transition from fto to ato · 2015. 9. 23. · 3. part-ora (annex 7 to eu 290/2012) i. ora.gen.105...

Federale Overheidsdienst Mobiliteit en Vervoer

Service public fédérale Mobilité et Transport

18 December 2012

Jelle Vanderhaeghe and Olivier Grisel – Training Department

Licencing Directorate

Transition from FTO to ATO

Content

18/12/2012 Transition from FTO to ATO 2

1. EU regulation 290/2012 – Transitional measures

2. JAR Approval vs Part-ORA Approval

3. PART-ORA (Annex 7 to EU 290/2012)

I. ORA.GEN.105 Competent authority

II. ORA.GEN.115/ORA.ATO.105 Application for an organisation certificate and fees

III. ORA.GEN.130 Changes to organisations

IV. ORA.GEN.150 Findings

V. ORA.GEN.160 Occurrence reporting

VI. ORA.GEN.200 Management system

VII. ORA.GEN.205 Contracted activities

VIII. ORA.GEN.210/ORA.ATO.110 Personnel requirements

IX. ORA.GEN.215 Facility requirements

X. ORA.GEN.220/ORA.ATO.120 Record-keeping

XI. ORA.ATO.125/130 Training programme and manuals

Content


3. PART-ORA (Annex 7 to EU 290/2012)

XII. ORA.GEN.135 Training A/C and FSTDs

XIII. ORA.ATO.140 Aerodromes and operating sites

XIV. ORA.ATO.145 Pre-requisites for training

XV. Distance Learning Course

XVI. Renewal of licences



• Reference : Article 10a §2

Already approved FTO are automatically converted in an ATO

• The management system shall be implemented in all organisations by 08/04/2014

• Training programs, procedures and manuals shall be adapted towards new regulation by 08/04/2014

• Practically :

FTOs may continue their operations but all “paper work” shall be compliant towards Part-ORA by 08/04/2014

08/04/2013 08/04/2014

Automatic conversion from FTO to

ATO

Management system, training programs, procedures

and manuals must be compliant towards Part-ORA

Existing FTOs are allowed to continue already approved training activities



How to assess compliance of the FTO towards ATO requirements?

• For each manual, a checklist will be developed and made available

• It is trough this documentation that the FTO assesses that the organisation and the training are in compliance with Part-FCL and Part-ORA.

• Planning : Deadline is 08/04/2014!!!

First in, first out

Do not apply updated documents on the last day

• ATO certificate numbers will remain the same as the one given under JAR-FCL era

BCAA will deliver the ATO certificate when all paper work is compliant and approved.

The ATO must assess himself the compliance of the organisationbefore submitting an update/change

3. PART-ORA (Annex 7 to EU 290/2012)I. ORA.GEN.105 Competent authority


• If principle place of business in Belgium

The competent authority is the BCAA

• If principle place of business within an EASA member state

The competent authority of that member state

• If principle place of business in third country

The EASA

• Definition (ARA.GEN.105) :

Principle place of business means the head office or registered office of the organisation within which the principal financial functions and operational control of the activities referred to in this regulation are exercised.

• Contact information / apply for changes :

[email protected]

• BCAA ATO surveyors :

� Pieter Dumont – [email protected]

� Jelle Vanderhaeghe – [email protected]

� Olivier Grisel – [email protected]

3. PART-ORA (Annex 7 to EU 290/2012)II. ORA.GEN.115/ORA.ATO.105 Application for an organisation certificate and fees


• Application for an ATO certificate is made trough a dedicated BCAA procedure

Deliver an ATO certificate – LA/L-TRA/0101 (not applicable for FTO)

• Within this main process, there are 5 sub processes in order to approve « items » of the ATO certificate

Approve a manual of an ATO – LA/L-TRA/0151

Approve a post holder of an ATO – LA/L-TRA/0152

Approve a FI/TKI of an ATO – LA/L-TRA/0153

Deliver an A/C user approval to an ATO – LA/L-TRA/0154

Deliver a FSTD user approval – LA/L-TRA/0155

• One process to audit the ATO

Perform an audit of an ATO – LA/L-TRA/0150

All BCAA procedures and support documents will be made available on our website (notification by twitter)

3. PART-ORA (Annex 7 to EU 290/2012)II. ORA.GEN.115/ORA.ATO.105 Application for an organisation certificate and fees


ATO certificate

• Continued validity of the certificate as long as the ATO remains in compliance

3. PART-ORA (Annex 7 to EU 290/2012)III. ORA.GEN.130 Changes to organisations


• Changes requiring prior approval from the competent authority

� Any change in the ATO approval (Manuals, locations, A/C, FSTDs, etc…)

