transition from rf to ato - belgium

Federale Overheidsdienst Mobiliteit en Vervoer

Service public fédérale Mobilité et Transport

11 December 2012

Pieter Dumont and Olivier Grisel – Training Department

Licencing Directorate

Transition from RF to ATO

Content

11/12/2012 Transition from RF to ATO 2

1. EU regulation 290/2012 – Transitional measures

2. Registration vs Approval certificate

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



• Existing RFs are allowed to continue already approved training activities in accordance with Royal Decree 08/03/2008 (JAR-FCL 1 – Airplanes) and/or Royal Decree 21/06/2004 (JAR-FCL – Helicopters) even after 08/04/2013 up to 08/04/2015

• If a training according to JAR-FCL has began before 08/04/2015, the final skill test must be performed before 08/04/2016 according the Part-FCL requirements

• RFs may apply for an ATO certificate as from 08/04/2013

NO RUSH BUT FIRST IN FIRST OUT

08/04/2013 08/04/2015 08/04/2016

RF may apply for an ATO certificate RF should be approved as ATO to

continue training

All training in accordance with JAR-

FCL shall be completed



AT0

08/04/2013 08/04/2015 08/04/2016

No conversion

provisions!

RF may apply

for an ATO

certificate

RF should be approved as ATO

to continue training

All training in

accordance

with JAR-FCL

shall be

completed

Training conform Jar-FCL Training conform Jar-FCL

Training conform Part-FCL

Credits

conform

creditreport

BCAA

2. Registered facility Vs Approved Training Organisation


• Registered facility :

� Registered trough an official reporting of the training activities to the BCAA

� Changes to the RF must be registered/reported to the BCAA

• Approved training organization :

� Means an organization qualified for the issue or continuation of an approval to provide training for pilot licenses and associated ratings and certificates.

� Approved by the competent authority (Certificate)

� May exercise training activities within the approved scope

� Changes to the organization or scope must be approved before implementation

Reason of the registered mail

2. Registered facility Vs Approved Training Organisation


There are no conversion provisions for an RF to become an ATO

An RF will not be converted automatically into an ATO

You must apply for an ATO certificate

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

• Contact informations :

[email protected] (yet operational!)

• 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

• 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

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



BCAA perform the initial Audit

Reduced scope, mainly facilities and training devices




If no findings or corrective action plan is approved

Issue o the • ATO approval certificate • Training course approval




• 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




MCCF :

• 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

• Combination of management position :

� AM/CMM and a SM

� AM and a CMM/SM

� Three post holders for non complex ATOs

Required for non-complex

Required for complex




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



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

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



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

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



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

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

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)

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

• Unforeseen changes

� At earliest opportunity

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)

• Oversight program : AMC1 ARA.ATO.105

• 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

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


• 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)

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

Safety Management System :

• Developped and managed by the safety manager (SM)

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

� Hazard identification

� Risk analysis

� Mitigation of the risks



What is the contain of the SMS:

• Safety policy :

� commitment to improve towards the highest safety standards

� Should be endorsed by the AM

� Just culture

• Emergency Response Plan (ERP) :

� Actions to be taken by the organization in an emergency

� Who coordinate the ERP and how?

• Responsibilities of hazard identification, risk assessment and mitigation

� Who do what, when and how?

• Assessment of the effectiveness of the mitigation by the SM

• Procedure to assess a safety risk related to a change (internal or external)

• Training and communication

• Safety audits plan



Safety Management System, How to build such system? :

• Hazard identification

� Who may identify hazards :

It could be anyone active in the ATO (FIs, TKIs, candidates,…)

� How the hazard should be communicate to the ATO :

On an approved form or a hazard checklist



Safety Management System, How to build such system? :

• 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)

• 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 monitoring manager (CMM)

• Goal of such system : to be certain that the ATO remains in compliance with applicable requirements

• How to build such system :

� Checklists to assess the compliance of the ATO

� Audit program

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

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


• All activities within scope of approval performed by another organisation

(certified or not)

• Should conform 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 montoring should check the scope of approval certificate and

the validity

• If not certified:

• working under the approval of contracting organisation

• Competent authority is given access to the contracted organisation to

determine continued compliance with applicable requirements

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


Accountable manager (AM) Compliance monitoring manager

Safety managerHead of training (HT)

Non-Complex organisation:

Flight instructorsTheoretical knowledge instructors Flight simulation training instructors



Accountable manager (AM):

Responsible for:

• Finances

• Management system

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 in a/c or FSTD 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.



