate its own competence and capability to interpret data from different sources in order to achieve the necessary level of data integrity reliably and correctly resolve any conflicts among data sources that may arise. 

In order to decide whether or not to operate into airspace forecast to be or aerodromes/operating sites known to be contaminated with volcanic ash, the ATO should make use of the safety risk assessment within its management system as required by ORA.GEN.200.

The ATO’s safety risk assessment should take into account all relevant data including data from the type certificate holders (TCHs) regarding the susceptibility of the aircraft they operate to volcanic cloud-related airworthiness effects, the nature and severity of these effects and the related pre-flight, in-flight and post-flight precautions to be observed by the ATO.

The ATO should ensure that personnel required to be familiar with the details of the safety risk assessments receives all relevant information (both pre-flight and in-flight) in order to be in a position to apply appropriate mitigation measures as specified by the safety risk assessments.

(b)     Procedures

The ATO should have documented procedures for the management of operations into airspace forecast to be or aerodromes/operating sites known to be contaminated with volcanic ash.

These procedures should ensure that, at all times, flight operations remain within the accepted safety boundaries as established through the management system allowing for any variations in information sources, equipment, operational experience or organisation. Procedures should include those for flight crew and any other relevant personnel such that they are in a position to evaluate correctly the risk of flights into airspace forecast to be contaminated by volcanic ash and to plan accordingly.

Continuing airworthiness personnel should be provided with procedures allowing them to correctly assess the need for and to execute relevant maintenance or continuing airworthiness interventions.

The ATO should retain sufficient qualified and competent staff to generate well supported operational risk management decisions and ensure that its staff are appropriately trained and current. It is recommended that the ATO make the necessary arrangements for its relevant staff to take up opportunities to be involved in volcanic ash exercises conducted in their areas of operation.

(c)      Volcanic activity information and the ATO’s potential response

Before and during operations, information valuable to the ATO is generated by various volcano agencies worldwide. The ATO’s risk assessment and mitigating actions need to take account of and respond appropriately to the information likely to be available during each phase of the eruptive sequence from pre-eruption through to end of eruptive activity. It is nevertheless noted that eruptions rarely follow a deterministic pattern of behaviour. A typical ATO’s response may consist of the following:

(1)     Pre-eruption

The ATO should have in place a robust mechanism for ensuring that it is constantly vigilant for any alerts of pre-eruption volcanic activity relevant to its operations. The staff involved need to understand the threat to safe operations that such alerts represent.

An ATO whose areas of activity include large, active volcanic areas for which immediate International Airways Volcano Watch (IAVW) alerts may not be available, should define its strategy for capturing information about increased volcanic activity before pre-eruption alerts are generated. For example, an ATO may combine elevated activity information with information concerning the profile and history of the volcano to determine an operating policy, which could include re-routing or restrictions at night. This would be useful when dealing with the 60% of volcanoes which are unmonitored.

Such an ATO should also ensure that its crews are aware that they may be the first to observe an eruption and so need to be vigilant and ready to ensure that this information is made available for wider dissemination as quickly as possible.

(2)     Start of an eruption

Given the likely uncertainty regarding the status of the eruption during the early stages of an event and regarding the associated volcanic cloud, the ATO’s procedures should include a requirement for crews to initiate re-routes to avoid the affected airspace.

The ATO should ensure that flights are planned to remain clear of the affected areas and that consideration is given to available aerodromes/operating sites and fuel requirements.

It is expected that the following initial actions will be taken by the ATO:

(i)      determine if any aircraft in flight could be affected, alert the crew and provide advice on re-routing as required; 

(ii)     alert management;

(iii)     for flight departures, brief flight crew and revise flight and fuel planning in accordance with the safety risk assessment;

(iv)     alert flight crew to the need for increased monitoring of information (e.g. special air report (AIREP), volcanic activity report (VAR), significant weather information (SIGMET), NOTAMs and company messages);

(v)      initiate the gathering of all data relevant to determining the risk; and 

(vi)     apply mitigations identified in the safety risk assessment. 

(3)     On-going eruption

As the eruptive event develops, the ATO can expect the responsible Volcanic Ash Advisory Centre (VAAC) to provide volcanic ash advisory messages (VAA/VAGs) defining, as accurately as possible, the vertical and horizontal extent of areas and layers of volcanic clouds. As a minimum, the ATO should monitor, and take account of, this VAAC information as well as of relevant SIGMETs and NOTAMs.

Other sources of information are likely to be available such as VAR/AIREPs, satellite imagery and a range of other information from State and commercial organisations. The ATO should plan its operations in accordance with its safety risk assessment taking into account the information that it considers accurate and relevant from these additional sources.

The ATO should carefully consider and resolve differences or conflicts among the information sources, notably between published information and observations (pilot reports, airborne measurements, etc.).

Given the dynamic nature of the volcanic hazards, the ATO should ensure that the situation is monitored closely and operations adjusted to suit changing conditions.