At least 30 days before the date of the intended changes

� Any change in the ATO nominated staff

At least 10 days before the date of the proposed change

• Changes not requiring approval

� i.e. items not mentioned in GM1 ORA.GEN.130 (a)(1) the name of the organisation;(2) the organisation’s principal place of business;(3) the organisation’s scope of activities;(4) additional locations of the organisation;(5) the accountable manager;(6) any of the persons referred to in ORA.GEN.210 (a) and (b);(7) the organisation’s documentation as required by this Part, safety policy andprocedures;(8) the facilities

� Must be covered by a proper internal procedure approved by the BCAA

• Unforeseen changes

� At earliest opportunity



Modify of an ATO certificate – LA/L-TRA/0102

• Two Cases :

� CASE 1 : Addition/suppression of course

� CASE 2 : Addition/suppression of a FSTD used by the ATO

• Only the Training course approval will be modified



Approve a manual of an ATO – LA/L-TRA/0151

• Three manuals to be approved :

� OMM : Organisation Management Manual

� OM : Operations Manual

� TM : Training Manual

• Manual Compliance Checklist and Findings (MCCF)

� Document to introduce a manual to the BCAA

� X-ref towards Part-ORA requirement



Approve a manual of an ATO – LA/L-TRA/0151MCCF :

• MCCF must be introduced for the initial approval of the manual

AND for each subsequent revision

• It is a compliance statement made by the ATO and confirmed by the BCAA

• Work documents to communicate findings on the manual




• Which positions in an ATO requires an approval ?

� Accountable manager

� Compliance Monitoring Manager

� Safety Manager

� Head of Training

� Chief Flight Instructor

� Chief Theoretical Instructor

Required for non-complex

Required for complex




DOC-Letter of intention-Post holder approval-Standardized resume-Working agreement / contract




DOC-Letter of intention-New/updated FI/TKI list-Staff application form-Standardisation certificate-Working agreement/contract




DOC-Letter of intention-A/C application form-Agreement/contract




DOC-Letter of intention-FSTD application form-Agreement/contract



General Remarks

• For each of the following sub processesApprove a manual of an ATO – LA/L-TRA/0151





� One dedicated checklist to apply for the change to the BCAA for each sub process

� As long as all needed documents are not in possession of the BCAA, the sub process will not be started.

3. PART-ORA (Annex 7 to EU 290/2012)IV. ORA.GEN.150 Findings


• Oversight of the ATO by the BCAA

� Audits – Performed by the L-TRA department

� Unannounced inspections – performed by the inspection department

• An ATO must be audited in full within 24 months

May be extended up to 48 months on special conditions ARA.GEN.305 (c), (d)

The oversight planning cycle may be extended to a maximum of 36 months if the competent authority has established that, during the previous 24 months:

(1) the organisation has demonstrated an effective identification of aviation safety hazards and management of associated risks(2) the organisation has continuously demonstrated under ORA.GEN.130 that it has full control over all changes(3) no level 1 findings have been issued(4) all corrective actions have been implemented within the time period accepted or extended by the competent authority as defined in ARA.GEN.350(d)(2)

The oversight planning cycle may be further extended to a maximum of 48 months if, in addition to the above, the organisation has established, and the competent authority has approved, an effective continuous reporting system to the competent authority on the safety performance and regulatory compliance of the organisation itself



• Oversight program : AMC1 ARA.ATO.105(1) information on flight instructors, validity of licences, certificates, ratings and log books(2) evidence of sufficient funding(3) training aircraft in use, including their registration, associated documents and maintenance records(4) aerodromes, operating sites and associated facilities(5) facilities with regard to their adequacy to the courses being conducted and number of students (6) FSTDs, including their qualification certificates, associated documents and maintenance records(7) documentation, in particular documents related to courses, information on the updating system, and training and operations manual(s)(8) training records and checking forms(9) flight instruction, including pre-briefing, actual flight and debriefing

• ATO will be warn in advance

� The date of the audit (agreement with ATO)

� Scope of the audit

• After the audit the ATO will receive a report stating the finding and the time fame allowed to correct the non compliances

• If any findings, the ATO must provide to the BCAA

� Root cause analysis

� Corrective action plan



• The corrective action plan must be submitted within 10 working days after the reception of the audit report by email

• The ATO must implement the corrective action plan in due time

• The ATO must provide the evidences of the implementation of the corrective actions in due time

If not, related findings raised to level 1!

