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Operations Manual. Capt Francisco Arenas Alvariño Rule Making Officer
TE.GEN.00409-001
ORO.GEN.110 Operator responsibilities
2014 Operational Manual 2
•(b) Every flight shall be conducted in accordance with the provisions of the operations manual
ORA.ATO.130Training manual and operations manual
(a) The ATO shall establish and maintain a
training manual and operations manual
containing information and instructions to
enable personnel to perform their duties and
to give guidance to students on how to
comply with course requirements.
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General RULES Ops Manual
The theory of a ‘system accident’ is widely accepted.
…..most accidents can be traced to one or more of four levels of failure:
Organizational influences
unsafe supervision
preconditions for unsafe acts
and the unsafe acts themselves.
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Remember is all about this:
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2014 the role of the OM 7
OM overarching principles
OM is the “backbone” of:
Operator’s safe operations
CA’s oversight of the operator
OM is the “mirror” of the operator
OM must be consistent with the AOC and the peripheral legal documents such as AFM, Rules of the Air, Part-ACAS, Aircrew (FCL, CC)
OM has to observe human factors principles
OM is a living document
ORO.MLR.100(K): […] and observes human factors principles.”
+ GM1 ORO.MLR.100(k)Operations manual — general
Key points from Reg. 965/2012 ORO.MLR.100
The operator shall ensure that information taken from approved documents is correctly reflected in the OM.
Performance data, limitations, emergency procedures and, in the future, OSD
Use of manufacturer’s FCOM – FCTM – FAM as supplementing documents
The content of the OM shall be presented in a form that can be used without difficulty and observes human factors principles.
Users must clearly understand what they can and cannot do (avoiding to “chase” the information)
Human Factors guidance material on ICAO Doc. 9683
2014 Ops Manual 8
Key points from Reg. 965/2012 ORO.MLR.100
The OM shall be kept up-to-date:
amendments requiring prior approval must be applied after receiving the approval
amendments to be notified shall be managed according to the approved procedure
amendments required in the interest of safety may be published and applied immediately
All personnel shall be made aware of the changes that are relevant to their duties.
2014 The role of the Ops Manual 9
GM3 ORO.GEN.130(b)
ARO.GEN.310(c)/ ORO.GEN.130(c)
ORO.MLR.100 (h)
- 2 Manuals: a)Training manual [ORO.ATO.230(a)]
b)Operations manual [ORO.ATO.230(b)]
a) Training manual sets the standards, objectives and training goals for each training phase. Shall include:
training plan,
briefing and air exercises,
flight training in an FSTD, if applicable,
theoretical knowledge instruction.
b) The operations manual is made for the personnel, (flight, Sim, theorical instructors, operations
and maintenance personnel…etc.)
shall include general, technical, route and staff training information.
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Key Points ORA.ATO.230 Training manual & Ops manual
Key points from Reg. 965/2012 ORO.MLR.100
The OM shall be kept up-to-date:
amendments requiring prior approval must be applied after receiving the approval
amendments to be notified shall be managed according to the approved procedure
amendments required in the interest of safety may be published and applied immediately
All personnel shall be made aware of the changes that are relevant to their duties.
2014 The role of the Ops Manual 11
GM3 ORO.GEN.130(b)
ARA.GEN.310(c)/ ORA.GEN.130(c)
ORO.MLR.100 (h)
Question
Who writes the OM?.....
For whom the OM is made?
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Question
How do the ATO that operate equipment as the EMB500 fulfil the BR article 8 section 3 requirements? Is it sufficient that the ATO has an OM related to the ATO approval which in turn has a section/OM-B that contains the description of the operation of that specific aircraft type?.
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Basic Regulation ART 8
3. Unless otherwise determined in the implementing rules, operators
engaged in the non-commercial operation of complex motor-powered
aircraft shall declare their capability and means of discharging the
responsibilities associated with the operation of that aircraft.
The AirOPS Regulation 965/2012 also requires a declaration…. See next slide.
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Regulation (EU) 965/2012
ARTICLE 5 Air operations 3. Operators of complex motor-powered aeroplanes and helicopters involved in non-commercial operations shall declare their capability and means to discharge their responsibilities associated with the operation of aircraft and operate the aircraft in accordance with the provisions specified in Annex III and Annex VI. Such operators when engaged in non-commercial specialised operations shall operate the aircraft in accordance with the provisions specified in Annex III and VIII instead.
ANNEX III Part ORO SUBPART DEC — DECLARATION
ORO.DEC.100 Declaration
ANNEX VI Part NCC
ANNEX VIII Part SPO
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BUT…
Regulation (EU) 965/2012
ARTICLE 5 Air operations 5. Training organisations having their principal place of business in a Member State and approved in accordance with Regulation (EU) No 1178/2011 when conducting flight training into, within or out of the Union shall operate:
(a) complex motor-powered aeroplanes and helicopters in accordance with the provisions specified in Annex VI;
(b) other aeroplanes and helicopters, as well as balloons and sailplanes in accordance with the provisions specified in Annex VII.