The ATO should be aware that, depending on the State concerned the affected or danger areas may be established and presented in a different way than the one currently used in Europe as described in EUR Doc 019-NAT Doc 006.

The ATO should require reports from its crews concerning any encounters with volcanic emissions. These reports should be passed immediately to the appropriate air traffic services (ATS) unit and to the ATO’s competent authority.

For the purpose of flight planning, the ATO should treat the horizontal and vertical limits of the temporary danger area (TDA) or airspace forecast to be contaminated by volcanic ash as applicable, to be over-flown as it would mountainous terrain, modified in accordance with its safety risk assessment. The ATO should take account of the risk of cabin depressurisation or engine failure resulting in the inability to maintain level flight above a volcanic cloud. Additional minimum Equipment List (MEL) provisions, if applicable, should be considered in consultation with the TCHs.

Flying below a volcanic ash contaminated airspace should be considered on a case by case basis. It should only be planned to reach or leave an aerodrome/operating site close to the boundary of this airspace or where the ash contamination is very high and stable. The establishment of Minimum Sector Altitude (MSA) and the availability of aerodromes/operating sites should be considered.

(d)     Safety risk assessment

When directed specifically at the issue of intended flight into airspace forecast to be or aerodromes/operating sites known to be contaminated with volcanic ash, the process should involve the following: 

(1)     Identifying the hazards

The generic hazard, in the context of this document, is airspace forecast to beor aerodromes/operating sites known to be contaminated with volcanic ash, and whose characteristics are harmful to the airworthiness and operation of the aircraft.

This GM is referring to volcanic ash contamination since it is the most significant hazard for flight operations in the context of a volcanic eruption. Nevertheless, it might not be the only hazard and therefore the operator should consider additional hazards which could have an adverse effect on aircraft structure or passengers safety such as gases.

Within this generic hazard, the ATO should develop its own list of specific hazards taking into account its specific aircraft, experience, knowledge and type of operation, and any other relevant data stemming from previous eruptions.

(2)     Considering the severity and consequences of the hazard occurring (i.e. the nature and actual level of damage expected to be inflicted on the particular aircraft from exposure to that volcanic ash cloud).

(3)     Evaluating the likelihood of encountering volcanic ash clouds with characteristics harmful to the safe operation of the aircraft.

For each specific hazard within the generic hazard, the likelihood of adverse consequences should be assessed, either qualitatively or quantitatively. 

(4)     Determining whether the consequent risk is acceptable and within the ATO’s risk performance criteria.

At this stage of the process, the safety risks should be classified as acceptable or unacceptable. The assessment of tolerability will be subjective, based on qualitative data and expert judgement, until specific quantitative data are available in respect of a range of parameters.

(5)     Taking action to reduce the safety risk to a level that is acceptable to the ATO’s management.

Appropriate mitigation for each unacceptable risk identified should then be considered in order to reduce the risk to a level acceptable to the ATO’s management. 

(e)     Procedures to be considered when identifying possible mitigations actions

When conducting a volcanic ash safety risk assessment, the ATO should consider the following non-exhaustive list of procedures and processes as mitigation: 

(1)     Type certificate holders

Obtaining advice from the TCHs and other engineering sources concerning operations in potentially contaminated airspace and/or aerodromes/operating sites contaminated by volcanic ash.

This advice should set out: 

(i)      the features of the aircraft that are susceptible to airworthiness effects related to volcanic ash; 

(ii)     the nature and severity of these effects; 

(iii)     the effect of volcanic ash on operations to/from contaminated aerodromes/ operating sites, including the effect on take-off and landing aircraft performance;

(iv)     the related pre-flight, in-flight and post-flight precautions to be observed by the ATO including any necessary amendments to aircraft operating manuals, aircraft maintenance manuals, master minimum equipment list/dispatch deviation or equivalents required to support the ATO; and 

(v)      the recommended inspections associated with inadvertent operations in volcanic ash contaminated airspace and operations to/from volcanic ash contaminated aerodromes/operating sites; this may take the form of instructions for continuing airworthiness or other advice.

(2)     ATO/contracted organisations’ personnel

Definition of procedures for flight planning and operations ensuring that: 

(i)      flight crews are in a position to evaluate correctly the risk of encountering   volcanic ash contaminated airspace, or aerodromes/operating sites, and can plan accordingly;

(ii)     flight planning and operational procedures enable crews to avoid areas and aerodromes/operating sites with unacceptable volcanic ash contamination; 

(iii)     flight crew are aware of the possible signs of entry into a volcanic ash cloud and execute the associated procedures;

(iv)     continuing airworthiness personnel are able to assess the need for, and to execute, any necessary maintenance or other required interventions; and 

(v)      crews are provided with appropriate aircraft performance data when operating to/from aerodromes/operating sites contaminated with volcanic ash.

(3)     Provision of enhanced flight watch

This should ensure: 

(i)      close and continuous monitoring of VAA, VAR/AIREP, SIGMET, NOTAM and ASHTAM and other relevant information, and information from crews, concerning the volcanic ash cloud hazard; 

(ii)     access to plots of the affected areas from SIGMETs, NOTAMs and other relevant information for crews; and 

(iii)     communication of the latest information to crews in a timely fashion. 