Related training activities are stopped!

If not, related findings raised to level 1!

Related training activities are stopped!

3. PART-ORA (Annex 7 to EU 290/2012)V. ORA.GEN.160 Occurence reporting


• The organisation shall report to the BCAA

� Accidents & Serious incidents (CIR/INS01)

� Occurrences (CIR/INS01)

• The organisation shall report to the BCAA and to the A/C manufacturer

� incident

� Malfunctions

� Technical defect…

That would highlights problems with data established in accordance with Part-21

• Reporting of those shall be made on a form and manner established by the BCAA (CIR/INS01)

• The procedure to notify the occurrences to the BCAA must be described in the OMM

3. PART-ORA (Annex 7 to EU 290/2012)VI. ORA.GEN.200 Management system


• Two aspects in the management system

� Safety management system

� Compliance monitoring system

• Both systems will be described within the ATO OMM ( Organisation Management Manual )

Safety Management System:

• Developed and managed by the Safety Manager (SM)

• SMS is a system that ensures that the ATO is performing its activities in a safe manner by

� Hazard identification

� Risk analysis

� Mitigation of the risks



What is the content of ‘SMS’:

• Based on the highlights of the SSP ( State Safety Program ), but specifically modified for the organization:

1. Development of an internal “Safety policy”:

� Commitment to aim for the highest safety standards

� Should be supported/endorsed by the Accountable Manager

� Closed loop: after analysis, procedures must be modified ( if necessary ), all involved must be informed, and all means necessary must be taken, to avoid reoccurrence of the incident

� Set up procedures to assess a safety risk related to a change (internal or external)

2. Emergency Response Plan (ERP) :

� Actions to be taken by the organization in an emergency

� Clear indication in the Safety Policy and OMM about who coordinate the ERP and how?



3. Set up of a Safety Team:

� Who does what, when and how?

� Designate responsibilities of hazard identification, riskassessment and mitigation to persons, or groups of people

� Assessment of the effectiveness of the mitigation by the SM

4. Training and communication:

� All involved must be informed about the existence of theSafety plan, and trained in the characteristics, staff,documents and changes

� Feedback must be provided after every incident, to avoidfuture reoccurrence

4. Statistics and analysis:

� Management is able to asses and analyze the safetyparameters of the organization

� Safety audits must be planned and executed annually



6. “Just culture”:

� Non-punitive approach to safety and incidents

� Inquiry in incidents not to discover who was responsible, toblame and punish

� Inquiry in incidents for the benefit of increasing safety in theorganization and to prevent future occurrence

� Feedback to all involved

� Will become a legal obligation with the intro of ICAO Annex 19

� Will require a change in mentality of all involved in civilaviation: authorities, organizations, pilots,…



Safety Management System, How to set up such a system?

1. Hazard identification:

� Who may identify hazards :

It could be anyone active in the ATO ( FI’s, TKI’s, student pilots, …)

� Set up forms and procedures on how the hazard should be reported to the ATO :

� On an approved form or a hazard checklist



Safety Management System, How to build such system? :

2. Risk analysis/assessment

� Who will analyze the risks :

SM, AM, FIs, TKIs

� How :

A lot of different systems available

( risk assessment matrix, SPE model, GAR model, FMEA )

3. Risk mitigation

� Who defines the mitigation plan/method

� Safety audits to assess effectiveness of the mitigation plan

KEEP IT SIMPLE!

BCAA will provide further guidance



Compliance Monitoring System:

• Developed and managed by the COMPLIANCE MONITORINGMANAGER (CMM)

• In EASA terminology the JAR-FCL “Quality Manager” has beenreplaced by the more “to the point” Compliance Monitoring Manager”

• Goal of such system : to be certain that the ATO remains compliantwith applicable legislation, requirements and the internal procedures

• How to build such system:

� Checklists to assess the compliance of the ATO

� Audit program

BCAA will provide checklist that will be in used during BCAA audits

3. PART-ORA (Annex 7 to EU 290/2012)VII. ORA.GEN.205 Contracted activities


• All activities within scope of approval of the ATO, but performedby another organisation ( certified or not )

• Should be conformal to the applicable requirements

• A written agreement between both organisations

• Subject to hazard identification and risk management,occurrence reporting and compliance monitoring,

• If certified:

• compliance monitoring should check the scope of approvalcertificate and the validity

• If not certified:

• Activities performed under the approval of the contractingorganisation

• Competent authority is given access to the contractedorganisation to determine continued compliance withapplicable requirements

