Civil Aviation Authority
Information Notice
Number: IN–2015/097
Issued: 23 October 2015
Aerodrome Emergency Planning – Emergency Exercises
This Information Notice contains information that is for guidance and/or awareness.
Recipients are asked to ensure that this Information Notice is copied to all members of their staff who
may have an interest in the information (including any ‘in-house’ or contracted maintenance
organisations and relevant outside contractors).
Applicability:
Aerodromes:
All Aerodrome Operators
Air Traffic:
All Aerodrome ANSP
Airspace:
Not primarily affected
Airworthiness:
Not primarily affected
Flight Operations:
Not primarily affected
Licensed/Unlicensed
Personnel:
Not primarily affected
1
Introduction
1.1
This information Notice (IN) applies to all certificated aerodromes operating to Commission
Regulation (EU) No. 139/2014 (EU rules), and UK licensed aerodromes operating to the
requirements of CAP 168 (Licensing of Aerodromes). It aims to assist aerodrome operators to
interpret the requirements for periodically testing their aerodrome emergency plan.
1.2
It includes notification of CAA’s intention to reduce the frequency of full-scale exercises, as
outlined in the UK guidance material contained in CAP 1168 (Guidance Material for
Organisations, Operations and Design Requirements for Aerodromes), and as described in
CAP 168 Chapter 9.
2
UK Modular Approach
2.1
ICAO Annex 14 (Volume 1 - Aerodrome Design and Operations) includes within its Standards
And Recommended Practices (SARPs) an option to test periodically the aerodrome
emergency plan by conducting a series of modular tests commencing in the first year and
concluding in a full-scale aerodrome emergency exercise at intervals not exceeding three
years.
2.2
EASA has produced an Acceptable Means of Compliance (AMC) that requires a full scale
aerodrome emergency exercise at intervals not exceeding two years, with a partial emergency
exercise in the intervening year (AMC1 ADR.OPS.B.005(c)).
2.3
Aerodrome operators are required to have and implement an aerodrome emergency plan that
is proportionate with the aircraft operations and other activities at the aerodrome. The plan is
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required to provide for the coordination of appropriate organisations in response to an
emergency occurring at the aerodrome or in its surroundings. Procedures for periodically
testing the adequacy of the plan, and for reviewing the results, are also required to be
included in the aerodrome’s emergency plan.
2.4
In accordance with ADR.AR.A.015 (means of compliance), the CAA has developed an
Alternative Means of Compliance (AltMoC) and UK guidance material, which introduces and
expands on the ICAO modular option outlined above. For further details see CAP 1168.
2.5
With effect from 1 November 2015, the CAA intends to change the maximum interval between
full-scale tests of the aerodrome emergency plan, when testing the plan by modular means,
from the current three years, to four years. The revised wording of UK-AltMoC1
ADR.OPS.B.005 (c) Emergency Exercises, and CAP168 chapter 9 paragraph 9.77(2) can
be seen at Appendix 1 below. These changes will take effect from 01 November 2015 and
will be incorporated into the documents at the next scheduled update.
Note: The frequency of full-scale emergency exercises for aerodromes choosing not to use
the UK modular approach remains unchanged.
2.6
It is anticipated that, by increasing the maximum interval between full-scale exercises to four
years, aerodrome operators will have greater flexibility to engage with other agencies that
have a key role within the aerodrome’s emergency plan, and for the aerodrome emergency
plan to be embedded in the local or regional emergency planning arrangements. In turn it is
anticipated that this will improve the level of support that external emergency services are able
to commit to aerodrome full-scale exercises.
3
Further Information
3.1
To assist aerodrome operators to interpret the compliance requirements and performance
aspects related to the implementation of the UK modular approach described in CAP 1168,
the CAA can provide the following guidance:
3.2
Implementation of the UK modular approach at the time of transition to the EU rules should be
documented in the aerodrome’s Operations Basis (OB) and managed in accordance with the
management of change process in the Aerodrome Operators Safety Management System
(SMS)
3.3
If an aerodrome operator wishes to implement the UK modular approach following transition to
the EU rules, this should be considered a change that requires prior approval; therefore AMC1
ADR.OR.B.040(a);(b) should be followed.
Note: when implementing the UK modular approach, the first full-scale test of the emergency
plan should take place no more than four years after the previous full-scale exercise.
3.4
A detailed plan should be recorded within the Aerodrome Manual or Emergency Plan
document outlining a rolling programme of events highlighting the objectives of each module
and how it is to be tested.
3.5
A guide to the modulation of exercises is contained within CAP 1168, and should be viewed
as a framework when designing modules specific to the airports emergency planning
arrangements. The modules should be developed in consultation with all participating
agencies and should be aligned to the type of operation and key risks at the aerodrome.
