Sofema Aviation Services (SAS) www.sassofia.com considers the process to deliver a Non – Complex Organisations ref to AMC1 ORA.GEN.200(a) Management system – ED Decision 2012/007/R.
Introduction – Definition of Complexity
- Complex with a workforce of more than 20 full-time equivalents (FTEs) involved in the activity subject to Regulation (EC) No 216/2008. (now 2018/1139 & its Implementing Rules.)
- May still be complex based on the following:
o In terms of complexity, the extent and scope of contracted activities subject to the approval;
o In terms of risk criteria, whether any of the following are present:
· Operations requiring the following specific approvals: performance-based navigation (PBN),
· low visibility operation (LVO), extended range operations with two-engined aeroplanes (ETOPS),
· helicopter hoist operation (HHO),
· helicopter emergency medical service (HEMS),
· night vision imaging system (NVIS) and
· dangerous goods (DG).
o Different types of aircraft used;
o The environment (offshore, mountainous area etc.).
Note 1 – Regardless of other criteria the organisations that provide training in the following areas should always be considered as complex:
- full flight simulators (FFSs); or
- multi-pilot (MP) type rating; or
- zero-flight-time training (ZFTT); or
- complex aircraft; or
- different categories of aircraft; or
- instructor certificates for multi & complex aircraft; or
- two or more aerodromes/operating sites.
Note 2 – Regardless of the criteria mentioned above, the following organisations should always be considered as non-complex:
- Approved Training Organisations (ATOs) only providing training for:
o The light aircraft pilot licence (LAPL),
o Private pilot licence (PPL),
o Sailplane pilot licence (SPL) or
o balloon pilot licence (BPL) and the associated ratings and certificates.
Note 3 – Aero-Medical Centres (AeMCs) are always considered as Non-Complex.
Non – Complex Organisations – General
Safety Risk Management
- May be performed using hazard checklists or similar risk management tools or processes. (Should be integrated into the activities of the organisation.)
- The organisation should manage safety risks related to a change.
- The management of change should be a documented process to identify an external and internal change that may have an adverse effect on safety.
- It should make use of the organisation’s existing hazard identification, risk assessment and mitigation processes.
Safety Manager Role – The organisation should identify a person who fulfils the role of safety manager and who is responsible for coordinating the safety management system.
Note – The SM may be the accountable manager or a person with an operational role in the organisation.
- Responsibilities should be identified for hazard identification, risk assessment and mitigation.
- Safety policy should include a commitment to improve towards the highest safety standards, comply with all applicable legal requirements, meet all applicable standards, consider best practices and provide appropriate resources.
Non-Complex Emergency Response Plan
The organisation should, in cooperation with other stakeholders, develop, coordinate and maintain an emergency response plan (ERP) that ensures orderly and safe transition from normal to emergency operations and return to normal operations.
- The ERP should provide the actions to be taken by the organisation or specified individuals in an emergency and reflect the size, nature and complexity of the activities performed by the organisation.
Example Roles & Responsibilities
Accountable Manager
- To endorse the safety policy;
- Establish & maintain an effective Management System;
- Authority to ensure activities can be financed in accordance with the applicable requirements;
- The authority to designate the person responsible for the organisational review programme;
- The duty to conduct the yearly organisational review and to lead the organisational review board;
- Shall grant direct access to nominated persons;
- Ensuring that the personnel continually promotes the Safety Policy and demonstrates their commitment to it;
- To address deficiencies & improve the Organisation’s Management System, based on the results of the Organisational Review.
Person Responsible to Manage Organisational Review Programme (ORP)
- Establishes maintains and conducts the Organisational Review Programme;
- Monitors all corrective and risk mitigation actions;
- Records the action closure, along with a summary of action taken;
- Presents to the Accountable Manager all non-compliance findings and new risks identified during the review.
Head of Training (HT)
- Manages and supervises the progress and completion of training within the organisation;
- Is subordinated to and reports to the Accountable Manager; and
- Head of Training shall:
o Ensures that the training is in compliance with the appropriate requirements, mainly Part-FCL and internal requirements;
o Ensures satisfactory integration of flight training and theoretical knowledge instruction;
o Develops, implements and improves the training programme, syllabi and session plans, including training publications, documents and records;
o Ensures the correct and adequate content of the organisation’s documentation in the area of responsibility;
o Supervises the student’s overall progress and completion of training;
o Assures the appropriate use of infrastructure, training facilities, equipment and tools;
o Is responsible for the processing, storing and filing of all documents and records according to the provisions of the management system;
o Records and analyses any occurrences and deviations from the standards and ensures corrective and preventive action within the organisation;
o Promotes a corporate culture of safety and compliance;
o Represents the ATO and liaises with CA regarding administration and coordination; and
o Manages and plans continuous education and career development of subordinates.
o Executes power and authority:
o Selects and nominates subordinates;
o Defines the action to be taken if subordinates do not achieve or maintain the required standards of performance and/or associated behaviour;
o Defines disciplinary actions in case of student’s inadmissible behaviour;
o Has the authority to implement corrective action within the designated department.
Next Steps
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Tags:
aviation, Regulation (EC) No 216/2008, Approved Training Organisation (ATO), ATO, SAS blogs, EC Regulation 2018/1139, EASA 2018/1139, Non-Complex Organisations, AMC1 ORA.GEN.200(a), ED Decision 2012/007/R, Organisational Review Programme (ORP)
