Information for pilot-training organisations
Training towards the issue or renewal of European professional pilot’s licences and the associated ratings must be provided by an ‘Approved Training Organisation’ (ATO). The approval has to be issued by one of the European Competent Authorities who will verify that the organisation complies with the requirements of the Aircrew regulation.
Some types of pilot training do not have to be provided within an ATO, for example training for the Private Pilot’s Licence and associated ratings can be provided in a flying club or flying school that isn’t an ATO. Aircraft operators (e.g. airlines) provide some training internally (e.g. recurrent training), see information for aircraft operators.
The regulations don’t make any distinction between flight training organisations (formally ‘FTOs’) and type-rating training organisations (formally ‘TRTOs’). The organisation requirements and the approval process are the same, and they’re all referred to as ‘approved training organisations’ or ‘ATOs’.
The regulation applicable to pilot training is Commission Regulation (EU) No 1178/2011, known as ‘the aircrew regulation’
The European aircrew regulation
All pilot training organisations in Europe need to comply with Commission Regulation (EU) No 1178/2011, known as ‘the aircrew regulation’. This regulation was published in 2011 and came into effect in most European countries in April 2013. There have already been several amendments, and there are more on the way. Pilot training organisations outside Europe also need to comply with the aircrew regulation in order to provide training towards the grant of pilot licences and ratings by any of the EU and EFTA member states.
What does the aircrew regulation say?
Well, it says a whole bunch of staff, but here’s a quick overview:
The regulation describes the requirements for pilot training organisations, operators of flight simulation training devices and aeromedical centres. It also describes all of the different types of pilot licences, ratings and certificates and the initial training requirements for cabin crew. The regulation is structured as a ‘cover regulation’ and eight annexes. You probably won’t need to refer to the cover regulation very often; the meat of the rules is in the annexes.
Training organisations (except those that only provide training for the LAPL, PPL and associated ratings) must have a particular management system including safety management, SMS, and compliance monitoring, CMS. These requirements are described in Annex VII ‘part-ORA’. For details of the organisation requirements see ‘organisation requirements for ATOs’ below.
Annex I, known as ‘part-FCL’ describes all the different types of pilot licences and ratings including instructor and examiner ratings and certificates.
Annex VI sets out the requirements for the national aviation authorities (NAAs) or ‘competent authorities’ as they are known in the regulation. Like other organisations the NAAs are now required to have a management system.
Annex IV (part-MED) has all the requirements for aeromedical examiners (AMEs) and the criteria for medical certificates for pilots.
Annex V (part-CC) describes the requirements for the initial training of cabin crew. There are additional requirements for cabin crew training in the air operations regulations as most of their training is the responsibility of the aircraft operators.
Organisation requirements for ATOs
The aircrew regulation requires ATOs to have a particular type of management system. This includes all of the elements of a safety management system (SMS) as required by ICAO annex 19; however the regulation does not treat safety management as a separate system but instead requires ATOs to implement a single, integrated management system incorporating a number of different elements. The heart of the management system requirements is ORA.GEN.200.
The 6 fundamental elements of the management system are as follows:
- Clearly defined lines of responsibility and accountability;
- A safety policy;
- Safety risk management;
- Personnel trained and competent to perform their tasks;
- Documentation of all management system key processes, and
- A compliance monitoring function (the equivalent of the old ‘quality system’).
There are also specific additional requirements for particular types of operation. ORA.GEN.200 specifies that the management system should be matched to the size of the organisation and the nature and complexity of its activities, so this is not intended to be a ‘one size fits all’ approach.
Implementing these management system requirements effectively requires a cultural change within an organisation as well as changes to documentation and procedures.
Pilot training organisations within the European Union member states need to hold an approval from the national aviation authority of the country where they’re based. Pilot training organisations based outside the EU need to hold an approval from EASA if they want to train pilots for European licences and ratings. For information on the application and approval process see pilot training organisation approvals.
For more information about the regulations see ‘Regulations for Air Operations and Air Crew training in Europe‘.
For information about the management system requirements for approved training organisations (including safety management systems and compliance monitoring) see ‘Management System Requirements‘.
For information about choosing software to help run your management system see ‘Management System Software‘.
If you need help implementing a management system, showing compliance with regulations or applying for new approvals then please get in touch.