How EASA Standardisation Activities Align with The ICAO USOAP Program

Sofema Aviation Services (SAS) discusses the following in detail, referencing the relationship between EASA and ICAO.

EASA Context: How EASA Standardisation activities align with the ICAO Universal Safety Oversight Audit Programme – USOAP program.

The relationship between the European Union Aviation Safety Agency (EASA) and the International Civil Aviation Organisation (ICAO) is characterised by a high degree of integration to eliminate duplication of effort.

Because EASA Member States are legally bound by both EU regulations (enforced by EASA) and the Chicago Convention (audited by ICAO), they theoretically face two separate audit regimes covering the same safety standards. To resolve this, EASA and ICAO have established a Working Arrangement (WA) that aligns EASA’s Standardisation activities with ICAO’s Universal Safety Oversight Audit Programme (USOAP).

The following details reference this relationship and how the alignment functions.

The Framework: Working Arrangement on Continuous Monitoring

The cornerstone of this relationship is the Working Arrangement on Continuous Monitoring Activities (signed in 2014). This legal instrument allows ICAO to recognise EASA’s oversight activities as a valid substitute for its own direct auditing of Member States in specific areas.

• The Goal: To move from a “double-check” system (where both EASA and ICAO audit the same state for the same thing) to a “complementary” system.
• The Mechanism: ICAO treats EASA as a Regional Safety Oversight Organisation (RSOO). Instead of auditing every EU Member State individually on every topic, ICAO relies on the data and findings generated by EASA’s own Standardisation Inspections.

Operational Alignment: EASA Standardisation vs. ICAO USOAP

While both programs aim to ensure safety oversight, they function differently. The alignment process bridges these operational differences.

How Alignment Works in Practice:

Mapped Standards: EASA regulations are designed to transpose ICAO Standards and Recommended Practices (SARPs) into EU law. Therefore, when EASA inspects a state for compliance with EU law, it is simultaneously verifying compliance with ICAO standards.

Evidence Collection: When EASA inspectors visit a Member State (e.g., France or Germany), they collect evidence that satisfies both EU requirements and ICAO Protocol Questions (PQs).

Credit for Oversight: ICAO can review EASA’s inspection reports and “take credit” for them. If EASA certifies that a Member State’s airworthiness department is compliant, ICAO updates that State’s USOAP score without sending its own team to re-audit that specific area.

Data Exchange and Transparency

For ICAO to trust EASA’s work, there must be full transparency. The relationship relies on a structured flow of data:

• Access to Reports: EASA provides ICAO with access to its final Standardisation Inspection reports, corrective action plans (CAPs), and closure statements.
• Compliance Checklists (CCs): EASA maintains centralised Compliance Checklists. These documents map every EU regulation against the corresponding ICAO SARP. This relieves Member States of the burden of manually mapping their national regulations to ICAO standards—EASA does it centrally for the “system.”
• Continuous Monitoring Approach (CMA): Both organisations use a CMA model. EASA feeds safety data (ramp checks, occurrence reports) into ICAO’s Online Framework (OLF), ensuring ICAO has up-to-date risk profiles for European states.

Joint Resources and Expertise

The alignment extends to personnel and technical cooperation:

• EASA Staff as ICAO Auditors: EASA staff members are often trained and qualified as ICAO USOAP auditors. They can participate in ICAO audits of non-EU states, ensuring global consistency in how standards are interpreted.
• EASA as a “State” (Functionally): In certain domains (like Airworthiness certification of Airbus aircraft), EASA acts as the Competent Authority rather than the Member States. In these cases, ICAO audits EASA directly (as if it were a State) regarding those specific functions.

Benefits of the Alignment

• Reduced Burden on States: National Aviation Authorities (NAAs) do not have to host two separate audit teams for the same subject.
• Resource Efficiency: ICAO can redirect its limited resources to other regions of the world that lack a robust RSOO like EASA (supporting the “No Country Left Behind” initiative).
• Harmonisation: It forces EU regulations to remain tightly synchronised with global ICAO standards to maintain the validity of the mutual recognition.

Summary of the Workflow

• ICAO updates a SARP (e.g., new Flight Time Limitations).
• EASA updates EU Regulations to match.
• EASA conducts a Standardisation Inspection of a Member State to ensure they are following the new rule.
• EASA uploads the findings/compliance status to the shared framework.
• ICAO reviews the data and validates the Member State’s compliance without a physical site visit.

The ICAO 8 Critical Elements (CEs)

The ICAO USOAP program measures a State’s safety oversight capability by assessing these eight elements. EASA Standardisation teams verify that Member States (National Aviation Authorities – NAAs) have effectively implemented them.

