United Arab Emirates (UAE) General Civil Aviation Authority (GCAA) CAR AIR OPS Compliance Management Considerations

Sofema Online (SOL) www.sofemaonline.com looks at the various elements within a CAR AIR OPS-approved organisation.

Introduction - AMC1 ORO.GEN.200(a)(6) Management system - Compliance Monitoring — General

Compliance monitoring

>> The operator 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 operator 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 compliance with the following:

>> privileges of the operator;
>> manuals, logs, and records;
>> training standards;
>> management system procedures and manuals;
>> activities of the organisation carried out under the supervision of the nominated persons in accordance with ORO.GEN.210(b); and
>> any outsourced activities in accordance with ORO.GEN.205, for compliance with the contract.

Organisational setup

The accountable manager should designate a compliance monitoring manager.

>> The role of the compliance monitoring manager is to ensure that the activities of the operator are monitored for compliance with the applicable regulatory requirements, and
>> Any additional requirements as established by the operator, and that these activities are carried out properly under the supervision of the relevant head of the functional area.

The compliance monitoring manager should be responsible for ensuring that the compliance monitoring programme is properly implemented, maintained and continually reviewed and improved.

The Compliance Monitoring Manager should:

>> Have direct access to the accountable manager;
>> Not be one of the other persons referred to in ORO.GEN.210 (b);
>> Be able to demonstrate relevant knowledge, background and appropriate experience related to the activities of the operator, including knowledge and experience in compliance monitoring; and
>> Have access to all parts of the operator, and as necessary, any contracted operator.

In the case, the same person acts as a compliance monitoring manager and as a safety manager, the accountable manager, with regard to his/her direct accountability for safety, should ensure that sufficient resources are allocated to both functions, taking into account the size of the operator and the nature and complexity of its activities.

Note: The independence of the compliance monitoring function should be established by ensuring that audits and inspections are carried out by personnel not responsible for the function, procedure or products being audited.

If more than one person is designated for the compliance monitoring function, the accountable manager should identify the person who acts as the unique focal point (i.e. the ‘compliance monitoring manager’).

Compliance monitoring documentation

>> Relevant documentation should include the relevant part(s) of the operator’s management system documentation.
>> In addition, relevant documentation should also include the following:

o Terminology;
o Specified activity standards;
o A description of the operator;
o Allocation of duties and responsibilities;
o Procedures to ensure regulatory compliance;
o Compliance monitoring programme, reflecting:

>> Schedule of the monitoring programme;
>> Audit procedures including an audit plan that is implemented, maintained, and continually reviewed and improved;
>> Reporting procedures;
>> Follow-up and corrective action procedures; and
>> Recording system.

o The training syllabus
o Document control.
o Training

Note: Correct and thorough training is essential to optimize compliance in every operator.

>> In order to achieve significant outcome of such training, the operator should ensure that all personnel understand the objectives as laid down in the operator’s management system documentation.
>> Those responsible for managing the compliance monitoring function should receive training on this task. Such training should cover the requirements of compliance monitoring, manuals and procedures related to the task, audit techniques, reporting and recording.
>> Time should be provided to train all personnel involved in compliance management and for briefing the remainder of the personnel.
>> The allocation of time and resources should be governed by the volume and complexity of the activities concerned.

GM1 ORO.GEN.200(a)(6) Management system – Compliance Monitoring -General

The organisational set-up of the compliance monitoring function should reflect the size of the operator and the nature and complexity of its activities.

>> The compliance monitoring manager may perform all audits and inspections himself/herself or appoint one or more auditors by choosing personnel having the related competence as defined in AMC1 ORO.GEN.200(a)(6) point (c)(3)(iii), either from, within or outside the operator.

Note regarding Independence

Regardless of the option chosen it must be ensured that the independence of the audit function is not affected, in particular in cases where those performing the audit or inspection are also responsible for other functions for the operator.

>> In case external personnel are used to perform compliance audits or inspections:

o Any such audits or inspections are performed under the responsibility of the compliance monitoring manager; and
o The operator remains responsible to ensure that the external personnel has relevant knowledge, background and experience as appropriate to the activities being audited or inspected; including knowledge and experience in compliance monitoring.

>> The operator 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.

GM2 ORO.GEN.200(a)(6) Management system - Complex Operators — Compliance Monitoring Programme

Typical subject areas for compliance monitoring audits and inspections for operators should be, as applicable:

>> actual flight operations;
>> ground de-icing/anti-icing;
>> flight support services;
>> load control;
>> technical standards.

Operators should monitor compliance with the operational procedures they have designed to ensure safe operations, airworthy aircraft and the serviceability of both operational and safety equipment. In doing so, they should, where appropriate, additionally monitor the following:

>> operational procedures;
>> flight safety procedures;
>> operational control and supervision;
>> aircraft performance;
>> all weather operations;
>> communications and navigational equipment and practices;
>> mass, balance and aircraft loading;
>> instruments and safety equipment;
>> ground operations;
>> flight and duty time limitations, rest requirements, and scheduling;
>> aircraft maintenance/operations interface;
>> use of the MEL;
>> flight crew;
>> cabin crew;
>> dangerous goods;
>> security.

Next Steps

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