ANNEX VI Part NCC
ANNEX VII Part NCO
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•ANNEX III Part ORO SUBPART DEC — DECLARATION
ORO.DEC.100 Declaration
How do the ATO that operate equipment as the EMB500 fulfil the BR article 8 section 3 requirements?
An ATO doesn’t need to comply with:
ANNEX III Part ORO
SUBPART DEC — DECLARATION
ORO.DEC.100 Declaration
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Is it sufficient that the ATO has an OM related to the ATO approval which in turn has a section/OM-B that contains the description of the operation of that specific aircraft type?.
Compliance with Reg(EU) 965/2012 and Reg (EU) 1178/2011 shall satisfy the competent authority.
Standardization input: Compliance checklist, different colors for the crew, 2 approvals for management of changes?
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Other Q&A
Does the operator need to be approved ATO to provide operator conversion training?
Answer
For operator conversion trainings, an ATO approval is usually not required. It would only be required if the conversion course is combined with a type rating or a class rating.
An ATO approval is needed for training activities related to the issuance and renewal of a license and rating when required by Part-FCL.
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QUESTION
Operators normally have different documents and manuals where they include
information, procedures, etc. for their personnel (SMM, Ground OPS Manual, Cabin
Crew Manual, Training Manual, General Procedures, Department Instructions, …).
Do all these documents need to be included (a reference) in the OM?,
Does the NAA need to review all these documents?, at what extent the information
included in these documents have to be evaluated (how deep) by the NAA?
When the operator notifies an OM change (without prior approval), does the NAA
need to review the change before the effective date for the change defined by the
operator?, is there a maximum time period for the NAA assessment of that change?,
what is expected on the NAA when evaluating these changes?
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Operators normally have different documents and manuals where
they include information, procedures, etc. for their personnel
(SMM, Ground OPS Manual, Cabin Crew Manual, Training Manual,
General Procedures, Department Instructions, …).
Do all these documents need to be included (a reference) in the
OM?,
Does the NAA need to review all these documents?, at what extent
the information included in these documents have to be evaluated
(how deep) by the NAA?
When the operator notifies an OM change (without prior approval),
does the NAA need to review the change before the effective date
for the change defined by the operator?, is there a maximum time
period for the NAA assessment of that change?, what is expected
on the NAA when evaluating these changes?
1) AMC1 ORO.MLR.100 provisions related to the use of the content of
other relevant document when compiling an OM, states that either the
content of these documents or a reference to them should be included in
the OM. This is applicable to the information required to be part of the OM
according to AMC3 ORO.MLR.100.
As stated in ORO.AOC.100, when applying for an AOC, the operator has to
submit a description of its management system and the operations manual.
Therefore the operator has to submit any document or manual which
contains any part of the minimum content of the OM as specified in AMC3
ORO.MLR.100 or of the management system documentation as specified in
AMC1 and AMC2 ORO.GEN.200(a)(5).
Regarding the competent authority, AMC1 ARO.GEN.310(a) clearly states
that the competent authority has to review the OM and any
documentation provided by the operator.
2) As stated in OROMLR.100(g), the operator has to submit such changes
(not requiring a prior approval) in advance of the effective date. These
amendments should be managed through the approved procedure
required in ORO.GEN.130. ARO.GEN.330(c) states that the competent
authority has to assess the information provided and notify any non-
compliance. It is then up to each competent authority to determine the
way/timeline to assess these amendments.
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Operations Manual
Rule references for CAT
ORO.MLR.100 Operations manual — general
AMC1 ORO.MLR.100 GENERAL
AMC3 ORO.MLR.100 CONTENTS – COMMERCIAL AIR TRANSPORT OPERATIONS
GM1 ORO.MLR.100 CONTENTS
GM1 ORO.MLR.100(h) HUMAN FACTORS PRINCIPLES
ORO.MLR.101 Operations manual — structure for commercial air transport
2014 22 WORK SHOP REGULATION 965/2012
Change management
Rule references
ORO.GEN.115 Application for an operator certificate ORO.GEN.130 Changes related to an AOC holder
AMC1 ORO.GEN.130 APPLICATION TIME FRAMES
GM1 ORO.GEN.130 GENERAL
GM2 ORO.GEN.130 CHANGE OF NAME
GM3 ORO.GEN.130 CHANGES REQUIRING PRIOR APPROVAL
ARO.GEN.310 (c) Initial certification procedure — organisations
ARO.GEN.330 Changes — organisations
AMC1 ARO.GEN.330 AOC HOLDERS
GM1 ARO.GEN.330 CHANGE OF NAME OF THE ORGANISAITON
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One more thing
ARA.GEN.120Means of compliance
ORA.GEN.120Means of compliance
ATO’s can proposed Alt-MOC
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End slide