The “Establishment” Phase (CE-1 to CE-5)

CE-1: Primary Aviation Legislation: Does the State have a basic aviation law?

• EASA verifies that the Member State has correctly transposed the EASA Basic Regulation into national law and empowered the NAA to enforce it.

CE-2: Specific Operating Regulations: Are there specific rules for aircraft, licensing, and ops?

• EASA checks if the State is using the latest versions of EASA Implementing Rules (e.g., Part-21, Part-OPS, Part-FCL) without unauthorized deviations.

CE-3: State System & Functions: Is the NAA structured correctly?

• EASA audits the organisational structure of the NAA to ensure there are no conflicts of interest and that lines of responsibility are clear.

CE-4: Qualified Technical Personnel: Are inspectors trained and qualified?

• EASA reviews inspector training records to ensure they meet the qualification standards defined in EASA regulations (e.g., Are Airworthiness Review Staff properly trained on new aircraft types?).

CE-5: Technical Guidance, Tools & Provision of Safety-Critical Information: Do inspectors have handbooks and checklists?

• EASA checks if the NAA provides its staff with up-to-date procedure manuals (how to conduct an audit, how to issue a finding) and if safety data is shared.

The “Implementation” Phase (CE-6 to CE-8)

CE-6: Licensing, Certification, Authorisation, and Approval Obligations: Is the issuance of certificates done correctly?

• EASA samples specific files (e.g., a pilot license or an airline AOC) to verify that the process was followed strictly.

CE-7: Surveillance Obligations: Does the NAA inspect its industry?

• This is the core of the audit. EASA looks at the NAA’s annual audit plan. Did the French/German/Italian authorities visit their airlines? Did they do Ramp Checks (SAFA)?

CE-8: Resolution of Safety Concerns: Does the NAA force the industry to fix problems?

• EASA reviews “Finding Closure.” If an NAA inspector found a problem at an airline, did the NAA ensure the airline fixed the root cause before closing the finding?

Domain Deep Dive: Airworthiness (AIR)

In the Airworthiness domain, the alignment is unique because responsibilities are split between EASA (design) and the Member State (continuing airworthiness).

• Design & Type Certification (CE-6):
  • ICAO Role: Usually audits the State of Design.
  • EASA Role: EASA acts as the Competent Authority for Type Certification (TC) of products (e.g., Airbus aircraft). ICAO audits EASA directly for this function, not the individual countries.
• Continuing Airworthiness (CE-7 & CE-8):
  • State Role: National authorities (NAAs) oversee the maintenance organizations (Part-145) and CAMOs (Part-CAMO).
  • EASA Audit: EASA Standardisation visits the NAA and selects a sample of Part-145 organizations. They check:
  • Did the NAA approve the Maintenance Organization Exposition (MOE) correctly? (CE-6)
  • Did the NAA perform the required oversight audits every 24 months? (CE-7)
  • Did the NAA follow up on Level 1 findings (safety critical)? (CE-8)

Domain Deep Dive: Air Operations (OPS)

In Air Operations, the Member State retains full responsibility for certifying airlines (issuing the Air Operator Certificate – AOC), making the audit focus heavily on the NAA’s surveillance capability.

• Certification (CE-6):
  • EASA Audit: The team reviews the “AOC checklist.” They verify that before the NAA issued an AOC to a new airline, they checked everything: financial health, management competence, and operations manuals (OM-A, OM-B).
• Surveillance (CE-7):
  • EASA Audit: EASA checks the Oversight Planning Cycle. EU regulations require a risk-based oversight cycle (usually 24 months). EASA verifies:
    • Is the oversight plan respected?
    • Are “Ramp Inspections” (SAFA/SACA) being performed on foreign and domestic aircraft?
• Resolution (CE-8):
  • EASA Audit: EASA looks for “Root Cause Analysis.” If an NAA inspector found that an airline’s pilots were not calculating fuel correctly, did the NAA just accept a quick fix, or did they force the airline to retrain all pilots? EASA checks the paperwork to ensure the NAA demanded a robust solution.

Next Steps

Sofema Aviation Services and Sofema Online provide Regulatory – Compliant and Vocational Classroom, Webinar and Online Training for EASA, FAA, UAE GCAA, Saudi GACA, OTAR – Explore the Sofema Library or email [email protected].

Tags:

EASA, ICAO, USOAP, Airworthiness, Air Operations, AviationSafety, SofemaAviationServices, AviationRegulation, AviationCompliance, SafetyOversight, Standardisation, AirOperations, RSOO, data exchange, ICAO Auditors, ICAO 8 Critical Elements