COMMENT RESPONSE DOCUMENT

1. COMMENT RESPONSE DOCUMENT NPA-OPS 46 Dangerous goods

2. SUMMARY • 16 Comments • 8 Organisations • National Authorities • International Air Carriers Association • Operators

3. General comments • Overall 8 comments • No specific objections to NPA, however • 3 suggested extra or amended text

4. General comments • 006 • Proposed a single reference to the Technical Instructions • Declined, based on previous advice from OST

5. General comments • 007 • Proposed standardisation of either “shall” or “must”; • Partially accepted, though a question for JAA Secretariat. • Proposed to Replace “JARs” with reference to EASA requirement; • Declined, beyond scope of NPA.

6. General comments • 013 • Suggested advantageous to change structure; • Noted – no alternative text proposed. • Suggested 1.420 and 1.1225 addressed by EU Reporting Directive; • Declined – Directive not applicable to all JAA States. • Suggested JAR-OPS cannot conflict with Technical Instructions; • Accepted and is the reason for this NPA.

7. 1.420 – Occurrence reporting • 012 • Proposed to include purpose of reporting i.e. not for punitive reasons; • Declined – beyond the remit of JAA and is a matter for States.

8. 1.1150 – Terminology • 009 • Suggested confusion in respect of “Approval”; • Declined – definition of “Approval” is only in respect of 1.1165 (b)(2) and applies only to dangerous goods which are forbidden in normal circumstances.

9. 1.1160 - Scope • 002 • Proposed that only operators holding approval to carry dangerous goods as cargo can carry dangerous goods permitted for carriage by passengers only with approval of the operator; • Declined – believed to be an isolated case of mis-understanding.

10. 1.1160 - Scope • 008 • Suggested proposed text for 1.1160 was confusing and needed to be reviewed; • Accepted - New text developed.

11. 1.1205 – Removal of Contamination(though actually referring to 1.1155) • 014 • Suggested approval to carry dangerous goods as cargo should form part of the AOC; • Declined – not all AOC holders require approval to carry dangerous goods.

12. 1.1220 – Training programmes • 010 • What is meant by “staff” and who is “the Authority”?; • Noted – outside the remit of the NPA.

13. And finally……. ACJ OPS 1.1220 3 Areas of training. The areas of training given in Tables 1 and 2 of JAR-OPS 1.1220 are applicable whether the training is for general information and guidance or to give an in-depth and detailed appreciation. The extent to which any area of training should be covered is dependent upon whether it is for general information or to give in-depth appreciation. Additional areas not identified in Tables 1 and 2 may be needed, or some areas omitted, depending on the responsibilities of the individual.

14. And finally……. ACJ OPS 1.1220 3 Areas Aspects of training. The areas aspects of training given in Tables 1 and 2 of JAR-OPS 1.1220 specifiedin the Technical Instructions are applicable whether the training is for general information and guidance or to give an in-depth and detailed appreciation. The extent to which any area aspect of training should be covered is dependent upon whether it is for general information or to give in-depth appreciation. Additional areas aspects not identified in Tables 1 and 2 the Technical Instructions may need to be covered be needed, or some areas aspectsomitted, depending on the responsibilities of the individual.