Compliance monitoring manager:

Responsible for:

• Organisation continues meet the requirements of this Part and other Parts

• Implementing of the compliance monitoring programme

Should:

• Have direct access to accountable manager

• Demonstrate relevant knowledge, background and appropriate experience

related to activities to the organisation, including knowledge and experience

in compliance monitoring

• Access to all parts of the organisation, and contracted organisations

• May be the AM

• Independent

Safety manager:

• Coordinating the SMS

• May be the AM

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

complex organisations if they receive sufficient resources of AM



Theoretical knowledge instructors:

Shall have:

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

• 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

• Office

• Rest areas

• Theoretical knowledge instruction:

• Classroom

• Demonstration equipment

• Office

• A single room may be sufficient

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


• A system of record–keeping:

• all developed activities

• all the elements of the Management System

Who, When, Where & How ?

• Paper and/or Electronic format

• 3 years after completion of the training

• including:

• Details of ground, flight, and simulated flight training

• Progress reports

• Information on the licenses of the students

• Student’s progress card

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

Provide all info regarding ATO general info (operating sites, staff, etc…)

� TM : Training manual

States standards, objectives and training goals for each phase of training

One per training course

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

� Which candidate

� Which FI/TKI

� When

� Where/which device or A/C

� Content of the lesson

� Grading (if applicable)



• Different ATO manuals :

� OM : Operations manual

States how the ATO works to the persons active in the ATO (candidates, staff)

• Each manual has a MCCF

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

• Each manual is approved by a signed LEP

REMEMBER! Who, what, when and how



Part-FCL PPL training programme

Theoretical Knowledge

• At least 100 hours of instruction

• Syllabus Part-FCL ~= Jar-FCL

Differences: Meteorology, Air law & ATC procedures, 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

• FI should ensure that an applicant can use R/T communication before solo nav

• Syllabus PPL(A): Part-FCL ~= Jar-FCL

Differences: Radio navigation: use of GNSS

• Syllabus PPL(H): Part-FCL ~= Jar-FCL

Differences: 30 ex: splitting of ex, DVE; Radio navigation: use of GNSS

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


• Part-ORA Regulation not applicable for A/C referred in

Annex 2 of Basic Regulation (EC 216/2008)

i.e. PA-18/19, SV-4, tigermoth, …

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


• Each training aircraft should be:

• Equipped as required in the training specifications concerning the course in

which it is used

• Fitted with primary flight controls that are instantly accessible by both the

student and the instructor (for example dual flight controls or a center

control stick).

• The fleet should include, as appropriate to the courses of training:

• Aircraft suitably equipped to simulate (IMC) and for the instrument flight

training required

• In the case of a non-complex ATO, one aircraft fulfilling all the required

characteristics for a training aircraft might be sufficient

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/characteristics taking into account the training provided and category

and type of A/C :

� For Aeroplane : most AIP aerodromes are suitable

� For Helicopter : Additional requirements

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 meet all pre-requisites for training as established in Part-MED and Part-FCL

• The proofs of the pre-requisites attested before the training shall be stored in the candidate’s training folder

• If the pre-requisites were not compliant with applicable regulations, the license or rating will not be issued by the BCAA

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

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


ORA.ATO.300 DL – General :

• Distance learning is approved to conduct :

� Theoretical knowledge

� 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 TKIs shall be fully familiar with the requirements of the DL course programme

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 rf to ato - belgium

Documents