3. PART-ORA (Annex 7 to EU 290/2012)VIII. ORA.GEN.210/ORA.ATO.110 Personel requirements

11/12/2012 Transition from RF to ATO 31

Accountable manager (AM) Compliance monitoring manager

Safety managerHead of training (HT)

Complex organisation:

Flight instructorsTheoretical knowledge instructors Flight simulation training instructors

Chief Theoretical Knowledge Instructor (CTKI)

Chief Flight Instructor(CFI)

3. PART-ORA (Annex 7 to EU 290/2012)VIII. ORA.GEN.210/ORA.ATO.110 Personnel requirements


1. Accountable manager ( AM ):

Responsible for:

• Finances

• Management system

2. Head of training (HT):

• Extensive experience as an instructor

• Possesses sound managerial capability

Responsible for:

• Ensuring training in compliance with Part-FCL

• Satisfactory integration of flight training and theoretical knowledge

instruction

• Supervising the progress of individual students

Shall be assisted by one or more deputy HT(s), if training courses for different a/c

categories are provided.



3. Compliance monitoring manager:

Responsible for:

• Making sure the organization continues to meet the requirements of

PART-FCL, PART-ARA & ORA

• Making sure the organization complies with own manuals and approved

programs

• Implements, overviews and coordinates the compliance monitoring

program

Should:

• Have direct access to Accountable Manager

• Must demonstrate relevant knowledge, background and appropriate

experience related to the activities of the organisation, including know-

ledge and experience in compliance monitoring to the authority

• Must have access to the whole organisation, and contracted organisations

• May be the AM in a non-complex organization

• Must be independent, not AM, in a complex organization



4. Safety manager:

• Responsible for coordinating the SMS

• May be the AM, also complex organization

Compliance monitoring manager and safety manager may be combined for non-

complex organisations if they receive sufficient resources of AM

For non-complex organizations, the relationship between CMM, SM and AM not

defined in the AMC’s

5. CTKI:

• Chief Theoretical Knowledge Instructor (former Chief Ground Instructor)

• No changes to be observed in the requirements and task descriptions between

the Chief Ground Instructor, or Chief Theoretical Knowledge Instructor

• The same applies for the Chief Flight Instructor



6. Theoretical knowledge instructors:

Shall have:

• Practical background in aviation in the areas relevant for the training provided

• Knowledge of instructional techniques

or

• Previous experience in giving theoretical knowledge instruction

• Appropriate theoretical background

Should, before appointment, prove their competency by giving a test lecture

3. PART-ORA (Annex 7 to EU 290/2012)IX. ORA.GEN.215 Facility requirements


Flight operations:

• Flight planning room

• Briefing room(s)/cubicles

• Offices for post holders

• Rest areas

Theoretical knowledge instruction:

• Classroom

• Demonstration equipment

• Office

• The number of rooms should be in accordance to the number of students in

training

3. PART-ORA (Annex 7 to EU 290/2012)X. ORA.GEN.220/ORA.ATO.120 Record-keeping


A system of record–keeping:

• Required for all developed activities

• Required for all the elements of the Management System

Who, When, Where & How?

• To be kept in a paper and/or electronic format

• To be kept for 3 years after completion of the training

• including:

• Details of ground, flight, and simulator training

• Progress reports

• Information on the licenses of the students

3. PART-ORA (Annex 7 to EU 290/2012)XI. ORA.ATO.125/130 Training programmes and manuals


Different ATO manuals :

� OMM : Organization Management Manual

Includes CMS and SMS

Provides all info regarding ATO general info (operating sites, staff,

etc…)

Will also include the former (Belgian) Administration manual

� TM : Training manual

States standards, objectives and training goals for each phase of

training

One separate TM per training course




Forms included in the TM must answer to the following questions :

� Identification of the candidate

� Identification of the FI/TKI

� Timing of the training ( start, training sessions, duration, progress

tests , … )

� Location, type, designation of the devices or A/C used

� Detailed content of the lessons

� Grading ( if applicable )




� OM : Operations manual

States how the ATO relates to the persons active in the ATO

( candidates, staff )

• Each manual has a MCCF

� MCCF = Manual Compliance Checklist & Findings

� If you can answer to each point of the MCCF, your manual is

approvable

• Each manual is approved by a signed LEP ( List of Effective Pages )

