EASA is proposing new regulation to expand and harmonise safety oversight of ground handling across the European Union, setting minimum levels of safety, driving best practices, curtailing the outsourcing ‘race to the bottom’, together with adding focuses on information security and cybersecurity. It will have implications for the 300,000 ground handling workers across the continents, as John Walton reports.
The regulation proposed in EASA’s Opinion No 01/2024 aims to change ground handling (GH) from what is today mostly a self-regulated industry to one that is recognised and regulated as a core player in aviation safety. Perhaps the most fundamental objective is a shift in perspective and paradigm: changing the mentality where ground handlers are presently regarded as simple service providers to one of being a core part of the aviation industry, and responsible for the safety of their own operations.
The goal, says EASA, is “a regulatory framework for a scalable management system proportional to the size and complexity of the operation, covering the management of safety, safety culture, training requirements for GH personnel, a maintenance programme for the ground support equipment used for the provision of GH services, and general operational requirements for the provision of GH services.”
EASA explains that it “proposes a new approach for the acceptance of industry standards applied in the GH domain, acknowledging their continued use and enabling their implementation on a voluntary basis. Their importance for the harmonisation and standardisation of GH operational procedures is more relevant than in any other aviation domain due to the number of different industry standards and their coverage of the entire spectrum of GH operations.”
The regulator has taken a three-phase approach to this work since 2018, including input from an expert group — comprising companies and associations of ground handlers, aircraft operators, aerodrome operators, trade unions, Eurocontrol and the ‘competent authority’ regulators — and two consultations, in 2022 and 2023.
“This entirely new proposal fills an important gap in the overall regulation of aviation operations in the European Union, which means that we will now have an end-to-end approach to ensuring aviation safety and cybersecurity,” says EASA acting executive director Luc Tytgat. “For passengers and their airlines this will provide increased certainty that ground handling operations are being carried out safely and consistently in all major airports across the EASA Member States.”
In context, the Basic Regulation (EU) 2018/1139 defines ground handling as: “any service provided at aerodromes comprising safety-related activities in the areas of ground supervision, flight dispatch and load control, passenger handling, baggage handling, freight and mail handling, apron handling of aircraft, aircraft services, fuel and oil handling, and loading of catering; including the case where aircraft operators provide those ground handling services to themselves (self-handling).”
Overall, the regulatory impact assessment for the proposal estimates that it is likely to save money in the long term, owing to reduction in damage to aircraft and other equipment, which the EU cites as approximately EUR 1.5 billion annually, out of a global IATA figure of USD 5 billion.
The new proposals are spurred on by safety risk portfolio and report analyses
EASA is up front that the industry has found itself — seemingly through regulatory gaps rather than any ill intent — in a situation where ground handling has ended up in a patchwork of safety frameworks across Europe. This includes the Groundhandling Directive 96/67/EC, which has a market access focus rather than a safety one, and although some national legislation implementing the Directive does include some safety requirements, this is neither consistent nor sufficient.
This has resulted, the regulator says, in insufficient safety culture, reporting culture and just culture — the latter defined by the EU as “a culture in which front-line operators or other persons are not punished for actions, omissions or decisions taken by them that are commensurate with their experience and training, but in which gross negligence, wilful violations and destructive acts are not tolerated” — within ground handlers and within the sector.
There are also concerns that ICAO Annex 13 and other air accident investigation concepts of operations do not include ground handling incidents where an aircraft is not involved, and that these are reported purely as occupational health and safety issues, leading to underreporting within aviation’s frameworks.
Information sharing is a particular concern, particularly in the key tripartite area of responsibility between airports, aircraft operators and ground handlers.
EASA also believes that the safety feedback loop from authorities to ground handlers is neither visible enough nor supported by regulatory framework. The worry here is that safety incidents go unreported or underreported owing to a lack of consequences, positive or negative, to reporting.
Further concerns include that, since aircraft operators take responsibility for the ground handling services they either provide themselves or contract in, and owing to a lack of EU regulation outlining clearly ground handlers’ responsibilities, there may be a perception that safety reporting is primarily or entirely the operator’s responsibility.
Reporting also raises concerns, with EASA highlighting complex reporting channels, lack of reporting systems, unclear or multiple reporting obligations, and unclear or inconsistent taxonomy.
EASA also emphasises that ground handling has the highest rate of staff turnover within aviation, annually some 70 percent overall and even reaching 100 percent within some European ground handling organisations. This lack of institutional knowledge combines poorly with the need to create a safety culture within newly recruited staff and the inherent drive in outsourced services businesses to reduce costs.
In addition, while the use of safety management systems within global or larger regional ground handlers on a voluntary basis is above average, there are many smaller ground handlers who serve one or a few airports, who may not engage with safety management systems to the same extent — or at all.
The current situation of both excessive reporting and insufficient safety must change
The historical context has led to a somewhat paradoxical situation where ground handlers are both overburdened with differing frameworks to demonstrate their safety credentials across airports, airlines and countries, yet also in a position where those safety credentials are in question, with what EASA calls a “low safety culture” across the industry.
“Today, a large ground handling organisation operating at 100 stations may be subject to over 600 audits from external stakeholders in a year, entailing almost 5 000 hours of work,” EASA acting executive director Luc Tytgat explains. “In future, air operators will be able to rely on the results of oversight performed only once by the competent authority and reduce their own audits only to the necessary additional aspects. This will reduce costs and free up resources to focus on more critical operations.”
The goals, EASA’s Opinion outlines, are to:
- establish a level playing field for the provision of GH services and for organisations providing them at EU aerodromes within the Basic Regulation’s scope;
- ensure a safety baseline for GH activities at EU aerodromes;
- provide a legal framework to support GH organisations in developing and fostering a safety culture;
- enable the development of effective interfaces for safety risk mitigations arising from GH activities by GH organisations, aircraft operators and aerodrome operators, including the exchange of safety-relevant information;
- establish minimum training standards for GH personnel, to ensure that personnel are trained and competent to perform the assigned tasks and that their competence is maintained;
- reduce the number of audits to GH organisations currently performed by aircraft operators under the current air operations requirements on contracted activities;
- establish a system for competent authorities to perform oversight of GH organisations and their activities, with particular focus on effective cooperative oversight and risk-based oversight.
Information security and cybersecurity improvements are also included in the proposed regulations, emphasising the importance of these aspects of security in safe operations.
EASA expects to publish the new regulations in late 2024 or early 2025.
Author: John Walton
Published 08 February 2024