Note: The UK modular approach may be extended to incorporate details of the tests for
aerodrome facilities and equipment to be used in emergencies (such as emergency
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operations centre, mobile command post, fire fighting vehicles and equipment, communication
means, first aid medical supplies, etc.)
3.6
Plans for testing should consider different types of emergencies that could occur at the
aerodrome and can include table-top exercises, partial exercises, full-scale tests. Objectives
should be developed and agreed for each module prior to testing.
3.7
Irrespective of whether the Aerodrome Operator chooses to continue with the EASA
emergency exercise testing model or adopt the UK modular approach (AltMOC), the following
guidance must be considered:
a) A debriefing and recording process should be developed and agreed which captures ‘real’
and ‘simulated’ evidence of performance in respect of all components of the emergency
plan that have been tested. Included within the recording process should be an action log
which tracks until closure, actions allocated during the emergency plan testing process.
b) Exercises should be held in locations which will provide maximum realism whilst ensuring
minimum disruption to aerodrome operations if carried out during the aerodrome’s
promulgated hours of operation.
c) Different scenarios, as described in the aerodrome emergency plan document, are used
for exercising purposes.
d) It should be planned to hold exercises on and near the aerodrome to test different
scenarios. Consideration should be given to alternating exercises from day to night, and at
different times of the year when seasonal changes may present additional challenges.
3.8
Appendix 2 to this Information Notice contains checklists of the compliance aspects, and
performance markers that CAA will use during its oversight of the testing of aerodrome
emergency plans.
3.9
Type of Exercise: The choice of exercise type is important; it should provide the most
appropriate way of achieving its aim and objectives. There are three basic types of exercise,
although there are variations on the theme of each. Table top exercises can be workshops or
discussion based exercises; Partial exercises should involve, at least one unit, such as rescue
and firefighting services, or medical, or a combination of several units and Live exercises, also
known as practical, operational or field exercises should include all participating services and
extend to the full range of activities anticipated to be performed during a real event.
Note: more detailed guidance on emergency exercises and preparedness can be found in
ICAO Airport services manual Part 7 – Airport Emergency Planning (under review) and on the
Cabinet Office website – GOV.UK.
4
Actual Emergencies
4.1
When an aerodrome experiences an actual emergency (aircraft accident or aircraft ground
incident) that tests all or a significant proportion of the aerodromes emergency plan, it may be
reasonable to consider deferring a full-scale exercise on the basis that the event has tested
the adequacy of the plan. Where an aerodrome operator deems this to be the case, the
following should be considered:
a) A documented gap analysis should be carried out to identify any aspects of the aerodrome
emergency plan that were not tested.
b) Any aspects that were not tested should be tested in a timely manner as part of the
ongoing exercise plans.
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c) Any learning from the event, debriefs, and actions arising, should be recorded and tracked
as per the process used for exercises.
4.2
The CAA should be consulted if the aircraft accident response is being considered a test of
the aerodrome emergency plan in lieu of a full-scale exercise.
4.3
Where the event is being used in lieu of a full-scale exercise, the next full-scale test should be
scheduled to take place within two years of the event.
4.4
Other agencies that have a key role within the aerodromes emergency plan should be
consulted over the decision to defer the full-scale exercise.
4.5
Any decision to defer the full scale exercise should be supported by the aerodrome’s
Accountable Manager.
5
Queries
5.1
Any queries or requests for further guidance as a result of this communication should be
addressed to:
Airspace, ATM and Aerodromes
Safety and Airspace Regulation Group
Civil Aviation Authority
1NE Aviation House
Gatwick Airport South
RH6 0YR
E-mail: aerodromes@caa.co.uk
6
Cancellation
6.1
This Information Notice will remain in force until further notice
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Appendix 1
The text of the amendment is arranged to show deleted text, new or amended text as shown below:
(a) deleted text is marked with strike through;
(b) new or amended text is highlighted in grey;
(c) an ellipsis (…) indicates that the remaining text is unchanged in front of or following the
reflected amendment.
Change to - UK-AltMoC1 ADR.OPS.B.005 (c) Emergency Exercises
As an alternative to the method of testing outlined in AMC1 ADR.OPS.B.005(c) Aerodrome Operators
may wish to test their emergency plan by conducting:
1
A series of modular tests commencing in the first year and concluding in a full-scale
aerodrome emergency exercise at intervals not exceeding three four years;
2
Periodic reviews thereafter, or after an actual emergency, so as to correct any deficiency
found during such exercises or actual emergency.