REMEMBER! Who, what, when and how



Part-FCL ATPL training program

Theoretical Knowledge

• JAA TO Learning objectives NPA 25 remain valid until further notice

• Syllabus PART-FCL ≈ JAR-FCL

• Differences: Importance of use of GNSS in Radio navigation

Flight Instruction

• Before being accepted for training an applicant should be informed that the

appropriate medical certificate must be obtained before solo flying is permitted

• The practicing license will no longer be issued, after April 8th, 2013

• FI should ensure that an applicant is proficient in R/T communication before

solo nav, especially on controlled aerodromes



Part-FCL ATPL training program

Theoretical Knowledge Exams:

• FCL.025 Theoretical knowledge examinations for the issue of licenses (b)(3):

“If an applicant has failed to pass one of the examination papers within 4 attempts,

or has failed to pass all papers within either 6 sittings or the period mentioned in

paragraph (2), he/she shall re-take the complete set of examination papers. “

• BCAA will ask clarification on EASA on how to interpret this rule.

• BCAA wishes to stick to the 4 attempts system.

3. PART-ORA (Annex 7 to EU 290/2012)XII. ORA.ATO.135 Training A/C and FSTDs


• Part-ORA Regulation is not applicable for aircraft referred to in Annex 2 of

Basic Regulation (EC 216/2008)

i.e. Piper Cub, …

Part-FCL CPL/IR Modular:

• FCL.025: Theoretical knowledge exams will remain valid for 7 years, if an IR is

entered on the license

=> No more mention of the necessity of obtaining a CPL(A) license within the 3

year period of initial validity of the ATPL(A) theoretical knowledge exams



Part-FCL CPL on multi-engine airplanes:

• Appendix 3 , chapter C, CPL Modular course, subsection 4: An applicant will

comply with the prerequisites for the issue of a class or type rating, for multi-

engine airplanes, if a multi-engine is to be used for the skill test

=> Only 70 hrs PIC required to start the CPL(A) and perform the hours of complex

training and the skill test on a multi-engine airplane?

• The AMC’s refer to “comply with the requirements for the issuance of a class or

type rating for multi-engine airplanes”

• This matter needs further clarification from EASA



Part-FCL Examiners:

• ARA.FCL.205(a): The competent authority shall develop an oversight program to

monitor the conduct and performance of the examiners

• There will no longer be lists of designated examiners

• HOWEVER: ARA.FCL.205(c): The competent authority shall develop procedures

to designate examiners for the conduct of the skill-test.

• BCAA is still negotiating the procedure for the designation of examiners…

• The skill-test registration is already active since October 2012

• The briefing for foreign examiners is being developed by BCAA

3. PART-ORA (Annex 7 to EU 290/2012)XIII. ORA.ATO.140 Aerodromes and operating sites


• Use of aerodromes and operating sites with appropriate facilities/ characte-

ristics, taking into account the training provided and category and type of A/C :

� For Aeroplane : most AIP aerodromes are suitable

� For Helicopter : Confined area

Simulated engine off autorotation

Sloping ground operation

• Aerodromes and operating sites are approved trough the OMM

3. PART-ORA (Annex 7 to EU 290/2012)XIV. ORA.ATO.145 Pre-requisites for training


• The ATO shall ensure that the student meets all pre-requisites for training as

established in Part-MED and Part-FCL

• The proof that a candidate is within the pre-requisites must be attested

before the training begins and shall be stored in the candidate’s training

folder

• If the pre-requisites were not met before the training began, the license or

rating will not be issued by the BCAA

• The ATO is responsible of the checking of the pre-requisites

• Licenses will be requested with a standard request form

3. PART-ORA (Annex 7 to EU 290/2012)XV. Distance Learning Course


ORA.ATO.300 DL – General :

Distance learning is approved for:

� Theoretical knowledge training

� Class or type rating

ORA.ATO.305 DL – Classroom instruction :

• An element of classroom instruction shall be conducted in all subjects

• At least 10% of the total duration of the course shall be performed in class

ORA.ATO.310 DL – Instructors :

• All TKI’s shall be fully familiar with the requirements of the DL course

programme

3. PART-ORA (Annex 7 to EU 290/2012)XVI. Renewal of licenses


Renewal of licenses:

• For example IR: Subpart G, FCL.625 (c): in order to renew their privileges, the

applicants shall (1) go through refresher training at an ATO, (2) complete a

proficiency check

• No more approval required from BCAA for the renewal training?

• This procedure will be clarified in future communication

Federale Overheidsdienst Mobiliteit en Vervoer

Service public fédérale Mobilité et Transport

Thank You

REMEMBER :

All BCAA working documents will be made available on the BCAA

website and discussed during the application meeting

transition from fto to ato · 2015. 9. 23. · 3. part-ora (annex 7 to eu 290/2012) i. ora.gen.105...

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