Sofema Aviation Services (SAS) www.sassofia.com reviews the required Compliance Monitoring Requirements within an Approved Training Organisation (ATO)
COMPLIANCE MONITORING – AMC1 ORA.GEN.200(a)(6) ED Decision 2012/007/R
Compliance Monitoring:
To monitor compliance with the relevant requirements of this Part and other applicable Parts.
- The organisation should specify the basic structure of the compliance monitoring function applicable to the activities conducted.
- The compliance monitoring function should be structured according to the size of the organisation and the complexity of the activities to be monitored.
- Organisations should monitor compliance with the procedures they have designed to ensure safe activities. In doing so, they should as a minimum, and where appropriate, monitor:
o Privileges of the organisation;
o Manuals, logs, and records;
o Training standards;
o Management system procedures and manuals.
Compliance Monitoring General – GM1 ORA.GEN.200(a)(6) ED Decision 2012/007/R
The compliance monitoring function should reflect the size of the organisation and the nature and complexity of its activities.
CMM may audit or appoint auditors
- Shall be competent – Ref AMC1 ORA.GEN.200(a)(6) point (c)(3)(iii), either from within or outside the organisation.
- Must Ensure independence of the audit function
- In case external personnel is used to perform compliance audits or inspections:
o Performed under the responsibility of the compliance monitoring manager.
o The organisation remains responsible to assess relevant knowledge, background, and experience as appropriate to the activities being audited or inspected; including knowledge and experience in compliance monitoring.
Note: The organisation retains the ultimate responsibility for the effectiveness of the compliance monitoring function in particular for the effective implementation and follow-up of all corrective actions.
Organisational Set-Up
To ensure that the organisation continues to meet the requirements of this Part and other applicable Parts, the accountable manager should designate a compliance monitoring manager.
- Compliance monitoring manager (CMM) is to ensure that the activities of the organisation are monitored for compliance with the applicable regulatory requirements, and any additional requirements as established by the organisation, and that these activities are being carried out properly under the supervision of the relevant head of the functional area.
- CMM responsible for compliance monitoring programme – implemented, maintained, and continually reviewed and improved.
CMM Responsibilities – CMM Should have:
- Direct access to the accountable manager;
- not be one of the other persons referred to in ORA.GEN.210(b); (AM & NP)
- Demonstrate knowledge, background & experience related to the activities of the organisation; knowledge, and experience in compliance monitoring; and
- Have access to all parts of the organisation, and as necessary, any contracted organisation.
Note 1: Non-Complex Organisation AM can be CM (subject to competence)
Note 2: AM to ensure sufficient resources if CM & SM performed by the same person (size, nature, and complexity of its activities.)
Note 3: Independence ensuring that audits and inspections are carried out by personnel not responsible for the function, procedure, or products being audited.
Compliance Monitoring Documentation
- Documentation should include the relevant part(s) of the organisation’s management system documentation. & include, relevant documentation should also include the following:
o terminology;
o specified activity standards;
o a description of the organisation;
o the allocation of duties and responsibilities;
o procedures to ensure regulatory compliance;
o the compliance monitoring programme, reflecting:
o schedule of the monitoring programme;
o audit procedures;
o reporting procedures;
o follow-up and corrective action procedures; and
o recording system.
o the training syllabus referred to in (e)(2);
o document control.
Training Related to Compliance Monitoring
Correct and thorough training is essential to optimize compliance in every organisation.
- In order to achieve significant outcomes of such training, the organisation should ensure that all personnel understand the objectives as laid down in the organisation’s management system documentation.
o Those responsible for managing the compliance monitoring function should receive training on this task.
o Such training should cover the requirements of compliance monitoring, manuals, and procedures related to the task, audit techniques, reporting and recording.
o Time should be provided to train all personnel involved in compliance management and for briefing the remainder of the personnel.
o The allocation of time and resources should be governed by the volume and complexity of the activities concerned.
Complex Organisations – Compliance Monitoring Program for ATO’s – Ref
GM2 ORA.GEN.200(a)(6) Management system ED Decision 2012/007/R
Typical Audit Areas:
- Facilities;
- Actual flight and ground training;
- Technical standards.
ATOs should monitor compliance with the training and operations manuals they have designed to ensure safe and efficient training. In doing so, they should, where appropriate, additionally monitor the following:
- Training procedures;
- Flight safety;
- Flight and duty time limitations, rest requirements and scheduling;
- Aircraft maintenance/operations interface.
ATOs Providing Training Only For LAPL, PPL, SPL OR BPL & Associated Ratings or Certificates – Organisational Review Program (Ref GM1 ORA.GEN.200(c) ED Decision 2015/011/R)
The organisational review programme may consist of:
- Checklist(s) covering
o All items necessary to ensure that the organisation identified its aviation safety hazards, effectively mitigates the associated risks and ensures effective compliance with the applicable requirements.
o These should address all procedures described in the management system documentation and training manual; and
- A schedule for the accomplishment of the different checklist items, with each item being checked at least once within any 12-month period.
o The organisation may choose to conduct one full review annually or to conduct several partial reviews.
- Performance of organisational reviews:
o Each review item may be addressed using an appropriate combination of:
- review of training records, training documentation;
- review of internal safety reports (e.g. notified difficulties in using current procedures and training material, etc.);
- review of the risk register and hazard checklists, as applicable;
- sample check of training courses;
- witnessing of examinations, as appropriate;
- interview of the personnel involved; and
- review of the feedback provided by students and customers.
- (c) It is recommended that internal safety reports and occurrence reports be reviewed on a continual basis with the aim of identifying possible corrective and risk mitigation actions.
Next Steps
Sofema Aviation Services www.sassofia.com and Sofema Online www.sofemaonline.com provide EASA regulatory compliant and vocational training. Please see the websites or email team@sassofia.com for more information about our services.
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Accountable Manager, Aircraft Maintenance, Approved Training Organisation (ATO), ATO, Compliance Monitoring, Compliance monitoring manager (CMM), compliance monitoring programme, EASA, EASA approved ATO, EASA Regulatory Compliant Training, Flight Safety, LAPL, Management Systems, PPL, Regulatory Compliance, SAS blogs, Technical Standards