Change to – CAP168 Chapter 9 Paragraph 9.77(2)
9.77
The plan shall be tested by conducting:
(…)
2.
a series of modular tests commencing in the first year and concluding in a full-scale
aerodrome emergency exercise at intervals not exceeding three four years and
reviewed thereafter, or after an actual emergency, so as to correct any deficiency
found during such exercises or actual emergency.
(…)
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Appendix 2 – Sample CAA Checklists for Oversight of Aerodrome Emergency Plan
Testing
Compliance questions.
Yes
No
Yes
No
Is the testing of the emergency plan included in compliance monitoring at the
aerodrome?
Has the Aerodrome Operator (AO) included in the emergency plan,
procedures for periodic testing of the adequacy of the plan?
Does the emergency plan include procedures for reviewing the results of the
tests in order to improve its effectiveness?
Does the AO test the plan by holding a full-scale aerodrome emergency
exercise at intervals not exceeding two years?
Does the AO hold (or plan to hold) partial emergency exercises in the
intervening year to ensure that any deficiencies found during the full-scale
aerodrome emergency exercise have been corrected?
Or
Does the AO conduct (or have a plan to conduct) a series of modular tests
commencing in the first year and concluding in a full-scale aerodrome
exercise at intervals not exceeding four years?
Following an actual emergency or an exercise, is there a process for
reviewing outcomes, for the purpose of correcting any deficiency found?
Does the AO coordinate the emergency response plan with the SMS in order
to ensure continuous improvement of the systems and procedures contained
in the plan?
Has the AO nominated a person(s) to manage and supervise the process
used for testing the emergency plan?
Is the nominated person(s) qualified for the planned tasks? (Note: GM1
ADR.OR.D.015(d) – Personnel Requirements – defines the term ’qualified’)
Performance Markers
The AO has determined how the plan is going to be tested and developed
processes and procedures to support this
The AO has documented the method of testing the emergency plan (or
referenced it) in the aerodrome manual/emergency plan document
Details of the tests for aerodrome facilities and equipment to be used in
emergencies (such as emergency operations centre, mobile command post,
fire fighting vehicles and equipment, communication means, first aid medical
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supplies, etc.,) are included in the emergency plan document
The periodicity of the exercises/modules has been determined and included
in the emergency plan document
The exercises are coordinated with all departments and agencies who may
be involved in the plan
Full-scale emergency exercises are supported by all aerodrome and
community authorities concerned
Modules are aligned to the type of operation and key risks at the aerodrome
Plans for testing consider different types of emergencies that could occur at
the aerodrome
Objectives have been developed for each module
A recording system has been implemented to capture ‘real’ and ‘simulated’
evidence of performance in respect of all components of the emergency plan
An action log is in place to track actions allocated during the emergency plan
testing process
The AO has developed and implemented a rolling programme to show how
and when the plan will be tested (including modules, table-top exercises,
partial exercises, full-scale tests)
Exercises are/will be held in locations which will provide maximum realism
while ensuring minimum disruption of the aerodrome operations
Different scenarios, as described in the aerodrome emergency plan
document, are used
It is planned to hold exercises during both day and night
It is planned to hold exercises at different times of the year when seasonal
changes may present additional challenges
It is planned to hold exercises both on or near the aerodrome to test different
scenarios
The aerodrome has applied appropriate change management if implementing
the modular exercise option
During full-scale emergency exercise, the entire proceedings are reviewed
An observer critique team has been established
The observer critique team is comprised of members who are familiar with
mass casualty accident proceedings (proportionate to the type of aircraft
operations taking place at the aerodrome).
Each member of the critique team observes the entire exercise, and
completes the appropriate emergency drill critique forms
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A critique meeting is held as soon as convenient after the exercise so
members of the team can present their observations and recommendations
for improvement of the plan
Exercises are followed by a full debriefing, critique, and analysis
Representatives of all organisations which participate in the exercise actively
participate in the debriefing, critique, and analysis
Partial emergency exercises involve, at least, one unit, such as rescue and
firefighting services, or medical, or combination of several units
Partial emergency exercises ensure that any deficiencies found during the
full-scale aerodrome emergency exercise (or actual emergency) have been
corrected
Tabletop exercises are held at regular intervals which verify that roles and
procedures are clear and understood
Tabletop exercises are used to test new or revised procedures, before
implementation
Tabletop exercises are held during preparation for a full-scale emergency
exercise
A review of the relevant parts of the emergency response plan is conducted
after a full or partial exercise
Debriefing and analysis of the emergency response operations after an
emergency situation is carried out
New emergency procedures or systems are developed as part of the
emergency response plan when new hazards are identified by the safety
management system
Coordination with the emergency response plans of other interfacing
organisations is evident
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