(4)     Flight planning

Flexibility of the process to allow re-planning at short notice should conditions change. 

(5)     Departure, destination and alternate aerodromes

For the airspace to be traversed, or the aerodromes/operating sites in use, parameters to evaluate and take account of:

(i)      the probability of contamination; 

(ii)     any additional aircraft performance requirements; 

(iii)     required maintenance considerations; 

(iv)     fuel requirements for re-routeing and extended holding. 

(6)     Routing policy

Parameters to evaluate and take account of: 

(i)      the shortest period in and over the forecast contaminated area; 

(ii)     the hazards associated with flying over the contaminated area; 

(iii)     drift down and emergency descent considerations; 

(iv)     the policy for flying below the contaminated airspace and the associated hazards. 

(7)     Diversion policy

Parameters to evaluate and take account of: 

(i)      maximum allowed distance from a suitable aerodrome/operating site; 

(ii)     availability of aerodromes/operating sites outside the forecast contaminated area; 

(iii)     diversion policy after an volcanic ash encounter. 

(8)     Minimum equipment list

Additional provisions in the MEL, if applicable, for dispatching aircraft with unserviceabilities that might affect the following non-exhaustive list of systems:

(i)      air conditioning packs; 

(ii)     engine bleeds; 

(iii)     pressurisation system; 

(iv)     electrical power distribution system;

(v)      air data system; 

(vi)     standby instruments; 

(vii)    navigation systems;

(viii)   de-icing systems;

(ix)     engine driven generators; 

(x)      auxiliary power unit (APU); 

(xi)     airborne collision avoidance system (ACAS); 

(xii)    terrain awareness warning system (TAWS); 

(xiii)   autoland systems; 

(xiv)   provision of crew oxygen; 

(xv)    supplemental oxygen for passengers. 

(9)     Standard operating procedures

Crew training to ensure they are familiar with normal and abnormal operating procedures and particularly any changes regarding but not limited to: 

(i)      pre-flight planning; 

(ii)     in-flight monitoring of volcanic ash cloud affected areas and avoidance procedures; 

(iii)     diversion;

(iv)     communications with ATC;

(v)      in-flight monitoring of engine and systems potentially affected by volcanic ash cloud contamination;

(vi)     recognition and detection of volcanic ash clouds and reporting procedures;

(vii)    in-flight indications of a volcanic ash cloud encounter;

(viii)   procedures to be followed if a volcanic ash cloud is encountered;

(ix)     unreliable or erroneous airspeed; 

(x)      non-normal procedures for engines and systems potentially affected by volcanic ash cloud contamination;

(xi)     engine-out and engine relight;

(xii)    escape routes; and

(xiii)   operations to/from aerodromes/operating sites contaminated with volcanic ash.

(10)    Provision for aircraft technical log

This should ensure: 

(i)      Systematic entry in the aircraft continuing airworthiness records or aircraft log if available related to any actual or suspected volcanic ash encounter whether in-flight or at an aerodrome/operating site; and 

(ii)     Checking, prior to flight, of the completion of maintenance actions related to an entry in the continuing airworthiness records or aircraft log if available for a volcanic ash cloud encounter on a previous flight.

(11)    Incident reporting

Crew requirements for: 

(i)      reporting an airborne volcanic ash cloud encounter (VAR); 

(ii)     post-flight volcanic ash cloud reporting (VAR);

(iii)     reporting non encounters in airspace forecast to be contaminated; and 

(iv)     filing a mandatory occurrence report in accordance with ORA.GEN.160.

(12)    Continuing airworthiness procedures

Procedures when operating in or near areas of volcanic ash cloud contamination: 

(i)      enhancement of vigilance during inspections and regular maintenance and appropriate adjustments to maintenance practices;

(ii)     definition of a follow-up procedure when a volcanic ash cloud encounter has been reported or suspected; 

(iii)     thorough investigation for any sign of unusual or accelerated abrasions or corrosion or of volcanic ash accumulation; 

(iv)     reporting to TCHs and the relevant authorities observations and experiences from operations in areas of volcanic ash cloud contamination; 

(v)      completion of any additional maintenance recommended by the TCH or by the competent authority. 

(f)      Reporting

The ATO should ensure that reports are immediately submitted to the nearest ATS unit using the VAR/AIREP procedures followed up by a more detailed VAR on landing together with, as applicable, a report as defined in Regulation (EU) No 996/2010 and Directive 2003/42/EC, and an aircraft technical log entry for: 

(1)     any incident related to volcanic clouds; 

(2)     any observation of volcanic ash activity and 

(3)     anytime that volcanic ash is not encountered in an area where it was forecast to be. 

(g)     Additional guidance

Further guidance on volcanic ash safety risk assessment is given in ICAO Doc. 9974 (Flight safety and volcanic ash – Risk management of flight operations with known or forecast volcanic ash contamination).